Beyond the 70/70 rule, Workforce Pell carries a third performance metric that most administrators have not yet planned for: the value-added earnings test (34 CFR 690.95–.96). It is deferred — the Secretary's 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 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.

The test in one sentence

A program's published tuition and fees must not exceed the "value-added earnings" of its completers, defined as:

median earnings of working Pell-recipient completers — regionally price-adjusted — minus 150% of the single-person federal poverty line

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.

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.

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 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.

(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.)

Whose earnings, measured when: the cohort period

The earnings in the test are not last year's graduates'. The cohort measured is from 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.

Two mechanics from the final rule shape whether your program can even be measured:

• 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.
• Minimum counts: the computation requires at least 30 completers sent for the earnings match and 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.

The practical consequence is the headline of this article: 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 four-year runway — but the outcomes being measured then are being produced today. You cannot fix a 2030 earnings number in 2030.

Why the test is deferred — and why that isn't a reprieve

The 70/70 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, 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.

Three things follow:

1. 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.
2. Occupation choice compounds. A program aligned to a genuinely high-wage occupation — the alignment your governor certifies at approval (see Governor Certification and ED Approval) — has structural margin under the earnings test. A program aligned to a low-wage occupation may pass 70/70 and still be priced out by this metric.
3. 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 Falling Below 70/70. Worse: a program whose value-added earnings come out zero or negative is not only ineligible but 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.

The data plumbing you already have

If FVT/GE reporting rings a bell, it should: Financial Value Transparency & Gainful Employment reporting continues, and it shares data plumbing with the Workforce Pell metrics (FSA Handbook / FVT-GE framework). Both regimes run on program-level rosters of completers matched to earnings data, plus accurate published cost figures.

That is good news operationally. The completer identification, program-level (CIP-coded) reporting, and cost-of-attendance data hygiene you built for FVT/GE is the same pipeline the value-added earnings test will draw on. Schools that treated FVT/GE reporting as a box-checking exercise will feel it here; schools with clean pipelines are most of the way ready.

What "published tuition and fees" puts in your control

Earnings arrive years later and depend on the labor market. 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?

Your 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.

What to do now

1. 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.
2. 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.
3. Keep completer rosters CIP-coded and match-ready, aligned with your FVT/GE reporting pipeline, so the 2030–31 calculation finds clean data.
4. Fold the earnings constraint into pricing governance now — no tuition change on a Workforce Pell program without an earnings-margin check.
5. Prioritize high-wage occupation alignment in any new program you take through governor certification; it is the cheapest insurance against this test.