[{"data":1,"prerenderedAt":1836},["ShallowReactive",2],{"article-\u002Flibrary\u002Fdata-playbooks\u002Fverifying-employment-outcomes":3,"siblings-data-playbooks":344},{"id":4,"title":5,"body":6,"description":315,"extension":316,"meta":317,"navigation":318,"path":319,"pillar":320,"pinned":321,"publishedDate":322,"readTime":323,"section":324,"seo":325,"sources":326,"stem":336,"tags":337,"updatedDate":322,"__hash__":343},"library\u002Flibrary\u002Fdata-playbooks\u002Fverifying-employment-outcomes.md","Verifying Employment Outcomes: UI Wage Records, Employer Letters, and Surveys",{"type":7,"value":8,"toc":302},"minimark",[9,23,26,31,59,69,72,103,114,118,121,126,129,136,147,150,156,160,163,168,172,175,180,192,196,199,240,251,261,265],[10,11,12,13,17,18,22],"p",{},"The placement half of the 70\u002F70 rule asks a precisely framed question: was each completer ",[14,15,16],"strong",{},"employed during the second quarter after program exit","? Answering it defensibly is a verification problem. A completer you ",[19,20,21],"em",{},"believe"," is working but cannot document is, for reporting purposes, at risk of counting against you — and unlike the completion metric, this one depends on evidence generated outside your walls.",[10,24,25],{},"For award years 2026–27 through 2028–29, completion and placement rates are determined and verified under your state's methodology — confirm specifics with your governor's office or state workforce board before relying on any calculation. That caveat matters doubly here, because verification method is exactly where state methodologies will differ most.",[27,28,30],"h2",{"id":29},"the-timing-mechanics-second-calendar-quarter-after-exit","The timing mechanics: second calendar quarter after exit",[10,32,33,34,37,38,41,42,46,47,50,51,54,55,58],{},"The binding measure is ",[14,35,36],{},"34 CFR 690.94",": the completer must be ",[14,39,40],{},"employed during the second calendar quarter after program exit",", as shown in state administrative data — unemployment insurance (UI) wage records. Work through two examples. A student whose ",[43,44,45],"code",{},"exit_date"," is November 25, 2026 exits during Q4 2026; the first quarter after exit is Q1 2027, and the ",[14,48,49],{},"second calendar quarter after exit is Q2 2027 (April–June)",". A ",[14,52,53],{},"June completer"," exits during Q2, so the measurement quarter is ",[14,56,57],{},"October–December",". Employment at any point within that quarter is what counts.",[10,60,61,64,65,68],{},[14,62,63],{},"Beware the 180-day myth."," The statute (P.L. 119-21, adding HEA § 401(k)) says placement is \"measured 180 days after completion,\" and \"placed within 180 days\" has become the most repeated error in coverage of the program. The regulation that actually binds you is quarter-based: employment ",[14,66,67],{},"during the second calendar quarter after exit",", shown in state data — not a day-count from completion. Build your tracking around the quarter.",[10,70,71],{},"Three operational consequences:",[73,74,75,91,97],"ol",{},[76,77,78,81,82,87,88,90],"li",{},[14,79,80],{},"The window is knowable on day one."," The moment a student exits, you can compute the verification quarter and diary the follow-up. Store it in your ",[83,84,86],"a",{"href":85},"\u002Flibrary\u002Fdata-playbooks\u002Fbuilding-your-cohort-file","cohort file"," alongside ",[43,89,45],{},".",[76,92,93,96],{},[14,94,95],{},"Quarter boundaries cluster your workload."," All completers exiting within the same quarter share a verification quarter, so verification work arrives in batches — plan career services capacity around those batches.",[76,98,99,102],{},[14,100,101],{},"The quarters are calendar quarters"," — the same quarters state UI wage records are kept in, which is exactly why 34 CFR 690.94 defines the window this way. What to confirm with your state workforce board is the process detail: match mechanics and any documentation deadline after the measurement quarter closes.",[10,104,105,106,109,110,113],{},"Note the phase change: for award years 2026–27 through 2028–29, ",[14,107,108],{},"any employment"," in the window counts. ",[14,111,112],{},"After award year 2028–29, employment must be in the occupation the program prepared the student for — matched by SOC code — or a comparable high-skill, high-wage, or in-demand occupation."," So begin capturing employer, start date, and occupation\u002FSOC now, even though Phase 1 does not require it. Retrofitting occupation data in 2029 will be miserable; capturing it in 2026 is one extra field.",[27,115,117],{"id":116},"the-verification-hierarchy","The verification hierarchy",[10,119,120],{},"The typical sources, in descending order of defensibility:",[122,123,125],"h3",{"id":124},"_1-state-ui-wage-records-best-evidence-least-effort-per-student","1. State UI wage records (best evidence, least effort per student)",[10,127,128],{},"State unemployment insurance wage records are quarterly, employer-reported, and administrative — no student cooperation needed — and under 34 CFR 690.94 they are the data the rate is actually built from. Where your state offers a data match for training providers (many workforce boards run one for WIOA-style reporting), it should be your primary source. Know the limitations: wage records lag the quarter they cover, generally miss self-employment, federal\u002Fmilitary employment, and out-of-state work (absent interstate data-sharing arrangements), and matching depends on accurate SSNs.",[10,130,131,132,135],{},"The lag has an operational moral: ",[14,133,134],{},"the student you can't find in the data is a placement you don't get credit for — collect the destination at graduation, verify later."," By the time match results return, a graduate who changed phones or moved is gone; the employer name and start date you captured at completion is what lets you fill the gap with an employer letter.",[10,137,138,139,142,143,146],{},"One gap deserves early escalation: ",[14,140,141],{},"1099 contractors and owner-operators may not appear in UI wage records at all",", because independent-contractor pay is not employer-reported wage data. For CDL programs — where owner-operator paths are common — this is a structural undercount worth raising with your state workforce board ",[14,144,145],{},"now",", before your first cohort is measured: ask how the state's methodology treats completers who are verifiably working but invisible to the wage match.",[10,148,149],{},"Ask your state workforce board: what match process exists, what consent or data agreements it requires, and how long after quarter-end results arrive.",[10,151,152,155],{},[14,153,154],{},"Retain:"," the match request, the returned result (or a screenshot\u002Fextract with date), and the consent documentation.",[122,157,159],{"id":158},"_2-employer-verification-letters-strong-evidence-moderate-effort","2. Employer verification letters (strong evidence, moderate effort)",[10,161,162],{},"A signed statement from the employer confirming the completer was employed during the window. Best practice: a one-page template asking for employee name, job title, start date, employment status during the specific quarter, and the signer's name and role.",[10,164,165,167],{},[14,166,154],{}," the signed letter or email thread, with the request date and the responder's identity.",[122,169,171],{"id":170},"_3-graduate-surveys-and-self-attestation-weakest-evidence-last-resort","3. Graduate surveys and self-attestation (weakest evidence, last resort)",[10,173,174],{},"A survey response from the graduate stating employer, title, and start date. On its own this is the easiest evidence to challenge; strengthen it by collecting corroboration — an offer letter, a pay stub (redact wage details if your state allows), or a LinkedIn-style public record captured with a date. Confirm whether your state accepts self-attestation at all, and whether it requires corroboration.",[10,176,177,179],{},[14,178,154],{}," the survey instrument, the response, the date, and any corroborating artifact.",[10,181,182,183,186,187,191],{},"Whatever the source, record it in the cohort file's ",[43,184,185],{},"verification_source"," field, one value per student. When your state's methodology specifies an order of precedence, follow it; when it is silent, use the hierarchy above and say so in your methodology notes — the ",[83,188,190],{"href":189},"\u002Flibrary\u002Fdata-playbooks\u002Fpreparing-the-70-70-report","70\u002F70 report"," should disclose the mix of sources behind your rate.",[27,193,195],{"id":194},"chasing-non-responders","Chasing non-responders",[10,197,198],{},"Every cohort has completers who vanish. The difference between a 65 percent and a 75 percent verified rate is usually chasing, not employment. A working protocol:",[200,201,202,208,214,220,226],"ul",{},[76,203,204,207],{},[14,205,206],{},"Start before exit."," Collect personal (non-school) email, phone, an emergency contact, and consent for the UI data match during enrollment — not after graduation, when leverage is gone.",[76,209,210,213],{},[14,211,212],{},"Sequence the outreach."," In the verification quarter: text first (highest response rate), then email, then phone, then the emergency contact, then the employer if known from placement records. Space attempts across the quarter; log every attempt with date and channel.",[76,215,216,219],{},[14,217,218],{},"Make responding trivial."," A two-question mobile survey outperforms a form. Offer to accept a photo of an offer letter.",[76,221,222,225],{},[14,223,224],{},"Use your placement pipeline."," If career services helped place the student, the employer relationship is your verification channel — the placement record is half the evidence already.",[76,227,228,231,232,235,236,239],{},[14,229,230],{},"Close the loop formally."," Only after the logged attempts are exhausted does a student move from ",[43,233,234],{},"pending"," to ",[43,237,238],{},"unknown"," — and your attempt log is itself evidence of good-faith methodology if the rate is ever questioned.",[10,241,242,243,247,248,250],{},"Run the numbers as verification comes in: the ",[83,244,246],{"href":245},"\u002Ftools\u002F70-70-report","70\u002F70 Report Generator"," will show your verified placement rate and how many ",[43,249,238],{}," rows stand between you and the 70 percent line.",[10,252,253,254,260],{},"For CDL and truck-driving schools — squarely in the 150–599 clock-hour band that makes them prime Workforce Pell candidates — ",[83,255,259],{"href":256,"rel":257},"https:\u002F\u002Fdrivertrack.ai",[258],"nofollow","DriverTrack"," is a school-management platform built for CDL programs that tracks placements alongside training records.",[27,262,264],{"id":263},"what-to-do-now","What to do now",[73,266,267,273,279,285,291],{},[76,268,269,272],{},[14,270,271],{},"Compute the verification quarter for every completer"," in your cohort file and diary the outreach batch for each quarter.",[76,274,275,278],{},[14,276,277],{},"Contact your state workforce board"," about UI wage record matching: process, consent requirements, and turnaround.",[76,280,281,284],{},[14,282,283],{},"Add consent and personal contact collection to enrollment paperwork"," effective immediately.",[76,286,287,290],{},[14,288,289],{},"Start capturing employer, start date, and occupation\u002FSOC"," now to be ready for the SOC-matched placement test that applies after award year 2028–29.",[76,292,293,296,297,301],{},[14,294,295],{},"Write the non-responder protocol"," — channels, sequence, attempt log — and hold ",[83,298,300],{"href":299},"\u002Flibrary\u002Faudits-reporting\u002Frecords-retention","the evidence"," as long as the rate it supports can be questioned.",{"title":303,"searchDepth":304,"depth":304,"links":305},"",2,[306,307,313,314],{"id":29,"depth":304,"text":30},{"id":116,"depth":304,"text":117,"children":308},[309,311,312],{"id":124,"depth":310,"text":125},3,{"id":158,"depth":310,"text":159},{"id":170,"depth":310,"text":171},{"id":194,"depth":304,"text":195},{"id":263,"depth":304,"text":264},"How to verify Workforce Pell job placement: UI wage records, employer letters, and surveys — second-quarter-after-exit timing, and chasing non-responders.","md",{},true,"\u002Flibrary\u002Fdata-playbooks\u002Fverifying-employment-outcomes","data-playbooks",false,"2026-07-19",7,"4.3",{"title":5,"description":315},[327,330,333],{"label":328,"url":329},"Final rule, 91 FR 29254 (May 19, 2026)","https:\u002F\u002Fwww.federalregister.gov\u002Fdocuments\u002F2026\u002F05\u002F19\u002F2026-10013\u002Faccountability-in-higher-education-and-access-through-demand-driven-workforce-pell-pell-grant",{"label":331,"url":332},"Workforce Pell final rule fact sheet (ED)","https:\u002F\u002Fwww.ed.gov\u002Fmedia\u002Fdocument\u002Fworkforce-pell-grant-final-rule-fact-sheet-114075.pdf",{"label":334,"url":335},"P.L. 119-21, § 83002 (statutory text, govinfo)","https:\u002F\u002Fwww.govinfo.gov\u002Fcontent\u002Fpkg\u002FPLAW-119publ21\u002Fhtml\u002FPLAW-119publ21.htm","library\u002Fdata-playbooks\u002Fverifying-employment-outcomes",[338,339,340,341,342],"job placement rate","70\u002F70 rule","UI wage records","employment verification","workforce pell","uNKgkMwSXemxcvsr6JQG7vnE5qrU-DTgUi3x4lDeNEw",[345,923,1299,1488],{"id":346,"title":347,"body":348,"description":912,"extension":316,"meta":913,"navigation":318,"path":85,"pillar":320,"pinned":318,"publishedDate":322,"readTime":323,"section":914,"seo":915,"sources":916,"stem":919,"tags":920,"updatedDate":322,"__hash__":922},"library\u002Flibrary\u002Fdata-playbooks\u002Fbuilding-your-cohort-file.md","Building Your 70\u002F70 Cohort File: The Minimum Data Schema",{"type":7,"value":349,"toc":905},[350,368,371,375,378,612,640,658,673,677,698,701,709,713,771,774,778,855,862,864,901],[10,351,352,353,356,357,360,361,363,364,367],{},"Every