Comprehensive Transition and Postsecondary (CTP) Programs

The Higher Education Opportunity Act of 2008 (HEOA) created a new kind of college program specifically for students with intellectual disability – the Comprehensive Transition and Postsecondary (CTP) Program. The Act defined the requirements of CTP programs, defined "student with an intellectual disability" for the purposes of these programs, and opened up access to federal student aid for students with intellectual disability attending an approved CTP program, even if those students do not have a standard high school diploma or are not matriculating towards a degree.  This page shares key resources that will assist colleges and universities interested in establishing a CTP program to learn more about these unique programs, to design a CTP program that meets the requirements as outlined in the HEOA, and to submit an application for program approval so that eligible students with intellectual disability have access to federal student aid.

Think College is happy to provide technical assistance to programs pursuing CTP program approval.  Contact us at thinkcollegeTA@gmail.com to request assistance. 

News & Features

becoming a comprehensive transition postsecondary program
Comprehensive transition postsecondary (CTP) program is a designation sought by college programs for students with intellectual disability who wish to offer access to federal financial aid to its s ...Read more
In this one hour webinar recording, originally broadcast in January 2020, Lindsay Wertenberger from Federal Student Aid at the U.S. Department of Education shares the basics of Comprehensive Transition and Postsecondary (CTP) programs. ...Read more
In this one-hour webinar, originally broadcast in May 2017, Clare Papay and Cate Weir from Think College presented the process for programs to become approved as Comprehensive Transition and Postsecondary program (CTP) for the purpose of being able to offer federal student aid to students with intellectual disability. ...Read more

Frequently Asked Questions

Why should we consider seeking approval as a Comprehensive Transition Postsecondary (CTP) Program?

Becoming approved as a CTP program means that your students can apply for federal financial aid. Eligible students who have an intellectual disability and who have financial need as determined by FAFSA can use federal financial aid to help pay for their studies. In some states, vocational rehabilitation funds, Medicaid funds or certain scholarships can only be accessedd by students with intellectual disability at approved CTP programs, so becoming approved as a CTP program can also open up funding sources in addition to federal student aid.

What is the process for applying to become an approved CTP program?

To become approved as a CTP program, you need to work with the financial aid office on your campus. You will provide the financial aid office with some basic information that they will enter into the institutions “e-app.” Then you write a narrative application that includes specific information. For a step-by-step guide on the application process, see this resource: https://thinkcollege.net/resource/comprehensive-transition-program-ctp-a....

Are CTP programs subject to the gainful employment regulations?

No. CTP programs are considered an exception to the current Gainful Employment (GE) regulations. While CTP programs are defined this way in the Higher Education Opportunity Act: designed to support students with intellectual disability seeking to continue academic, career and technical, and independent living at an institute of higher education in order to prepare for gainful employment; in this instance the term “gainful employment” refers generally to employment and participation in the workforce, and thus CTP are not required to meet gainful employment regulations.
For further information, see GE Electronic Announcement #53 (5/20/2015)
https://ifap.ed.gov/electronic-announcements/05-20-2015-gainful-employme...

What can be counted as a credit/clock hour for a student enrolled in a CTP program?

What may be counted as a contact hour in a comprehensive transition and postsecondary (CTP) program is significantly broader than what may count as an hour in degree programs. Activities such as auditing courses, individualized instruction to support independent living, meetings with a career adviser, participating in college clubs, or attending campus events with a peer mentor are all things that could count towards the CTP program hours. If these activities fulfill requirements of the CTP program credential, they can be counted as hours in the program. Note that all activities included in credit or clock hours in the course of study must have a grading/evaluation process in order to factor these activities in when determining satisfactory academic progress. This excerpt from the FSA Handbook 2023-24 (Volume 7, Chapter 3) explains how to use equivalent credit hours to calculate enrollment status of CTP program students . "Enrollment status for students with intellectual disabilities enrolled in CTP programs may also be determined using credit hour equivalencies. These equivalent credits, earned from audited courses and other normally non-credit activities undertaken as part of a program for students with disabilities, may be awarded for purposes of determining enrollment status. For more detail, see Volume 1, Chapter 1 of the FSA Handbook."

What are the academic components of a CTP program?

The HEOA lists these four activities as meeting the academic components of a CTP program:
(i) Taking credit-bearing courses with students without disabilities
(ii) Auditing or otherwise participating in courses with students without disabilities for which the student does not receive regular academic credit
(iii) Taking non-credit-bearing, nondegree courses with students without disabilities
(iv) Participating in internships or work-based training in settings with individuals without disabilities.
Students attending a CTP program must spend at least 50% of their time in one or more of these academic activities.

As college courses may be taken for credit or for audit and including non-credit classes and internships, a CTP program can individualize a course of study based on individual students. In some cases, students may wish to take a credit-bearing course for credit. In other instances, a student may benefit more from auditing a class. One student would benefit from attending a class and participating in a discussion but would be better served by not participating in a final research project, while for another student that same final paper or project is a meaningful learning experience. It's perfectly fine, and encouraged, to tailor participation level to an individual student's interests and abilities, and integrate that in each student's plan as part of your advising process. The program has the flexibility to allow students to learn and participate at a level that works for them and to still consider that as part of their program participation.

