[{"data":1,"prerenderedAt":1988},["ShallowReactive",2],{"home-pinned":3},[4,452,827,1058,1640],{"id":5,"title":6,"body":7,"description":422,"extension":423,"meta":424,"navigation":425,"path":426,"pillar":427,"pinned":425,"publishedDate":428,"readTime":429,"section":430,"seo":431,"sources":432,"stem":445,"tags":446,"updatedDate":428,"__hash__":451},"library\u002Flibrary\u002Fworkforce-pell\u002Fwhat-is-workforce-pell.md","What Is Workforce Pell? The Short-Term Pell Grant, Explained",{"type":8,"value":9,"toc":410},"minimark",[10,27,36,41,68,79,83,86,117,124,128,146,156,189,196,200,223,234,238,241,255,258,262,265,275,289,292,296,370,374],[11,12,13,14,18,19,22,23,26],"p",{},"Workforce Pell is a new category of federal Pell Grant that, for the first time, funds short-term workforce training programs — programs of ",[15,16,17],"strong",{},"150 to 599 clock hours"," delivered over ",[15,20,21],{},"at least 8 but less than 15 weeks",". It took effect ",[15,24,25],{},"July 1, 2026"," (award year 2026–27), and applications for program approval opened the same day.",[11,28,29,30,35],{},"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 ",[31,32,34],"a",{"href":33},"\u002Flibrary\u002Fworkforce-pell\u002Fthe-70-70-rule-explained","70\u002F70 rule",".",[37,38,40],"h2",{"id":39},"where-it-comes-from","Where it comes from",[11,42,43,44,47,48,51,52,55,56,59,60,63,64,67],{},"Workforce Pell Grants were created by the ",[15,45,46],{},"Working Families Tax Cuts Act"," — the 2025 budget reconciliation law (H.R. 1), enacted as ",[15,49,50],{},"P.L. 119-21"," — signed into law on ",[15,53,54],{},"July 4, 2025",". The operative provision is ",[15,57,58],{},"§ 83002",", which adds a new ",[15,61,62],{},"HEA § 401(k)"," (the Workforce Pell Grant program itself) and ",[15,65,66],{},"HEA § 481(b)(3)"," (the definition of an eligible workforce program).",[11,69,70,71,74,75,78],{},"The Department of Education implemented the statute through rulemaking: a Notice of Proposed Rulemaking on March 9, 2026, and a ",[15,72,73],{},"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 ",[15,76,77],{},"subpart H of 34 CFR part 690",". That final rule is the controlling text for everything on this site.",[37,80,82],{"id":81},"what-it-funds","What it funds",[11,84,85],{},"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:",[87,88,89,99,110],"ul",{},[90,91,92,93,96,97],"li",{},"Run ",[15,94,95],{},"150–599 clock hours"," over ",[15,98,21],{},[90,100,101,102,105,106,109],{},"Lead to a ",[15,103,104],{},"recognized postsecondary credential"," that is ",[15,107,108],{},"stackable"," toward higher-level, for-credit programs",[90,111,112,113,116],{},"Prepare students for ",[15,114,115],{},"high-skill, high-wage, or in-demand occupations",", as identified by the state governor with the state workforce board",[11,118,119,120,35],{},"Correspondence programs are excluded, and distance education offered across state lines may require bilateral agreements between states — see ",[31,121,123],{"href":122},"\u002Flibrary\u002Fworkforce-pell\u002Fgovernor-certification-and-ed-approval","Governor Certification and ED Approval",[37,125,127],{"id":126},"who-qualifies","Who qualifies",[11,129,130,133,134,137,138,141,142,145],{},[15,131,132],{},"Students."," Workforce Pell recipients are Pell-eligible students — the same need-based framework as traditional Pell, applied through the ordinary FAFSA. COD returns a ",[15,135,136],{},"\"Workforce Pell Eligible\" indicator"," on the student record; there is no separate student application. Two eligibility points surprise people. First, ",[15,139,140],{},"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 ",[15,143,144],{},"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.",[11,147,148,151,152,155],{},[15,149,150],{},"Programs."," This is where the real gatekeeping happens. Approval is ",[15,153,154],{},"per program, not per institution",". Each program must clear five gates:",[157,158,159,162,165,168,175],"ol",{},[90,160,161],{},"The length band (150–599 clock hours, 8 to less-than-15 weeks)",[90,163,164],{},"A stackable, recognized postsecondary credential",[90,166,167],{},"Governor-certified occupation alignment",[90,169,170,171,174],{},"At least ",[15,172,173],{},"1 year"," of operating history at an accredited institution, with no suspension, emergency action, or program termination in the previous 5 years",[90,176,177,178,181,182,185,186,188],{},"The ",[15,179,180],{},"70\u002F70 performance tests"," — a ",[15,183,184],{},"70 percent"," completion rate and a ",[15,187,184],{}," job placement rate — plus, beginning award year 2030–31, a value-added earnings test",[11,190,191,192,35],{},"The full checklist, gate by gate, is in ",[31,193,195],{"href":194},"\u002Flibrary\u002Fworkforce-pell\u002Fprogram-eligibility-checklist","Workforce Pell Program Eligibility: The Complete Checklist",[37,197,199],{"id":198},"how-awards-are-sized-and-the-loan-catch","How awards are sized — and the loan catch",[11,201,202,203,206,207,210,211,214,215,218,219,222],{},"Awards follow the regular Pell schedule, prorated for program length under ",[15,204,205],{},"Pell formulas 3 or 4",", and must be paid in ",[15,208,209],{},"at least two disbursements",". For award year 2026–27, the Pell maximum is ",[15,212,213],{},"$7,395"," and the minimum is ",[15,216,217],{},"$740",". ED's regulatory impact analysis estimates the average Workforce Pell award at roughly ",[15,220,221],{},"$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.",[11,224,225,226,229,230,233],{},"The catch: Workforce Pell is ",[15,227,228],{},"Pell-only",". Students enrolled in a workforce program receive ",[15,231,232],{},"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.",[37,235,237],{"id":236},"the-two-step-approval-process","The two-step approval process",[11,239,240],{},"A program does not become eligible just by meeting the criteria. It must be:",[157,242,243,249],{},[90,244,245,248],{},[15,246,247],{},"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",[90,250,251,254],{},[15,252,253],{},"Approved by the Department of Education",", which verifies the federal requirements: hours, weeks, completion, and placement",[11,256,257],{},"Applications have been open since July 1, 2026. If your program is a candidate, the process starts at your state, not at ED.",[37,259,261],{"id":260},"why-it-matters-for-trade-and-technical-schools","Why it matters for trade and technical schools",[11,263,264],{},"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.",[11,266,267,268,274],{},"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 — ",[31,269,273],{"href":270,"rel":271},"https:\u002F\u002Fdrivertrack.ai",[272],"nofollow","DriverTrack"," is the school-management platform built for CDL programs navigating this.",[11,276,277,278,280,281,283,284,288],{},"The trade-off is accountability. Every approved program must continuously demonstrate that ",[15,279,184],{}," of participants complete within 150% of normal time and ",[15,282,184],{}," of completers are employed in the second