Workforce Pell compliance question ultimately reduces to a table with one row per student. Can your program show that ",[14,354,355],{},"at least 70 percent"," of participants completed within ",[14,358,359],{},"150 percent of normal time",", and that ",[14,362,355],{}," of completers were employed in the ",[14,365,366],{},"second quarter after program exit","? If you cannot produce the row-level data behind those two rates, you cannot defend them — to your state, to your governor's certification process, or eventually under federal methodology.",[10,369,370],{},"This article defines the minimum schema for that table: the 70\u002F70 cohort file. Start it on day one of your first Workforce Pell cohort. Reconstructing it later from scattered systems is the single most expensive mistake schools make.",[27,372,374],{"id":373},"the-minimum-schema","The minimum schema",[10,376,377],{},"One row per student, per program enrollment. Ten fields are non-negotiable:",[379,380,381,400],"table",{},[382,383,384],"thead",{},[385,386,387,391,394,397],"tr",{},[388,389,390],"th",{},"#",[388,392,393],{},"Field",[388,395,396],{},"Type",[388,398,399],{},"Notes",[401,402,403,425,440,456,472,488,503,518,555,584],"tbody",{},[385,404,405,409,414,417],{},[406,407,408],"td",{},"1",[406,410,411],{},[43,412,413],{},"student_id",[406,415,416],{},"string",[406,418,419,420,424],{},"Your SIS identifier. Use the same ID you use for NSLDS and ",[83,421,423],{"href":422},"\u002Flibrary\u002Faudits-reporting\u002Ffvt-ge-reporting","FVT\u002FGE reporting"," so files reconcile.",[385,426,427,430,435,437],{},[406,428,429],{},"2",[406,431,432],{},[43,433,434],{},"program",[406,436,416],{},[406,438,439],{},"Program name or code, tied to a CIP code. One file per program — eligibility is per program, not per institution.",[385,441,442,445,450,453],{},[406,443,444],{},"3",[406,446,447],{},[43,448,449],{},"start_date",[406,451,452],{},"date (YYYY-MM-DD)",[406,454,455],{},"First scheduled day of attendance for this enrollment.",[385,457,458,461,466,469],{},[406,459,460],{},"4",[406,462,463],{},[43,464,465],{},"normal_completion_weeks",[406,467,468],{},"integer",[406,470,471],{},"The program's published normal time in weeks (8–14 for Workforce Pell programs, which run at least 8 but fewer than 15 weeks).",[385,473,474,477,482,485],{},[406,475,476],{},"5",[406,478,479],{},[43,480,481],{},"actual_completion_date",[406,483,484],{},"date or blank",[406,486,487],{},"Date the student completed. Blank if withdrawn or still enrolled.",[385,489,490,493,498,500],{},[406,491,492],{},"6",[406,494,495],{},[43,496,497],{},"withdrawal_date",[406,499,484],{},[406,501,502],{},"Date of withdrawal, if any. Exactly one of fields 5 and 6 is populated once the student's outcome is known.",[385,504,505,508,512,515],{},[406,506,507],{},"7",[406,509,510],{},[43,511,45],{},[406,513,514],{},"date",[406,516,517],{},"Date the student left the program for any reason — completion or withdrawal. This starts the placement clock.",[385,519,520,523,528,542],{},[406,521,522],{},"8",[406,524,525],{},[43,526,527],{},"employment_status_q2",[406,529,530,531,534,535,534,538,534,540],{},"enum: ",[43,532,533],{},"employed"," \u002F ",[43,536,537],{},"not_employed",[43,539,238],{},[43,541,234],{},[406,543,544,545,548,549,551,552,554],{},"Employment status during the ",[14,546,547],{},"second calendar quarter after exit"," (34 CFR 690.94). ",[43,550,234],{}," until the window closes; ",[43,553,238],{}," only after verification attempts are exhausted.",[385,556,557,560,564,578],{},[406,558,559],{},"9",[406,561,562],{},[43,563,185],{},[406,565,530,566,534,569,534,572,534,575],{},[43,567,568],{},"ui_wage_records",[43,570,571],{},"employer_letter",[43,573,574],{},"survey",[43,576,577],{},"none",[406,579,580,581,90],{},"How field 8 was verified. See ",[83,582,583],{"href":319},"verifying employment outcomes",[385,585,586,589,594,609],{},[406,587,588],{},"10",[406,590,591],{},[43,592,593],{},"exclusion",[406,595,530,596,534,599,534,602,534,605,608],{},[43,597,598],{},"death",[43,600,601],{},"disabling-condition",[43,603,604],{},"military-30plus",[43,606,607],{},"incarcerated",", blank otherwise",[406,610,611],{},"The four allowable exclusions under 34 CFR part 690, subpart H. Blank for every student who counts.",[10,613,614,615,617,618,621,622,625,626,629,630,632,633,636,637,639],{},"The ",[43,616,593],{}," column deserves its own rule. Under 34 CFR part 690, subpart H, exactly four circumstances let you remove a student from the 70\u002F70 math: the student ",[14,619,620],{},"died",", suffered a ",[14,623,624],{},"totally disabling condition",", was ",[14,627,628],{},"called to military service for more than 30 days",", or was ",[14,631,607],{},". An excluded student comes out of ",[14,634,635],{},"both the numerator and the denominator of both rates"," — completion and placement alike. Every non-blank value in this column needs an evidence file behind it (death certificate, medical documentation, military orders, incarceration record); an undocumented exclusion is an audit finding, not a judgment call. The ",[83,638,246],{"href":245}," roster template now supports this column and applies the exclusions to both rates automatically.",[10,641,642,643,646,647,649,650,652,653,657],{},"A derived eleventh column is worth storing rather than recomputing: ",[43,644,645],{},"deadline_150"," = ",[43,648,449],{}," + (1.5 × ",[43,651,465],{},") weeks. For a 12-week program, that is week 18. The ",[83,654,656],{"href":655},"\u002Flibrary\u002Fdata-playbooks\u002Ftracking-completion-within-150-percent","150 percent tracking playbook"," covers the operational edge cases — leaves of absence, re-entries, transfers.",[10,659,660,661,664,665,668,669,672],{},"Beyond the per-student rows, the file (or a companion program record) must carry: the program's length in ",[14,662,663],{},"both weeks and clock hours"," — the two eligibility bounds run independently; the ",[14,666,667],{},"published tuition and fees for each award year"," — the future input to the value-added earnings test; and graduate follow-up fields — ",[14,670,671],{},"employer, start date, and occupation with SOC code"," — which become load-bearing when placement shifts to occupation matching after award year 2028–29.",[27,674,676],{"id":675},"sample-csv-row","Sample CSV row",[678,679,683],"pre",{"className":680,"code":681,"language":682,"meta":303,"style":303},"language-csv shiki shiki-themes github-light github-dark","student_id,program,start_date,normal_completion_weeks,actual_completion_date,withdrawal_date,exit_date,employment_status_q2,verification_source,exclusion\nS-2027-0142,Commercial Truck Driving (CIP 