[{"data":1,"prerenderedAt":2900},["ShallowReactive",2],{"article-\u002Flibrary\u002Fworkforce-pell\u002Fjob-placement-rate-calculation":3,"siblings-workforce-pell":324},{"id":4,"title":5,"body":6,"description":294,"extension":295,"meta":296,"navigation":297,"path":298,"pillar":299,"pinned":300,"publishedDate":301,"readTime":302,"section":303,"seo":304,"sources":305,"stem":318,"tags":319,"updatedDate":301,"__hash__":323},"library\u002Flibrary\u002Fworkforce-pell\u002Fjob-placement-rate-calculation.md","How the Job Placement Rate Is Calculated (Second Quarter After Exit)",{"type":7,"value":8,"toc":285},"minimark",[9,33,38,49,54,83,90,101,104,108,119,131,135,153,164,168,175,178,207,210,214,217,241,249,253],[10,11,12,13,17,18,21,22,26,27,32],"p",{},"The Workforce Pell placement test requires that ",[14,15,16],"strong",{},"at least 70 percent of a program's completers be employed during the second calendar quarter after program exit"," (",[14,19,20],{},"34 CFR 690.94","). Unlike the completion rate, which lives entirely in your student records, the placement rate depends on data about what happens ",[23,24,25],"em",{},"after"," students leave you. That makes it the harder half of the ",[28,29,31],"a",{"href":30},"\u002Flibrary\u002Fworkforce-pell\u002Fthe-70-70-rule-explained","70\u002F70 rule"," to operationalize.",[34,35,37],"h2",{"id":36},"the-measurement-window-second-calendar-quarter-after-exit","The measurement window: second calendar quarter after exit",[10,39,40,41,44,45,48],{},"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 ",[14,42,43],{},"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 ",[14,46,47],{},"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.",[10,50,51],{},[14,52,53],{},"Worked example.",[55,56,57,64,71,78],"ul",{},[58,59,60,61],"li",{},"Student completes a 14-week diesel tech program on ",[14,62,63],{},"March 10, 2027",[58,65,66,67,70],{},"Exit quarter: ",[14,68,69],{},"Q1 2027"," (January–March)",[58,72,73,74,77],{},"First quarter after exit: ",[14,75,76],{},"Q2 2027"," (April–June)",[58,79,80],{},[14,81,82],{},"Measurement quarter: Q3 2027 (July–September)",[10,84,85,86,89],{},"The student must be employed ",[14,87,88],{},"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.",[10,91,92,93,96,97,100],{},"A second student who completes on ",[14,94,95],{},"April 2, 2027"," exits in Q2 2027, so their measurement quarter is ",[14,98,99],{},"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.",[10,102,103],{},"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.",[34,105,107],{"id":106},"the-rate-itself","The rate itself",[109,110,115],"pre",{"className":111,"code":113,"language":114},[112],"language-text","placement rate = completers employed during their second quarter after exit\n                 ÷ total completers\n","text",[116,117,113],"code",{"__ignoreMap":118},"",[10,120,121,122,125,126,130],{},"Note the denominator: ",[14,123,124],{},"completers",", not all participants. A student who withdrew hurts your ",[28,127,129],{"href":128},"\u002Flibrary\u002Fworkforce-pell\u002Fcompletion-rate-calculation","completion rate"," but never enters the placement calculation. The two tests chain: participants → completers (≥ 70%) → employed completers (≥ 70% of those).",[34,132,134],{"id":133},"phase-1-vs-phase-2-what-employed-means","Phase 1 vs. Phase 2: what \"employed\" means",[55,136,137,143],{},[58,138,139,142],{},[14,140,141],{},"Phase 1 — award years 2026–27 through 2028–29: any employment counts."," A welding completer working retail in the measurement quarter is a placement.",[58,144,145,148,149,152],{},[14,146,147],{},"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, ",[14,150,151],{},"or a comparable high-skill, high-wage, or in-demand occupation",".",[10,154,155,156,159,160,152],{},"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 ",[14,157,158],{},"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 ",[28,161,163],{"href":162},"\u002Flibrary\u002Fworkforce-pell\u002Fgovernor-certification-and-ed-approval","Governor Certification and ED Approval",[34,165,167],{"id":166},"verification-who-checks-and-against-what","Verification: who checks, and against what",[10,169,170,171,174],{},"During the transitional years, placement rates are ",[14,172,173],{},"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.",[10,176,177],{},"Typical verification sources, in descending order of strength:",[179,180,181,195,201],"ol",{},[58,182,183,186,187,190,191,194],{},[14,184,185],{},"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, ",[14,188,189],{},"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, ",[14,192,193],{},"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.",[58,196,197,200],{},[14,198,199],{},"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.",[58,202,203,206],{},[14,204,205],{},"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.",[10,208,209],{},"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.",[34,211,213],{"id":212},"building-the-tracking-operation","Building the tracking operation",[10,215,216],{},"The placement rate rewards schools that treat graduate follow-up as a scheduled operation rather than an annual scramble:",[55,218,219,225,231],{},[58,220,221,224],{},[14,222,223],{},"At exit:"," capture personal (non-school) email, phone, and a signed consent\u002Frelease for employment verification and wage-record matching if your state requires one.",[58,226,227,230],{},[14,228,229],{},"Continuously:"," log employer, job title, start date, and occupation for every known placement, with the evidence source attached.",[58,232,233,236,237,240],{},[14,234,235],{},"At each completer's measurement quarter:"," confirm employment ",[23,238,239],{},"during that quarter"," specifically, and document it.",[10,242,243,244,248],{},"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 ",[28,245,247],{"href":246},"\u002Ftools\u002F70-70-report","70\u002F70 Report Generator"," to see each program's rate and its documentation gaps.",[34,250,252],{"id":251},"what-to-do-now","What to do now",[179,254,255,261,267,273,279],{},[58,256,257,260],{},[14,258,259],{},"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.",[58,262,263,266],{},[14,264,265],{},"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)?",[58,268,269,272],{},[14,270,271],{},"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.",[58,274,275,278],{},[14,276,277],{},"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.",[58,280,281,284],{},[14,282,283],{},"Review the rate quarterly."," A program trending toward 70 percent needs career-services intervention months before the annual verification, not after it.",{"title":118,"searchDepth":286,"depth":286,"links":287},2,[288,289,290,291,292,293],{"id":36,"depth":286,"text":37},{"id":106,"depth":286,"text":107},{"id":133,"depth":286,"text":134},{"id":166,"depth":286,"text":167},{"id":212,"depth":286,"text":213},{"id":251,"depth":286,"text":252},"Workforce Pell placement rate math under 34 CFR 690.94: the second-calendar-quarter window (not 180 days), occupation-aligned phase-in, verification sources.","md",{},true,"\u002Flibrary\u002Fworkforce-pell\u002Fjob-placement-rate-calculation","workforce-pell",false,"2026-07-19",7,"1.4",{"title":5,"description":294},[306,309,312,315],{"label":307,"url":308},"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":310,"url":311},"P.L. 119-21, § 83002 (statute text, govinfo)","https:\u002F\u002Fwww.govinfo.gov\u002Fcontent\u002Fpkg\u002FPLAW-119publ21\u002Fhtml\u002FPLAW-119publ21.htm",{"label":313,"url":314},"ED Workforce Pell final rule fact sheet","https:\u002F\u002Fwww.ed.gov\u002Fmedia\u002Fdocument\u002Fworkforce-pell-grant-final-rule-fact-sheet-114075.pdf",{"label":316,"url":317},"New America: State Workforce Pell implementation playbook","https:\u002F\u002Fwww.newamerica.org\u002Finsights\u002Fstate-workforce-pell-grants-a-playbook-for-implementation\u002F","library\u002Fworkforce-pell\u002Fjob-placement-rate-calculation",[320,31,321,322],"job placement rate","workforce pell","employment verification","oUFY7TvCSkXSRJ6KkPlt-dZP90bAdOJ5uH-GSCFGZfY",[325,744,1111,1502,1682,1927,2345,2671],{"id":326,"title":327,"body":328,"description":726,"extension":295,"meta":727,"navigation":297,"path":728,"pillar":299,"pinned":297,"publishedDate":301,"readTime":302,"section":729,"seo":730,"sources":731,"stem":738,"tags":739,"updatedDate":301,"__hash__":743},"library\u002Flibrary\u002Fworkforce-pell\u002Fwhat-is-workforce-pell.md","What Is Workforce Pell? The Short-Term Pell Grant, Explained",{"type":7,"value":329,"toc":716},[330,345,350,354,381,392,396,399,428,433,437,455,465,497,504,508,531,542,546,549,563,566,570,573,583,597,600,604,678,680],[10,331,332,333,336,337,340,341,344],{},"Workforce Pell is a new category of federal Pell Grant that, for the first time, funds short-term workforce training programs — programs of ",[14,334,335],{},"150 to 599 clock hours"," delivered over ",[14,338,339],{},"at least 8 but less than 15 weeks",". It took effect ",[14,342,343],{},"July 1, 2026"," (award year 2026–27), and applications for program approval opened the same day.",[10,346,347,348,152],{},"If you run a trade school, technical college, or short-term certificate program, this is the most significant expansion of Title IV aid in a generation. It is also arriving with the toughest performance accountability regime ever attached to Pell: the ",[28,349,31],{"href":30},[34,351,353],{"id":352},"where-it-comes-from","Where it comes from",[10,355,356,357,360,361,364,365,368,369,372,373,376,377,380],{},"Workforce Pell Grants were created by the ",[14,358,359],{},"Working Families Tax Cuts Act"," — the 2025 budget reconciliation law (H.R. 1), enacted as ",[14,362,363],{},"P.L. 119-21"," — signed into law on ",[14,366,367],{},"July 4, 2025",". The operative provision is ",[14,370,371],{},"§ 83002",", which adds a new ",[14,374,375],{},"HEA § 401(k)"," (the Workforce Pell Grant program itself) and ",[14,378,379],{},"HEA § 481(b)(3)"," (the definition of an eligible workforce program).",[10,382,383,384,387,388,391],{},"The Department of Education implemented the statute through rulemaking: a Notice of Proposed Rulemaking on March 9, 2026, and a ",[14,385,386],{},"Final Rule published May 19, 2026, at 91 FR 29254"," — \"Accountability in Higher Education and Access Through Demand-Driven Workforce Pell\" (Federal Register doc 2026-10013), amending 34 CFR parts 600, 668, and 690 and creating a new ",[14,389,390],{},"subpart H of 34 CFR part 690",". That final rule is the controlling text for everything on this site.",[34,393,395],{"id":394},"what-it-funds","What it funds",[10,397,398],{},"Traditional Pell has always required programs long enough to meet minimum credit- or clock-hour thresholds — leaving most short-term certificate and licensure programs, and the students in them, outside federal grant aid entirely. Workforce Pell closes that gap for programs that:",[55,400,401,410,421],{},[58,402,403,404,407,408],{},"Run ",[14,405,406],{},"150–599 clock hours"," over ",[14,409,339],{},[58,411,412,413,416,417,420],{},"Lead to a ",[14,414,415],{},"recognized postsecondary credential"," that is ",[14,418,419],{},"stackable"," toward higher-level, for-credit programs",[58,422,423,424,427],{},"Prepare students for ",[14,425,426],{},"high-skill, high-wage, or in-demand occupations",", as identified by the state governor with the state workforce board",[10,429,430,431,152],{},"Correspondence programs