December 19, 2025
This JFF brief analyzes the regulatory framework agreed upon in the U.S. Department of Education’s recent “negotiated rulemaking” session about how the Workforce Pell Grant program will be implemented.
On New Year’s Day, implementation of the Workforce Pell Grant program will be just six months away. As states, institutions, and other stakeholders prepare for their role in this process, which is set to begin July 1, it’s essential to understand the fundamentals of the law as well as recent developments in assembling a regulatory framework for the program.
Earlier this month, the U.S. Department of Education held negotiated rulemaking—a process that brings together experts representing a variety of constituencies to hammer out the details of definitions and processes for implementing Workforce Pell. Ethan Pollack, a senior director on Jobs for the Future’s Policy & Advocacy team, served as a negotiator on the rulemaking committee, joining a group of representatives from across the education and workforce ecosystem, including students, employers, institutions, veterans, states, workforce agencies, and accreditors.
The result of the negotiated rulemaking process was a consensus regulatory framework. This brief offers JFF’s analysis of the framework voted on by negotiators in mid-December. Consensus doesn’t represent the final word on the regulations, but it does constitute a binding agreement that the Education Department will utilize an agreed-upon framework for solicitation of the next round of public comments. The department will have the ability to make changes to the regulations before issuing a final rule. However, the agreement reached via negotiated rulemaking represents an important step forward in providing states and institutions with insights and guidance that will help them begin carrying out their responsibilities for implementation.
Workforce Pell is designed to expand upon the existing Pell Grant program to provide grant aid to students in shorter-term workforce-oriented education and training programs. It passed into law as part of the One Big Beautiful Bill Act in July 2025 and is slated to go into effect on July 1, 2026. Workforce Pell can break down barriers for learners who often have had limited access to need-based financial aid because their programs don’t meet credit hour requirements. Workforce Pell therefore has the potential to broaden pathways to quality jobs and expand opportunities for learners and workers from a wide range of backgrounds to pursue careers that lead to economic advancement.
To understand Workforce Pell, it’s essential to know how regular Pell Grant eligibility works. There are three mechanisms for Pell Grant eligibility: student eligibility, institutional eligibility, and programmatic eligibility. The process and requirements for student eligibility and institutional eligibility remain mostly the same under Workforce Pell. Institutions must be eligible to participate in Title IV student aid programs and student eligibility is assessed based on need (via the filing of a FAFSA). One exception is that students who have earned a bachelor’s degree may be eligible to receive a Workforce Pell Grant, even though they can’t receive regular Pell Grants in most instances.
Funding for Workforce Pell comes from the same appropriations pool as the current Pell Grant program. Awards will be calculated on a prorated basis, per existing Pell Grant requirements. This means that no short-term program will be eligible for a maximum Pell award (which is currently $7,395). Instead, the Department of Education will use a formula that considers a student’s cost of attendance, the student’s aid index (as determined by the FAFSA), and the length of the program. Awards are unlikely to exceed a few thousand dollars, even for students with a high amount of calculated need and a high cost of attendance. Where Workforce Pell primarily differs is on the program side—it lowers existing clock hour and week requirements (to between 150 and 599 clock hours and eight to 15 weeks, respectively) and adds additional accountability metrics in order for a program to gain and retain eligibility.
The biggest difference between the existing Pell Grant program and a Workforce Pell Grant is the process and metrics for becoming an eligible program. The reason Congress decided to include additional outcomes standards and thresholds is that shorter-term programs can have mixed results for students. The goal was to align Workforce Pell with the highest-performing short-term programs offered by institutions of higher education to ensure that students receiving aid were likely to complete the program and get a job. Hence, there are a number of additional metrics that will apply for initial program approval, as well as continued approval. Those metrics are outlined in the table below.
As part of the Workforce Pell implementation process, the negotiated rulemaking committee that met in December 2025 ironed out details and regulations around how definitions, metrics, and approval processes will be applied. The committee came to consensus, meaning that there’s likely a good snapshot of the framework for implementation, but there may be some additional changes before the final rule.
One of the biggest takeaways from the regulations is that there will likely be an outsized role for states and governors’ offices in approving Workforce Pell programs. Another is that they will have some flexibility in establishing those eligibility frameworks and processes. Having Congress give this much authority to states is a bit unusual for a federal student aid program, and there really isn’t an existing road map for this type of effort. Essentially, states will develop their own processes without needing prior approval from the U.S. Department of Education, and they will then certify programs based on federal requirements. Then the department will approve or deny the states’ programs. At this point, there is no proposed regulation or statutory language that would prevent states from augmenting these requirements with additional metrics to better support alignment with other programs and state goals around credentials of value.