49.0205),2026-09-08,12,2026-11-25,,2026-11-25,employed,ui_wage_records,\n","csv",[43,684,685,693],{"__ignoreMap":303},[686,687,690],"span",{"class":688,"line":689},"line",1,[686,691,692],{},"student_id,program,start_date,normal_completion_weeks,actual_completion_date,withdrawal_date,exit_date,employment_status_q2,verification_source,exclusion\n",[686,694,695],{"class":688,"line":304},[686,696,697],{},"S-2027-0142,Commercial Truck Driving (CIP 49.0205),2026-09-08,12,2026-11-25,,2026-11-25,employed,ui_wage_records,\n",[10,699,700],{},"This student started September 8, completed on November 25 — comfortably inside the 18-week (150 percent) deadline — and was verified employed in the second quarter after exit via state UI wage records. That row contributes favorably to both rates.",[10,702,703,708],{},[14,704,705,706,90],{},"This schema matches the roster template used by the ",[83,707,246],{"href":245}," If you maintain your cohort file in exactly these columns, you can upload it and generate both rates — and a submission-ready report — without any remapping.",[27,710,712],{"id":711},"rules-that-keep-the-file-defensible","Rules that keep the file defensible",[200,714,715,729,744,755,765],{},[76,716,717,720,721,724,725,728],{},[14,718,719],{},"Denominators are decided by definitions, not convenience."," The completion rate is measured over program ",[19,722,723],{},"participants","; the placement rate is measured over ",[19,726,727],{},"completers",". Record every enrolled student — including withdrawals — or your completion denominator is wrong. Never delete a row.",[76,730,731,734,735,737,738,740,741,743],{},[14,732,733],{},"Dates come from source systems."," ",[43,736,449],{}," from the enrollment agreement, ",[43,739,481],{}," from the registrar's completion record, ",[43,742,497],{}," from the same determination you use for R2T4. If the cohort file and the student file disagree, you have an audit problem, not just a data problem.",[76,745,746,754],{},[14,747,748,750,751,753],{},[43,749,238],{}," is not ",[43,752,537],{}," — but plan conservatively."," How unverified completers are treated in the rate calculation depends on your state's methodology; until confirmed, assume an unverifiable completer does not help your numerator, which is why chasing verification matters.",[76,756,757,760,761,764],{},[14,758,759],{},"Snapshot it."," Freeze a dated copy of the file at each reporting milestone. The version you submitted must be reproducible years later — see ",[83,762,763],{"href":299},"records retention"," for why the retention horizon here is longer than the Title IV three-year baseline.",[76,766,767,770],{},[14,768,769],{},"One file per program per cohort period."," Failure consequences attach at the program level: a program that fails 70\u002F70 loses Workforce Pell eligibility, and it (or a substantially similar program) cannot be re-established for two years.",[10,772,773],{},"For award years 2026–27 through 2028–29, completion and placement rates are determined and verified under your state's methodology — confirm specifics with your governor's office or state workforce board before relying on any calculation. Your state may require additional fields (for example, wage amounts, occupation codes for the Phase 2 placement definition starting 2029–30, or demographic data). Treat this schema as the floor, and add state-required columns to the same file rather than starting a parallel one.",[27,775,777],{"id":776},"where-the-data-comes-from","Where the data comes from",[379,779,780,789],{},[382,781,782],{},[385,783,784,786],{},[388,785,393],{},[388,787,788],{},"System of record",[401,790,791,805,814,827,838,847],{},[385,792,793,802],{},[406,794,795,797,798,797,800],{},[43,796,413],{},", ",[43,799,434],{},[43,801,449],{},[406,803,804],{},"SIS \u002F enrollment agreement",[385,806,807,811],{},[406,808,809],{},[43,810,465],{},[406,812,813],{},"Program approval documents (what you certified to the governor)",[385,815,816,824],{},[406,817,818,797,820,797,822],{},[43,819,481],{},[43,821,497],{},[43,823,45],{},[406,825,826],{},"Registrar \u002F attendance system",[385,828,829,835],{},[406,830,831,797,833],{},[43,832,527],{},[43,834,185],{},[406,836,837],{},"Career services \u002F state UI data match",[385,839,840,844],{},[406,841,842],{},[43,843,593],{},[406,845,846],{},"Registrar determination + the evidence file for each excluded student",[385,848,849,852],{},[406,850,851],{},"Tuition\u002Ffees per award year, weeks and clock hours",[406,853,854],{},"Catalog \u002F program approval documents",[10,856,857,858,861],{},"The file is a join across at least three offices. Assign one owner who reconciles it monthly; the ",[83,859,860],{"href":655},"monitoring cadence article"," describes the rhythm.",[27,863,264],{"id":263},[73,865,866,877,883,889,895],{},[76,867,868,871,872,874,875,90],{},[14,869,870],{},"Create the file today"," for every active Workforce Pell cohort, with the ten fields above plus ",[43,873,645],{}," — even if employment columns sit at ",[43,876,234],{},[76,878,879,882],{},[14,880,881],{},"Backfill from source systems",", not memory: enrollment agreements, registrar records, R2T4 withdrawal determinations.",[76,884,885,888],{},[14,886,887],{},"Ask your state workforce board"," for its data specification and add any extra required columns now.",[76,890,891,894],{},[14,892,893],{},"Assign a single owner"," and a monthly reconciliation step against the SIS.",[76,896,897,900],{},[14,898,899],{},"Run the file through the report generator"," (linked above) to see your current rates and which rows are dragging them.",[902,903,904],"style",{},"html .default .shiki span {color: var(--shiki-default);background: var(--shiki-default-bg);font-style: var(--shiki-default-font-style);font-weight: var(--shiki-default-font-weight);text-decoration: var(--shiki-default-text-decoration);}html .shiki span {color: var(--shiki-default);background: var(--shiki-default-bg);font-style: var(--shiki-default-font-style);font-weight: var(--shiki-default-font-weight);text-decoration: var(--shiki-default-text-decoration);}html .dark .shiki span {color: var(--shiki-dark);background: var(--shiki-dark-bg);font-style: var(--shiki-dark-font-style);font-weight: var(--shiki-dark-font-weight);text-decoration: var(--shiki-dark-text-decoration);}html.dark .shiki span {color: var(--shiki-dark);background: var(--shiki-dark-bg);font-style: var(--shiki-dark-font-style);font-weight: var(--shiki-dark-font-weight);text-decoration: var(--shiki-dark-text-decoration);}",{"title":303,"searchDepth":304,"depth":304,"links":906},[907,908,909,910,911],{"id":373,"depth":304,"text":374},{"id":675,"depth":304,"text":676},{"id":711,"depth":304,"text":712},{"id":776,"depth":304,"text":777},{"id":263,"depth":304,"text":264},"The minimum per-student data schema for tracking Workforce Pell 70\u002F70 compliance — fields, formats, a sample CSV row, and how it maps to the report generator.",{},"4.1",{"title":347,"description":912},[917,918],{"label":328,"url":329},{"label":331,"url":332},"library\u002Fdata-playbooks\u002Fbuilding-your-cohort-file",[339,342,86,921],"data