quarter after exit. A program that falls below either threshold loses eligibility and faces a ",[31,285,287],{"href":286},"\u002Flibrary\u002Fworkforce-pell\u002Flosing-eligibility-two-year-bar","two-year bar"," on re-establishing it or a substantially similar program.",[11,290,291],{},"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.",[37,293,295],{"id":294},"the-timeline-at-a-glance","The timeline at a glance",[297,298,299,312],"table",{},[300,301,302],"thead",{},[303,304,305,309],"tr",{},[306,307,308],"th",{},"Date",[306,310,311],{},"Event",[313,314,315,323,331,339,346,354,362],"tbody",{},[303,316,317,320],{},[318,319,54],"td",{},[318,321,322],{},"Working Families Tax Cuts Act signed (statute created)",[303,324,325,328],{},[318,326,327],{},"March 9, 2026",[318,329,330],{},"Notice of Proposed Rulemaking",[303,332,333,336],{},[318,334,335],{},"May 19, 2026",[318,337,338],{},"Final Rule published (91 FR 29254)",[303,340,341,343],{},[318,342,25],{},[318,344,345],{},"Statutory start of award year 2026–27; applications open; ED permits early implementation",[303,347,348,351],{},[318,349,350],{},"July 20, 2026",[318,352,353],{},"Final rule effective date",[303,355,356,359],{},[318,357,358],{},"Award year 2029–30",[318,360,361],{},"Placement test tightens to occupation-aligned employment; first Secretary value-added earnings determinations",[303,363,364,367],{},[318,365,366],{},"Award year 2030–31",[318,368,369],{},"Value-added earnings cap first applies to published tuition and fees",[37,371,373],{"id":372},"what-to-do-now","What to do now",[157,375,376,382,388,394,404],{},[90,377,378,381],{},[15,379,380],{},"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.",[90,383,384,387],{},[15,385,386],{},"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.",[90,389,390,393],{},[15,391,392],{},"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.",[90,395,396,399,400,403],{},[15,397,398],{},"Start measuring your 70\u002F70 numbers today."," You will need defensible completion and placement rates before you apply — read ",[31,401,402],{"href":33},"The 70\u002F70 Rule Explained"," next.",[90,405,406,409],{},[15,407,408],{},"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":411,"searchDepth":412,"depth":412,"links":413},"",2,[414,415,416,417,418,419,420,421],{"id":39,"depth":412,"text":40},{"id":81,"depth":412,"text":82},{"id":126,"depth":412,"text":127},{"id":198,"depth":412,"text":199},{"id":236,"depth":412,"text":237},{"id":260,"depth":412,"text":261},{"id":294,"depth":412,"text":295},{"id":372,"depth":412,"text":373},"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.","md",{},true,"\u002Flibrary\u002Fworkforce-pell\u002Fwhat-is-workforce-pell","workforce-pell","2026-07-19",7,"1.1",{"title":6,"description":422},[433,436,439,442],{"label":434,"url":435},"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":437,"url":438},"P.L. 119-21, § 83002 (statute text, govinfo)","https:\u002F\u002Fwww.govinfo.gov\u002Fcontent\u002Fpkg\u002FPLAW-119publ21\u002Fhtml\u002FPLAW-119publ21.htm",{"label":440,"url":441},"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":443,"url":444},"ED Workforce Pell final rule fact sheet","https:\u002F\u002Fwww.ed.gov\u002Fmedia\u002Fdocument\u002Fworkforce-pell-grant-final-rule-fact-sheet-114075.pdf","library\u002Fworkforce-pell\u002Fwhat-is-workforce-pell",[447,448,449,450],"workforce pell","short-term pell","pell grant","program eligibility","OjaZlsEgmMQQ1NOq2wgo9PpgfhnRQsIdag4kfSeSJbM",{"id":453,"title":454,"body":455,"description":809,"extension":423,"meta":810,"navigation":425,"path":33,"pillar":427,"pinned":425,"publishedDate":428,"readTime":811,"section":812,"seo":813,"sources":814,"stem":821,"tags":822,"updatedDate":428,"__hash__":826},"library\u002Flibrary\u002Fworkforce-pell\u002Fthe-70-70-rule-explained.md","The 70\u002F70 Rule Explained: Completion and Placement Thresholds for Workforce Pell",{"type":8,"value":456,"toc":800},[457,466,491,495,500,503,506,527,534,538,548,563,566,587,594,598,613,617,620,705,708,722,725,729,740,747,751,759,766,768],[11,458,459,460,462,463,465],{},"The 70\u002F70 rule is the performance backbone of the Workforce Pell Grant program: to gain and keep eligibility, a program must show that ",[15,461,184],{}," of its participants complete on time and ",[15,464,184],{}," 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.",[11,467,468,469,472,473,476,477,479,480,482,483,486,487,490],{},"The rule comes from the Working Families Tax Cuts Act (",[15,470,471],{},"P.L. 119-21, § 83002",", signed July 4, 2025) as implemented by ED's final rule of May 19, 2026 (",[15,474,475],{},"91 FR 29254","), which creates a new ",[15,478,77],{},". Watch the dates: ",[15,481,25],{}," is the statutory start of award year 2026–27, but the final rule's formal ",[15,484,485],{},"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 ",[31,488,489],{"href":426},"Workforce Pell",", learn this rule — it is the ongoing test, not a one-time application hurdle.",[37,492,494],{"id":493},"test-1-the-70-completion-rate","Test 1: The 70% completion rate",[11,496,497],{},[15,498,499],{},"At least 70 percent of program participants must complete the program within 150% of the normal time to completion.",[11,501,502],{},"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.",[11,504,505],{},"Who calculates it depends on the year:",[87,507,508,518],{},[90,509,510,513,514,517],{},[15,511,512],{},"Transitional years (2026–27 through 2028–29):"," the ",[15,515,516],{},"Governor determines and verifies"," the completion rate. States may set their own data systems and verification methodology.",[90,519,520,523,524,35],{},[15,521,522],{},"After 2028–29:"," the rate is calculated under federal methodology — the clock-hour completion calculation of ",[15,525,526],{},"34 CFR 668.8(f)",[11,528,529,530,35],{},"The full mechanics, with a worked example, are in ",[31,531,533],{"href":532},"\u002Flibrary\u002Fworkforce-pell\u002Fcompletion-rate-calculation","How the Completion Rate Is Calculated",[37,535,537],{"id":536},"test-2-the-70-job-placement-rate","Test 2: The 70% job placement rate",[11,539,540,543,544,547],{},[15,541,542],{},"At least 70 percent of completers must be employed during the second calendar quarter after program exit"," (",[15,545,546],{},"34 CFR 690.94",").",[11,549,550,551,554,555,558,559,562],{},"One correction worth internalizing, because it is the most repeated error in coverage of this rule — call it the ",[15,552,553],{},"\"180-day myth.\""," The statute says placement is \"measured 180 days after\" completion, but the binding regulation, 34 CFR 690.94, measures employment ",[15,556,557],{},"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 ",[15,560,561],{},"October through December"," — not \"day 180.