Non-credit bearing or non-degree courses taken with students without disabilities, often offered through Continuing Education, may also be counted toward the academic component of the program. If the courses are included as program requirements, those also count as contact hours. School offerings for non-credit bearing or non-degree courses will vary from school to school, but a common example might be a leisure and recreation offering. Those can provide an integrated experience and can fit within the spirit of what CTP programs aim to offer. Students would be learning alongside their peers without disabilities in a setting that's a bit more relaxed than a lecture style class and may afford more opportunities for student interaction.

Internships and work‑based training also provide a valuable opportunity for students to experience integrated learning that will be directly applicable to future employment.

What is the minimum number of clock or credit hours for a CTP program to be considered full time?

There is no regulatory designation of an eligible program as full-time. CTP are designed to be flexible. Schools should state in the CTP application whether they consider the program to be part or full time.

How should Satisfactory Academic Progress be determined for students enrolled in a CTP program?

CTP programs are required to have a defined standard for satisfactory academic progress, but because students are likely to be auditing courses and are likely to have various noncredit experiences that can still count as part of their program, you're going to be making that determination in a different way than you would for a standard program at your school. Any required program component that counts towards the contact hours for the program must have a corresponding evaluation of student progress.

Are there tips to consider when completing a CTP program application?

Use the regulations as a checklist to make sure that you've included all the details that you need in your application. When you've carefully designed a program to meet all of the requirements and goals for a CTP program, make sure that you're communicating and providing details for how it is that your program is meeting those requirements. You want to make sure to show how your program is designed to socially and academically integrate students with your general student population to the maximum extent possible. With CTP programs, programming both inside and outside of the classroom is important to the student's experience. Be sure that you don't limit descriptions of your program strictly to what is occurring in the formal classroom setting. Expand your descriptions to include a broader view of the programming you provide to students attending the program. As you go through some of these requirements, you may feel a bit frustrated that some of them are not very prescriptive. You might want more reassurance that you're on the right track. Please keep in mind these are broad to give you freedom to find what works within your institutional structures and what works well for the students you serve.

Can students without intellectual disability attend CTP programs?

Students must meet the criteria for having an intellectual disability as outlined in the Higher Education Opportunity Act to qualify for Title IV aid. The definition of a student with an intellectual disability is a student—
(1) With a cognitive impairment characterized by significant limitations in—
(i) Intellectual and cognitive functioning; and
(ii) Adaptive behavior as expressed in conceptual, social, and practical adaptive skills; and
(2) Who is currently, or was formerly, eligible for special education and related services under the Individuals with Disabilities Education Act (IDEA) (20 U.S.C. 1401), including a student who was determined eligible for special education or related services under the IDEA but was home-schooled or attended private school.

Do schools have to hear back from their accrediting agency before submitting an application to add a CTP program?

No. Schools do not have to have a reply from the accrediting agency. The requirement is that you notify your IHE accreditor that you are submitting an application for a CTP program, but no response from the accrediting agency is required.

If a college or university that wants to seek CTP approval offers different program lengths (e.g., a 2-year program with an optional 3rd year), how should they structure the CTP application?

Treat those as separate programs and write separate CTP applications for each program. You would enroll the student in the program that fits the course of study they are pursuing, but you can always transfer them from one program to another, should they choose to pursue a program of different length than they had originally planned on. For example, a student who began in the two-year program could transfer to the three-year program or the other way around, but separate programs would be established, and students would enroll in one program or the other.

Once a CTP program is approved, does the school need to go through periodic re-approval?

At the present time, approved CTPs do not have an end date and schools do not need to seek re-approval.

If a program undergoes revisions, when should they consider re-applying for CTP approval?

The general guideline that schools should look at is whether their state or accreditor would consider the change to be a substantive change. If the program is changing credential levels such as going from a two year program to a four year program, that would be significant. If the program is changing from having two supervised study periods a week to three supervised study periods a week for students, probably not. Contact the state or accrediting agency to seek advice on whether the program revisions are a substantive change.

How does the CTP-specific CIP code affect CTP programs that were approved before this code was in place?

CIP stands for Classification of Instructional Programs. A CIP code is used by the National Center for Education Statistics. Schools enter a CIP code into COD (Common Origination and Disbursement website) when administering financial aid. The current CIP code, for CTP programs is 30.0001. This was instituted in 2020. Schools do not need to do anything in their E‑app if they used a different CIP code at the time of application. The next time your school updates their E‑app they should update the CIP code associated with the CTP to match what you're using in COD.

Finally, the new CIP code is an option for schools to use. It's not mandatory. Your school's academic governance structure is still responsible for assigning CIP codes to programs. However, since it was designed specifically for CTP programs, we encourage schools to use it.

What type of oversight is provided once an institution's CTP program is approved?

Approved CTP programs are included in program reviews and audits. School Participation Division teams conduct program reviews, and schools are required to have annual compliance audits for all Title IV programs.