The Workforce Pell completion test requires that at least 70 percent of program participants complete the program within 150% of the normal time to completion. This article walks through the window, the cohort, the two calculation regimes, and the per-student data you need to produce a defensible rate.

This is half of the 70/70 rule; the other half is the job placement rate.

The 150% window, worked

"Normal time to completion" is your program's published length. The completion window is that length times 1.5.

Example: a 12-week, 320-clock-hour CDL program.

• Normal time: 12 weeks
• Completion window: 12 × 1.5 = 18 weeks
• A student who starts January 5 has until roughly May 10 (week 18) to complete and count as a completer

A student who finishes in week 14 after retaking a unit counts for you. A student who finishes in week 20 is a completion for the student — but against you in the rate. A student who withdraws in week 3 counts against you. There is no partial credit: within the window or not.

Note the deliberate parallel with Satisfactory Academic Progress: SAP's maximum timeframe is also 150% of program length (FSA Handbook). A student who blows through the 150% window has typically also failed SAP quantitative standards — the two compliance regimes reinforce each other, and your SAP monitoring data is a natural early-warning feed for the completion rate.

Who counts in the cohort

The rate is computed over program participants — students who began the program — not over completers or Pell recipients only:

completion rate = students completing within 150% of normal time
                  ÷ students who began the program (the cohort)

Practical cohort questions your methodology must answer — and where the final rule and your state's guidance control:

• Cohort boundaries: which start dates or award year define one cohort (rolling-enrollment programs need a clear convention)
• Exclusions: exactly four categories of students may be removed — see the next section. Nothing else comes out.
• Transfers and restarts: how a student who drops and re-enrolls in a later cohort is counted

Where this document's grounding is silent, the answer is the final rule and your state's published methodology — not an analogy to IPEDS or Graduation Rate Survey conventions.

The four allowable exclusions

The final rule (91 FR 29254; 34 CFR part 690, subpart H) allows exactly four exclusions, applied to the numerator and the denominator: students who (1) died; (2) suffered a totally disabling condition; (3) were called to military service for more than 30 days; or (4) were incarcerated. Each must be documented with evidence — an undocumented exclusion is an audit finding. There is no exclusion for transfers, no-shows after the cohort forms, or students you simply cannot reach.

A worked rate, exclusions included

• 40 students began the program
• 2 carry documented exclusions (one called to military service for more than 30 days, one totally disabling condition)
• Denominator: 40 − 2 = 38
• 29 completed within the 150% window
• Completion rate: 29 ÷ 38 = 76.3% — passing

Margin analysis: the 70 percent line on a 38-student denominator sits at 26.6 students, so this cohort could absorb two more non-completions and still pass. At typical short-program cohort sizes, the distance between passing and failing is two or three students — which is the arithmetic behind setting an internal floor well above 70.

Two regimes: who calculates, and how

Transitional years: 2026–27 through 2028–29 — the Governor

For the first three award years, the Governor determines and verifies the completion rate. States may set their own data systems and verification methodology. That means the operative definition of your cohort, your window, and your evidence requirements is a state document. Two schools with identical outcomes in different states could report different rates.

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.

After 2028–29 — the federal calculation

Beginning after award year 2028–29, the rate is calculated under federal methodology — the clock-hour completion calculation of 34 CFR 668.8(f), the same math clock-hour schools already know from short-program eligibility rules. If your registrar already produces 668.8(f) completion rates for other Title IV purposes, that machinery is the long-term home of your Workforce Pell completion number.

Build to the federal standard from day one. A state may accept looser evidence during the transition; the federal calc arriving in 2029–30 will not.

The data you need per student

A defensible completion rate is a per-student ledger. For every student in every cohort, you need:

Most of this is data you already keep for R2T4, SAP, and NSLDS enrollment reporting. The Workforce Pell difference is that it must roll up, per program and per cohort, into one number that clears 70 percent — and survive state verification or a federal audit. When you have the ledger assembled, run your numbers in the 70/70 Report Generator to see where each program stands.

Common failure modes

• No recorded conferral dates. If you can't prove when a student completed, you can't prove they completed inside the window.
• Rolling enrollment with no cohort convention. Pick a convention consistent with your state's methodology and apply it identically every reporting cycle.
• Counting "still enrolled past the window" as pending. Once the 150% window closes, a non-completer is a non-completer for that cohort's rate.
• Optimistic denominators. Quietly dropping withdrawals from the denominator is the fastest way to fail a verification. Only the four documented exclusions come out — nothing else.

What to do now

1. Publish and freeze each program's normal time (weeks and clock hours) — the whole calculation keys off it.
2. Build the per-student ledger with the seven fields above for every current cohort, starting with students enrolled this award year.
3. Ask your state workforce board for the written completion-rate methodology — cohort definition, allowed exclusions, evidence requirements — before you certify any number.
4. Backtest the last two years of cohorts. If any program's historical rate is under roughly 80 percent, it needs intervention (scheduling, tutoring, attendance follow-up) before it needs Pell.
5. Wire SAP monitoring into completion forecasting — students failing SAP's 150% pace today are your completion-rate misses next quarter.