are excluded, and distance education offered across state lines may require bilateral agreements between states — see ",[28,432,163],{"href":162},[34,434,436],{"id":435},"who-qualifies","Who qualifies",[10,438,439,442,443,446,447,450,451,454],{},[14,440,441],{},"Students."," Workforce Pell recipients are Pell-eligible students — the same need-based framework as traditional Pell, applied through the ordinary FAFSA. COD returns a ",[14,444,445],{},"\"Workforce Pell Eligible\" indicator"," on the student record; there is no separate student application. Two eligibility points surprise people. First, ",[14,448,449],{},"bachelor's-degree holders are eligible"," (34 CFR 690.6(f)) — a reversal of the traditional Pell bar — though students who hold or are enrolled in graduate credentials are not. Second, Workforce Pell ",[14,452,453],{},"counts against the same 12-semester Pell lifetime limit"," as traditional Pell; a student spends lifetime eligibility on a short program just as on a degree.",[10,456,457,460,461,464],{},[14,458,459],{},"Programs."," This is where the real gatekeeping happens. Approval is ",[14,462,463],{},"per program, not per institution",". Each program must clear five gates:",[179,466,467,470,473,476,483],{},[58,468,469],{},"The length band (150–599 clock hours, 8 to less-than-15 weeks)",[58,471,472],{},"A stackable, recognized postsecondary credential",[58,474,475],{},"Governor-certified occupation alignment",[58,477,478,479,482],{},"At least ",[14,480,481],{},"1 year"," of operating history at an accredited institution, with no suspension, emergency action, or program termination in the previous 5 years",[58,484,485,486,489,490,493,494,496],{},"The ",[14,487,488],{},"70\u002F70 performance tests"," — a ",[14,491,492],{},"70 percent"," completion rate and a ",[14,495,492],{}," job placement rate — plus, beginning award year 2030–31, a value-added earnings test",[10,498,499,500,152],{},"The full checklist, gate by gate, is in ",[28,501,503],{"href":502},"\u002Flibrary\u002Fworkforce-pell\u002Fprogram-eligibility-checklist","Workforce Pell Program Eligibility: The Complete Checklist",[34,505,507],{"id":506},"how-awards-are-sized-and-the-loan-catch","How awards are sized — and the loan catch",[10,509,510,511,514,515,518,519,522,523,526,527,530],{},"Awards follow the regular Pell schedule, prorated for program length under ",[14,512,513],{},"Pell formulas 3 or 4",", and must be paid in ",[14,516,517],{},"at least two disbursements",". For award year 2026–27, the Pell maximum is ",[14,520,521],{},"$7,395"," and the minimum is ",[14,524,525],{},"$740",". ED's regulatory impact analysis estimates the average Workforce Pell award at roughly ",[14,528,529],{},"$1,710"," — note that the \"$2,200 CBO estimate\" circulating in coverage is not traceable to a primary CBO document; use ED's figure when you model revenue.",[10,532,533,534,537,538,541],{},"The catch: Workforce Pell is ",[14,535,536],{},"Pell-only",". Students enrolled in a workforce program receive ",[14,539,540],{},"no Direct Loans and no other Title IV aid for that program"," (34 CFR 690.90). For a program priced at $6,000 drawing a roughly $1,700 average award, the remaining gap is cash, employer sponsorship, or state\u002FWIOA funding — build your packaging and payment-plan strategy around that reality before you enroll your first Workforce Pell cohort.",[34,543,545],{"id":544},"the-two-step-approval-process","The two-step approval process",[10,547,548],{},"A program does not become eligible just by meeting the criteria. It must be:",[179,550,551,557],{},[58,552,553,556],{},[14,554,555],{},"Certified by the state governor",", acting with the state workforce board — covering occupation alignment, stackability, and (in the transitional years) verification of the 70\u002F70 rates",[58,558,559,562],{},[14,560,561],{},"Approved by the Department of Education",", which verifies the federal requirements: hours, weeks, completion, and placement",[10,564,565],{},"Applications have been open since July 1, 2026. If your program is a candidate, the process starts at your state, not at ED.",[34,567,569],{"id":568},"why-it-matters-for-trade-and-technical-schools","Why it matters for trade and technical schools",[10,571,572],{},"For decades, students in short trades programs — CDL and truck driving, welding, HVAC, medical assisting, cosmetology-adjacent licensure tracks, IT certifications — have paid cash, taken private loans, or leaned on employer sponsorship, while degree-seeking peers received Pell. Workforce Pell changes the economics of enrollment for exactly this population.",[10,574,575,576,582],{},"CDL and truck-driving programs are a clear example: most fall squarely in the 150–599 clock-hour band, making them prime Workforce Pell candidates — ",[28,577,581],{"href":578,"rel":579},"https:\u002F\u002Fdrivertrack.ai",[580],"nofollow","DriverTrack"," is the school-management platform built for CDL programs navigating this.",[10,584,585,586,588,589,591,592,596],{},"The trade-off is accountability. Every approved program must continuously demonstrate that ",[14,587,492],{}," of participants complete within 150% of normal time and ",[14,590,492],{}," of completers are employed in the second quarter after exit. A program that falls below either threshold loses eligibility and faces a ",[28,593,595],{"href":594},"\u002Flibrary\u002Fworkforce-pell\u002Flosing-eligibility-two-year-bar","two-year bar"," on re-establishing it or a substantially similar program.",[10,598,599],{},"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.",[34,601,603],{"id":602},"the-timeline-at-a-glance","The timeline at a glance",[605,606,607,620],"table",{},[608,609,610],"thead",{},[611,612,613,617],"tr",{},[614,615,616],"th",{},"Date",[614,618,619],{},"Event",[621,622,623,631,639,647,654,662,670],"tbody",{},[611,624,625,628],{},[626,627,367],"td",{},[626,629,630],{},"Working Families Tax Cuts Act signed (statute created)",[611,632,633,636],{},[626,634,635],{},"March 9, 2026",[626,637,638],{},"Notice of Proposed Rulemaking",[611,640,641,644],{},[626,642,643],{},"May 19, 2026",[626,645,646],{},"Final Rule published (91 FR 29254)",[611,648,649,651],{},[626,650,343],{},[626,652,653],{},"Statutory start of award year 2026–27; applications open; ED permits early implementation",[611,655,656,659],{},[626,657,658],{},"July 20, 2026",[626,660,661],{},"Final rule effective date",[611,663,664,667],{},[626,665,666],{},"Award year 2029–30",[626,668,669],{},"Placement test tightens to occupation-aligned employment; first Secretary value-added earnings determinations",[611,671,672,675],{},[626,673,674],{},"Award year 2030–31",[626,676,677],{},"Value-added earnings cap first applies to published tuition and fees",[34,679,252],{"id":251},[179,681,682,688,694,700,710],{},[58,683,684,687],{},[14,685,686],{},"Inventory your programs against the length band."," Pull clock hours and weeks of instruction for every program; anything in the 150–599 hour, 8-to-under-15-week range is a candidate.",[58,689,690,693],{},[14,691,692],{},"Check the 1-year history and clean-record gates."," A program must have existed at least a year at an accredited institution with no adverse actions in the previous 5 years.",[58,695,696,699],{},[14,697,698],{},"Contact your state workforce board."," Governor certification is step one of approval, and each state is setting its own occupation lists, stackability requirements, and transitional-year rate methodology.",[58,701,702,705,706,709],{},[14,703,704],{},"Start measuring your 70\u002F70 numbers today."," You will need defensible completion and placement rates before you apply — read ",[28,707,708],{"href":30},"The 70\u002F70 Rule Explained"," next.",[58,711,712,715],{},[14,713,714],{},"Assign an owner."," Workforce Pell compliance spans admissions, registrar, financial aid, and career services data; someone has to own the pipeline end to end.",{"title":118,"searchDepth":286,"depth":286,"links":717},[718,719,720,721,722,723,724,725],{"id":352,"depth":286,"text":353},{"id":394,"depth":286,"text":395},{"id":435,"depth":286,"text":436},{"id":506,"depth":286,"text":507},{"id":544,"depth":286,"text":545},{"id":568,"depth":286,"text":569},{"id":602,"depth":286,"text":603},{"id":251,"depth":286,"text":252},"Workforce Pell extends Pell Grants to short-term programs of 150-599 clock hours starting July 1, 2026. What it funds, who qualifies, and why it matters.",{},"\u002Flibrary\u002Fworkforce-pell\u002Fwhat-is-workforce-pell","1.1",{"title":327,"description":726},[732,733,734,737],{"label":307,"url":308},{"label":310,"url":311},{"label":735,"url":736},"ED press release announcing the final rule","https:\u002F\u002Fwww.ed.gov\u002Fabout\u002Fnews\u002Fpress-release\u002Fus-department-of-education-issues-final-rule-create-new-workforce-pell-grant-program",{"label":313,"url":314},"library\u002Fworkforce-pell\u002Fwhat-is-workforce-pell",[321,740,741,742],"short-term pell","pell grant","program eligibility","OjaZlsEgmMQQ1NOq2wgo9PpgfhnRQsIdag4kfSeSJbM",{"id":745,"title":746,"body":747,"description":1095,"extension":295,"meta":1096,"navigation":297,"path":30,"pillar":299,"pinned":297,"publishedDate":301,"readTime":1097,"section":1098,"seo":1099,"sources":1100,"stem":1107,"tags":1108,"updatedDate":301,"__hash__":1110},"library\u002Flibrary\u002Fworkforce-pell\u002Fthe-70-70-rule-explained.md","The 70\u002F70 Rule Explained: Completion and Placement Thresholds for Workforce Pell",{"type":7,"value":748,"toc":1086},[749,758,783,787,792,795,798,819,825,829,837,852,855,876,882,886,901,905,908,993,996,1010,1013,1017,1028,1035,1039,1045,1052,1054],[10,750,751,752,754,755,757],{},"The 70\u002F70 rule is the performance backbone of the Workforce Pell Grant program: to gain and keep eligibility, a program must show that ",[14,753,492],{}," of its participants complete on time and ",[14,756,492],{}," of its completers are employed shortly after exit. Miss either number and the program loses Workforce Pell — with a two-year bar on bringing it back.",[10,759,760,761,764,765,768,769,771,772,774,775,778,779,782],{},"The rule comes from the Working Families Tax Cuts Act (",[14,762,763],{},"P.L. 119-21, § 83002",", signed July 4, 2025) as implemented by ED's final rule of May 19, 2026 (",[14,766,767],{},"91 FR 29254","), which creates a new ",[14,770,390],{},". Watch the dates: ",[14,773,343],{}," is the statutory start of award year 2026–27, but the final rule's formal ",[14,776,777],{},"effective date is July 20, 2026"," — ED permits early implementation from July 1, and institutions with qualifying ECAR programs between July 1 and July 20 are presumed early implementers. If you learn one thing about ",[28,780,781],{"href":728},"Workforce Pell",", learn this rule — it is the ongoing test, not a one-time application hurdle.",[34,784,786],{"id":785},"test-1-the-70-completion-rate","Test 1: The 70% completion rate",[10,788,789],{},[14,790,791],{},"At least 70 percent of program participants must complete the program within 150% of the normal time to completion.",[10,793,794],{},"The 150% window works exactly like it sounds: a 12-week program gives students 18 weeks to finish and still count as completers. Students who finish inside the window count for you; students who withdraw, or finish after the window closes, count against you.",[10,796,797],{},"Who calculates it depends on the year:",[55,799,800,810],{},[58,801,802,805,806,809],{},[14,803,804],{},"Transitional years (2026–27 through 2028–29):"," the ",[14,807,808],{},"Governor determines and verifies"," the completion rate. States may set their own data systems and verification methodology.",[58,811,812,815,816,152],{},[14,813,814],{},"After 2028–29:"," the rate is calculated under federal methodology — the clock-hour completion calculation of ",[14,817,818],{},"34 CFR 668.8(f)",[10,820,821,822,152],{},"The full mechanics, with a worked example, are in ",[28,823,824],{"href":128},"How the Completion Rate Is Calculated",[34,826,828],{"id":827},"test-2-the-70-job-placement-rate","Test 2: The 70% job placement rate",[10,830,831,17,834,836],{},[14,832,833],{},"At least 70 percent of completers must be employed during the second calendar quarter after program exit",[14,835,20],{},").",[10,838,839,840,843,844,847,848,851],{},"One correction worth internalizing, because it is the most repeated error in coverage of this rule — call it the ",[14,841,842],{},"\"180-day myth.