Student Eligibility Policy

Effective Date: To Be Determined | Date Issued: August 26, 2025 | Last Version: August 14, 2025

Policy Summary

  1. AE students must meet eligibility requirements in order to receive services.
  2. Students must be at least 16 years old.
  3. Students must be basic skills deficient, lack a high school diploma/equivalency, or be an English language learner.
  4. Students must be a U.S. citizen or have lawful immigration status; local staff must verify citizenship/immigration status, upload digital copies of documentation to the data system, and then destroy sensitive student records.

Revisions Summary

  • Added driver’s license to the list of documents for citizenship and immigration status verification.

Policy

1. Eligible Individuals

Local Adult Education (AE) programs must only allow eligible individuals to participate in services.1 The term “eligible individual” means an individual —

A. who has attained 16 years of age;

B. who is not enrolled or required to be enrolled in secondary school under State law; and

C. who—

i. is basic skills deficient;

ii. does not have a secondary school diploma or its recognized equivalent, and has not achieved an equivalent level of education; or

iii. is an English language learner.

In addition, AE programs must only provide services to individuals who are U.S. citizens or have lawful immigration status.

2. Determining Age Eligibility

Local program staff must determine that a prospective student meets the minimum age requirement during the intake process. A prospective student must disclose their age during initial conversations with staff or when completing program registration information.

If an individual indicates that they are under 16 years of age, they are ineligible for Adult Education services. If an individual indicates that they are 16 or 17 years of age, then they must comply with the State’s compulsory school attendance laws, and may only enroll in the program if their parent or guardian unenrolls them from secondary school and approves enrollment in the Adult Education program.

3. Determining Academic Need Eligibility

Local staff must determine that a prospective student meets the academic need requirement during the intake process. A prospective student demonstrates academic need through (1) being basic skills deficient; or (2) disclosing that they do not have a high school diploma or equivalency diploma; or (3) being an English language learner. Each of these is discussed further, below.

A. Basic Skills Deficient

An individual is considered basic skills deficient if they are “unable to compute or solve problems, or read, write, or speak English, at a level necessary to function on the job, in the individual’s family, or in society.”2

To determine a student’s educational functioning level and specific academic needs, the student must be given an assessment during the intake process. These assessments are TABE (for ABE students) and CASAS (for ESL students). Assessment scores can be used by local staff to help design a program of instruction best-suited to the student’s learning needs (see the TDLWD Assessment Policy for additional details).

Every student who meets the eligibility requirements for the Adult Education program must be indicated as “basic skills deficient” in Jobs4TN for federal reporting purposes.

B. High School Diploma or Equivalency

During intake, an individual may choose to disclose that they do not have a high school diploma or equivalency diploma, thereby automatically meeting the academic need eligibility requirement. However, individuals who do have a high school diploma or equivalency may still receive services if they demonstrate academic need through one of the other options (i.e., they are basic skills deficient or are English language learners).

C. English Language Learner

During intake, an individual may choose to disclose that they are an English language learner, or local staff may make this determination through initial conversations. An individual is considered an English language learner if they have “limited ability in reading, writing, speaking, or comprehending the English language, and —

i. [their] native language is a language other than English; or

ii. [they] live in a family or community environment where a language other than English is the dominant language.”3

A CASAS assessment must be used during the intake process to determine students’ educational functioning levels and academic needs.

4. Citizenship and Immigration Status Verification

Prospective students must prove they are a U.S. citizen or have lawful immigration status. A student must provide documentation for verification prior to attaining 12 program hours and being designated “participant” status. Individuals must provide one of the following documents:

  • Driver’s license (from Tennessee or any other state or territory NOT excluded4)
  • REAL ID license or card (from any state or territory)
  • U.S. social security card
  • U.S. birth certificate
  • U.S. passport or passport card
  • Permanent resident card (Form I-551 or “green card”)
  • Foreign passport or visa with temporary Form I-551
  • Foreign passport with Form I-94 or I-94A
  • Employment Authorization Document (Form I-766 or “work permit”)
  • U.S. Citizen ID card (Form I-197)
  • Identification Card for Use of Resident Citizen (Form I-179)
  • Native American tribal document
  • Other documents that might be specifically held by refugees, asylees, parolees, and other immigrants5

Local staff must inform prospective students of this requirement upfront, prior to them attending intake/orientation, and staff must provide students the list of acceptable documents they can bring. This information should be on the program’s website and be available as a handout that can be sent electronically or provided as a hard copy.

Ideally, students should bring their document when they first attend intake/orientation. If they do not, they can still proceed, but if they do not provide the document prior to attaining 12 program hours, they are ineligible for Adult Education services and may not participate further in the program.

When receiving a document, local staff must briefly review it for authenticity and validity, scan it into an electronic file, and return it to the student. Staff must then upload the digital file to the student’s profile in the student data management system as soon as possible. After documents are uploaded to the data system, staff must use appropriate methods for destroying sensitive personally identifiable information (PII) in paper files and securely deleting sensitive electronic PII.

Governance

Local program directors are responsible for disseminating this policy to their staff members and for providing staff with associated training, checking for understanding, enforcing compliance, and seeking technical assistance from TDLWD staff as necessary.

To ensure compliance with this policy, TDLWD staff will review student enrollment records and verification documents entered into the data system.

1 See WIOA Title II Sec. 203(4).
2 See WIOA Title I Sec. 3(5).
3 See WIOA Title II Sec. 203(7)
4 Excluded states include: California, Colorado, Connecticut, Delaware, Hawaii, Illinois, Maryland, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, Oregon, Rhode Island, Utah, Vermont, Virginia and Washington. Driver’s licenses from these states do NOT qualify for eligibility.
5 This list is non-exhaustive. Additional examples of acceptable documents, including images of what the various documents look like, can be found on the Form 1-9 Acceptable Documents page.