\" A tracking calendar built on a 180-day count will check the wrong window.",[11,564,565],{},"What counts as \"employed\" tightens over time:",[87,567,568,578],{},[90,569,570,573,574,577],{},[15,571,572],{},"Phase 1 (award years 2026–27 through 2028–29):"," ",[15,575,576],{},"any employment"," in that window counts.",[90,579,580,583,584,35],{},[15,581,582],{},"Phase 2 (starting award year 2029–30):"," employment must be ",[15,585,586],{},"in the occupation the program prepared the student for, or a similar high-skill, high-wage, or in-demand occupation",[11,588,589,590,35],{},"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 ",[31,591,593],{"href":592},"\u002Flibrary\u002Fworkforce-pell\u002Fjob-placement-rate-calculation","How the Job Placement Rate Is Calculated",[37,595,597],{"id":596},"the-four-allowable-exclusions","The four allowable exclusions",[11,599,600,601,604,605,608,609,612],{},"Both rates permit exactly ",[15,602,603],{},"four"," categories of students to be excluded — and the exclusion applies to the numerator ",[15,606,607],{},"and"," the denominator: students who (1) died; (2) suffered a totally disabling condition; (3) were called to military service for ",[15,610,611],{},"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.",[37,614,616],{"id":615},"the-phase-in-timeline","The phase-in timeline",[11,618,619],{},"The 70\u002F70 rule does not arrive all at once. Three distinct regimes phase in:",[297,621,622,638],{},[300,623,624],{},[303,625,626,629,632,635],{},[306,627,628],{},"Award year",[306,630,631],{},"Completion test",[306,633,634],{},"Placement test",[306,636,637],{},"Earnings test",[313,639,640,663,684],{},[303,641,642,645,652,660],{},[318,643,644],{},"2026–27 through 2028–29",[318,646,647,648,651],{},"≥ ",[15,649,650],{},"70%"," within 150% of normal time — Governor-determined\u002Fverified methodology",[318,653,647,654,656,657,659],{},[15,655,650],{}," employed in second quarter after exit — ",[15,658,576],{}," counts",[318,661,662],{},"Not yet in effect",[303,664,665,668,673,682],{},[318,666,667],{},"2029–30",[318,669,647,670,672],{},[15,671,650],{}," — federal clock-hour methodology (34 CFR 668.8(f))",[318,674,647,675,677,678,681],{},[15,676,650],{}," — employment must be ",[15,679,680],{},"occupation-aligned by SOC code"," (the trained-for occupation or a similar high-skill, high-wage, or in-demand occupation)",[318,683,662],{},[303,685,686,689,694,699],{},[318,687,688],{},"2030–31 and later",[318,690,647,691,693],{},[15,692,650],{}," — federal methodology",[318,695,647,696,698],{},[15,697,650],{}," — occupation-aligned",[318,700,701,704],{},[15,702,703],{},"Value-added earnings test begins:"," published tuition + fees must not exceed completers' median earnings minus 150% of the single-person federal poverty line",[11,706,707],{},"Two practical consequences of this table:",[157,709,710,716],{},[90,711,712,715],{},[15,713,714],{},"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.",[90,717,718,721],{},[15,719,720],{},"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.",[11,723,724],{},"The third metric — the earnings test — gets its own treatment in the Value-Added Earnings Test article (section 1.5 of this handbook).",[37,726,728],{"id":727},"what-failing-costs-you","What failing costs you",[11,730,731,732,735,736,739],{},"A program that fails either 70% threshold ",[15,733,734],{},"loses Workforce Pell eligibility for that program",". The institution then ",[15,737,738],{},"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.",[11,741,742,743,746],{},"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 ",[31,744,745],{"href":286},"Falling Below 70\u002F70: Losing Eligibility and the Two-Year Bar"," for the failure mechanics and early-warning practices.",[37,748,750],{"id":749},"running-your-own-numbers","Running your own numbers",[11,752,753,754,758],{},"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 ",[31,755,757],{"href":756},"\u002Ftools\u002F70-70-report","70\u002F70 Report Generator"," to see where your programs stand and what documentation gaps you have.",[11,760,761,762,765],{},"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 — ",[31,763,273],{"href":270,"rel":764},[272]," is the school-management platform built to track this data for CDL programs.",[37,767,373],{"id":372},[157,769,770,776,782,788,794],{},[90,771,772,775],{},[15,773,774],{},"Compute both rates for every candidate program today",", using your best available data — before your state or ED does it for you.",[90,777,778,781],{},[15,779,780],{},"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.",[90,783,784,787],{},[15,785,786],{},"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.",[90,789,790,793],{},[15,791,792],{},"Start capturing occupation of employment now."," The 2029–30 shift to occupation-aligned placement will punish programs that only tracked \"employed yes\u002Fno.\"",[90,795,796,799],{},[15,797,798],{},"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":411,"searchDepth":412,"depth":412,"links":801},[802,803,804,805,806,807,808],{"id":493,"depth":412,"text":494},{"id":536,"depth":412,"text":537},{"id":596,"depth":412,"text":597},{"id":615,"depth":412,"text":616},{"id":727,"depth":412,"text":728},{"id":749,"depth":412,"text":750},{"id":372,"depth":412,"text":373},"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":454,"description":809},[815,816,817,818],{"label":434,"url":435},{"label":437,"url":438},{"label":443,"url":444},{"label":819,"url":820},"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",[34,447,823,824,825],"completion rate","job placement rate","compliance","CUDaSnuslsdQytRzSidPaM-_sS5EutJ8nEkXp-It2Ws",{"id":828,"title":829,"body":830,"description":1040,"extension":423,"meta":1041,"navigation":425,"path":1042,"pillar":1043,"pinned":425,"publishedDate":428,"readTime":1044,"section":1045,"seo":1046,"sources":1047,"stem":1051,"tags":1052,"updatedDate":1056,"__hash__":1057},"library\u002Flibrary\u002Fpell-fundamentals\u002Fpell-for-clock-hour-programs.md","Pell Grants at Clock-Hour Schools: How the Basics Differ",{"type":8,"value":831,"toc":1033},[832,835,839,842,876,879,882,886,893,896,907,911,914,933,936,944,948,951,993,996,998],[11,833,834],{},"Clock-hour schools administer the same Federal Pell Grant program as every other institution, but almost every mechanic underneath — the academic year, the payment period, the award calculation — runs on different plumbing. If your staff learned Pell at a credit-hour college, the habits they bring with them are the single most common source of findings at trade and technical schools. This article covers the ground rules; the rest of this chapter goes deeper on each one.",[37,836,838],{"id":837},"the-clock-hour-academic-year-900-hours-and-26-weeks","The clock-hour academic year: 900 hours AND 26 weeks",[11,840,841],{},"Every institution must define an academic year for each program. For a clock-hour program, the regulatory minimums are:",[297,843,844,854],{},[300,845,846],{},[303,847,848,851],{},[306,849,850],{},"Measure",[306,852,853],{},"Minimum",[313,855,856,866],{},[303,857,858,861],{},[318,859,860],{},"Clock hours",[318,862,863],{},[15,864,865],{},"900",[303,867,868,871],{},[318,869,870],{},"Weeks of instructional time",[318,872,873],{},[15,874,875],{},"26",[11,877,878],{},"Both