\""," The statute says placement is \"measured 180 days after\" completion, but the binding regulation, 34 CFR 690.94, measures employment ",[14,845,846],{},"during the second calendar quarter after the quarter of exit",", using state administrative data such as UI wage records. A June completer's measurement quarter is ",[14,849,850],{},"October through December"," — not \"day 180.\" A tracking calendar built on a 180-day count will check the wrong window.",[10,853,854],{},"What counts as \"employed\" tightens over time:",[55,856,857,867],{},[58,858,859,862,863,866],{},[14,860,861],{},"Phase 1 (award years 2026–27 through 2028–29):"," ",[14,864,865],{},"any employment"," in that window counts.",[58,868,869,872,873,152],{},[14,870,871],{},"Phase 2 (starting award year 2029–30):"," employment must be ",[14,874,875],{},"in the occupation the program prepared the student for, or a similar high-skill, high-wage, or in-demand occupation",[10,877,878,879,152],{},"During the transitional years, placement rates are verified annually against state-defined rates set by the Governor. Typical verification sources are state UI wage records, employer verification, and graduate surveys. Worked quarter-by-quarter math is in ",[28,880,881],{"href":298},"How the Job Placement Rate Is Calculated",[34,883,885],{"id":884},"the-four-allowable-exclusions","The four allowable exclusions",[10,887,888,889,892,893,896,897,900],{},"Both rates permit exactly ",[14,890,891],{},"four"," categories of students to be excluded — and the exclusion applies to the numerator ",[14,894,895],{},"and"," the denominator: students who (1) died; (2) suffered a totally disabling condition; (3) were called to military service for ",[14,898,899],{},"more than 30 days","; or (4) were incarcerated. Each exclusion must be documented with evidence — an undocumented exclusion is an audit finding, not a judgment call. There is no exclusion for transfers, unreachable graduates, or students who \"weren't a fit.\" Everyone else who started stays in the denominator.",[34,902,904],{"id":903},"the-phase-in-timeline","The phase-in timeline",[10,906,907],{},"The 70\u002F70 rule does not arrive all at once. Three distinct regimes phase in:",[605,909,910,926],{},[608,911,912],{},[611,913,914,917,920,923],{},[614,915,916],{},"Award year",[614,918,919],{},"Completion test",[614,921,922],{},"Placement test",[614,924,925],{},"Earnings test",[621,927,928,951,972],{},[611,929,930,933,940,948],{},[626,931,932],{},"2026–27 through 2028–29",[626,934,935,936,939],{},"≥ ",[14,937,938],{},"70%"," within 150% of normal time — Governor-determined\u002Fverified methodology",[626,941,935,942,944,945,947],{},[14,943,938],{}," employed in second quarter after exit — ",[14,946,865],{}," counts",[626,949,950],{},"Not yet in effect",[611,952,953,956,961,970],{},[626,954,955],{},"2029–30",[626,957,935,958,960],{},[14,959,938],{}," — federal clock-hour methodology (34 CFR 668.8(f))",[626,962,935,963,965,966,969],{},[14,964,938],{}," — employment must be ",[14,967,968],{},"occupation-aligned by SOC code"," (the trained-for occupation or a similar high-skill, high-wage, or in-demand occupation)",[626,971,950],{},[611,973,974,977,982,987],{},[626,975,976],{},"2030–31 and later",[626,978,935,979,981],{},[14,980,938],{}," — federal methodology",[626,983,935,984,986],{},[14,985,938],{}," — occupation-aligned",[626,988,989,992],{},[14,990,991],{},"Value-added earnings test begins:"," published tuition + fees must not exceed completers' median earnings minus 150% of the single-person federal poverty line",[10,994,995],{},"Two practical consequences of this table:",[179,997,998,1004],{},[58,999,1000,1003],{},[14,1001,1002],{},"The transitional years are state-defined."," Your rates in 2026–27 through 2028–29 live or die on your governor's methodology, not a uniform federal formula. 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.",[58,1005,1006,1009],{},[14,1007,1008],{},"Any-employment placement is a grace period, not the destination."," A program that clears 70% placement today on the strength of graduates working unrelated jobs will face a harder test in 2029–30, when only occupation-aligned employment counts. Start tracking occupation of employment now, even though you don't yet need it to pass.",[10,1011,1012],{},"The third metric — the earnings test — gets its own treatment in the Value-Added Earnings Test article (section 1.5 of this handbook).",[34,1014,1016],{"id":1015},"what-failing-costs-you","What failing costs you",[10,1018,1019,1020,1023,1024,1027],{},"A program that fails either 70% threshold ",[14,1021,1022],{},"loses Workforce Pell eligibility for that program",". The institution then ",[14,1025,1026],{},"cannot re-establish that program — or a \"substantially similar\" one, meaning the same 4-digit CIP code with overlapping SOC codes — for two years",". The reinstatement path runs through appeal and governor recertification of compliance.",[10,1029,1030,1031,1034],{},"That is a severe penalty for a program whose enrollment economics may now depend on Pell funding. It is why monitoring your rates continuously — not annually, after the fact — is the core operational discipline of Workforce Pell compliance. See ",[28,1032,1033],{"href":594},"Falling Below 70\u002F70: Losing Eligibility and the Two-Year Bar"," for the failure mechanics and early-warning practices.",[34,1036,1038],{"id":1037},"running-your-own-numbers","Running your own numbers",[10,1040,1041,1042,1044],{},"Both tests are cohort math: define the cohort, count the numerator, divide, compare to 70 percent. The failure mode we see most is not bad outcomes — it is bad bookkeeping: no exit dates recorded, no employment verification trail, cohort definitions that shift between reports. You can run your numbers in the ",[28,1043,247],{"href":246}," to see where your programs stand and what documentation gaps you have.",[10,1046,1047,1048,1051],{},"For CDL and truck-driving schools — whose programs sit almost entirely in the 150–599 clock-hour band that makes them prime Workforce Pell candidates — ",[28,1049,581],{"href":578,"rel":1050},[580]," is the school-management platform built to track this data for CDL programs.",[34,1053,252],{"id":251},[179,1055,1056,1062,1068,1074,1080],{},[58,1057,1058,1061],{},[14,1059,1060],{},"Compute both rates for every candidate program today",", using your best available data — before your state or ED does it for you.",[58,1063,1064,1067],{},[14,1065,1066],{},"Get your state's methodology in writing."," The transitional-year rates are governor-determined; ask your state workforce board how completion and placement will be measured and verified in your state.",[58,1069,1070,1073],{},[14,1071,1072],{},"Fix the data pipeline before the outcome."," Every student needs a recorded start date, scheduled completion date, actual completion or withdrawal date, and post-exit employment record with a verification source.",[58,1075,1076,1079],{},[14,1077,1078],{},"Start capturing occupation of employment now."," The 2029–30 shift to occupation-aligned placement will punish programs that only tracked \"employed yes\u002Fno.\"",[58,1081,1082,1085],{},[14,1083,1084],{},"Set an internal floor above 70."," Programs operating at 72–74 percent have no buffer for a bad cohort; treat anything under roughly 80 percent as an early warning.",{"title":118,"searchDepth":286,"depth":286,"links":1087},[1088,1089,1090,1091,1092,1093,1094],{"id":785,"depth":286,"text":786},{"id":827,"depth":286,"text":828},{"id":884,"depth":286,"text":885},{"id":903,"depth":286,"text":904},{"id":1015,"depth":286,"text":1016},{"id":1037,"depth":286,"text":1038},{"id":251,"depth":286,"text":252},"The 70\u002F70 rule requires a 70% completion rate and 70% job placement rate for Workforce Pell eligibility. Both tests, the phase-in timeline, and what failure costs.",{},8,"1.2",{"title":746,"description":1095},[1101,1102,1103,1104],{"label":307,"url":308},{"label":310,"url":311},{"label":313,"url":314},{"label":1105,"url":1106},"ACE summary of the final Workforce Pell rule","https:\u002F\u002Fwww.acenet.edu\u002FDocuments\u002FSummary-OBBB-Final-Workforce-Pell-Rule.pdf","library\u002Fworkforce-pell\u002Fthe-70-70-rule-explained",[31,321,129,320,1109],"compliance","CUDaSnuslsdQytRzSidPaM-_sS5EutJ8nEkXp-It2Ws",{"id":1112,"title":1113,"body":1114,"description":1491,"extension":295,"meta":1492,"navigation":297,"path":128,"pillar":299,"pinned":300,"publishedDate":301,"readTime":302,"section":1493,"seo":1494,"sources":1495,"stem":1498,"tags":1499,"updatedDate":301,"__hash__":1501},"library\u002Flibrary\u002Fworkforce-pell\u002Fcompletion-rate-calculation.md","How the Workforce Pell Completion Rate Is Calculated (the 150% of Normal Time Window)",{"type":7,"value":1115,"toc":1476},[1116,1123,1131,1135,1138,1143,1157,1168,1171,1175,1182,1188,1191,1214,1217,1219,1227,1232,1265,1276,1280,1284,1295,1297,1301,1311,1314,1318,1321,1399,1408,1412,1442,1444],[10,1117,1118,1119,1122],{},"The Workforce Pell completion test requires that ",[14,1120,1121],{},"at least 70 percent of program participants complete the program within 150% of the normal time to completion",". This article walks through the window, the cohort, the two calculation regimes, and the per-student data you need to produce a defensible rate.",[10,1124,1125,1126,1128,1129,152],{},"This is half of the ",[28,1127,31],{"href":30},"; the other half is the ",[28,1130,320],{"href":298},[34,1132,1134],{"id":1133},"the-150-window-worked","The 150% window, worked",[10,1136,1137],{},"\"Normal time to completion\" is your program's published length. The completion window is that length times 1.5.",[10,1139,1140],{},[14,1141,1142],{},"Example: a 12-week, 320-clock-hour CDL program.",[55,1144,1145,1148,1154],{},[58,1146,1147],{},"Normal time: 12 weeks",[58,1149,1150,1151],{},"Completion window: 12 × 1.5 = ",[14,1152,1153],{},"18 weeks",[58,1155,1156],{},"A student who starts January 5 has until roughly May 10 (week 18) to complete and count as a completer",[10,1158,1159,1160,1163,1164,1167],{},"A student who finishes in week 14 after retaking a unit counts ",[14,1161,1162],{},"for"," you. A student who finishes in week 20 is a completion for the student — but ",[14,1165,1166],{},"against"," you in the rate. A student who withdraws in week 3 counts against you. There is no partial credit: within the window or not.",[10,1169,1170],{},"Note the deliberate parallel with Satisfactory Academic Progress: SAP's maximum timeframe is also 150% of