The Workforce Pell placement test requires that at least 70 percent of a program's completers be employed during the second calendar quarter after program exit (34 CFR 690.94). Unlike the completion rate, which lives entirely in your student records, the placement rate depends on data about what happens after students leave you. That makes it the harder half of the 70/70 rule to operationalize.

The measurement window: second calendar quarter after exit

Start by unlearning the most repeated error in coverage of this rule. The statute (P.L. 119-21, § 83002) says placement is "measured 180 days after" completion — but the binding regulation, 34 CFR 690.94, measures employment during the second calendar quarter after the quarter in which the student exits, via state administrative data (UI wage records). Count on a calendar-quarter grid, not a day count: a June completer's measurement quarter is October–December, not "day 180." A tracking calendar built on a 180-day count will check the wrong window.

Worked example.

• Student completes a 14-week diesel tech program on March 10, 2027
• Exit quarter: Q1 2027 (January–March)
• First quarter after exit: Q2 2027 (April–June)
• Measurement quarter: Q3 2027 (July–September)

The student must be employed during Q3 2027 to count in the numerator. Employment in April that ends in June — before the measurement quarter — does not help; a job that starts in August does.

A second student who completes on April 2, 2027 exits in Q2 2027, so their measurement quarter is Q4 2027 (October–December). Two students finishing three weeks apart land in different measurement quarters — your tracking system must key each completer to their own quarter, not batch everyone to a single survey date.

The quarter grid itself is set by 34 CFR 690.94 — standard calendar quarters. What remains state-defined in the transitional years is the verification machinery around it: which data systems, what evidence, and how rates are certified.

The rate itself

placement rate = completers employed during their second quarter after exit
                 ÷ total completers

Note the denominator: completers, not all participants. A student who withdrew hurts your completion rate but never enters the placement calculation. The two tests chain: participants → completers (≥ 70%) → employed completers (≥ 70% of those).

Phase 1 vs. Phase 2: what "employed" means

• Phase 1 — award years 2026–27 through 2028–29: any employment counts. A welding completer working retail in the measurement quarter is a placement.
• Phase 2 — after award year 2028–29: employment must be occupation-aligned, matched by SOC code — in the occupation the program prepared the student for, or a comparable high-skill, high-wage, or in-demand occupation.

Phase 1 is a grace period. A program passing today on unrelated employment has a structural problem that surfaces in 2029–30. From your first cohort, your follow-up data must capture not just "got hired" but the employer, start date, and occupation (with SOC code) for every placement — that is what mapping placements to the trained-for occupation and its comparable occupations will require when Phase 2 arrives. How "similar" occupations are identified runs through the governor's high-skill, high-wage, in-demand framework; see Governor Certification and ED Approval.

Verification: who checks, and against what

During the transitional years, placement rates are verified annually against state-defined rates set by the Governor. 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.

Typical verification sources, in descending order of strength:

1. State UI wage records — the primary source under 34 CFR 690.94: the state matches completers against unemployment insurance wage files. Two structural limits to plan around. First, wage records lag — a measurement quarter's data may not be matchable until a quarter or more after it closes, so your internal rate will always run ahead of the official one. Second, 1099 contractors and owner-operators may never appear in UI wage files at all (nor may out-of-state, federal, or military employment). For programs feeding independent-contractor occupations — owner-operator trucking is the canonical case — that is a structural measurement issue worth raising with your state early, not at verification time.
2. Employer verification — signed or documented confirmation from the employer of employment during the measurement quarter (and, for Phase 2, the position). Strong evidence, labor-intensive to collect.
3. Graduate surveys — self-reported employment. Weakest evidence and vulnerable to non-response: a completer you cannot reach is usually a zero in your numerator, not an exclusion.

Whether your state runs the UI wage match for you, requires you to submit evidence, or blends sources is a state design decision — ask before you build your process around an assumption.

Building the tracking operation

The placement rate rewards schools that treat graduate follow-up as a scheduled operation rather than an annual scramble:

• At exit: capture personal (non-school) email, phone, and a signed consent/release for employment verification and wage-record matching if your state requires one.
• Continuously: log employer, job title, start date, and occupation for every known placement, with the evidence source attached.
• At each completer's measurement quarter: confirm employment during that quarter specifically, and document it.

A CDL program graduating 40 students a year has completers rolling into new measurement quarters every quarter of the calendar. Once your completer roster and employment records are assembled, run your numbers in the 70/70 Report Generator to see each program's rate and its documentation gaps.

What to do now

1. Key every completer to their measurement quarter — exit date → exit quarter → second quarter after — in your student information system, starting with everyone who completed this award year.
2. Ask your state two questions in writing: will the state run UI wage-record matching for Workforce Pell programs, and what evidence does it accept where wage records miss (out-of-state, self-employed, non-respondents)?
3. Add an exit-packet step that collects personal contact info and any consent your state's verification process needs — it is nearly impossible to collect retroactively.
4. Record occupation and SOC code, not just employment, for every placement starting now, so the post-2028–29 shift to SOC-matched occupation-aligned placement doesn't zero out your history.
5. Review the rate quarterly. A program trending toward 70 percent needs career-services intervention months before the annual verification, not after it.