minimums apply together. A program's defined academic year cannot be shorter than 900 clock hours or shorter than 26 weeks of instructional time, and a \"week of instructional time\" is a week in which at least one day of regularly scheduled instruction occurs — not simply a calendar week. Holidays, breaks, and weeks with no scheduled class do not count.",[11,880,881],{},"Why it matters: the academic year is the denominator in the Pell calculation. Get it wrong and every award built on it is wrong.",[37,883,885],{"id":884},"payment-periods-run-on-hours-and-weeks-not-dates","Payment periods run on hours and weeks, not dates",[11,887,888,889,892],{},"Credit-hour schools disburse by term. Clock-hour schools disburse by ",[15,890,891],{},"payment period",", and a payment period is defined by hours and weeks — never by calendar dates.",[11,894,895],{},"For a program that is one academic year or shorter, there are generally two payment periods, each covering half the clock hours and half the weeks of instructional time in the program. For longer programs, payment periods continue in academic-year-sized increments, with the remainder split per the FSA Handbook rules.",[11,897,898,899,902,903,35],{},"The critical operational consequence: a student does not reach the second payment period on a scheduled date. The student reaches it by ",[15,900,901],{},"successfully completing both the clock hours and the weeks of instructional time"," in the first payment period. A student who is behind schedule is paid later; a school that pays on the calendar anyway has made an improper disbursement. This is the most common clock-hour audit finding, and it is covered in detail in ",[31,904,906],{"href":905},"\u002Flibrary\u002Fpell-fundamentals\u002Fpayment-periods-disbursements","Payment Periods and Disbursements",[37,908,910],{"id":909},"how-the-award-is-calculated-proration-is-the-default","How the award is calculated: proration is the default",[11,912,913],{},"At a credit-hour school, a full-time student in a standard term generally receives the scheduled award for the year in even term-sized pieces. At a clock-hour school, the payment for a payment period is prorated against the academic year using the FSA Handbook's clock-hour formula. Conceptually:",[157,915,916,919,926],{},[90,917,918],{},"Take the student's scheduled annual award (from the Pell payment schedule for the student's SAI\u002Feligibility).",[90,920,921,922,925],{},"Multiply by the fraction of an academic year the payment period represents — measured in ",[15,923,924],{},"both"," clock hours (hours in the payment period ÷ hours in the academic year, with 900 as the floor denominator) and weeks (weeks in the payment period ÷ weeks in the academic year, with 26 as the floor denominator).",[90,927,928,929,932],{},"The formula uses the lesser of the applicable fractions, so a program that is short on either hours ",[15,930,931],{},"or"," weeks produces a smaller payment.",[11,934,935],{},"The practical upshot: a 720-hour program delivered over 24 weeks does not generate a full annual Pell award, no matter how it is packaged. Programs shorter than an academic year in either measure always produce prorated awards. Run the exact steps in the current FSA Handbook, Volume 3, rather than from memory — the formula's ordering matters.",[11,937,938,939,943],{},"Note also that \"full-time\" and \"three-quarter-time\" enrollment statuses do essentially no work in clock-hour Pell. Payment is driven by hours and weeks in the payment period, not enrollment intensity. See ",[31,940,942],{"href":941},"\u002Flibrary\u002Fpell-fundamentals\u002Fpell-recalculation-census","Pell Recalculation and Enrollment Census Policies"," for what that means when a student's circumstances change.",[37,945,947],{"id":946},"where-clock-hour-schools-trip-up","Where clock-hour schools trip up",[11,949,950],{},"The recurring failure patterns are worth naming plainly:",[87,952,953,959,965,971,987],{},[90,954,955,958],{},[15,956,957],{},"Paying on the calendar."," Disbursing the second payment period on a projected date instead of verifying completed hours and weeks. Progress varies by student; disbursement timing must too.",[90,960,961,964],{},[15,962,963],{},"Forgetting the weeks test."," Tracking hours meticulously but never checking weeks of instructional time — a student can complete the hours early and still not have completed the weeks.",[90,966,967,970],{},[15,968,969],{},"A defined academic year that doesn't match reality."," The catalog says 900 hours\u002F26 weeks, but the actual schedule delivers 26 calendar weeks including two holiday weeks with no instruction — leaving only 24 weeks of instructional time.",[90,972,973,976,977,981,982,986],{},[15,974,975],{},"Attendance records that can't support the numbers."," Every hour you pay on must be traceable to attendance documentation. Weak attendance records undermine disbursements, ",[31,978,980],{"href":979},"\u002Flibrary\u002Fpell-fundamentals\u002Fr2t4-clock-hour-withdrawals","R2T4 calculations",", and ",[31,983,985],{"href":984},"\u002Flibrary\u002Fpell-fundamentals\u002Fsatisfactory-academic-progress","SAP determinations"," simultaneously.",[90,988,989,992],{},[15,990,991],{},"Confusing clock hours with credit hours after a conversion."," Programs subject to clock-to-credit conversion must still track clock hours for the purposes that require them.",[11,994,995],{},"Each of these produces liabilities that compound across every affected student, which is why clock-hour findings tend to be expensive relative to school size.",[37,997,373],{"id":372},[157,999,1000,1006,1015,1021,1027],{},[90,1001,1002,1005],{},[15,1003,1004],{},"Pull your academic year definition"," for each Pell-eligible program and verify it meets both the 900 clock-hour and 26-week minimums against the actual delivered schedule, not the catalog.",[90,1007,1008,1011,1012,1014],{},[15,1009,1010],{},"Map each program's payment periods"," in hours and weeks, and confirm your SIS or spreadsheet gates the second disbursement on completed hours ",[15,1013,607],{}," completed weeks.",[90,1016,1017,1020],{},[15,1018,1019],{},"Sample five recent disbursements"," and re-derive each from attendance records: hours completed, weeks completed, proration math. Document the check.",[90,1022,1023,1026],{},[15,1024,1025],{},"Cross-train staff"," who came from credit-hour institutions on the differences in this article — make the FSA Handbook Volume 3 clock-hour sections required reading.",[90,1028,1029,1032],{},[15,1030,1031],{},"Fix the definitions before the next award year starts"," — mid-year changes to academic year definitions create recalculation work you do not want.",{"title":411,"searchDepth":412,"depth":412,"links":1034},[1035,1036,1037,1038,1039],{"id":837,"depth":412,"text":838},{"id":884,"depth":412,"text":885},{"id":909,"depth":412,"text":910},{"id":946,"depth":412,"text":947},{"id":372,"depth":412,"text":373},"How Pell Grants work at clock-hour schools: the 900-hour\u002F26-week academic year, payment