program length (FSA Handbook). A student who blows through the 150% window has typically also failed SAP quantitative standards — the two compliance regimes reinforce each other, and your SAP monitoring data is a natural early-warning feed for the completion rate.",[34,1172,1174],{"id":1173},"who-counts-in-the-cohort","Who counts in the cohort",[10,1176,1177,1178,1181],{},"The rate is computed over ",[14,1179,1180],{},"program participants"," — students who began the program — not over completers or Pell recipients only:",[109,1183,1186],{"className":1184,"code":1185,"language":114},[112],"completion rate = students completing within 150% of normal time\n                  ÷ students who began the program (the cohort)\n",[116,1187,1185],{"__ignoreMap":118},[10,1189,1190],{},"Practical cohort questions your methodology must answer — and where the final rule and your state's guidance control:",[55,1192,1193,1199,1208],{},[58,1194,1195,1198],{},[14,1196,1197],{},"Cohort boundaries:"," which start dates or award year define one cohort (rolling-enrollment programs need a clear convention)",[58,1200,1201,1204,1205,1207],{},[14,1202,1203],{},"Exclusions:"," exactly ",[14,1206,891],{}," categories of students may be removed — see the next section. Nothing else comes out.",[58,1209,1210,1213],{},[14,1211,1212],{},"Transfers and restarts:"," how a student who drops and re-enrolls in a later cohort is counted",[10,1215,1216],{},"Where this document's grounding is silent, the answer is the final rule and your state's published methodology — not an analogy to IPEDS or Graduation Rate Survey conventions.",[34,1218,885],{"id":884},[10,1220,1221,1222,896,1224,1226],{},"The final rule (91 FR 29254; 34 CFR part 690, subpart H) allows exactly four exclusions, applied to the numerator ",[14,1223,895],{},[14,1225,899],{},"; or (4) were incarcerated. Each must be documented with evidence — an undocumented exclusion is an audit finding. There is no exclusion for transfers, no-shows after the cohort forms, or students you simply cannot reach.",[1228,1229,1231],"h3",{"id":1230},"a-worked-rate-exclusions-included","A worked rate, exclusions included",[55,1233,1234,1240,1246,1252,1258],{},[58,1235,1236,1239],{},[14,1237,1238],{},"40"," students began the program",[58,1241,1242,1245],{},[14,1243,1244],{},"2"," carry documented exclusions (one called to military service for more than 30 days, one totally disabling condition)",[58,1247,1248,1249],{},"Denominator: 40 − 2 = ",[14,1250,1251],{},"38",[58,1253,1254,1257],{},[14,1255,1256],{},"29"," completed within the 150% window",[58,1259,1260,1261,1264],{},"Completion rate: 29 ÷ 38 = ",[14,1262,1263],{},"76.3%"," — passing",[10,1266,1267,1268,1271,1272,1275],{},"Margin analysis: the 70 percent line on a 38-student denominator sits at ",[14,1269,1270],{},"26.6"," students, so this cohort could absorb ",[14,1273,1274],{},"two more non-completions"," and still pass. At typical short-program cohort sizes, the distance between passing and failing is two or three students — which is the arithmetic behind setting an internal floor well above 70.",[34,1277,1279],{"id":1278},"two-regimes-who-calculates-and-how","Two regimes: who calculates, and how",[1228,1281,1283],{"id":1282},"transitional-years-202627-through-202829-the-governor","Transitional years: 2026–27 through 2028–29 — the Governor",[10,1285,1286,1287,1290,1291,1294],{},"For the first three award years, ",[14,1288,1289],{},"the Governor determines and verifies the completion rate",". States may set their own data systems and verification methodology. That means the operative definition of your cohort, your window, and your evidence requirements is a ",[14,1292,1293],{},"state"," document. Two schools with identical outcomes in different states could report different rates.",[10,1296,599],{},[1228,1298,1300],{"id":1299},"after-202829-the-federal-calculation","After 2028–29 — the federal calculation",[10,1302,1303,1304,1307,1308,1310],{},"Beginning after award year 2028–29, the rate is calculated under ",[14,1305,1306],{},"federal methodology"," — the clock-hour completion calculation of ",[14,1309,818],{},", the same math clock-hour schools already know from short-program eligibility rules. If your registrar already produces 668.8(f) completion rates for other Title IV purposes, that machinery is the long-term home of your Workforce Pell completion number.",[10,1312,1313],{},"Build to the federal standard from day one. A state may accept looser evidence during the transition; the federal calc arriving in 2029–30 will not.",[34,1315,1317],{"id":1316},"the-data-you-need-per-student","The data you need per student",[10,1319,1320],{},"A defensible completion rate is a per-student ledger. For every student in every cohort, you need:",[605,1322,1323,1333],{},[608,1324,1325],{},[611,1326,1327,1330],{},[614,1328,1329],{},"Field",[614,1331,1332],{},"Why it matters",[621,1334,1335,1343,1351,1359,1367,1375,1383,1391],{},[611,1336,1337,1340],{},[626,1338,1339],{},"Program start date",[626,1341,1342],{},"Defines cohort membership and starts the 150% clock",[611,1344,1345,1348],{},[626,1346,1347],{},"Program normal length (weeks and clock hours)",[626,1349,1350],{},"Sets the window (× 1.5)",[611,1352,1353,1356],{},[626,1354,1355],{},"Scheduled completion date",[626,1357,1358],{},"Start + normal time; window end = start + 150% of normal time",[611,1360,1361,1364],{},[626,1362,1363],{},"Actual completion date (credential conferral)",[626,1365,1366],{},"Determines whether the student completed inside the window",[611,1368,1369,1372],{},[626,1370,1371],{},"Withdrawal \u002F last date of attendance, if applicable",[626,1373,1374],{},"Documents non-completers; also drives R2T4 (FSA Handbook)",[611,1376,1377,1380],{},[626,1378,1379],{},"Clock hours completed vs. scheduled",[626,1381,1382],{},"Feeds the 34 CFR 668.8(f) federal calculation and disbursement rules",[611,1384,1385,1388],{},[626,1386,1387],{},"Leave-of-absence or status-change records",[626,1389,1390],{},"Explains gaps an auditor will ask about",[611,1392,1393,1396],{},[626,1394,1395],{},"Exclusion evidence, where claimed",[626,1397,1398],{},"Each of the four allowable exclusions must be documented, or it is an audit finding",[10,1400,1401,1402,1404,1405,1407],{},"Most of this is data you already keep for R2T4, SAP, and NSLDS enrollment reporting. The Workforce Pell difference is that it must roll up, per program and per cohort, into one number that clears ",[14,1403,492],{}," — and survive state verification or a federal audit. When you have the ledger assembled, run your numbers in the ",[28,1406,247],{"href":246}," to see where each program stands.",[34,1409,1411],{"id":1410},"common-failure-modes","Common failure modes",[55,1413,1414,1424,1430,1436],{},[58,1415,1416,1419,1420,1423],{},[14,1417,1418],{},"No recorded conferral dates."," If you can't prove ",[23,1421,1422],{},"when"," a student completed, you can't prove they completed inside the window.",[58,1425,1426,1429],{},[14,1427,1428],{},"Rolling enrollment with no cohort convention."," Pick a convention consistent with your state's methodology and apply it identically every reporting cycle.",[58,1431,1432,1435],{},[14,1433,1434],{},"Counting \"still enrolled past the window\" as pending."," Once the 150% window closes, a non-completer is a non-completer for that cohort's rate.",[58,1437,1438,1441],{},[14,1439,1440],{},"Optimistic denominators."," Quietly dropping withdrawals from the denominator is the fastest way to fail a verification. Only the four documented exclusions come out — nothing else.",[34,1443,252],{"id":251},[179,1445,1446,1452,1458,1464,1470],{},[58,1447,1448,1451],{},[14,1449,1450],{},"Publish and freeze each program's normal time"," (weeks and clock hours) — the whole calculation keys off it.",[58,1453,1454,1457],{},[14,1455,1456],{},"Build the per-student ledger"," with the seven fields above for every current cohort, starting with students enrolled this award year.",[58,1459,1460,1463],{},[14,1461,1462],{},"Ask your state workforce board for the written completion-rate methodology"," — cohort definition, allowed exclusions, evidence requirements — before you certify any number.",[58,1465,1466,1469],{},[14,1467,1468],{},"Backtest the last two years of cohorts."," If any program's historical rate is under roughly 80 percent, it needs intervention (scheduling, tutoring, attendance follow-up) before it needs Pell.",[58,1471,1472,1475],{},[14,1473,1474],{},"Wire SAP monitoring into completion forecasting"," — students failing SAP's 150% pace today are your completion-rate misses next quarter.",{"title":118,"searchDepth":286,"depth":286,"links":1477},[1478,1479,1480,1484,1488,1489,1490],{"id":1133,"depth":286,"text":1134},{"id":1173,"depth":286,"text":1174},{"id":884,"depth":286,"text":885,"children":1481},[1482],{"id":1230,"depth":1483,"text":1231},3,{"id":1278,"depth":286,"text":1279,"children":1485},[1486,1487],{"id":1282,"depth":1483,"text":1283},{"id":1299,"depth":1483,"text":1300},{"id":1316,"depth":286,"text":1317},{"id":1410,"depth":286,"text":1411},{"id":251,"depth":286,"text":252},"Step-by-step Workforce Pell completion rate math: the 150% of normal time window, who counts in the cohort, and the student data you need to defend a 70% rate.",{},"1.3",{"title":1113,"description":1491},[1496,1497],{"label":307,"url":308},{"label":313,"url":314},"library\u002Fworkforce-pell\u002Fcompletion-rate-calculation",[129,31,321,1500],"150% normal time","ws9zs9OgNo9_J_y1Ef4GwN2LhoTMtSyGMtVo8lyh5ho",{"id":4,"title":5,"body":1503,"description":294,"extension":295,"meta":1674,"navigation":297,"path":298,"pillar":299,"pinned":300,"publishedDate":301,"readTime":302,"section":303,"seo":1675,"sources":1676,"stem":318,"tags":1681,"updatedDate":301,"__hash__":323},{"type":7,"value":1504,"toc":1666},[1505,1515,1517,1523,1527,1545,1549,1555,1557,1559,1564,1570,1572,1584,1590,1592,1596,1598,1616,1618,1620,1622,1638,1642,1644],[10,1506,12,1507,17,1509,21,1511,26,1513,32],{},[14,1508,16],{},[14,1510,20],{},[23,1512,25],{},[28,1514,31],{"href":30},[34,1516,37],{"id":36},[10,1518,40,1519,44,1521,48],{},[14,1520,43],{},[14,1522,47],{},[10,1524,1525],{},[14,1526,53],{},[55,1528,1529,1533,1537,1541],{},[58,1530,60,1531],{},[14,1532,63],{},[58,1534,66,1535,70],{},[14,1536,69],{},[58,1538,73,1539,77],{},[14,1540,76],{},[58,1542,1543],{},[14,1544,82],{},[10,1546,85,1547,89],{},[14,1548,88],{},[10,1550,92,1551,96,1553,100],{},[14,1552,95],{},[14,1554,99],{},[10,1556,103],{},[34,1558,107],{"id":106},[109,1560,1562],{"className":1561,"code":113,"language":114},[112],[116,1563,113],{"__ignoreMap":118},[10,1565,121,1566,125,1568,130],{},[14,1567,124],{},[28,1569,129],{"href":128},[34,1571,134],{"id":133},[55,1573,1574,1578],{},[58,1575,1576,142],{},[14,1577,141],{},[58,1579,1580,148,1582,152],{},[14,1581,147],{},[14,1583,151],{},[10,1585,155,1586,159,1588,152],{},[14,1587,158],{},[28,1589,163],{"href":162},[34,1591,167],{"id":166},[10,1593,170,1594,174],{},[14,1595,173],{},[10,1597,177],{},[179,1599,1600,1608,1612],{},[58,1601,1602,186,1604,190,1606,194],{},[14,1603,185],{},[14,1605,189],{},[14,1607,193],{},[58,1609,1610,200],{},[14,1611,199],{},[58,1613,1614,206],{},[14,1615,205],{},[10,1617,209],{},[34,1619,213],{"id":212},[10,1621,216],{},[55,1623,1624,1628,1632],{},[58,1625,1626,224],{},[14,1627,223],{},[58,1629,1630,230],{},[14,1631,229],{},[58,1633,1634,236,1636,240],{},[14,1635,235],{},[23,1637,239],{},[10,1639,243,1640,248],{},[28,1641,247],{"href":246},[34,1643,252],{"id":251},[179,1645,1646,1650,1654,1658,1662],{},[58,1647,1648,260],{},[14,1649,259],{},[58,1651,1652,266],{},[14,1653,265],{},[58,1655,1656,272],{},[14,1657,271],{},[58,1659,1660,278],{},[14,1661,277],{},[58,1663,1664,284],{},[14,1665,283],{},{"title":118,"searchDepth":286,"depth":286,"links":1667},[1668,1669,1670,1671,1672,1673],{"id":36,"depth":286,"text":37},{"id":106,"depth":286,"text":107},{"id":133,"depth":286,"text":134},{"id":166,"depth":286,"text":167},{"id":212,"depth":286,"text":213},{"id":251,"depth":286,"text":252},{},{"title":5,"description":294},[1677,1678,1679,1680],{"label":307,"url":308},{"label":310,"url":311},{"label":313,"url":314},{"label":316,"url":317},[320,31,321,322],{"id":1683,"title":1684,"body":1685,"description":1913,"extension":295,"meta":1914,"navigation":297,"path":1915,"pillar":299,"pinned":300,"publishedDate":301,"readTime":302,"section":1916,"seo":1917,"sources":1918,"stem":1921,"tags":1922,"updatedDate":301,"__hash__":1926},"library\u002Flibrary\u002Fworkforce-pell\u002Fvalue-added-earnings-test.md","The