Workforce Pell: Expanding Access to Short-Term Job Training

• Credit articulation. Programs must articulate into a related credit‑bearing certificate or degree at the same institution or at least one other institution, with written verification.
   
• Eligible programs. Programs must be 150–599 clock hours (8–15 weeks); be aligned with high‑skill, high‑wage, or in‑demand occupations; meet student completion and job placement rate requirements; demonstrate that programs yield positive educational and labor market outcomes; articulate into a related credential; lead to a recognized postsecondary credential; and have operated while meeting all requirements for at least 12 months prior to approval.
   
• Working with ineligible programs. Working with ineligible entities. Under a written arrangement, an eligible institution generally may not have an ineligible institution or organization provide more than 25% of an eligible workforce program. For related instruction components of Registered Apprenticeship programs, an ineligible entity may provide more than 25% but less than 50% of the program with accreditor approval.
   
• Registered apprenticeships. Registered apprenticeship programs may participate by counting the related technical instruction (RTI) component that independently meets Workforce Pell requirements (completion, placement, recognized credential). Registered apprenticeship status automatically satisfies the high‑skill, high‑wage, or in‑demand criterion.
   
• Online out-of-state programs. Online Workforce Pell programs may enroll students across state lines only through bilateral agreements between governors. The governor in the institution’s home state must approve the program, and the governor in the student’s state must separately determine that it aligns with local workforce needs. These agreements must also include data‑sharing provisions to support state certification of completion and job placement outcomes.

• Program approval. Governors must approve every Workforce Pell program enrolling students in their state and certify alignment with state high‑skill, high‑wage, or in‑demand definitions (as established under WIOA and Perkins), employer demand, meaningful credit articulation, and 12‑month compliance with eligibility requirements (including for out‑of‑state programs).
   
• State approval in reciprocity situations. Governors must approve any Workforce Pell program enrolling students located in their state, even when the institution participates in state authorization reciprocity. States may enter into bilateral agreements to streamline approvals where appropriate (e.g., among neighboring states).
   
• Review cadence. States must maintain transparent, consistent, and fair approval procedures and review determinations at least every two years, aligned with the WIOA state plan cycle.
   
• Federal oversight. Following gubernatorial approval, ED applies a 12‑month lookback to verify compliance and administers the value-added earnings (VAE) test (see “Annual ED calculation” under “Institutional Accountability and Risk”) using federal earnings data, with authority to determine eligibility, enforce price‑to‑value requirements, and assess liability for noncompliant programs.
   
• Calculate completion and job placement rates. States will calculate annual completion and job placement rates, as they can include all students (not just Workforce Pell recipients) and generally have more complete employment data. States will not be required to calculate completion rates after the 2028–29 award year but will have to calculate job placement in perpetuity.
   
• Written verification required. States must verify in writing, through articulation agreements, transfer‑of‑credit policies, consortia, or comparable documentation, that Workforce Pell credits are accepted by the same institution or by one or more other institutions.
   
• State discretion to strengthen requirements. States may go further by requiring that credits articulate into a related program of study and that short‑term credentials count toward degree or certificate requirements, rather than as elective credit.

• Career pathways misalignment. Students who continue on to a bachelor’s program are included in job placement calculations and may be counted as unemployed, effectively treating continued education as a negative outcome.
   
  • Limited exclusions. Students may be excluded from job placement calculations only due to death, documented medical conditions preventing work, incarceration, or active‑duty military service. Continued education is not an exclusion.
     
  • Transitional on‑ramp. States may use existing administrative data for job placement calculations through 2027–28; beginning in 2028–29, placement must be measured based on employment in the occupation(s) the program prepares students for, or in comparable occupations.
     
• Calculations for out-of-state students. Programs with more than half of students residing outside the state where the program is located will be compared using national price parity.
   
• Timing. Earnings are measured using the first full tax year after completion; tuition comparisons reference the cohort from three years prior (e.g., 2026 completers’ earnings measured in 2027, with VAE determination in 2029).
   
• Annual ED calculation. ED will calculate VAE once per year using a standardized formula:

VAE = (Median earnings of program completers three years after exit [adjusted for regional cost of living] - 150% of the federal poverty level) − published tuition and fees.

• Price enforcement. If tuition exceeds VAE, institutions must immediately reduce charges below VAE. Continued over‑charging results in program ineligibility for the entire award year, applied retroactively.
   
• Consequences. Confirmed VAE failure triggers loss of eligibility and may subject the institution to liability for Pell funds disbursed during the failing year.
   
• Failure to meet completion or placement requirements results in loss of program eligibility. Programs will have a two‑award‑year waiting period before they may reapply. “Substantially similar” programs cannot be approved during the waiting period, preventing evasive rebrands.
   
• Failure to meet VAE requirement triggers liability and loss of eligibility. The pathways to reinstatement require updated governor certification, tuition documentation/attestation, and VAE recalculation for the next award year.
   
• Reporting and certification. States are explicitly responsible for annual oversight and certification, with institutions providing required data and later assuming completion-rate calculations while job placement remains a state accountability function. Institutions must submit completer lists and required student information to enable the state’s calculations. Placement is measured as employment during the second quarter after exit, aligned with WIOA performance indicators.
   
• Accountability. Minimum 70% completion and job placement rates are required, alongside passage of the VAE test (median completer earnings minus 150% of the federal poverty level exceeds tuition and fees). Under the final rules, self-employment is considered part of the 70% job placement and excludes students from VAE calculations if the student was enrolled in any other educational program at the institution or at another eligible institution during the calendar year.
   
• Accountability in 2029–30 and beyond. Students must be employed in the occupation the program prepares them for, or in a comparable high‑skill, high‑wage, or in‑demand occupation. This requirement does not take effect until after the three-year transition period (i.e., 2029–30 academic year).
   
• Known Unknown. How states will submit governor certifications and in what format is still to be determined. However, ED is currently seeking Office of Management and Budget (OMB) approval for a new form to utilize for Governor approval requirements. Additionally, although there is a clearly defined 15-day decision notification requirement, the expected turnaround times for appeals and recertifications are not described.