periods measured in hours and weeks, and proration rules.",{},"\u002Flibrary\u002Fpell-fundamentals\u002Fpell-for-clock-hour-programs","pell-fundamentals",6,"2.1",{"title":829,"description":1040},[1048],{"label":1049,"url":1050},"FSA Handbook, Vol. 3 — Academic Calendars, Cost of Attendance, and Packaging","https:\u002F\u002Ffsapartners.ed.gov\u002Fknowledge-center\u002Ffsa-handbook","library\u002Fpell-fundamentals\u002Fpell-for-clock-hour-programs",[449,1053,1054,1055],"clock-hour programs","academic year","payment periods",null,"4Iyr9S_bK36iwcMcn36ikyhtk49bGnnT1fNtzGeH8Fc",{"id":1059,"title":1060,"body":1061,"description":1625,"extension":423,"meta":1626,"navigation":425,"path":1627,"pillar":1628,"pinned":425,"publishedDate":428,"readTime":429,"section":1629,"seo":1630,"sources":1631,"stem":1635,"tags":1636,"updatedDate":428,"__hash__":1639},"library\u002Flibrary\u002Fdata-playbooks\u002Fbuilding-your-cohort-file.md","Building Your 70\u002F70 Cohort File: The Minimum Data Schema",{"type":8,"value":1062,"toc":1618},[1063,1081,1084,1088,1091,1325,1352,1370,1385,1389,1410,1413,1421,1425,1484,1487,1491,1568,1575,1577,1614],[11,1064,1065,1066,1069,1070,1073,1074,1076,1077,1080],{},"Every Workforce Pell compliance question ultimately reduces to a table with one row per student. Can your program show that ",[15,1067,1068],{},"at least 70 percent"," of participants completed within ",[15,1071,1072],{},"150 percent of normal time",", and that ",[15,1075,1068],{}," of completers were employed in the ",[15,1078,1079],{},"second quarter after program exit","? If you cannot produce the row-level data behind those two rates, you cannot defend them — to your state, to your governor's certification process, or eventually under federal methodology.",[11,1082,1083],{},"This article defines the minimum schema for that table: the 70\u002F70 cohort file. Start it on day one of your first Workforce Pell cohort. Reconstructing it later from scattered systems is the single most expensive mistake schools make.",[37,1085,1087],{"id":1086},"the-minimum-schema","The minimum schema",[11,1089,1090],{},"One row per student, per program enrollment. Ten fields are non-negotiable:",[297,1092,1093,1109],{},[300,1094,1095],{},[303,1096,1097,1100,1103,1106],{},[306,1098,1099],{},"#",[306,1101,1102],{},"Field",[306,1104,1105],{},"Type",[306,1107,1108],{},"Notes",[313,1110,1111,1133,1148,1164,1180,1196,1211,1227,1266,1297],{},[303,1112,1113,1116,1122,1125],{},[318,1114,1115],{},"1",[318,1117,1118],{},[1119,1120,1121],"code",{},"student_id",[318,1123,1124],{},"string",[318,1126,1127,1128,1132],{},"Your SIS identifier. Use the same ID you use for NSLDS and ",[31,1129,1131],{"href":1130},"\u002Flibrary\u002Faudits-reporting\u002Ffvt-ge-reporting","FVT\u002FGE reporting"," so files reconcile.",[303,1134,1135,1138,1143,1145],{},[318,1136,1137],{},"2",[318,1139,1140],{},[1119,1141,1142],{},"program",[318,1144,1124],{},[318,1146,1147],{},"Program name or code, tied to a CIP code. One file per program — eligibility is per program, not per institution.",[303,1149,1150,1153,1158,1161],{},[318,1151,1152],{},"3",[318,1154,1155],{},[1119,1156,1157],{},"start_date",[318,1159,1160],{},"date (YYYY-MM-DD)",[318,1162,1163],{},"First scheduled day of attendance for this enrollment.",[303,1165,1166,1169,1174,1177],{},[318,1167,1168],{},"4",[318,1170,1171],{},[1119,1172,1173],{},"normal_completion_weeks",[318,1175,1176],{},"integer",[318,1178,1179],{},"The program's published normal time in weeks (8–14 for Workforce Pell programs, which run at least 8 but fewer than 15 weeks).",[303,1181,1182,1185,1190,1193],{},[318,1183,1184],{},"5",[318,1186,1187],{},[1119,1188,1189],{},"actual_completion_date",[318,1191,1192],{},"date or blank",[318,1194,1195],{},"Date the student completed. Blank if withdrawn or still enrolled.",[303,1197,1198,1201,1206,1208],{},[318,1199,1200],{},"6",[318,1202,1203],{},[1119,1204,1205],{},"withdrawal_date",[318,1207,1192],{},[318,1209,1210],{},"Date of withdrawal, if any. Exactly one of fields 5 and 6 is populated once the student's outcome is known.",[303,1212,1213,1216,1221,1224],{},[318,1214,1215],{},"7",[318,1217,1218],{},[1119,1219,1220],{},"exit_date",[318,1222,1223],{},"date",[318,1225,1226],{},"Date the student left the program for any reason — completion or withdrawal. This starts the placement clock.",[303,1228,1229,1232,1237,1253],{},[318,1230,1231],{},"8",[318,1233,1234],{},[1119,1235,1236],{},"employment_status_q2",[318,1238,1239,1240,1243,1244,1243,1247,1243,1250],{},"enum: ",[1119,1241,1242],{},"employed"," \u002F ",[1119,1245,1246],{},"not_employed",[1119,1248,1249],{},"unknown",[1119,1251,1252],{},"pending",[318,1254,1255,1256,1259,1260,1262,1263,1265],{},"Employment status during the ",[15,1257,1258],{},"second calendar quarter after exit"," (34 CFR 690.94). ",[1119,1261,1252],{}," until the window closes; ",[1119,1264,1249],{}," only after verification attempts are exhausted.",[303,1267,1268,1271,1276,1290],{},[318,1269,1270],{},"9",[318,1272,1273],{},[1119,1274,1275],{},"verification_source",[318,1277,1239,1278,1243,1281,1243,1284,1243,1287],{},[1119,1279,1280],{},"ui_wage_records",[1119,1282,1283],{},"employer_letter",[1119,1285,1286],{},"survey",[1119,1288,1289],{},"none",[318,1291,1292,1293,35],{},"How field 8 was verified. See ",[31,1294,1296],{"href":1295},"\u002Flibrary\u002Fdata-playbooks\u002Fverifying-employment-outcomes","verifying employment outcomes",[303,1298,1299,1302,1307,1322],{},[318,1300,1301],{},"10",[318,1303,1304],{},[1119,1305,1306],{},"exclusion",[318,1308,1239,1309,1243,1312,1243,1315,1243,1318,1321],{},[1119,1310,1311],{},"death",[1119,1313,1314],{},"disabling-condition",[1119,1316,1317],{},"military-30plus",[1119,1319,1320],{},"incarcerated",", blank otherwise",[318,1323,1324],{},"The four allowable exclusions under 34 CFR part 690, subpart H. Blank for every student who counts.",[11,1326,177,1327,1329,1330,1333,1334,1337,1338,1341,1342,1344,1345,1348,1349,1351],{},[1119,1328,1306],{}," column deserves its own rule. Under 34 CFR part 690, subpart H, exactly four circumstances let you remove a student from the 70\u002F70 math: the student ",[15,1331,1332],{},"died",", suffered a ",[15,1335,1336],{},"totally disabling condition",", was ",[15,1339,1340],{},"called to military service for more than 30 days",", or was ",[15,1343,1320],{},". An excluded student comes out of ",[15,1346,1347],{},"both the numerator and the denominator of both rates"," — completion and placement alike. Every non-blank value in this column needs an evidence file behind it (death certificate, medical documentation, military orders, incarceration record); an undocumented exclusion is an audit finding, not a judgment call. The ",[31,1350,757],{"href":756}," roster template now supports this column and applies the exclusions to both rates automatically.",[11,1353,1354,1355,1358,1359,1361,1362,1364,1365,1369],{},"A derived eleventh column is worth storing rather than recomputing: ",[1119,1356,1357],{},"deadline_150"," = ",[1119,1360,1157],{}," + (1.5 × ",[1119,1363,1173],{},") weeks. For a 12-week program, that is week 18. The ",[31,1366,1368],{"href":1367},"\u002Flibrary\u002Fdata-playbooks\u002Ftracking-completion-within-150-percent","150 percent tracking playbook"," covers the operational edge cases — leaves of absence, re-entries, transfers.",[11,1371,1372,1373,1376,1377,1380,1381,1384],{},"Beyond the per-student rows, the file (or a companion program record) must carry: the program's length in ",[15,1374,1375],{},"both weeks and clock hours"," — the two eligibility bounds run independently; the ",[15,1378,1379],{},"published tuition and fees for each award year"," — the future input to the value-added earnings test; and graduate follow-up fields — ",[15,1382,1383],{},"employer, start date, and occupation with SOC code"," — which become load-bearing when placement shifts to occupation matching after award year 2028–29.",[37,1386,1388],{"id":1387},"sample-csv-row","Sample CSV row",[1390,1391,1395],"pre",{"className":1392,"code":1393,"language":1394,"meta":411,"style":411},"language-csv shiki shiki-themes github-light github-dark","student_id,program,start_date,normal_completion_weeks,actual_completion_date,withdrawal_date,exit_date,employment_status_q2,verification_source,exclusion\nS-2027-0142,Commercial Truck Driving (CIP 49.0205),2026-09-08,12,2026-11-25,,2026-11-25,employed,ui_wage_records,\n","csv",[1119,1396,1397,1405],{"__ignoreMap":411},[1398,1399,1402],"span",{"class":1400,"line":1401},"line",1,[1398,1403,1404],{},"student_id,program,start_date,normal_completion_weeks,actual_completion_date,withdrawal_date,exit_date,employment_status_q2,verification_source,exclusion\n",[1398,1406,1407],{"class":1400,"line":412},[1398,1408,1409],{},"S-2027-0142,Commercial Truck Driving (CIP 49.0205),2026-09-08,12,2026-11-25,,2026-11-25,employed,ui_wage_records,\n",[11,1411,1412],{},"This student started September 8, completed on November 25 — comfortably inside the 18-week (150 percent) deadline — and was verified employed in the second quarter after exit via state UI wage records. That row contributes favorably to both rates.",[11,1414,1415,1420],{},[15,1416,1417,1418,35],{},"This schema matches the roster template used by the ",[31,1419,757],{"href":756}," If you maintain your cohort file in exactly these columns, you can upload it and generate both rates — and a submission-ready report — without any remapping.",[37,1422,1424],{"id":1423},"rules-that-keep-the-file-defensible","Rules that keep the file defensible",[87,1426,1427,1442,1456,1467,1478],{},[90,1428,1429,1432,1433,1437,1438,1441],{},[15,1430,1431],{},"Denominators are decided by definitions, not convenience."," The completion rate is measured over program ",[1434,1435,1436],"em",{},"participants","; the placement rate is measured over ",[1434,1439,1440],{},"completers",". Record every enrolled student — including withdrawals — or your completion denominator is wrong. Never delete a row.",[90,1443,1444,573,1447,1449,1450,1452,1453,1455],{},[15,1445,1446],{},"Dates come from source systems.",[1119,1448,1157],{}," from the enrollment agreement, ",[1119,1451,1189],{}," from the registrar's completion record, ",[1119,1454,1205],{}," from the same determination you use for R2T4. If the cohort file and the student file disagree, you have an audit problem, not just a data problem.",[90,1457,1458,1466],{},[15,1459,1460,1462,1463,1465],{},[1119,1461,1249],{}," is not ",[1119,1464,1246],{}," — but plan conservatively."," How unverified completers are treated in the rate calculation depends on your state's methodology; until confirmed, assume an unverifiable completer does not help your numerator, which is why chasing verification matters.",[90,1468,1469,1472,1473,1477],{},[15,1470,1471],{},"Snapshot it."," Freeze a dated copy of the file at each reporting milestone. The version you submitted must be reproducible years later — see ",[31,1474,1476],{"href":1475},"\u002Flibrary\u002Faudits-reporting\u002Frecords-retention","records retention"," for why the retention horizon here is longer than the Title IV three-year baseline.",[90,1479,1480,1483],{},[15,1481,1482],{},"One file per program per cohort period."," Failure consequences attach at the program level: a program that fails 70\u002F70 loses Workforce Pell eligibility, and it (or a substantially similar program) cannot be re-established for two years.",[11,1485,1486],{},"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. Your state may require additional fields (for example, wage amounts, occupation codes for the Phase 2 placement definition starting 2029–30, or demographic data). Treat this schema as the floor, and add state-required columns to the same file rather than starting a parallel one.",[37,1488,1490],{"id":1489},"where-the-data-comes-from","Where the data comes from",[297,1492,1493,1502],{},[300,1494,1495],{},[303,1496,1497,1499],{},[306,1498,1102],{},[306,1500,1501],{},"System of record",[313,1503,1504,1518,1527,1540,1551,1560],{},[303,1505,1506,1515],{},[318,1507,1508,1510,1511,1510,1513],{},[1119,1509,1121],{},", ",[1119,1512,1142],{},[1119,1514,1157],{},[318,1516,1517],{},"SIS \u002F enrollment agreement",[303,1519,1520,1524],{},[318,1521,1522],{},[1119,1523,1173],{},[318,1525,1526],{},"Program approval documents (what you certified to the governor)",[303,1528,1529,1537],{},[318,1530,1531,1510,1533,1510,1535],{},[1119,1532,1189],{},[1119,1534,1205],{},[1119,1536,1220],{},[318,1538,1539],{},"Registrar \u002F attendance system",[303,1541,1542,1548],{},[318,1543,1544,1510,1546],{},[1119,1545,1236],{},[1119,1547,1275],{},[318,1549,1550],{},"Career services \u002F state UI data match",[303,1552,1553,1557],{},[318,1554,1555],{},[1119,1556,1306],{},[318,1558,1559],{},"Registrar determination + the evidence file for each excluded student",[303,1561,1562,1565],{},[318,1563,1564],{},"Tuition\u002Ffees per award year, weeks and clock hours",[318,1566,1567],{},"Catalog \u002F program approval documents",[11,1569,1570,1571,1574],{},"The file is a join across at least three offices. Assign one owner who reconciles it monthly; the ",[31,1572,1573],{"href":1367},"monitoring cadence article"," describes the rhythm.",[37,1576,373],{"id":372},[157,1578,1579,1590,1596,1602,1608],{},[90,1580,1581,1584,1585,1587,1588,35],{},[15,1582,1583],{},"Create the file today"," for every active Workforce Pell cohort, with the ten fields above plus ",[1119,1586,1357],{}," — even if employment columns sit at ",[1119,1589,1252],{},[90,1591,1592,1595],{},[15,1593,1594],{},"Backfill from source systems",", not memory: enrollment agreements, registrar records, R2T4 withdrawal determinations.",[90,1597,1598,1601],{},[15,1599,1600],{},"Ask your state workforce board"," for its data specification and add any extra required columns now.",[90,1603,1604,1607],{},[15,1605,1606],{},"Assign a single owner"," and a monthly reconciliation step against the SIS.",[90,1609,1610,1613],{},[15,1611,1612],{},"Run the file through the report generator"," (linked above) to see your current rates and which rows are