Value-Added Earnings Test: The Third Metric (and Why You Have Until 2030)",{"type":7,"value":1686,"toc":1905},[1687,1705,1709,1716,1724,1727,1730,1737,1740,1744,1751,1754,1776,1787,1791,1801,1804,1839,1843,1850,1853,1857,1864,1871,1873],[10,1688,1689,1690,1692,1693,1696,1697,1700,1701,1704],{},"Beyond the ",[28,1691,31],{"href":30},", Workforce Pell carries a third performance metric that most administrators have not yet planned for: the ",[14,1694,1695],{},"value-added earnings test"," (34 CFR 690.95–.96). It is deferred — the Secretary's ",[14,1698,1699],{},"first determinations come in award year 2029–30 and apply to published tuition and fees for the following award year",", so the cap first bites in ",[14,1702,1703],{},"2030–31",". (You will see both years cited in coverage; they are the same fact.) But it is a price test, and price is a decision you are making right now.",[34,1706,1708],{"id":1707},"the-test-in-one-sentence","The test in one sentence",[10,1710,1711,1712,1715],{},"A program's published ",[14,1713,1714],{},"tuition and fees must not exceed the \"value-added earnings\" of its completers",", defined as:",[1717,1718,1719],"blockquote",{},[10,1720,1721],{},[14,1722,1723],{},"median earnings of working Pell-recipient completers — regionally price-adjusted — minus 150% of the single-person federal poverty line",[10,1725,1726],{},"The regional price adjustment matters: median earnings are adjusted for local price levels before the subtraction, so a program in a low-cost region is not measured against raw national dollars.",[10,1728,1729],{},"If your program charges $8,000 and your working Pell completers' median earnings clear the 150%-of-poverty-line floor by less than $8,000, the program fails.",[10,1731,1732,1733,1736],{},"The structure is worth pausing on. The test does not ask whether graduates earn \"enough\" in the abstract. It subtracts a baseline — 150% of the single-person federal poverty guideline — from median earnings, treats the remainder as the ",[23,1734,1735],{},"value added"," by the credential, and demands that you charged no more than that value. It is a return-on-investment cap written into program eligibility.",[10,1738,1739],{},"(The specific poverty guideline figures change annually — use the current single-person federal poverty guideline when you model your own numbers, and do not build projections on invented dollar amounts.)",[34,1741,1743],{"id":1742},"whose-earnings-measured-when-the-cohort-period","Whose earnings, measured when: the cohort period",[10,1745,1746,1747,1750],{},"The earnings in the test are not last year's graduates'. The cohort measured is from ",[14,1748,1749],{},"an award year ending three full award years before the award year for which value-added earnings are determined",". Earnings need time to mature and to appear in administrative data, so the test looks back several years at completers who have been in the labor market for a while.",[10,1752,1753],{},"Two mechanics from the final rule shape whether your program can even be measured:",[55,1755,1756,1762],{},[58,1757,1758,1761],{},[14,1759,1760],{},"Cohorts pool by six-digit CIP code."," Programs sharing a six-digit CIP at your institution are measured together — another reason to code CIP assignments deliberately.",[58,1763,1764,1767,1768,1771,1772,1775],{},[14,1765,1766],{},"Minimum counts:"," the computation requires at least ",[14,1769,1770],{},"30 completers sent"," for the earnings match and ",[14,1773,1774],{},"16 matched earnings records",". Small programs may fall below the threshold in a given cycle; that is a measurement question to raise with ED, not an exemption to assume.",[10,1777,1778,1779,1782,1783,1786],{},"The practical consequence is the headline of this article: ",[14,1780,1781],{},"students enrolling in 2026–27 are the raw material of the earliest earnings calculations."," With the Secretary's first determinations in award year 2029–30 (applying to 2030–31 tuition), programs enrolling students now have roughly a ",[14,1784,1785],{},"four-year runway"," — but the outcomes being measured then are being produced today. You cannot fix a 2030 earnings number in 2030.",[34,1788,1790],{"id":1789},"why-the-test-is-deferred-and-why-that-isnt-a-reprieve","Why the test is deferred — and why that isn't a reprieve",[10,1792,485,1793,1796,1797,1800],{},[28,1794,1795],{"href":30},"70\u002F70 tests"," can be computed within a year or so of a cohort exiting. Median earnings cannot: the earnings observation itself sits years after enrollment. The deferred start is a data-availability lag, not a policy grace period — and the interim is not unsupervised. Until the Secretary's calculations begin, ",[14,1798,1799],{},"the governor certifies having weighed each program's cost against expected occupational wages"," as part of certification, so a price wildly out of line with the target occupation's wages is already a certification risk today.",[10,1802,1803],{},"Three things follow:",[179,1805,1806,1812,1821],{},[58,1807,1808,1811],{},[14,1809,1810],{},"Your current pricing is already inside the test."," Published tuition and fees for programs enrolling Workforce Pell students now are the numbers that will be compared against those students' eventual earnings.",[58,1813,1814,1817,1818,1820],{},[14,1815,1816],{},"Occupation choice compounds."," A program aligned to a genuinely high-wage occupation — the alignment your governor certifies at approval (see ",[28,1819,163],{"href":162},") — has structural margin under the earnings test. A program aligned to a low-wage occupation may pass 70\u002F70 and still be priced out by this metric.",[58,1822,1823,1826,1827,1830,1831,1834,1835,1838],{},[14,1824,1825],{},"Failure consequences are severe — and can be retroactive in effect."," A failing program loses Workforce Pell eligibility, with the same two-year bar on substantially similar programs described in ",[28,1828,1829],{"href":594},"Falling Below 70\u002F70",". Worse: a program whose value-added earnings come out ",[14,1832,1833],{},"zero or negative"," is not only ineligible but ",[14,1836,1837],{},"owes a liability for the Pell funds disbursed in the measured year"," (34 CFR 690.95–.96). This is the only Workforce Pell metric that can send money back.",[34,1840,1842],{"id":1841},"the-data-plumbing-you-already-have","The data plumbing you already have",[10,1844,1845,1846,1849],{},"If FVT\u002FGE reporting rings a bell, it should: ",[14,1847,1848],{},"Financial Value Transparency & Gainful Employment reporting continues, and it shares data plumbing with the Workforce Pell metrics"," (FSA Handbook \u002F FVT-GE framework). Both regimes run on program-level rosters of completers matched to earnings data, plus accurate published cost figures.",[10,1851,1852],{},"That is good news operationally. The completer identification, program-level (CIP-coded) reporting, and cost-of-attendance data hygiene you built for FVT\u002FGE is the same pipeline the value-added earnings test will draw on. Schools that treated FVT\u002FGE reporting as a box-checking exercise will feel it here; schools with clean pipelines are most of the way ready.",[34,1854,1856],{"id":1855},"what-published-tuition-and-fees-puts-in-your-control","What \"published tuition and fees\" puts in your control",[10,1858,1859,1860,1863],{},"Earnings arrive years later and depend on the labor market. ",[14,1861,1862],{},"Price is the variable you control today."," The test creates a hard business constraint: every tuition increase raises the bar your completers' future median earnings must clear. Before any price change on a Workforce Pell program, someone should ask: what earnings premium over 150% of the single-person poverty line does this price now require, and does our placement data support it?",[10,1865,1866,1867,1870],{},"Your ",[28,1868,1869],{"href":298},"job placement records"," — especially occupation and employer, which you should be capturing anyway for the 2029–30 occupation-aligned placement phase — are your best early proxy for where completer earnings are heading. And keep the near-term tests in view while you plan for this one: 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.",[34,1872,252],{"id":251},[179,1874,1875,1881,1887,1893,1899],{},[58,1876,1877,1880],{},[14,1878,1879],{},"Document published tuition and fees per program, per award year, starting with 2026–27"," — the historical price record is half of the eventual test, and it must match what you actually published.",[58,1882,1883,1886],{},[14,1884,1885],{},"Model the test with current numbers."," Take your best estimate of completer median earnings (state wage data, placement records), subtract 150% of the current single-person federal poverty guideline, and compare to your price. If the margin is thin, you have four years to change price, occupation alignment, or outcomes.",[58,1888,1889,1892],{},[14,1890,1891],{},"Keep completer rosters CIP-coded and match-ready",", aligned with your FVT\u002FGE reporting pipeline, so the 2030–31 calculation finds clean data.",[58,1894,1895,1898],{},[14,1896,1897],{},"Fold the earnings constraint into pricing governance now"," — no tuition change on a Workforce Pell program without an earnings-margin check.",[58,1900,1901,1904],{},[14,1902,1903],{},"Prioritize high-wage occupation alignment"," in any new program you take through governor certification; it is the cheapest insurance against this test.",{"title":118,"searchDepth":286,"depth":286,"links":1906},[1907,1908,1909,1910,1911,1912],{"id":1707,"depth":286,"text":1708},{"id":1742,"depth":286,"text":1743},{"id":1789,"depth":286,"text":1790},{"id":1841,"depth":286,"text":1842},{"id":1855,"depth":286,"text":1856},{"id":251,"depth":286,"text":252},"Workforce Pell's value-added earnings test caps tuition and fees at completers' median earnings minus 150% of the poverty line, starting award year 2030-31.",{},"\u002Flibrary\u002Fworkforce-pell\u002Fvalue-added-earnings-test","1.5",{"title":1684,"description":1913},[1919,1920],{"label":307,"url":308},{"label":1105,"url":1106},"library\u002Fworkforce-pell\u002Fvalue-added-earnings-test",[1923,321,1924,1925],"value-added earnings","earnings test","tuition and