schema","gE0BSw4XBL3Lt-q9_W_nyGacWhMDN0kl0dfpkKMlwuk",{"id":924,"title":925,"body":926,"description":1285,"extension":316,"meta":1286,"navigation":318,"path":655,"pillar":320,"pinned":321,"publishedDate":322,"readTime":323,"section":1287,"seo":1288,"sources":1289,"stem":1294,"tags":1295,"updatedDate":322,"__hash__":1298},"library\u002Flibrary\u002Fdata-playbooks\u002Ftracking-completion-within-150-percent.md","Tracking Completion Within 150% of Normal Time: Operational Playbook",{"type":7,"value":927,"toc":1277},[928,935,939,945,1005,1008,1011,1044,1047,1051,1058,1092,1095,1099,1111,1144,1148,1151,1156,1191,1197,1201,1204,1237,1239],[10,929,930,931,934],{},"The Workforce Pell completion metric is unforgiving in one specific way: it is a deadline test. ",[14,932,933],{},"At least 70 percent of program participants must complete within 150 percent of the normal time to completion."," A student who finishes in week 19 of a 12-week program is, for this metric, indistinguishable from a student who never finished at all. That makes completion tracking a scheduling problem, not just a records problem — and scheduling problems are solvable with monitoring.",[27,936,938],{"id":937},"computing-each-students-deadline","Computing each student's deadline",[10,940,941,942,90],{},"The formula is simple: ",[14,943,944],{},"deadline = start date + (1.5 × normal completion weeks)",[379,946,947,960],{},[382,948,949],{},[385,950,951,954,957],{},[388,952,953],{},"Normal program length",[388,955,956],{},"150% window",[388,958,959],{},"Example: start Sept 8, 2026",[401,961,962,973,984,994],{},[385,963,964,967,970],{},[406,965,966],{},"8 weeks",[406,968,969],{},"12 weeks",[406,971,972],{},"deadline Dec 1, 2026",[385,974,975,978,981],{},[406,976,977],{},"10 weeks",[406,979,980],{},"15 weeks",[406,982,983],{},"deadline Dec 22, 2026",[385,985,986,988,991],{},[406,987,969],{},[406,989,990],{},"18 weeks",[406,992,993],{},"deadline Jan 12, 2027",[385,995,996,999,1002],{},[406,997,998],{},"14 weeks",[406,1000,1001],{},"21 weeks",[406,1003,1004],{},"deadline Feb 2, 2027",[10,1006,1007],{},"(Workforce Pell programs run at least 8 but fewer than 15 weeks, so every deadline lands between 12 and 21 weeks after start.)",[10,1009,1010],{},"Three practical rules:",[73,1012,1013,1029,1038],{},[76,1014,1015,1018,1019,734,1022,1024,1025,90],{},[14,1016,1017],{},"\"Normal time\" is the published length you certified"," for the program — the same figure in your program approval documents and your ",[83,1020,1021],{"href":85},"cohort file's",[43,1023,465],{}," field. Don't let marketing materials, catalogs, and certification documents disagree on program length; any mismatch surfaces in an ",[83,1026,1028],{"href":1027},"\u002Flibrary\u002Faudits-reporting\u002Fprogram-reviews-what-to-expect","audit or review",[76,1030,1031,1034,1035,1037],{},[14,1032,1033],{},"Compute the deadline at enrollment and store it"," (",[43,1036,645],{},") rather than recalculating ad hoc. A stored deadline can be monitored; a formula in someone's head cannot.",[76,1039,1040,1043],{},[14,1041,1042],{},"Half-weeks: pick a convention and document it."," For odd-week programs (1.5 × 9 = 13.5 weeks), decide whether you round to the scheduled class day and write the convention into your methodology notes. Confirm whether your state's methodology prescribes a convention before you rely on yours.",[10,1045,1046],{},"If your school runs clock-hour Title IV programs, you already track a 150 percent maximum timeframe for SAP. The parallel is useful — the muscle memory transfers — but do not assume the two calculations are interchangeable. SAP is governed by the FSA Handbook; the 70\u002F70 completion window is governed by the final rule (FR 2026-10013) and, in the transitional years, your state's methodology.",[27,1048,1050],{"id":1049},"edge-cases-leaves-re-entries-transfers","Edge cases: leaves, re-entries, transfers",[10,1052,1053,1054,1057],{},"This is where completion tracking gets litigated. After award year 2028–29, the completion calculation runs under the clock-hour completion methodology of ",[14,1055,1056],{},"34 CFR 668.8(f)","; how the tricky cases count during the transitional years is largely in your state's hands.",[200,1059,1060,1070,1076,1082],{},[76,1061,1062,1065,1066,1069],{},[14,1063,1064],{},"Leaves of absence."," For Title IV purposes, an approved LOA has strict conditions, and an LOA that fails them becomes a withdrawal (with R2T4 consequences). Whether an approved LOA pauses the 150 percent clock for the 70\u002F70 completion metric is ",[14,1067,1068],{},"not something to assume"," — confirm against the final rule and your state's methodology. Until confirmed, plan conservatively: treat the calendar deadline as fixed and the LOA as consuming it.",[76,1071,1072,1075],{},[14,1073,1074],{},"Re-entries."," A student who withdraws and later re-enrolls raises two questions: is that one enrollment or two, and which start date governs the deadline? Document your treatment, apply it uniformly, and get your state's written concurrence.",[76,1077,1078,1081],{},[14,1079,1080],{},"Transfers between programs."," A student who moves from one of your programs to another is a withdrawal from the first program's cohort unless your state's methodology says otherwise. Eligibility and rates attach per program — the receiving program's cohort file gets a new row with a new start date.",[76,1083,1084,1087,1088,1091],{},[14,1085,1086],{},"Still-enrolled at measurement time."," A student whose deadline has not yet passed when you cut a report is neither a completer nor a failure; your methodology notes should state how in-window students are handled in any interim rate you publish. The ",[83,1089,1090],{"href":189},"report preparation guide"," covers cohort-period framing.",[10,1093,1094],{},"For award years 2026–27 through 2028–29, completion and placement rates are determined and verified under your state's methodology — confirm specifics with your governor's office or state workforce board before relying on any calculation.",[27,1096,1098],{"id":1097},"the-four-exclusions-that-shrink-your-denominator","The four exclusions that shrink your denominator",[10,1100,1101,1102,621,1104,625,1106,629,1108,1110],{},"One set of adjustments is not in your state's hands — it is written into 34 CFR part 690, subpart H. Exactly four circumstances allow a student to be excluded from the completion math: the student ",[14,1103,620],{},[14,1105,624],{},[14,1107,628],{},[14,1109,607],{},". Nothing else qualifies — not a family emergency, not a job offer, not a move out of state. An excluded student comes out of both the numerator and the denominator (of the placement rate too), and each exclusion must be documented with evidence; an undocumented exclusion is an audit finding.",[10,1112,1113,1114,1117,1118,1121,1122,1125,1126,1129,1130,1133,1134,1137,1138,1140,1141,1143],{},"Worked