This table provides detailed descriptions of each of the Workforce Pell Grant program’s metrics and requirements.
| Program Metric | Description1 |
|---|---|
| Program is provided by a Title IV eligible institution of higher education | Awards may only be given to students enrolled in eligible programs at Title IV eligible institutions. However, an eligible institution may enter into a written agreement (per 34 CFR § 668.5) that permits an ineligible provider to offer up to 25% of the educational program. |
| Program length | Program is 150 to 599 clock hours and between 8 and 15 weeks.
(In lieu of clock hours, a program may be between 4 and 16 semester or trimester hours,
or 6 and 24 quarter hours.) During the rulemaking process, negotiators considered whether instructional weeks must occur within a consecutive 8-to-15-week timeframe. The Department of Education signaled that the weeks do not have to be consecutive, indicating intent to open eligibility for related instruction for Registered Apprenticeship programs. Additionally, the regulations clarified that correspondence courses, study abroad, and direct assessment programs are not eligible for Workforce Pell Grants. |
| Recognized postsecondary credential | Program must lead to a recognized postsecondary credential that is stackable and portable
to more than one employer. An exception exists for programs that prepare students for an
occupation with only one recognized credential (e.g., a commercial driver’s license). States must have a written policy defining stackability and portability, including documented connections to additional credentials and consideration of labor market information and employer validation. A recognized postsecondary credential includes industry-recognized certificates or certifications, Registered Apprenticeship certificates, licenses recognized by state or federal government, or associate’s or bachelor’s degrees. |
| High-skill, high-wage, or in-demand | Determined through the state certification process. “High-skill” has the same meaning as under
the Perkins Career and Technical Education Act. “In-demand” includes assessments of current
and future economic impact and job growth. States must maintain a public list of in-demand sectors and occupations and update it every two years in alignment with WIOA state plans. |
| Employer hiring alignment | Part of the state certification process. States must establish a written policy assessing whether program competencies align with employer needs in high-skill, high-wage, or in-demand sectors, incorporating direct employer input. |
| Credit articulation | Applies to all programs, including noncredit. States must ensure program completers receive academic credit applicable toward an additional certificate or degree, accepted by one or more institutions. |
| Program existence | Program must have existed for at least one year prior to state approval, meeting all state certification metrics during that period. |
| Completion rate | Program must meet a 70% completion rate within 150% of normal time to completion for a full year prior to certification. The U.S. Secretary of Education may waive some or all requirements if an alternative process is developed. |
| Job placement rate | Programs must meet a 70% placement rate for a full year prior to approval. For award years 2026–27 through 2028–29, placement is defined as employment in any job two quarters after exit. Beginning in 2029–30, placement must be in a related occupation within 180 days of completion, requiring SOC code reporting. Waivers may apply. |
| Value-added earnings | A retroactive metric assessing cohorts of at least 30 completers over multiple award years. Median regional earnings minus 150% of the federal poverty line must exceed published tuition and fees. States must also consider cost and earnings potential during certification.2 |
| Bilateral agreements | States may enter bilateral agreements allowing programs to serve students across state lines, ensuring programs are high-skill, high-wage, or in-demand in either state and requiring data sharing. |
| Program expiration | Approval length is tied to an institution’s Program Participation Agreement (PPA). Programs must be recertified prior to PPA expiration. |
| Losing and regaining eligibility | Programs failing completion or placement metrics must wait two years before reapplying. Programs decertified by a governor may reapply, and those failing value-added earnings may regain eligibility by demonstrating compliance. |
1 Insights presume that the negotiated rulemaking consensus reached on December 12, 2025,
will be upheld in the final rule.
2 During negotiated rulemaking, the Department of Education requested additional time to
review cost and earnings considerations, though the language received a consensus vote.
Under the law, the U.S. Department of Education can technically begin providing Workforce Pell Grants to students starting on July 1, 2026. In reality, the process may take longer. In fact, the Department of Education’s lead negotiator in developing Workforce Pell regulations acknowledged that this may take additional time. However, the department is committed to getting the approval process up and running during the 2026-27 award year, according to Inside Higher Ed.
While states and other stakeholders can start thinking about and planning for implementation, they will still need additional information and guidance from the U.S. Department of Education to move forward. Here are a few key areas that stakeholders should keep track of in the coming months:
Ultimately, this is a rather short window in which to implement a new process for financial aid eligibility, and the current framework relies on state-level decision-making in a way that is a bit unprecedented. JFF will continue to provide you with information, insights, and analysis as updates arise.
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