fees","BdX1PvQrstxBHrfCPEjWE9epfuMuAFm9fyBV4a9gac0",{"id":1928,"title":503,"body":1929,"description":2333,"extension":295,"meta":2334,"navigation":297,"path":502,"pillar":299,"pinned":300,"publishedDate":301,"readTime":2335,"section":2336,"seo":2337,"sources":2338,"stem":2341,"tags":2342,"updatedDate":301,"__hash__":2344},"library\u002Flibrary\u002Fworkforce-pell\u002Fprogram-eligibility-checklist.md",{"type":7,"value":1930,"toc":2324},[1931,1938,1944,1951,1955,1962,2006,2012,2026,2030,2060,2065,2070,2074,2102,2107,2116,2120,2149,2154,2159,2163,2213,2218,2225,2229,2283,2290,2292],[10,1932,1933,1934,1937],{},"Five gates stand between a program and Workforce Pell eligibility. Every gate must be cleared — a program that aces four and misses one is ineligible. This checklist covers all five, with the evidence you should have in hand before you approach your state or ED. Remember throughout: eligibility is ",[14,1935,1936],{},"per program",", not per institution.",[10,1939,1940,1941,1943],{},"Work through it program by program. For background on what ",[28,1942,781],{"href":728}," is and where it came from, start there.",[10,1945,1946,1947,1950],{},"One framing point before the gates: ",[14,1948,1949],{},"no program category is automatically eligible — CDL included",". However obviously workforce-aligned a program is, it still needs governor approval (after state workforce board consultation), a Secretary determination, at least a year of operating history, the length bounds, and ongoing 70\u002F70 performance. There is no fast lane by occupation.",[34,1952,1954],{"id":1953},"gate-1-program-length-150-to-under-600-clock-hours-over-8-to-under-15-weeks","Gate 1: Program length — 150 to under 600 clock hours over 8 to under 15 weeks",[10,1956,1957,1958,1961],{},"The precise bounds: ",[14,1959,1960],{},"at least 8 but less than 15 weeks of instruction AND at least 150 but less than 600 clock hours"," (or the credit-hour equivalents). Both conditions must hold simultaneously.",[55,1963,1966,1979,1988,1998],{"className":1964},[1965],"contains-task-list",[58,1967,1970,1974,1975,1978],{"className":1968},[1969],"task-list-item",[1971,1972],"input",{"disabled":297,"type":1973},"checkbox"," Program delivers ",[14,1976,1977],{},"150 to under 600 clock hours"," of instruction (or credit equivalents)",[58,1980,1982,1984,1985],{"className":1981},[1969],[1971,1983],{"disabled":297,"type":1973}," Instruction spans ",[14,1986,1987],{},"at least 8 weeks but less than 15 weeks",[58,1989,1991,1993,1994,1997],{"className":1990},[1969],[1971,1992],{"disabled":297,"type":1973}," Program is ",[14,1995,1996],{},"not"," a correspondence program",[58,1999,2001,2003,2004],{"className":2000},[1969],[1971,2002],{"disabled":297,"type":1973}," If delivered by distance education across state lines: bilateral state agreements are in place (or confirmed unnecessary) — see ",[28,2005,163],{"href":162},[10,2007,2008,2011],{},[14,2009,2010],{},"Evidence:"," published program schedule, clock-hour breakdown by unit, academic calendar.",[10,2013,2014,2017,2018,2021,2022,2025],{},[14,2015,2016],{},"Watch for:"," both dimensions bind ",[14,2019,2020],{},"independently"," — hours cannot rescue weeks, or vice versa. A 140-hour program is too short; a 600-hour program is outside the band (though it may qualify for Title IV under existing short-program rules); a 15-week program is one week too long. The trap case is the accelerated program: a ",[14,2023,2024],{},"4-week, 160-hour intensive clears the hour floor but fails the 8-week floor — ineligible as-is",", and the fix is re-pacing the same hours across at least 8 weeks, not adding hours. If a program sits near any boundary, document the clock-hour accounting carefully — this is the first thing verified.",[34,2027,2029],{"id":2028},"gate-2-credential-recognized-and-stackable","Gate 2: Credential — recognized and stackable",[55,2031,2033,2041,2050],{"className":2032},[1965],[58,2034,2036,2038,2039],{"className":2035},[1969],[1971,2037],{"disabled":297,"type":1973}," Program leads to a ",[14,2040,415],{},[58,2042,2044,2046,2047],{"className":2043},[1969],[1971,2045],{"disabled":297,"type":1973}," The credential is ",[14,2048,2049],{},"stackable toward higher-level, for-credit programs",[58,2051,2053,2055,2056,2059],{"className":2052},[1969],[1971,2054],{"disabled":297,"type":1973}," Stackability meets ",[14,2057,2058],{},"your governor's stackability requirements"," (the governor determines what qualifies as stackable in your state)",[10,2061,2062,2064],{},[14,2063,2010],{}," credential description, articulation or credit-recognition agreements showing the pathway into a higher-level for-credit program, and your state's stackability criteria.",[10,2066,2067,2069],{},[14,2068,2016],{}," stackability is state-defined, not self-declared. A certificate that terminates — with no documented pathway into anything for-credit above it — is the likely failure point at this gate. Get your state's definition in writing before asserting compliance.",[34,2071,2073],{"id":2072},"gate-3-occupation-alignment-high-skill-high-wage-or-in-demand","Gate 3: Occupation alignment — high-skill, high-wage, or in-demand",[55,2075,2077,2086,2096],{"className":2076},[1965],[58,2078,2080,2082,2083],{"className":2079},[1969],[1971,2081],{"disabled":297,"type":1973}," Program prepares students for a ",[14,2084,2085],{},"high-skill, high-wage, or in-demand occupation",[58,2087,2089,2091,2092,2095],{"className":2088},[1969],[1971,2090],{"disabled":297,"type":1973}," That occupation is one ",[14,2093,2094],{},"identified by the state governor with the state workforce board"," — not merely one you believe qualifies",[58,2097,2099,2101],{"className":2098},[1969],[1971,2100],{"disabled":297,"type":1973}," Program-to-occupation mapping (CIP and SOC codes) is documented",[10,2103,2104,2106],{},[14,2105,2010],{}," your state's identified-occupations list (or the governor's\u002Fworkforce board's process for designating them), plus your program's CIP code and target SOC code(s).",[10,2108,2109,2111,2112,2115],{},[14,2110,2016],{}," this gate is decided in your state capital. If your target occupation isn't on your state's list, the path forward is the state workforce board's process — not the ED application. Your CIP\u002FSOC mapping also matters later: it defines \"substantially similar\" if you ever lose eligibility (see ",[28,2113,2114],{"href":594},"the two-year bar",") and feeds the occupation-aligned placement test starting 2029–30.",[34,2117,2119],{"id":2118},"gate-4-history-1-year-of-operation-clean-5-year-record","Gate 4: History — 1 year of operation, clean 5-year record",[55,2121,2123,2132,2141],{"className":2122},[1965],[58,2124,2126,2128,2129],{"className":2125},[1969],[1971,2127],{"disabled":297,"type":1973}," Program has ",[14,2130,2131],{},"existed for at least 1 year",[58,2133,2135,2137,2138],{"className":2134},[1969],[1971,2136],{"disabled":297,"type":1973}," Institution is ",[14,2139,2140],{},"accredited",[58,2142,2144,862,2146],{"className":2143},[1969],[1971,2145],{"disabled":297,"type":1973},[14,2147,2148],{},"No suspension, emergency action, or program termination in the previous 5 years",[10,2150,2151,2153],{},[14,2152,2010],{}," first-enrollment records for the program, current accreditation documentation, and your Title IV participation history.",[10,2155,2156,2158],{},[14,2157,2016],{}," brand-new programs cannot enter Workforce Pell on day one — the 1-year clock must run first. If you're building a new program for Workforce Pell, launch it now under other funding and apply once it has a year of history (and real completion data for Gate 5). Institutional-history questions — exactly which adverse actions count, and at what level — should be confirmed against the final rule (FR 2026-10013).",[34,2160,2162],{"id":2161},"gate-5-performance-the-7070-tests-and-later-the-earnings-test","Gate 5: Performance — the 70\u002F70 tests (and, later, the earnings test)",[55,2164,2166,2179,2188,2194,2204],{"className":2165},[1965],[58,2167,2169,862,2171,2174,2175,2178],{"className":2168},[1969],[1971,2170],{"disabled":297,"type":1973},[14,2172,2173],{},"Completion rate ≥ 70 percent"," — participants completing within 150% of normal time (",[28,2176,2177],{"href":128},"calculation details",")",[58,2180,2182,862,2184,2187],{"className":2181},[1969],[1971,2183],{"disabled":297,"type":1973},[14,2185,2186],{},"Job placement rate ≥ 70 percent"," — completers employed during the second quarter after exit",[58,2189,2191,2193],{"className":2190},[1969],[1971,2192],{"disabled":297,"type":1973}," Per-student data pipeline exists to keep producing both rates every year",[58,2195,2197,2199,2200,2203],{"className":2196},[1969],[1971,2198],{"disabled":297,"type":1973}," The ",[14,2201,2202],{},"four allowable exclusions"," (death, totally disabling condition, military service over 30 days, incarceration) are applied only with documented evidence — to numerator and denominator alike",[58,2205,2207,2209,2210,2212],{"className":2206},[1969],[1971,2208],{"disabled":297,"type":1973}," For the long run: pricing and outcomes positioned for the ",[14,2211,1695],{}," beginning award year 2030–31",[10,2214,2215,2217],{},[14,2216,2010],{}," cohort-level completion and placement calculations with underlying student records and employment verification sources.",[10,2219,2220,2222,2223,152],{},[14,2221,2016],{}," this is the only gate you must keep passing forever. Gates 1–4 are largely static; Gate 5 is measured continuously, and failing it triggers loss of eligibility plus a two-year bar on substantially similar programs. 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. Before you assert either rate, run your numbers in the ",[28,2224,247],{"href":246},[34,2226,2228],{"id":2227},"scoring-a-program","Scoring a program",[605,2230,2231,2241],{},[608,2232,2233],{},[611,2234,2235,2238],{},[614,2236,2237],{},"Result",[614,2239,2240],{},"Meaning",[621,2242,2243,2251,2259,2267,2275],{},[611,2244,2245,2248],{},[626,2246,2247],{},"5 of 5 gates",[626,2249,2250],{},"Ready to start the two-step approval: governor certification, then ED approval",[611,2252,2253,2256],{},[626,2254,2255],{},"Fails Gate 1",[626,2257,2258],{},"Restructure hours\u002Fweeks into the band, or accept the program is out of scope",[611,2260,2261,2264],{},[626,2262,2263],{},"Fails Gate 2 or 3",[626,2265,2266],{},"The fix runs through your state: stackability pathway or occupation designation",[611,2268,2269,2272],{},[626,2270,2271],{},"Fails Gate 4",[626,2273,2274],{},"Wait out the 1-year history (or the 5-year record), building outcomes data meanwhile",[611,2276,2277,2280],{},[626,2278,2279],{},"Fails Gate 5",[626,2281,2282],{},"Fix operations first — applying with sub-70 rates invites the two-year bar",[10,2284,2285,2286,2289],{},"For CDL and truck-driving schools, Gate 1 is usually free — most CDL programs sit naturally in the 150–599 clock-hour band, making them prime Workforce Pell candidates. ",[28,2287,581],{"href":578,"rel":2288},[580]," is the school-management platform for CDL programs working through the rest of this checklist.",[34,2291,252],{"id":251},[179,2293,2294,2300,2306,2312,2318],{},[58,2295,2296,2299],{},[14,2297,2298],{},"Run every program through the five gates"," and record the result — most schools find a mix of \"ready,\" \"fixable,\" and \"out of scope.