By Michelle Mott, AACRAO Consultant, Innovative Credentials Project Manager
Prison Education Programs are a vital expression of higher education’s commitment to justice, opportunity, and transformation. These structured initiatives provide justice-involved individuals with access to academic and career-focused learning that supports rehabilitation, promotes dignity, and enables successful reentry. At their best, PEPs are engines of transformation—for individuals, for institutions, and for systems.
Recent federal policy shifts reflect a broader recognition of this potential. After decades of exclusion under the 1994 Violent Crime Control and Law Enforcement Act, Congress restored Pell Grant eligibility for incarcerated students as of July 2023—but only through formally approved PEPs that meet rigorous standards for quality, compliance, and educational integrity. AACRAO members are playing a central role in ensuring that these programs are not only compliant but learner-centered and sustainable.
Navigating the Intersection of Student Services and Prison Education
At last week’s 2025 NASFAA Prison Education Program Convening, held in Washington, D.C., leaders from AACRAO’s Prison Education Work Group joined colleagues across financial aid, student services, and prison education to explore strategies and solutions for building systems that truly support incarcerated learners.
The message was clear: programs that fail to center the unique needs and rights of incarcerated learners—and that overlook the essential expertise of registrars, admissions officers, and academic recordkeepers—risk undermining the very integrity, portability, and equity these programs are meant to provide.
In a featured session, workgroup members Dr. Sarah Adams, Dean of Enrollment Services and Registrar at the Milwaukee Area Technical College, and JP Rees, Registrar at the Community College of Vermont, addressed core challenges and considerations for supporting incarcerated students from enrollment through reentry. The discussion, moderated by Quintina Barnett Gallion, AACRAO’s Associate Executive Director for Strategy and Planning, covered critical areas including:
Establishing timely and sustainable enrollment processes.
Adapting student information systems.
Managing transcript accessibility and workflows.
Aligning graduation procedures with correctional timelines.
The session emphasized that registrars and enrollment professionals are not peripheral actors but critical partners in ensuring that incarcerated learners can access, retain, and transfer their academic progress.
AACRAO Senior Fellow Dale King and NASFAA Director of Policy Analysis Jill Desjean led a dedicated session on privacy, underscoring the high stakes of compliance in prison education. Incarcerated students retain the same rights and protections as any other learner under FERPA, with additional layers of federal regulation applying to FAFSA and Federal Tax Information. King stressed both the legal and ethical imperative of protecting student data in PEPs, recommending that institutions focus on:
Comprehensive staff training
Securing informed student consent.
Establishing clear data agreements with correctional partners.
Get Updates on Building Infrastructure for Learning Mobility
This convening marked a pivotal step toward national alignment on the administration of PEPs. With cross-functional input from financial aid, student services, enrollment, and prison education leaders, AACRAO will move forward to develop guidance that aims to address the operational, compliance, and ethical complexities of serving incarcerated learners.
AACRAO’s Prison Education Work Group will continue leading this effort, leveraging its expertise in student records, systems, and learner mobility to ensure incarcerated students have equitable, portable, and verifiable access to education.
As PEP approvals accelerate in 2025, institutional readiness is critical. Colleges and universities must treat PEPs not as side projects, but as integrated extensions of their mission and operations. As one provost at the convening shared: “Treat your prison education program as a location. If you’re serious about your mission, this work is part of it.”
To contribute to this ongoing work or receive updates on draft guidance, join the Learning Mobility mailing list. Together, we are shaping a system where justice-involved learners are fully recognized as part of the higher education community—and where learning truly moves with the learner.