Eligibility & Certification
Eligible Providers
To be eligible for Workforce Pell, a program must be offered by an institution of higher education approved by ED to administer Title IV student aid. Independent training entities, employers, and other non-traditional providers will not be eligible, but in some instances could partner with an eligible institution.
Additionally, the regulation prohibits eligible institutions from offering an eligible workforce program if they have been subject to any suspension, emergency action, or termination of programs during the five years preceding the date of the determination.
Partnering with a Non-Title IV Eligible Provider: An eligible institution may contract out a portion of the eligible workforce program to an unaccredited or ineligible provider, but no more than 25% of the program can be offered by the ineligible entity. That flexibility is expanded to up to 49% for the related technical instruction (RTI) of a Registered Apprenticeship program (only the RTI portion of a Registered Apprenticeship program can qualify for Workforce Pell).
Program Length and Other Restrictions
A program is an eligible workforce program if the Secretary of Education determines that it meets the following requirements. It is an undergraduate program that:
- Is a minimum of 8 weeks, but less than 15 weeks of instruction;
- Is at least 150 clock hours but less than 600 clock hours; at least 4 but less than 16 semester or trimester hours; or at least 6 but less than 24 quarter hours; and
- Is not offered using correspondence courses, coursework that takes place as part of a study abroad program; or credit or clock hour equivalencies that are part of a direct assessment program.
Programs must meet both the clock/credit hour requirements and the week requirements. This is statutory, and there are no exceptions. However, the regulation clarifies that a program does not have to be offered in sequential weeks. This flexibility is particularly important for Registered Apprenticeship programs, which may offer related technical instruction (RTI) at various points throughout the program.
Registered Apprenticeship: The regulation specifically mentions Registered Apprenticeship as potentially eligible for Workforce Pell; however, only the related technical instruction (i.e., classroom portion) would be eligible for aid to cover the cost of attendance. The application of the required metrics for RTI is somewhat more complex and may ultimately receive additional guidance from ED. Based on the regulations, certain requirements would be waived—for example, the program would not have to demonstrate that it is aligned with the hiring requirements of employers, and would automatically meet the requirement of being a high-wage, high-skill, or in-demand sector or occupation. However, other requirements, such as completion rate, placement rate, and VAE would still apply. Additionally, the RTI would have to be primarily provided by a Title IV eligible institution of higher education, with the option to contract with a non-eligible provider to deliver up to 49% of the instruction.
Certification by the Governor
The regulation requires that the governor submit a certification for each program meeting state approval for Workforce Pell to the U.S. Secretary of Education. ED has stated that it will be providing a standard certification template to states prior to July 1, 2026. Based on information provided in the final Rule, the certification template will likely require the following information:
- The name of the program.
- The 6-digit Classification of Instructional Programs (CIP) Code of the program.
- The Standard Occupational Classification (SOC) code(s) for the occupation(s) for which the program prepares individuals for employment.
- A signed statement that the program was approved by the governor and that the program currently meets and has met for the 12 months immediately preceding the certification, the requirements described in §690.93(a). Those requirements include that the eligible workforce program:
• provides an education aligned with the requirements of high-skill, high-wage, or in-demand industry sections or occupations,
• meets the hiring needs of employers,
• leads to a recognized postsecondary credential that is stackable and portable (or prepares students for employment for which there is only one recognized postsecondary credential), and
• ensures that a student receives academic credit for the program for at least one certificate or degree program at one or more eligible institutions. - The date the eligible workforce program was approved.
- If applicable, a certification that the state determined that the program meets the alternative completion and placement standards. (This is primarily for the 2026-2027, 2027-2028, and 2028-2029 award years where states are directed to use administrative data to verify these metrics).
- An agreement that, upon request of the U.S. Secretary of Education or Secretary of Labor, the governor will make available to the Secretary of Education and Secretary of Labor documentation of its process for making the determination whether a workforce program meets the standards of high-skill, high-wage, or in-demand industry sections or occupations, meets the hiring needs of employers, leads to a recognized postsecondary credential that is stackable and portable (or prepares students for employment for which there is only one recognized postsecondary credential), and ensures that a student receives academic credit for the program for at least one certificate or degree program at one or more eligible institutions.
- An agreement that the governor will inform ED and DOL and the eligible institution within 15 calendar days of its final decision to withdraw approval of the eligible workforce program.
