At some point your 70/70 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.

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.

Who reviews it, and when

Under the final rule's approval structure, the governor — with the state workforce board — certifies each program: occupation alignment, stackability, and, in the transitional years (2026–27 through 2028–29), the 70/70 rates themselves, which the governor determines and verifies under state-set methodology. ED then verifies the federal requirements. Rates are 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).

Practically, that means your report's first audience is your state workforce board, its cadence is at least annual, and its stakes are program-level: a program that fails 70/70 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.

The reporting chains, precisely

The final rule sets out two distinct chains your data travels, and the report you prepare feeds both:

• Institution → Governor: annual completer lists, the 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 (FSA Electronic Announcement GENERAL-26-44).
• Institution → ED: your published tuition and fees; current NSLDS enrollment and completion data — ED compiles program completer lists from NSLDS, and you get a 60-day window to correct them, so stale NSLDS reporting becomes a 70/70 problem directly; and the Governor's certification, uploaded via E-App.

One timing fact worth planning around: the 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.

Anatomy of a defensible report

Six components. If any is missing, a reviewer has to take your word for something — and taking your word is not their job.

1. Program identification

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.

2. Cohort definition and period

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 150 percent tracking playbook.)

3. Methodology notes

Short, explicit statements of how each rate was produced:

• Completion: deadline formula (start date + 1.5 × normal weeks), your half-week convention, LOA/re-entry treatment, and the data sources for each date field.
• Placement: how the second-quarter-after-exit window was computed, the verification hierarchy used (UI wage match, employer letters, surveys — see verifying employment outcomes), the mix of sources behind the rate, and how non-responders were pursued and classified.

4. Both rates, shown with their arithmetic

Not just the percentages — the fractions:

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 cohort file rather than two spreadsheets.

5. Roster appendix

The row-level data behind the rates: one line per student with the ten schema fields (ID, program, start date, normal weeks, completion/withdrawal 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.

6. Attestation

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.

The 70/70 Report Generator 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.

Cadence: annual submission, quarterly rehearsal

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:

• Quarterly: generate the full report internally as a dress rehearsal. Every pending employment row and every unverifiable completer is a task list for the next quarter.
• At cohort close: snapshot the cohort file and draft the cohort definition and methodology sections while decisions are fresh.
• 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 value-added earnings test beginning award year 2030–31.)

What to do now

1. Get your state's submission requirements in writing — format, cadence, deadlines, identifier rules — from the governor's office or state workforce board.
2. Draft the methodology notes now, before the first submission, and send them to the state for concurrence on the edge cases.
3. Run a quarterly dress rehearsal from your live cohort file and work the pending/unknown rows as a task list.
4. Establish the attestation chain — who signs, on what evidence, after what internal review.
5. Archive every submitted report and its frozen roster with your long-horizon retention records.