dragging them.",[1615,1616,1617],"style",{},"html .default .shiki span {color: var(--shiki-default);background: var(--shiki-default-bg);font-style: var(--shiki-default-font-style);font-weight: var(--shiki-default-font-weight);text-decoration: var(--shiki-default-text-decoration);}html .shiki span {color: var(--shiki-default);background: var(--shiki-default-bg);font-style: var(--shiki-default-font-style);font-weight: var(--shiki-default-font-weight);text-decoration: var(--shiki-default-text-decoration);}html .dark .shiki span {color: var(--shiki-dark);background: var(--shiki-dark-bg);font-style: var(--shiki-dark-font-style);font-weight: var(--shiki-dark-font-weight);text-decoration: var(--shiki-dark-text-decoration);}html.dark .shiki span {color: var(--shiki-dark);background: var(--shiki-dark-bg);font-style: var(--shiki-dark-font-style);font-weight: var(--shiki-dark-font-weight);text-decoration: var(--shiki-dark-text-decoration);}",{"title":411,"searchDepth":412,"depth":412,"links":1619},[1620,1621,1622,1623,1624],{"id":1086,"depth":412,"text":1087},{"id":1387,"depth":412,"text":1388},{"id":1423,"depth":412,"text":1424},{"id":1489,"depth":412,"text":1490},{"id":372,"depth":412,"text":373},"The minimum per-student data schema for tracking Workforce Pell 70\u002F70 compliance — fields, formats, a sample CSV row, and how it maps to the report generator.",{},"\u002Flibrary\u002Fdata-playbooks\u002Fbuilding-your-cohort-file","data-playbooks","4.1",{"title":1060,"description":1625},[1632,1633],{"label":434,"url":435},{"label":1634,"url":444},"Workforce Pell final rule fact sheet (ED)","library\u002Fdata-playbooks\u002Fbuilding-your-cohort-file",[34,447,1637,1638],"cohort file","data schema","gE0BSw4XBL3Lt-q9_W_nyGacWhMDN0kl0dfpkKMlwuk",{"id":1641,"title":1642,"body":1643,"description":1972,"extension":423,"meta":1973,"navigation":425,"path":1974,"pillar":1628,"pinned":425,"publishedDate":428,"readTime":429,"section":1975,"seo":1976,"sources":1977,"stem":1983,"tags":1984,"updatedDate":428,"__hash__":1987},"library\u002Flibrary\u002Fdata-playbooks\u002Fpreparing-the-70-70-report.md","Preparing Your 70\u002F70 Report: From Cohort File to Submission-Ready Document",{"type":8,"value":1644,"toc":1956},[1645,1648,1651,1655,1670,1681,1686,1689,1734,1741,1745,1748,1752,1755,1759,1765,1769,1772,1789,1793,1796,1853,1859,1863,1866,1870,1873,1881,1885,1888,1916,1918],[11,1646,1647],{},"At some point your 70\u002F70 numbers stop being an internal dashboard and become a submission: a document your institution stands behind, that a state reviewer reads, and that determines whether a program keeps its Workforce Pell eligibility. The gap between \"we know our rates\" and \"we can hand someone a defensible report\" is exactly the gap this article closes.",[11,1649,1650],{},"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. Your state may prescribe its own submission format; where it does, that format wins. What follows is the content any defensible report needs regardless of the wrapper.",[37,1652,1654],{"id":1653},"who-reviews-it-and-when","Who reviews it, and when",[11,1656,1657,1658,1661,1662,1665,1666,1669],{},"Under the final rule's approval structure, the ",[15,1659,1660],{},"governor — with the state workforce board — certifies"," each program: occupation alignment, stackability, and, in the transitional years (2026–27 through 2028–29), the ",[15,1663,1664],{},"70\u002F70 rates themselves",", which the governor determines and verifies under state-set methodology. ED then verifies the federal requirements. Rates are ",[15,1667,1668],{},"verified annually"," during the transitional years; after 2028–29, the completion calculation moves to federal methodology (in the style of the 34 CFR 668.8(f) clock-hour calculation).",[11,1671,1672,1673,1676,1677,1680],{},"Practically, that means your report's first audience is your ",[15,1674,1675],{},"state workforce board",", its cadence is ",[15,1678,1679],{},"at least annual",", and its stakes are program-level: a program that fails 70\u002F70 loses Workforce Pell eligibility, and neither it nor a substantially similar program (same 4-digit CIP with overlapping SOC codes) can be re-established for two years. Reinstatement runs through appeal or governor recertification — which is argued from exactly the records this report packages.",[1682,1683,1685],"h3",{"id":1684},"the-reporting-chains-precisely","The reporting chains, precisely",[11,1687,1688],{},"The final rule sets out two distinct chains your data travels, and the report you prepare feeds both:",[87,1690,1691,1708],{},[90,1692,1693,1696,1697,1700,1701,1704,1705,547],{},[15,1694,1695],{},"Institution → Governor:"," annual ",[15,1698,1699],{},"completer lists",", the ",[15,1702,1703],{},"placement-verification data"," behind them, and your certification request, all through the state's process. The State Workforce Pell Program Certification form has been available since July 1, 2026 (",[15,1706,1707],{},"FSA Electronic Announcement GENERAL-26-44",[90,1709,1710,1713,1714,1717,1718,1721,1722,1725,1726,1730,1731,35],{},[15,1711,1712],{},"Institution → ED:"," your ",[15,1715,1716],{},"published tuition and fees","; ",[15,1719,1720],{},"current NSLDS enrollment and completion data"," — ED compiles program completer lists from NSLDS, and you get a ",[15,1723,1724],{},"60-day window to correct"," them, so stale ",[31,1727,1729],{"href":1728},"\u002Flibrary\u002Fpell-fundamentals\u002Fnslds-enrollment-reporting","NSLDS reporting"," becomes a 70\u002F70 problem directly; and the ",[15,1732,1733],{},"Governor's certification, uploaded via E-App",[11,1735,1736,1737,1740],{},"One timing fact worth planning around: the ",[15,1738,1739],{},"first certifications draw on the most recent 12 months of administrative data",". Your earliest cohorts are not a practice round — the enrollment and completion records you are generating right now are the data the first certification will stand on.",[37,1742,1744],{"id":1743},"anatomy-of-a-defensible-report","Anatomy of a defensible report",[11,1746,1747],{},"Six components. If any is missing, a reviewer has to take your word for something — and taking your word is not their job.",[1682,1749,1751],{"id":1750},"_1-program-identification","1. Program identification",[11,1753,1754],{},"Program name, CIP code, credential awarded, clock hours, and normal completion time in weeks — matching your governor certification and ED approval documents exactly. One report per program; eligibility attaches per program, not per institution.",[1682,1756,1758],{"id":1757},"_2-cohort-definition-and-period","2. Cohort definition and period",[11,1760,1761,1762,1764],{},"State precisely who is in the denominator and why: the enrollment window covered, the number of participants, and your treatment of edge cases — withdrawals, re-entries, transfers, and students whose 150 percent deadline had not passed at the measurement date. This is where reports fail review. A rate without a cohort definition is a number, not a metric. (Your treatment of edge cases