example of what the exclusions and the 70 percent line mean in practice: a cohort of ",[14,1115,1116],{},"40 enrolled"," students with ",[14,1119,1120],{},"2 documented exclusions"," has a denominator of ",[14,1123,1124],{},"38",". If ",[14,1127,1128],{},"29"," complete within 150 percent of normal time, the rate is 29\u002F38 = ",[14,1131,1132],{},"76.3 percent",". The 70 percent line sits at 26.6 students — so this cohort clears it with roughly ",[14,1135,1136],{},"two additional non-completions of slack",". That is the margin a typical small cohort actually operates with, which is why the monthly monitoring below is not optional. Record exclusions in the ",[43,1139,593],{}," column of your ",[83,1142,86],{"href":85},", one evidence file per excluded student.",[27,1145,1147],{"id":1146},"the-monthly-monitoring-cadence","The monthly monitoring cadence",[10,1149,1150],{},"A deadline-based metric rewards early detection. The rhythm that works:",[10,1152,1153],{},[14,1154,1155],{},"Monthly (registrar + program director, 30 minutes per program):",[200,1157,1158,1172,1175,1181],{},[76,1159,1160,1161,1163,1164,1167,1168,1171],{},"Sort the cohort file by ",[43,1162,645],{},". For every active student, compute ",[14,1165,1166],{},"weeks remaining"," and ",[14,1169,1170],{},"percent of program completed"," (hours earned ÷ hours scheduled to date).",[76,1173,1174],{},"Flag every student who is behind pace — attendance shortfalls in a clock-hour program translate directly into blown deadlines.",[76,1176,1177,1178,1180],{},"Reconcile withdrawals: every R2T4 determination this month must appear as a ",[43,1179,497],{}," in the cohort file.",[76,1182,1183,1184,1187,1188,1190],{},"Recompute the program's projected completion rate under two scenarios: (a) all active students finish by deadline, (b) currently-behind students do not. If scenario (b) drops you below ",[14,1185,1186],{},"70 percent",", you are in intervention territory now, not at year-end. Run both scenarios in the ",[83,1189,246],{"href":245}," from your current roster.",[10,1192,1193,1196],{},[14,1194,1195],{},"Weekly (instructor level):"," attendance exceptions only — any student missing enough scheduled hours that their pace slips, reported to the program director the same week.",[27,1198,1200],{"id":1199},"early-intervention-triggers","Early-intervention triggers",[10,1202,1203],{},"Write these into procedure so intervention is automatic, not discretionary:",[200,1205,1206,1212,1218,1227],{},[76,1207,1208,1211],{},[14,1209,1210],{},"Pace trigger:"," student's completed hours fall below a set fraction of scheduled hours (you choose the threshold; make it early enough that make-up hours are feasible).",[76,1213,1214,1217],{},[14,1215,1216],{},"Absence trigger:"," any absence streak long enough to threaten LOA\u002Fwithdrawal territory — intervene before the paperwork question arises.",[76,1219,1220,1223,1224,1226],{},[14,1221,1222],{},"Deadline trigger:"," fewer than N weeks to ",[43,1225,645],{}," with more than the normally scheduled remaining hours outstanding — meaning the student now needs above-normal pace to finish. Offer make-up sessions immediately.",[76,1228,1229,1232,1233,1236],{},[14,1230,1231],{},"Cohort trigger:"," projected completion rate under the conservative scenario falls below ",[14,1234,1235],{},"75 percent"," — a self-imposed buffer above the 70 percent floor that gives you one cohort's warning before a real failure. A failed program loses Workforce Pell eligibility and cannot return (nor can a substantially similar program) for two years, so the buffer is cheap insurance.",[27,1238,264],{"id":263},[73,1240,1241,1253,1259,1265,1271],{},[76,1242,1243,1249,1250,1252],{},[14,1244,1245,1246,1248],{},"Store ",[43,1247,645],{}," for every enrolled student"," in your cohort file this week; verify ",[43,1251,465],{}," matches your certified program length.",[76,1254,1255,1258],{},[14,1256,1257],{},"Stand up the monthly monitoring meeting"," with the two-scenario projection as a standing agenda item.",[76,1260,1261,1264],{},[14,1262,1263],{},"Write your LOA \u002F re-entry \u002F transfer treatment"," into a one-page methodology memo and send it to your state workforce board for confirmation.",[76,1266,1267,1270],{},[14,1268,1269],{},"Define your early-intervention triggers"," numerically and assign who acts on each within what timeframe.",[76,1272,1273,1276],{},[14,1274,1275],{},"Set a make-up hours pathway"," (open lab, extra range time, weekend sessions) so a flagged student always has a concrete route back to pace.",{"title":303,"searchDepth":304,"depth":304,"links":1278},[1279,1280,1281,1282,1283,1284],{"id":937,"depth":304,"text":938},{"id":1049,"depth":304,"text":1050},{"id":1097,"depth":304,"text":1098},{"id":1146,"depth":304,"text":1147},{"id":1199,"depth":304,"text":1200},{"id":263,"depth":304,"text":264},"How to compute each student's 150% completion deadline for the Workforce Pell 70\u002F70 rule, handle leaves and re-entries, and run a monthly monitoring cadence.",{},"4.2",{"title":925,"description":1285},[1290,1291],{"label":328,"url":329},{"label":1292,"url":1293},"FSA Handbook (Federal Student Aid)","https:\u002F\u002Ffsapartners.ed.gov\u002Fknowledge-center\u002Ffsa-handbook","library\u002Fdata-playbooks\u002Ftracking-completion-within-150-percent",[339,1296,1297,342],"completion rate","150 percent","1TBG7GjuUxddwoOxVVKyxfDfj33SQv9ErynA6NGI4qY",{"id":4,"title":5,"body":1300,"description":315,"extension":316,"meta":1481,"navigation":318,"path":319,"pillar":320,"pinned":321,"publishedDate":322,"readTime":323,"section":324,"seo":1482,"sources":1483,"stem":336,"tags":1487,"updatedDate":322,"__hash__":343},{"type":7,"value":1301,"toc":1471},[1302,1308,1310,1312,1326,1332,1334,1352,1358,1360,1362,1364,1366,1370,1376,1378,1382,1384,1386,1390,1392,1394,1398,1404,1406,1408,1434,1440,1445,1447],[10,1303,12,1304,17,1306,22],{},[14,1305,16],{},[19,1307,21],{},[10,1309,25],{},[27,1311,30],{"id":29},[10,1313,33,1314,37,1316,41,1318,46,1320,50,1322,54,1324,58],{},[14,1315,36],{},[14,1317,40],{},[43,1319,45],{},[14,1321,49],{},[14,1323,53],{},[14,1325,57],{},[10,1327,1328,64,1330,68],{},[14,1329,63],{},[14,1331,67],{},[10,1333,71],{},[73,1335,1336,1344,1348],{},[76,1337,1338,81,1340,87,1342,90],{},[14,1339,80],{},[83,1341,86],{"href":85},[43,1343,45],{},[76,1345,1346,96],{},[14,1347,95],{},[76,1349,1350,102],{},[14,1351,101],{},[10,1353,105,1354,109,1356,113],{},[14,1355,108],{},[14,1357,112],{},[27,1359,117],{"id":116},[10,1361,120],{},[122,1363,125],{"id":124},[10,1365,128],{},[10,1367,131,1368,135],{},[14,1369,134],{},[10,1371,138,1372,142,1374,146],{},[14,1373,141],{},[14,1375,145],{},[10,1377,149],{},[10,1379,1380,155],{},[14,1381,154],{},[122,1383,159],{"id":158},[10,1385,162],{},[10,1387,1388,167],{},[14,1389,154],{},[122,1391,171],{"id":170},[10,1393,174],{},[10,1395,