On February 17, 2025, correctional officers across New York state staged an unsanctioned strike—the second statewide walkout of the correctional workforce in state history. Following an incident and ensuing lockdown at Collins Correctional Facility, officers at Collins and Elmira began a series of wildcat strikes. At its peak, thousands of officers walked off the job, prompting Governor Kathy Hochul to deploy the National Guard to staff prisons. Officers cited low pay, chronic understaffing, and forced overtime as key grievances, along with ongoing opposition to a 2021 law that limits the use of long-term solitary confinement as a disciplinary measure.

For 22 days, until Governor Hochul announced a deal between the state and strike organizers, life inside New York’s prisons came to a near standstill. Programming for incarcerated individuals was halted, visits were suspended, and even mail and other forms of communication were delayed or disrupted. Reports emerged of people going without hot food, showers, and even basic medical or mental health care. At least seven people died while incarcerated during the strike.

Among the many programs disrupted was the state’s network of college-in-prison initiatives, which serve upwards of 2,000 incarcerated students. Classes were canceled, faculty could not access facilities or communicate with students, and, in the middle of a busy semester, instruction came to an abrupt halt. Even once the National Guard was deployed, understaffing made it impossible for most programs to resume instruction remotely. With no way to connect, students and instructors were left in limbo—uncertain whether classes would resume at all.

While the strike officially ended on March 10, 2025, educational programming has still not fully resumed. The firing of over 2,000 correctional officers who refused to return to work has left some of the state’s prisons significantly understaffed. In early April, a memo from DOCCS Commissioner Daniel Martusciello instructed prison superintendents to compile lists of individuals who might be eligible for early release—a sign of just how strained operations remain.

This ongoing disruption to postsecondary education poses a particular challenge for programs and students receiving federal Pell Grant funding. Under current Return to Title IV (R2T4) regulations, incarcerated students in New York risk not only losing the semester and the coursework they’ve completed so far, but also jeopardizing their future eligibility for financial aid.

R2T4 rules are a complex set of federal regulations governing what happens when a student who receives federal financial aid (including Pell Grants) withdraws from a college or university before completing the term. These rules are crucial because they determine how much of the aid a student has “earned” up to the point of withdrawal—and how much must be returned to the federal government. If the student withdraws early, the school must perform a R2T4 calculation to determine the amount of aid the student “earned” based on the percentage of the term completed. If the student completed less than 60 percent of the term, the school typically must return a portion of the aid to the federal government. Due to the strike, colleges operating inside New York prisons may now be forced to conduct R2T4 calculations for entire cohorts.

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As Ithaka S+R explained in a recent blog post, even before the strike R2T4 rules imposed significant administrative burdens on college-in-prison programs and placed incarcerated students in a particularly vulnerable position. Frequent disruptions—such as lockdowns and transfers—can prevent incarcerated students from finishing their coursework, putting them at risk of losing access to federal aid, and even incur debt, for circumstances outside of their control. New regulations published in January 2025 by the Department of Education addressed some of the specific barriers facing incarcerated learners, allowing prison education programs more flexibility in granting approved leaves of absence for their students.

Frequent disruptions—such as lockdowns and transfers—can prevent incarcerated students from finishing their coursework, putting them at risk of losing access to federal aid, and even incur debt, for circumstances outside of their control.

This mechanism has a catch, though: students are still required to resume and complete their courses in order to remain eligible for future Pell Grant funding. Failing to do so could jeopardize their academic standing and financial aid. For some of the students affected by the New York strike, however, that may be all but impossible—especially in facilities where staffing levels remain too low to restart programming, or in cases where students were transferred or had their security classification changed during the shutdown.

To prevent their students from losing Pell Grant eligibility, many New York prison education programs are already exploring creative strategies to salvage the semester—such as granting leaves of absence en masse or shifting instruction to correspondence formats. But for both students and institutions, earning credit for the term is easier said than done. Granting widespread approved leaves of absence poses procedural challenges for colleges, which will likely need to coordinate with their accreditors and, in some cases, state and federal education agencies to ensure compliance. Federal regulations, moreover, draw a clear line between distance education and correspondence education; programs approved to offer one type cannot simply switch to the other. This distinction carries real consequences: completing coursework via mail or electronic communication may only be viable if institutions can maintain the “regular and substantive interaction” between students and instructors required for distance education—something that is difficult to ensure in a correctional setting under current conditions.

Some programs are turning to the same policies and provisions that enabled the rapid shift to distance education during the COVID-19 pandemic, adapting those emergency frameworks to address a very different kind of disruption. Others—one program administrator told us—are attempting to leverage a provision within the New York State Department of Education’s regulations that allows for credit to be granted with fewer hours of instruction and study than typically required, provided the reduction results from a “disaster” declared by state or local government. Still, programs are left to navigate the murky question of instructional equivalency—deciding what level of reduced contact hours can reasonably, and ethically, be extended to students under these extraordinary conditions.

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The entire field of higher education in prison should take note of what is unfolding in New York State—and learn from it. While large-scale, system-wide disruptions may seem rare, as one higher education administrator reminded us, New York has now experienced two in just five years. This latest crisis underscores the need to prepare for a range of more common challenges, including facility-specific staffing shortages, extended lockdowns, student transfers, and releases. Programs must also plan for less predictable disruptions—natural disasters, public health emergencies, or other events that can disproportionately impact correctional settings.

This latest crisis underscores the need to prepare for a range of more common challenges, including facility-specific staffing shortages, extended lockdowns, student transfers, and releases.

To ensure educational continuity and protect students, colleges and programs should engage proactively with faculty, departments of corrections, state education agencies, and accreditors to develop clear contingency plans. One faculty member we spoke to suggested incorporating distance education backup plans directly into course design and syllabi—laying out alternate delivery methods and workflows from the start, so they can be activated quickly when needed.

Fortunately, colleges and programs don’t need to start from scratch. Many higher education in prison programs already developed emergency instruction policies in the wake of the COVID-19 pandemic, often in collaboration with departments of corrections and other stakeholders. These efforts, along with prior experiences managing lockdowns and other disruptions, can serve as a foundation for more comprehensive preparedness planning. By building on existing frameworks, programs can begin to craft more resilient education protocols that account for the full range of disruptions students may face, from the individual to the system-wide. The goal is not just continuity, but continuity without sacrificing instructional quality. Coalitions of higher education in prison programs can also serve a particularly important role in times of uncertainty and tumult, by providing a forum for collaborative problem solving, and allowing institutions to pool resources and protocols.

This work should not fall solely on the shoulders of those operating and overseeing college-in-prison programs. As they continue to revise R2T4 regulations, policymakers need to ensure they reflect the realities of all financial aid recipients—including incarcerated Pell Grant students—so that they are not penalized for disruptions beyond their control. The rules published in January 2025 represent progress in this direction, but as this blog has shown, more work remains.

Departments of corrections and higher education institutions also have critical roles to play. Corrections agencies, in consultation with prison education programs, must develop policies that minimize educational disruptions caused by transfers between facilities or changes in security classification. When such transfers are necessary, there must be clear pathways in place for students to complete their coursework and continue their education. Similarly, higher education institutions must create more flexible and accessible pathways for their incarcerated students, including clear options for re-enrollment and course completion on their main campus following release.