The U.S. Department of Education has established December 31, 2026, as the reporting deadline for institutions participating in eligible Prison Education Programs (PEPs) for the 2025–26 award year.
The deadline applies to institutions offering eligible PEPs through which confined or incarcerated students receive Federal Pell Grants. Institutions have annual reporting responsibilities covering both students receiving Pell Grants through PEPs and information about the programs themselves.
Two PEP Reporting Requirements
1. Student Reporting through COD
Institutions must report information about every Pell Grant awarded to a student enrolled in a PEP. This reporting is completed using a template available through the Common Origination and Disbursement (COD) System.
The report supplements information already reported through COD and FAFSA data and must include required information such as the transfer and release dates of confined or incarcerated individuals who participated in the institution’s PEP.
The template and instructions for submitting the completed report are available through COD.
2. PEP Institution Survey
Institutions must also complete a separate survey covering their PEP offerings. The survey collects information on topics including:
- Challenges encountered in offering PEPs
- Student transfer and release information
- Services provided to incarcerated students
- How satisfactorily the best interests of incarcerated students are being monitored
ED will contact PEP institutions with instructions for accessing and completing the survey.
Institutions are expected to complete both the COD report and the institution survey by December 31, 2026.
Failure to Report May Result in Penalties
The Federal Register notice emphasizes the importance of completing the annual reporting requirement. An institution’s failure to submit a complete annual report may result in ED initiating an adverse action, including a fine or other penalty under the General Provisions regulations.
PEP Approval Documentation Must Be Shared
In addition to the annual reporting requirements, FSA provided important guidance (GENERAL-26-56) for institutions following approval of a PEP.
When ED approves a PEP, the institution receives an approval letter or approval notice and an updated Eligibility and Certification Approval Report (ECAR) identifying the PEP and its initial approval date.
Institutions should provide copies of these approval documents to both their:
- Accrediting agency
- Oversight entity
This notification is important because it informs those entities of the date the applicable Best Interest Determination timeframe begins and of their respective responsibilities.
FSA noted that the Electronic Announcement serves as the notification to institutions to provide these approval documents, following the process previously discussed in ED’s December 3, 2024 PEP Guidance Letter to Accrediting Agencies.
Looking Ahead
ED is exploring improvements to PEP reporting for future award years, with the goal of eventually streamlining the reporting requirements into a single system and process. Any future changes to the reporting process will be announced separately.
Key Takeaways
For institutions administering Prison Education Programs, the immediate priorities are to:
- Complete the required 2025–26 student reporting through COD.
- Complete ED’s PEP institution survey.
- Ensure required transfer and release information is included in the annual reporting.
- Complete both reporting components by December 31, 2026.
- Confirm that PEP approval documentation, including the approval letter or notice and updated ECAR, has been provided to the institution’s accrediting agency and oversight entity.
- Institutions should review their PEP reporting and documentation processes now to ensure all requirements are completed by the deadline.
References
Federal Register Notice:
2025–26 Award Year Deadline Date for Reports and Other Records Associated With Prison Education Programs Accessing the Federal Pell Grant
Published September 21, 2026
Federal Student Aid Electronic Announcement GENERAL-26-56:
Prison Education Programs – Reporting and Approval Documentation
Published September 21, 2026