\"",[58,2301,2302,2305],{},[14,2303,2304],{},"Collect the evidence files listed under each gate"," into a per-program eligibility dossier before starting any application.",[58,2307,2308,2311],{},[14,2309,2310],{},"Open the state conversation early"," — Gates 2, 3, and (transitionally) 5 are defined by your governor and state workforce board, and their timelines are not yours.",[58,2313,2314,2317],{},[14,2315,2316],{},"Start the 1-year clock on any new program now"," if you intend to seek Workforce Pell for it later.",[58,2319,2320,2323],{},[14,2321,2322],{},"Compute both 70\u002F70 rates for every \"ready\" program"," before certifying anything to anyone.",{"title":118,"searchDepth":286,"depth":286,"links":2325},[2326,2327,2328,2329,2330,2331,2332],{"id":1953,"depth":286,"text":1954},{"id":2028,"depth":286,"text":2029},{"id":2072,"depth":286,"text":2073},{"id":2118,"depth":286,"text":2119},{"id":2161,"depth":286,"text":2162},{"id":2227,"depth":286,"text":2228},{"id":251,"depth":286,"text":252},"All five Workforce Pell eligibility gates in one checklist: 150-599 clock hours, stackable credential, occupation alignment, program history, and the 70\u002F70 tests.",{},6,"1.6",{"title":503,"description":2333},[2339,2340],{"label":307,"url":308},{"label":313,"url":314},"library\u002Fworkforce-pell\u002Fprogram-eligibility-checklist",[321,742,2343,31],"checklist","Sst2AsP16CaLsiOKst7OVZNRjSXzGmfuIpNRBSKoi-U",{"id":2346,"title":2347,"body":2348,"description":2656,"extension":295,"meta":2657,"navigation":297,"path":162,"pillar":299,"pinned":300,"publishedDate":301,"readTime":302,"section":2658,"seo":2659,"sources":2660,"stem":2666,"tags":2667,"updatedDate":301,"__hash__":2670},"library\u002Flibrary\u002Fworkforce-pell\u002Fgovernor-certification-and-ed-approval.md","Governor Certification and ED Approval: How a Program Actually Becomes Workforce Pell Eligible",{"type":7,"value":2349,"toc":2645},[2350,2374,2377,2381,2388,2416,2423,2439,2443,2446,2450,2457,2471,2484,2488,2491,2527,2531,2538,2551,2555,2562,2566,2572,2611,2613],[10,2351,2352,2353,2356,2357,2360,2361,2364,2365,2368,2369,2371,2372,152],{},"Meeting the ",[28,2354,2355],{"href":502},"eligibility criteria"," does not make a program Workforce Pell eligible. Eligibility is conferred through a ",[14,2358,2359],{},"two-step approval process"," — first your ",[14,2362,2363],{},"state governor",", then the ",[14,2366,2367],{},"Department of Education"," — and it is granted ",[14,2370,463],{},". Applications have been open since ",[14,2373,343],{},[10,2375,2376],{},"If you internalize one thing from this article: the process starts in your state capital, not in Washington.",[34,2378,2380],{"id":2379},"step-1-governor-certification","Step 1: Governor certification",[10,2382,2383,2384,2387],{},"The governor, acting with the ",[14,2385,2386],{},"state workforce board",", certifies each program on three fronts:",[179,2389,2390,2400,2410],{},[58,2391,2392,2395,2396,2399],{},[14,2393,2394],{},"Occupation alignment"," — the program prepares students for a high-skill, high-wage, or in-demand occupation ",[23,2397,2398],{},"as identified by the governor with the state workforce board",". The state's occupation list (or designation process) is the operative document; your own labor-market analysis, however good, doesn't substitute for the state's determination.",[58,2401,2402,2405,2406,2409],{},[14,2403,2404],{},"Stackability"," — the program's recognized postsecondary credential stacks toward higher-level, for-credit programs, under ",[14,2407,2408],{},"stackability requirements the governor determines",". What counts as an adequate pathway — articulation agreements, credit recognition, statewide frameworks — is a state call.",[58,2411,2412,2415],{},[14,2413,2414],{},"The 70\u002F70 rates (transitional years)"," — for award years 2026–27 through 2028–29, the governor determines and verifies each program's completion and placement rates. States may set their own data systems and verification methodology, which means your evidence requirements are written by your state.",[10,2417,2418,2419,2422],{},"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. One federal anchor does exist: the ",[14,2420,2421],{},"first certifications draw on the most recent 12 months of state administrative data",", so the rates your governor certifies at the outset reflect the cohorts you graduated over the past year.",[10,2424,2425,2426,17,2429,2434,2435,2438],{},"The certification instrument itself is federal: ED released the ",[14,2427,2428],{},"State Workforce Pell Program Certification form on July 1, 2026",[28,2430,2433],{"href":2431,"rel":2432},"https:\u002F\u002Ffsapartners.ed.gov\u002Fknowledge-center\u002Flibrary\u002Felectronic-announcements\u002F2026-07-01\u002Feligible-workforce-programs-state-workforce-pell-certification-form-available",[580],"FSA Electronic Announcement GENERAL-26-44","). Once the governor signs it, ",[14,2436,2437],{},"the institution uploads the certification via E-App",", and the Secretary makes the eligibility determination.",[1228,2440,2442],{"id":2441},"the-state-workforce-board-is-your-primary-counterpart","The state workforce board is your primary counterpart",[10,2444,2445],{},"In most states, the governor's Workforce Pell functions run operationally through the state workforce board. That board (or the agency staffing it) is where you should expect to find: the identified-occupations list, the stackability criteria, the rate-verification methodology, and the certification application itself. States are building these processes on different timelines and with different designs — one state may run UI wage-record matching for placement verification, another may put the evidence burden on institutions. Do not assume your state looks like a neighboring one.",[34,2447,2449],{"id":2448},"step-2-ed-approval","Step 2: ED approval",[10,2451,2452,2453,2456],{},"After governor certification, ",[14,2454,2455],{},"ED verifies the federal requirements",":",[55,2458,2459,2466],{},[58,2460,2461,2462,407,2464],{},"Program length: ",[14,2463,406],{},[14,2465,339],{},[58,2467,2468,2469,2178],{},"The completion and placement performance requirements (the ",[28,2470,31],{"href":30},[10,2472,2473,2474,2477,2478,152],{},"ED's step is verification against the federal criteria in the final rule (91 FR 29254), layered on top of the state's certification — not a rubber stamp of it, and not a substitute for it. A program cannot skip the governor and apply straight to ED; equally, governor certification alone confers nothing until the ",[14,2475,2476],{},"Secretary's determination",". For process questions along the way, ED's dedicated program mailbox is ",[14,2479,2480],{},[28,2481,2483],{"href":2482},"mailto:OB3SchoolQuestions@ed.gov","OB3SchoolQuestions@ed.gov",[34,2485,2487],{"id":2486},"the-reporting-chains-once-approved","The reporting chains, once approved",[10,2489,2490],{},"Approval starts three standing data flows. Know which reports you owe, and which the governor owes on your behalf:",[55,2492,2493,2499,2509],{},[58,2494,2495,2498],{},[14,2496,2497],{},"Institution → Governor:"," annual completer lists and placement-verification data, plus the certification request itself, all through your state's process.",[58,2500,2501,2504,2505,2508],{},[14,2502,2503],{},"Institution → ED:"," published tuition and fees; current NSLDS enrollment and completion data. ED compiles completer lists from NSLDS and gives institutions a ",[14,2506,2507],{},"60-day window to correct"," them — a deadline that punishes lazy NSLDS reporting.",[58,2510,2511,2514,2515,2518,2519,2522,2523,2526],{},[14,2512,2513],{},"Governor → ED and DOL:"," each program certification (program name, ",[14,2516,2517],{},"six-digit CIP code",", SOC codes, approval date); notice of any ",[14,2520,2521],{},"withdrawn approval within 15 days","; and recertification ",[14,2524,2525],{},"before the institution's PPA expires",". That last item makes recertification part of your PPA calendar, not just the state's.",[34,2528,2530],{"id":2529},"per-program-approval-what-that-means-in-practice","Per-program approval: what that means in practice",[10,2532,2533,2534,2537],{},"Approval attaches to the ",[14,2535,2536],{},"program",", not the institution:",[55,2539,2540,2543,2548],{},[58,2541,2542],{},"An institution with six qualifying programs makes six cases — each with its own occupation alignment, stackability showing, and 70\u002F70 rates.",[58,2544,2545,2546,152],{},"One program failing 70\u002F70 later does not strip the others — but that program loses eligibility and triggers the two-year bar on substantially similar programs (same 4-digit CIP with overlapping SOC codes). See ",[28,2547,1829],{"href":594},[58,2549,2550],{},"Program identity matters. How your programs are defined — CIP codes, credential boundaries, clock-hour structures — determines what is \"a program\" for approval and what is \"substantially similar\" for the bar. Decide these definitions deliberately before you apply.",[34,2552,2554],{"id":2553},"distance-education-across-state-lines-bilateral-agreements","Distance education across state lines: bilateral agreements",[10,2556,2557,2558,2561],{},"Correspondence programs are excluded outright. Distance education programs serving students across state lines ",[14,2559,2560],{},"may need bilateral agreements between the states involved"," — a meaningful wrinkle, since governor certification is inherently a single-state act while online enrollment is not. If you enroll out-of-state students in a candidate program by distance education, raise the bilateral-agreement question with your state workforce board early; whether and how agreements are in place is state-level information this site cannot supply. Confirm the details against the final rule (FR 2026-10013) and your state's guidance.",[34,2563,2565],{"id":2564},"sequencing-your-application","Sequencing your application",[10,2567,2568,2569,2571],{},"Applications opened ",[14,2570,343],{},", the same day the program took effect for award year 2026–27. A realistic sequence:",[179,2573,2574,2584,2590,2596,2602],{},[58,2575,2576,2579,2580,2583],{},[14,2577,2578],{},"Screen internally"," against the ",[28,2581,2582],{"href":502},"five-gate checklist"," — no point spending state goodwill on a program that fails the length band.",[58,2585,2586,2589],{},[14,2587,2588],{},"Assemble the rate evidence"," — cohort-level completion and placement calculations with per-student backup, built to your state's methodology.",[58,2591,2592,2595],{},[14,2593,2594],{},"Apply for governor certification"," through your state workforce board's process, using the GENERAL-26-44 certification form.",[58,2597,2598,2601],{},[14,2599,2600],{},"Upload the signed certification via E-App"," and proceed to the Secretary's determination.",[58,2603,2604,2607,2608,2610],{},[14,2605,2606],{},"Keep measuring"," — approval is the start of the compliance obligation, not the end. The 70\u002F70 tests are ongoing, and the ",[28,2609,1695],{"href":1915}," arrives in award year 2030–31.",[34,2612,252],{"id":251},[179,2614,2615,2621,2627,2633,2639],{},[58,2616,2617,2620],{},[14,2618,2619],{},"Identify your state's Workforce Pell contact"," — the state workforce board or governor's workforce office — and get on their distribution list for guidance and application materials.",[58,2622,2623,2626],{},[14,2624,2625],{},"Request four documents from your state:"," the identified high-skill\u002Fhigh-wage\u002Fin-demand occupation list, the stackability requirements, the transitional-year rate methodology, and the certification application process.",[58,2628,2629,2632],{},[14,2630,2631],{},"Build one complete program dossier"," (eligibility evidence plus 70\u002F70 