should match the methodology memo from the ",[31,1763,1368],{"href":1367},".)",[1682,1766,1768],{"id":1767},"_3-methodology-notes","3. Methodology notes",[11,1770,1771],{},"Short, explicit statements of how each rate was produced:",[87,1773,1774,1780],{},[90,1775,1776,1779],{},[15,1777,1778],{},"Completion:"," deadline formula (start date + 1.5 × normal weeks), your half-week convention, LOA\u002Fre-entry treatment, and the data sources for each date field.",[90,1781,1782,1785,1786,1788],{},[15,1783,1784],{},"Placement:"," how the second-quarter-after-exit window was computed, the verification hierarchy used (UI wage match, employer letters, surveys — see ",[31,1787,1296],{"href":1295},"), the mix of sources behind the rate, and how non-responders were pursued and classified.",[1682,1790,1792],{"id":1791},"_4-both-rates-shown-with-their-arithmetic","4. Both rates, shown with their arithmetic",[11,1794,1795],{},"Not just the percentages — the fractions:",[297,1797,1798,1817],{},[300,1799,1800],{},[303,1801,1802,1805,1808,1811,1814],{},[306,1803,1804],{},"Metric",[306,1806,1807],{},"Numerator",[306,1809,1810],{},"Denominator",[306,1812,1813],{},"Rate",[306,1815,1816],{},"Threshold",[313,1818,1819,1837],{},[303,1820,1821,1824,1827,1830,1833],{},[318,1822,1823],{},"Completion within 150% of normal time",[318,1825,1826],{},"completers by deadline",[318,1828,1829],{},"program participants",[318,1831,1832],{},"n\u002Fd",[318,1834,647,1835],{},[15,1836,650],{},[303,1838,1839,1842,1845,1847,1849],{},[318,1840,1841],{},"Employed in second quarter after exit",[318,1843,1844],{},"verified employed completers",[318,1846,1440],{},[318,1848,1832],{},[318,1850,647,1851],{},[15,1852,650],{},[11,1854,1855,1856,1858],{},"Note that the metrics chain: the placement denominator is the completion numerator's population. An error in completion status propagates into placement, which is one more reason both rates must come from a single ",[31,1857,1637],{"href":1627}," rather than two spreadsheets.",[1682,1860,1862],{"id":1861},"_5-roster-appendix","5. Roster appendix",[11,1864,1865],{},"The row-level data behind the rates: one line per student with the ten schema fields (ID, program, start date, normal weeks, completion\u002Fwithdrawal dates, exit date, second-quarter employment status, verification source, and any documented exclusion). Follow your state's guidance on identifiers and privacy — a reviewer needs to be able to tie every roster row to retained source records, but how much personally identifying detail travels with the report is a state call. Keep the full-identifier version internally under your retention schedule; the submitted version may use masked IDs if your state permits.",[1682,1867,1869],{"id":1868},"_6-attestation","6. Attestation",[11,1871,1872],{},"A signature block in which a named institutional official (and, where your state requires, the program director) attests that the data is complete and accurate and that supporting records are retained and available for inspection. Unsigned reports invite the question of who stands behind the numbers; the attestation answers it before it is asked.",[11,1874,177,1875,1880],{},[15,1876,1877,1879],{},[31,1878,757],{"href":756}," produces exactly this document"," — both rates with their arithmetic, methodology notes, and a roster appendix — from a cohort file in the standard schema. Upload your roster, review the flagged rows, and export.",[37,1882,1884],{"id":1883},"cadence-annual-submission-quarterly-rehearsal","Cadence: annual submission, quarterly rehearsal",[11,1886,1887],{},"The submission is at least annual (verified annually during the transitional years — confirm your state's calendar and deadlines). But producing the report once a year is how schools discover problems eleven months too late. The working cadence:",[87,1889,1890,1899,1905],{},[90,1891,1892,1895,1896,1898],{},[15,1893,1894],{},"Quarterly:"," generate the full report internally as a dress rehearsal. Every ",[1119,1897,1252],{}," employment row and every unverifiable completer is a task list for the next quarter.",[90,1900,1901,1904],{},[15,1902,1903],{},"At cohort close:"," snapshot the cohort file and draft the cohort definition and methodology sections while decisions are fresh.",[90,1906,1907,1910,1911,1915],{},[15,1908,1909],{},"At submission:"," freeze the submitted version — the exact file, the exact report, dated — and archive it beyond the Title IV three-year floor, since the value-added earnings horizon and the two-year re-establishment bar both outlive it. (The same roster data ultimately feeds the ",[31,1912,1914],{"href":1913},"\u002Flibrary\u002Fworkforce-pell\u002Fvalue-added-earnings-test","value-added earnings test"," beginning award year 2030–31.)",[37,1917,373],{"id":372},[157,1919,1920,1926,1932,1944,1950],{},[90,1921,1922,1925],{},[15,1923,1924],{},"Get your state's submission requirements in writing"," — format, cadence, deadlines, identifier rules — from the governor's office or state workforce board.",[90,1927,1928,1931],{},[15,1929,1930],{},"Draft the methodology notes now",", before the first submission, and send them to the state for concurrence on the edge cases.",[90,1933,1934,1937,1938,1940,1941,1943],{},[15,1935,1936],{},"Run a quarterly dress rehearsal"," from your live cohort file and work the ",[1119,1939,1252],{},"\u002F",[1119,1942,1249],{}," rows as a task list.",[90,1945,1946,1949],{},[15,1947,1948],{},"Establish the attestation chain"," — who signs, on what evidence, after what internal review.",[90,1951,1952,1955],{},[15,1953,1954],{},"Archive every submitted report and its frozen roster"," with your long-horizon retention records.",{"title":411,"searchDepth":412,"depth":412,"links":1957},[1958,1962,1970,1971],{"id":1653,"depth":412,"text":1654,"children":1959},[1960],{"id":1684,"depth":1961,"text":1685},3,{"id":1743,"depth":412,"text":1744,"children":1963},[1964,1965,1966,1967,1968,1969],{"id":1750,"depth":1961,"text":1751},{"id":1757,"depth":1961,"text":1758},{"id":1767,"depth":1961,"text":1768},{"id":1791,"depth":1961,"text":1792},{"id":1861,"depth":1961,"text":1862},{"id":1868,"depth":1961,"text":1869},{"id":1883,"depth":412,"text":1884},{"id":372,"depth":412,"text":373},"What a defensible 70\u002F70 report contains — cohort period, methodology, both rates, roster appendix, attestation — who reviews it, and how often you produce it.",{},"\u002Flibrary\u002Fdata-playbooks\u002Fpreparing-the-70-70-report","4.4",{"title":1642,"description":1972},[1978,1979,1980],{"label":434,"url":435},{"label":1634,"url":444},{"label":1981,"url":1982},"FSA Electronic Announcement GENERAL-26-44 (July 1, 2026)","https:\u002F\u002Ffsapartners.ed.gov\u002Fknowledge-center\u002Flibrary\u002Felectronic-announcements\u002F2026-07-01\u002Feligible-workforce-programs-state-workforce-pell-certification-form-available","library\u002Fdata-playbooks\u002Fpreparing-the-70-70-report",[34,447,1985,1986],"compliance report","governor certification","yyBojwZyF_D53XM3UM0z6ui_-tno9xNN9M5o3Ih1Gyk",1784625503904]