1396,179],{},[14,1397,154],{},[10,1399,182,1400,186,1402,191],{},[43,1401,185],{},[83,1403,190],{"href":189},[27,1405,195],{"id":194},[10,1407,198],{},[200,1409,1410,1414,1418,1422,1426],{},[76,1411,1412,207],{},[14,1413,206],{},[76,1415,1416,213],{},[14,1417,212],{},[76,1419,1420,219],{},[14,1421,218],{},[76,1423,1424,225],{},[14,1425,224],{},[76,1427,1428,231,1430,235,1432,239],{},[14,1429,230],{},[43,1431,234],{},[43,1433,238],{},[10,1435,242,1436,247,1438,250],{},[83,1437,246],{"href":245},[43,1439,238],{},[10,1441,253,1442,260],{},[83,1443,259],{"href":256,"rel":1444},[258],[27,1446,264],{"id":263},[73,1448,1449,1453,1457,1461,1465],{},[76,1450,1451,272],{},[14,1452,271],{},[76,1454,1455,278],{},[14,1456,277],{},[76,1458,1459,284],{},[14,1460,283],{},[76,1462,1463,290],{},[14,1464,289],{},[76,1466,1467,296,1469,301],{},[14,1468,295],{},[83,1470,300],{"href":299},{"title":303,"searchDepth":304,"depth":304,"links":1472},[1473,1474,1479,1480],{"id":29,"depth":304,"text":30},{"id":116,"depth":304,"text":117,"children":1475},[1476,1477,1478],{"id":124,"depth":310,"text":125},{"id":158,"depth":310,"text":159},{"id":170,"depth":310,"text":171},{"id":194,"depth":304,"text":195},{"id":263,"depth":304,"text":264},{},{"title":5,"description":315},[1484,1485,1486],{"label":328,"url":329},{"label":331,"url":332},{"label":334,"url":335},[338,339,340,341,342],{"id":1489,"title":1490,"body":1491,"description":1821,"extension":316,"meta":1822,"navigation":318,"path":189,"pillar":320,"pinned":318,"publishedDate":322,"readTime":323,"section":1823,"seo":1824,"sources":1825,"stem":1831,"tags":1832,"updatedDate":322,"__hash__":1835},"library\u002Flibrary\u002Fdata-playbooks\u002Fpreparing-the-70-70-report.md","Preparing Your 70\u002F70 Report: From Cohort File to Submission-Ready Document",{"type":7,"value":1492,"toc":1806},[1493,1496,1499,1503,1518,1529,1533,1536,1582,1589,1593,1596,1600,1603,1607,1613,1617,1620,1637,1641,1644,1703,1709,1713,1716,1720,1723,1731,1735,1738,1766,1768],[10,1494,1495],{},"At some point your 70\u002F70 numbers stop being an internal dashboard and become a submission: a document your institution stands behind, that a state reviewer reads, and that determines whether a program keeps its Workforce Pell eligibility. The gap between \"we know our rates\" and \"we can hand someone a defensible report\" is exactly the gap this article closes.",[10,1497,1498],{},"For award years 2026–27 through 2028–29, completion and placement rates are determined and verified under your state's methodology — confirm specifics with your governor's office or state workforce board before relying on any calculation. Your state may prescribe its own submission format; where it does, that format wins. What follows is the content any defensible report needs regardless of the wrapper.",[27,1500,1502],{"id":1501},"who-reviews-it-and-when","Who reviews it, and when",[10,1504,1505,1506,1509,1510,1513,1514,1517],{},"Under the final rule's approval structure, the ",[14,1507,1508],{},"governor — with the state workforce board — certifies"," each program: occupation alignment, stackability, and, in the transitional years (2026–27 through 2028–29), the ",[14,1511,1512],{},"70\u002F70 rates themselves",", which the governor determines and verifies under state-set methodology. ED then verifies the federal requirements. Rates are ",[14,1515,1516],{},"verified annually"," during the transitional years; after 2028–29, the completion calculation moves to federal methodology (in the style of the 34 CFR 668.8(f) clock-hour calculation).",[10,1519,1520,1521,1524,1525,1528],{},"Practically, that means your report's first audience is your ",[14,1522,1523],{},"state workforce board",", its cadence is ",[14,1526,1527],{},"at least annual",", and its stakes are program-level: a program that fails 70\u002F70 loses Workforce Pell eligibility, and neither it nor a substantially similar program (same 4-digit CIP with overlapping SOC codes) can be re-established for two years. Reinstatement runs through appeal or governor recertification — which is argued from exactly the records this report packages.",[122,1530,1532],{"id":1531},"the-reporting-chains-precisely","The reporting chains, precisely",[10,1534,1535],{},"The final rule sets out two distinct chains your data travels, and the report you prepare feeds both:",[200,1537,1538,1556],{},[76,1539,1540,1543,1544,1547,1548,1551,1552,1555],{},[14,1541,1542],{},"Institution → Governor:"," annual ",[14,1545,1546],{},"completer lists",", the ",[14,1549,1550],{},"placement-verification data"," behind them, and your certification request, all through the state's process. The State Workforce Pell Program Certification form has been available since July 1, 2026 (",[14,1553,1554],{},"FSA Electronic Announcement GENERAL-26-44",").",[76,1557,1558,1561,1562,1565,1566,1569,1570,1573,1574,1578,1579,90],{},[14,1559,1560],{},"Institution → ED:"," your ",[14,1563,1564],{},"published tuition and fees","; ",[14,1567,1568],{},"current NSLDS enrollment and completion data"," — ED compiles program completer lists from NSLDS, and you get a ",[14,1571,1572],{},"60-day window to correct"," them, so stale ",[83,1575,1577],{"href":1576},"\u002Flibrary\u002Fpell-fundamentals\u002Fnslds-enrollment-reporting","NSLDS reporting"," becomes a 70\u002F70 problem directly; and the ",[14,1580,1581],{},"Governor's certification, uploaded via E-App",[10,1583,1584,1585,1588],{},"One timing fact worth planning around: the ",[14,1586,1587],{},"first certifications draw on the most recent 12 months of administrative data",". Your earliest cohorts are not a practice round — the enrollment and completion records you are generating right now are the data the first certification will stand on.",[27,1590,1592],{"id":1591},"anatomy-of-a-defensible-report","Anatomy of a defensible report",[10,1594,1595],{},"Six components. If any is missing, a reviewer has to take your word for something — and taking your word is not their job.",[122,1597,1599],{"id":1598},"_1-program-identification","1. Program identification",[10,1601,1602],{},"Program name, CIP code, credential awarded, clock hours, and normal completion time in weeks — matching your governor certification and ED approval documents exactly. One report per program; eligibility attaches per program, not per institution.",[122,1604,1606],{"id":1605},"_2-cohort-definition-and-period","2. Cohort definition and period",[10,1608,1609,1610,1612],{},"State precisely who is in the denominator and why: the enrollment window covered, the number of participants, and your treatment of edge cases — withdrawals, re-entries, transfers, and students whose 150 percent deadline had not passed at the measurement date. This is where reports fail review. A rate without a cohort definition is a number, not a metric. (Your treatment of edge cases should match the methodology memo from the ",[83,1611,656],{"href":655},".)",[122,1614,1616],{"id":1615},"_3-methodology-notes","3. Methodology notes",[10,1618,1619],{},"Short, explicit statements of how each rate was produced:",[200,1621,1622,1628],{},[76,1623,1624,1627],{},[14,1625,1626],{},"Completion:"," deadline formula (start date + 1.5 × normal weeks), your half-week convention, LOA\u002Fre-entry treatment, and the data sources for each date field.",[76,1629,1630,1633,1634,1636],{},[14,1631,1632],{},"Placement:"," how the second-quarter-after-exit window was computed, the verification hierarchy used (UI wage match, employer letters, surveys — see ",[83,1635,583],{"href":319},"), the mix of sources behind the rate, and how non-responders were pursued and classified.",[122,1638,1640],{"id":1639},"_4-both-rates-shown-with-their-arithmetic","4. Both rates, shown with their arithmetic",[10,1642,1643],{},"Not just the percentages — the fractions:",[379,1645,1646,1665],{},[382,1647,1648],{},[385,1649,1650,1653,1656,1659,1662],{},[388,1651,1652],{},"Metric",[388,1654,1655],{},"Numerator",[388,1657,1658],{},"Denominator",[388,1660,1661],{},"Rate",[388,1663,1664],{},"Threshold",[401,1666,1667,1687],{},[385,1668,1669,1672,1675,1678,1681],{},[406,1670,1671],{},"Completion within 150% of normal time",[406,1673,1674],{},"completers by deadline",[406,1676,1677],{},"program participants",[406,1679,1680],{},"n\u002Fd",[406,1682,1683,1684],{},"≥ ",[14,1685,1686],{},"70%",[385,1688,1689,1692,1695,1697,1699],{},[406,1690,1691],{},"Employed in second quarter after exit",[406,1693,1694],{},"verified employed completers",[406,1696,727],{},[406,1698,1680],{},[406,1700,1683,1701],{},[14,1702,1686],{},[10,1704,1705,1706,1708],{},"Note that the metrics chain: the placement denominator is the completion numerator's population. An error in completion status propagates into placement, which is one more reason both rates must come from a single ",[83,1707,86],{"href":85}," rather than two spreadsheets.",[122,1710,1712],{"id":1711},"_5-roster-appendix","5. Roster appendix",[10,1714,1715],{},"The row-level data behind the rates: one line per student with the ten schema fields (ID, program, start date, normal weeks, completion\u002Fwithdrawal dates, exit date, second-quarter employment status, verification source, and any documented exclusion). Follow your state's guidance on identifiers and privacy — a reviewer needs to be able to tie every roster row to retained source records, but how much personally identifying detail travels with the report is a state call. Keep the full-identifier version internally under your retention schedule; the submitted version may use masked IDs if your state permits.",[122,1717,1719],{"id":1718},"_6-attestation","6. Attestation",[10,1721,1722],{},"A signature block in which a named institutional official (and, where your state requires, the program director) attests that the data is complete and accurate and that supporting records are retained and available for inspection. Unsigned reports invite the question of who stands behind the numbers; the attestation answers it before it is asked.",[10,1724,614,1725,1730],{},[14,1726,1727,1729],{},[83,1728,246],{"href":245}," produces exactly this document"," — both rates with their arithmetic, methodology notes, and a roster appendix — from a cohort file in the standard schema. Upload your roster, review the flagged rows, and export.",[27,1732,1734],{"id":1733},"cadence-annual-submission-quarterly-rehearsal","Cadence: annual submission, quarterly rehearsal",[10,1736,1737],{},"The submission is at least annual (verified annually during the transitional years — confirm your state's calendar and deadlines). But producing the report once a year is how schools discover problems eleven months too late. The working cadence:",[200,1739,1740,1749,1755],{},[76,1741,1742,1745,1746,1748],{},[14,1743,1744],{},"Quarterly:"," generate the full report internally as a dress rehearsal. Every ",[43,1747,234],{}," employment row and every unverifiable completer is a task list for the next quarter.",[76,1750,1751,1754],{},[14,1752,1753],{},"At cohort close:"," snapshot the cohort file and draft the cohort definition and methodology sections while decisions are fresh.",[76,1756,1757,1760,1761,1765],{},[14,1758,1759],{},"At submission:"," freeze the submitted version — the exact file, the exact report, dated — and archive it beyond the Title IV three-year floor, since the value-added earnings horizon and the two-year re-establishment bar both outlive it. (The same roster data ultimately feeds the ",[83,1762,1764],{"href":1763},"\u002Flibrary\u002Fworkforce-pell\u002Fvalue-added-earnings-test","value-added earnings test"," beginning award year 2030–31.)",[27,1767,264],{"id":263},[73,1769,1770,1776,1782,1794,1800],{},[76,1771,1772,1775],{},[14,1773,1774],{},"Get your state's submission requirements in writing"," — format, cadence, deadlines, identifier rules — from the governor's office or state workforce board.",[76,1777,1778,1781],{},[14,1779,1780],{},"Draft the methodology notes now",", before the first submission, and send them to the state for concurrence on the edge cases.",[76,1783,1784,1787,1788,1790,1791,1793],{},[14,1785,1786],{},"Run a quarterly dress rehearsal"," from your live cohort file and work the ",[43,1789,234],{},"\u002F",[43,1792,238],{}," rows as a task list.",[76,1795,1796,1799],{},[14,1797,1798],{},"Establish the attestation chain"," — who signs, on what evidence, after what internal review.",[76,1801,1802,1805],{},[14,1803,1804],{},"Archive every submitted report and its frozen roster"," with your long-horizon retention records.",{"title":303,"searchDepth":304,"depth":304,"links":1807},[1808,1811,1819,1820],{"id":1501,"depth":304,"text":1502,"children":1809},[1810],{"id":1531,"depth":310,"text":1532},{"id":1591,"depth":304,"text":1592,"children":1812},[1813,1814,1815,1816,1817,1818],{"id":1598,"depth":310,"text":1599},{"id":1605,"depth":310,"text":1606},{"id":1615,"depth":310,"text":1616},{"id":1639,"depth":310,"text":1640},{"id":1711,"depth":310,"text":1712},{"id":1718,"depth":310,"text":1719},{"id":1733,"depth":304,"text":1734},{"id":263,"depth":304,"text":264},"What a defensible 70\u002F70 report contains — cohort period, methodology, both rates, roster appendix, attestation — who reviews it, and how often you produce it.",{},"4.4",{"title":1490,"description":1821},[1826,1827,1828],{"label":328,"url":329},{"label":331,"url":332},{"label":1829,"url":1830},"FSA Electronic Announcement GENERAL-26-44 (July 1, 2026)","https:\u002F\u002Ffsapartners.ed.gov\u002Fknowledge-center\u002Flibrary\u002Felectronic-announcements\u002F2026-07-01\u002Feligible-workforce-programs-state-workforce-pell-certification-form-available","library\u002Fdata-playbooks\u002Fpreparing-the-70-70-report",[339,342,1833,1834],"compliance report","governor certification","yyBojwZyF_D53XM3UM0z6ui_-tno9xNN9M5o3Ih1Gyk",1784625504567]