- A certification that the governor takes into consideration the cost of the program and the anticipated wages of the industry or occupation prior to the initial determination of the program’s value-added earnings.
- Other information as may be required by the Secretary of Education or Secretary of Labor.
Recertification: Program approval does not last in perpetuity. State programmatic approval expires at the same time as an institution’s program participation agreement. Once certified by the state and subsequently approved by ED, programs will not only have to demonstrate that they continue to meet standards for completion rate, placement rate, and VAE, but will also periodically require a certification of continued approval from the state. Recertification should be sought before the institution’s program participation agreement expires. It is unclear if the Department will provide a separate template for recertification.
Bilateral Agreements
The regulation addresses cross-state approval of Workforce Pell programs by briefly outlining a process for bilateral agreements. The regulation does not allow for multi-state reciprocity agreements, citing the importance of programmatic alignment with employers in the state as well as the need to assess whether a program would align with demand for certain sectors or occupations. Because agreements can be bilateral only, this may pose a significant challenge for distance education programs seeking to enroll students across multiple states. Bilateral agreements must be published publicly and demonstrate that the program seeking recognition aligns with the new state’s list for high-wage, high-skill, or in-demand sectors and occupations, as well as other metrics such as employer alignment, stackability, and credit articulation. Additionally, the states must agree to data sharing to support continued monitoring of completion and placement rate metrics.
Losing and Regaining Eligibility
In prior sections, this resource identified ways that a program can lose Workforce Pell eligibility. These include failure to meet the 70% completion rate requirement or 70% placement rate requirement during annual reporting, as well as failure to meet the requirements under value-added earnings.
Additionally, governors hold administrative discretion over the certification of Workforce Pell programs. If a governor determines a program no longer aligns with an in-demand sector, fails to meet local employer requirements, or loses its credit-transferability agreements, the governor can revoke certification, causing an immediate loss of Workforce Pell eligibility. Institutions also have the ability to withdraw their program from Workforce Pell eligibility, but may not immediately seek to reestablish eligibility.
The regulation sets forth a specific process for reestablishing eligibility. This includes:
- Two-Year Waiting Period: If a program loses eligibility due to failing the VAE test, completion rates, or placement metrics, the institution is barred from re-applying for eligibility for that specific program (or a substantially similar program) for at least two full award years.
- Corrective Tuition Restructuring: For programs that lost eligibility solely because they failed the value-added earnings metric, the institution can regain eligibility after the waiting period by demonstrating a permanent reduction in published tuition and fees to a level equal to or below the program’s calculated value-added earnings.
- Submission of a New Cohort: To regain eligibility based on completion and placement rates, the institution must look to a new cohort window, demonstrating that the program’s metrics have risen back above the 70% threshold during the required period.
- Re-Certification Cycle: Even for programs that voluntarily withdrew from eligibility, regaining eligibility is not automatic after two years. The institution must restart the application process: securing a certification from the state and subsequently receiving approval from ED.
Workforce Pell Implementation—A Beginning, Not an End
Even as states begin to check the boxes for all the elements required for Workforce Pell implementation, additional questions and complexities may surface. Ultimately, each state’s road map for Workforce Pell implementation may differ and include decisions and choice points that are specific to that state. These could include how Workforce Pell may or may not influence existing nondegree accountability or data infrastructures, interactions with other state aid programs, and investment and scaling of quality nondegree credentials and programs. Workforce Pell has the potential to change how we assess and invest in shorter-term nondegree programs, but it is unlikely to be a silver bullet in itself. It should be paired with other state strategies to boost access and outcomes for nondegree student populations. Thus, the elements and metrics outlined here are a starting point to foster the successful implementation of Workforce Pell in the near term, but should ultimately be complemented by larger-scale planning to enhance the state’s nondegree credential ecosystem as a whole.
Information in this resource is based on the legal statute establishing Workforce Pell, the regulation finalized (PDF) by the U.S. Department of Education on May 19, 2026, prior information released by the U.S. Department of Education as part of its Notice of Proposed Rulemaking (PDF), and analysis provided by Jobs for the Future (JFF).
This resource was funded by the Annie E. Casey Foundation. We thank them for their support but acknowledge that the findings and conclusions presented in this report are those of the authors alone, and do not necessarily reflect the opinions of the Foundation.