As California prepares to implement Workforce Pell, policymakers, higher education leaders, and institutions will need to understand the federal standards that define which short-term programs qualify for federal financial aid. The table below summarizes these eligibility standards, the criteria associated with each, how compliance is assessed, and which governing body has oversight over the standard’s evaluation.
Looking for the broader policy context? Read the companion blog to learn how Workforce Pell can serve as an avenue for modernizing California’s higher education and workforce systems.
| Eligibility Standard | Criteria | How It Will Be Assessed | Who Evaluates Compliance |
|---|---|---|---|
| Alignment with Workforce Needs | To qualify, programs must offer an education aligned with the requirements of high-skill, high-wage, or in-demand industry sectors or occupations and meet the hiring needs of potential employers in those sectors or occupations. | States develop a method for identifying and reviewing which occupations and industries are “high-skill,” “high-wage,” or “in-demand,” and the skills and competencies needed for those jobs and industries. This list must be reviewed at least every two years, at the same time the State Workforce Innovation and Opportunity Act Plan is developed or updated. The state must also develop a written policy for determining whether a program meets employer hiring needs in high-skill, high-wage, or in-demand sectors and occupations. This policy must incorporate direct input from employers, which can be obtained via the State Workforce Board, local workforce development boards, industry or sector partnerships, sponsors of Registered Apprenticeship programs, joint labor-management partnerships, or other methods. | States |
| Portability, Stackability, and Receipt of Credit | Programs must either:
Students who complete the short-term program must also be able to continue into a related certificate or degree program and receive academic credit that counts towards that certificate or degrees’ requirements. | The state must establish a written policy and processes to evaluate whether a program meets these requirements. | States |
| Program Length | Programs must be 8–14 weeks in length and provide 150–599 clock hours, 4–15 semester or trimester hours, or 6–23 quarter hours of instruction. They must meet these duration and clock-hour requirements for at least 12 months before an institution applies for program eligibility. | The Department reviews documentation provided by an institution to confirm that, for the 12 months before the institution applied, the program met the eligible-workforce-program length and hour requirements. | US Education Department |
| Program Completion | At least 70 percent of students must complete the program within 150 percent of the program’s normal time to completion. | From award year 2026–27 through award year 2028–29, the State assesses and certifies that at least 70 percent of students completed the program within 150 percent of normal time. The Department then evaluates the institution’s documentation to determine that the requirement has been met. From award year 2029–30 onward, institutions calculate their completion rates using the process outlined in 34 CFR 668.8 (f). The Department then evaluates the institution’s documentation to determine that the requirement has been met. | States and US Education Department |
| Job Placement | From award year 2026–27 through award year 2028–29, at least 70 percent of students must be employed in any job by the second quarter after leaving the program. From 2029–30 onward, at least 70 percent of students must be employed in either
by the second quarter after they successfully complete the program. | The institution submits a list of program completers and other information that the Governor may need. The Governor then verifies the placement rate using available administrative data, including wage records, and certifies the result. The Education Department evaluates the documentation. | States and US Education Department |
| Value Added Earnings | For each award year, a program’s total tuition and fees can’t exceed the value-added earnings of students who completed the program, received a Pell grant, and are working. Programs with value-added earnings (VAE) that are zero or negative are ineligible for Workforce Pell. A program’s VAE are calculated as the difference between:
Programs that fail the VAE test may be subject to a liability for the amount of Pell Grants disbursed to students enrolled in the program for the award year tied to the failed VAE calculation. | At least three months before an award year, the Education Department will publish the value-added earnings for eligible workforce programs for that upcoming award year. To calculate VAE, the Department will use student completion data that institutions must already report. The Department will compile a list of students who received Federal Pell Grants and completed the program during the cohort period. They will then give this list to the institution, which has up to 60 days to verify or correct this list. If the list includes at least 30 students, the Department will then obtain information on their median annual earnings from a Federal agency that maintains earnings records and use that information to calculate the program’s VAE. If fewer than 30 students completed the program during the cohort period, the Department will supplement the list with students who completed the same program during up to three preceding award years before obtaining information on median annual earnings. If the combined list still includes fewer than 30 students, the Department will not calculate VAE for the program for that award year. | US Education Department |