calculations) for your strongest candidate program and take it through the process first — learn the state's expectations on your best case, not your marginal one.",[58,2634,2635,2638],{},[14,2636,2637],{},"Map every candidate program's CIP and SOC codes now"," — they drive occupation alignment, program identity, and the substantially-similar analysis if anything ever goes wrong.",[58,2640,2641,2644],{},[14,2642,2643],{},"Flag any cross-state distance-ed enrollment"," in candidate programs and put the bilateral-agreement question to your state in writing.",{"title":118,"searchDepth":286,"depth":286,"links":2646},[2647,2650,2651,2652,2653,2654,2655],{"id":2379,"depth":286,"text":2380,"children":2648},[2649],{"id":2441,"depth":1483,"text":2442},{"id":2448,"depth":286,"text":2449},{"id":2486,"depth":286,"text":2487},{"id":2529,"depth":286,"text":2530},{"id":2553,"depth":286,"text":2554},{"id":2564,"depth":286,"text":2565},{"id":251,"depth":286,"text":252},"Workforce Pell approval is a two-step, per-program process: governor certification with the state workforce board, then ED verification. Open since July 1, 2026.",{},"1.7",{"title":2347,"description":2656},[2661,2662,2664,2665],{"label":307,"url":308},{"label":2663,"url":2431},"FSA Electronic Announcement GENERAL-26-44 (state certification form)",{"label":316,"url":317},{"label":313,"url":314},"library\u002Fworkforce-pell\u002Fgovernor-certification-and-ed-approval",[2668,2669,321,2386],"governor certification","ED approval","Cc_OqGW-3S7rgdH-Y3Yx_6Hcdg7bDujEc_pnow7c07A",{"id":2672,"title":1033,"body":2673,"description":2888,"extension":295,"meta":2889,"navigation":297,"path":594,"pillar":299,"pinned":300,"publishedDate":301,"readTime":2335,"section":2890,"seo":2891,"sources":2892,"stem":2895,"tags":2896,"updatedDate":301,"__hash__":2899},"library\u002Flibrary\u002Fworkforce-pell\u002Flosing-eligibility-two-year-bar.md",{"type":7,"value":2674,"toc":2881},[2675,2692,2695,2699,2706,2713,2716,2720,2723,2731,2734,2748,2751,2758,2762,2769,2772,2797,2800,2804,2807,2812,2826,2832,2838,2847,2849],[10,2676,485,2677,2679,2680,2682,2683,2685,2686,2688,2689,2691],{},[28,2678,31],{"href":30}," has teeth. A program that falls below either threshold — ",[14,2681,492],{}," completion within 150% of normal time, or ",[14,2684,492],{}," of completers employed during the second calendar quarter after exit (34 CFR 690.94) — ",[14,2687,1022],{},". And the institution cannot simply rename the program and reapply: a ",[14,2690,595],{}," blocks re-establishing the program or any \"substantially similar\" one.",[10,2693,2694],{},"This article covers what loss of eligibility means, how \"substantially similar\" is defined, the path back, and — most importantly — the monitoring practices that keep you from ever needing that path.",[34,2696,2698],{"id":2697},"what-loss-of-eligibility-means","What loss of eligibility means",[10,2700,2701,2702,2705],{},"Failure of either 70\u002F70 test ends ",[14,2703,2704],{},"that program's"," Workforce Pell eligibility. Because approval is per program, your other approved programs are not automatically affected — but for the failing program, the Workforce Pell funding stream stops, and with it the enrollment economics that may have been built on it.",[10,2707,2708,2709,2712],{},"The loss also moves fast on the state side. When a governor withdraws a program's approval, the governor must ",[14,2710,2711],{},"notify ED (and DOL) within 15 days",". There is no quiet interval in which a withdrawn program keeps drawing funds while paperwork catches up — assume the federal consequence follows the state decision within two weeks, and plan enrollment communications accordingly.",[10,2714,2715],{},"Operational questions raised by a mid-stream loss — how currently enrolled students' awards are handled, effective dates, institutional notification duties — are implementation details you should confirm against the final rule (91 FR 29254; 34 CFR part 690, subpart H) and current FSA guidance rather than assume.",[34,2717,2719],{"id":2718},"the-substantially-similar-two-year-bar","The \"substantially similar\" two-year bar",[10,2721,2722],{},"Here is the provision that surprises people. After a program fails 70\u002F70:",[1717,2724,2725],{},[10,2726,2727,2728],{},"The institution ",[14,2729,2730],{},"cannot re-establish that program, or a \"substantially similar\" program — meaning the same 4-digit CIP code with overlapping SOC codes — for two years.",[10,2732,2733],{},"The definition has two prongs, both of which matter:",[55,2735,2736,2742],{},[58,2737,2738,2741],{},[14,2739,2740],{},"Same 4-digit CIP code"," — the program-content classification. Rebranding \"Commercial Vehicle Operation I\" as \"Professional Truck Driving\" changes nothing if both live under the same 4-digit CIP.",[58,2743,2744,2747],{},[14,2745,2746],{},"Overlapping SOC codes"," — the target occupations. A restructured program aiming at the same jobs, with the same CIP family, is the same program in the rule's eyes.",[10,2749,2750],{},"The bar is aimed squarely at the obvious workaround: shut down the failing program, tweak the syllabus, relaunch under a new name next term. That door is closed for two years.",[10,2752,2753,2754,2757],{},"The flip side: your CIP and SOC code assignments — made back at ",[28,2755,2756],{"href":162},"approval time"," — define the blast radius of a failure. Sloppy, overly broad CIP coding across multiple programs could entangle more than the failing program in a substantially-similar analysis. Code deliberately.",[34,2759,2761],{"id":2760},"the-path-back-appeal-and-recertification","The path back: appeal and recertification",[10,2763,2764,2765,2768],{},"The reinstatement path runs through ",[14,2766,2767],{},"appeal and governor recertification of compliance",". The grounding for this site records the path at that level of generality — the procedural specifics (deadlines, evidentiary standards, who adjudicates what) are exactly the kind of detail you must confirm against the final rule (91 FR 29254; 34 CFR part 690, subpart H) and your state's process before relying on them.",[10,2770,2771],{},"Two practical notes:",[55,2773,2774,2791],{},[58,2775,2776,2779,2780,2783,2784,2787,2788,2790],{},[14,2777,2778],{},"An appeal is a data exercise."," Whether you are contesting the rate calculation or demonstrating restored compliance, the case is built from the same per-student completion ledger and employment verification records described in ",[28,2781,2782],{"href":128},"the completion-rate"," and ",[28,2785,2786],{"href":298},"placement-rate"," articles. Start any dispute by checking the mechanics: were the ",[14,2789,2202],{}," (death, totally disabling condition, military service over 30 days, incarceration) applied — with documentation — to both the numerator and the denominator, and was each placement measured in the correct second calendar quarter? A school with a clean, contemporaneous data trail can argue; a school reconstructing records after the fact cannot.",[58,2792,2793,2796],{},[14,2794,2795],{},"The governor is in the loop."," Recertification of compliance runs through the same state machinery that certified you originally. The working relationship you build with your state workforce board during approval is the relationship you will need in a dispute.",[10,2798,2799],{},"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 cuts both ways: it also means a rate you dispute is, in the transitional years, a conversation with your state about its methodology.",[34,2801,2803],{"id":2802},"early-warning-monitoring-the-discipline-that-prevents-all-of-this","Early-warning monitoring: the discipline that prevents all of this",[10,2805,2806],{},"The 70\u002F70 tests are annual verdicts on daily operations. By the time a rate is officially below 70, the students who caused it exited months ago. Prevention is a monitoring cadence:",[10,2808,2809],{},[14,2810,2811],{},"Track leading indicators, not just the rates.",[55,2813,2814,2820],{},[58,2815,2816,2819],{},[23,2817,2818],{},"Completion side:"," attendance gaps, SAP failures (SAP's 150% maximum timeframe parallels the completion window — an SAP-failing student is a probable completion miss), leave-of-absence starts, students pacing behind scheduled clock hours.",[58,2821,2822,2825],{},[23,2823,2824],{},"Placement side:"," completers with no employment record 60–90 days after exit, unreachable graduates (a non-respondent is usually a zero in the numerator), and — ahead of the 2029–30 occupation-aligned phase — placements outside the trained-for occupation.",[10,2827,2828,2831],{},[14,2829,2830],{},"Run the rates quarterly, per program, per cohort."," Not annually. And run them the way the rule counts: only the four documented exclusions out of both numerator and denominator, and each placement keyed to that completer's second calendar quarter. A program at 74 percent in Q2 is a solvable problem; the same number discovered at annual verification is a crisis.",[10,2833,2834,2837],{},[14,2835,2836],{},"Set an internal action floor above 70."," Treat roughly 80 percent as the intervention trigger: below it, career services intensifies outreach, instruction reviews at-risk students, leadership gets a monthly report. The 10-point buffer is what absorbs one bad cohort.",[10,2839,2840,2843,2844,2846],{},[14,2841,2842],{},"Assign ownership."," Completion data lives with the registrar, placement data with career services, and the consequence with financial aid. A rate that everyone contributes to and no one owns is how programs drift under 70 unnoticed. Run your numbers in the ",[28,2845,247],{"href":246}," on a recurring schedule and put the output in front of whoever owns the risk.",[34,2848,252],{"id":251},[179,2850,2851,2857,2863,2869,2875],{},[58,2852,2853,2856],{},[14,2854,2855],{},"Compute current 70\u002F70 rates for every approved or candidate program"," and flag anything under 80 percent as an active intervention, not a watch item.",[58,2858,2859,2862],{},[14,2860,2861],{},"Stand up a quarterly rate review"," — per program, per cohort, with leading indicators (SAP failures, unverified completers) alongside the headline rates.",[58,2864,2865,2868],{},[14,2866,2867],{},"Audit your CIP and SOC code assignments"," so you know, in advance, exactly which programs a substantially-similar analysis would sweep in.",[58,2870,2871,2874],{},[14,2872,2873],{},"Preserve the evidence trail contemporaneously"," — completion ledger, employment verifications, methodology notes — because it is both your compliance record and your entire appeal case.",[58,2876,2877,2880],{},[14,2878,2879],{},"Get your state's dispute and recertification process in writing now",", while you don't need it.",{"title":118,"searchDepth":286,"depth":286,"links":2882},[2883,2884,2885,2886,2887],{"id":2697,"depth":286,"text":2698},{"id":2718,"depth":286,"text":2719},{"id":2760,"depth":286,"text":2761},{"id":2802,"depth":286,"text":2803},{"id":251,"depth":286,"text":252},"A Workforce Pell program that fails the 70\u002F70 tests loses eligibility, with a two-year bar on substantially similar programs. The failure mechanics and early warnings.",{},"1.8",{"title":1033,"description":2888},[2893,2894],{"label":307,"url":308},{"label":313,"url":314},"library\u002Fworkforce-pell\u002Flosing-eligibility-two-year-bar",[31,2897,595,321,2898],"losing eligibility","compliance monitoring","vHaTeplxnkp2DLSPUS9sOz3yn4tVujoJbw4BSZSfnXM",1784624486759]