The 70/70 rule is the performance backbone of the Workforce Pell Grant program: to gain and keep eligibility, a program must show that 70 percent of its participants complete on time and 70 percent 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.

The rule comes from the Working Families Tax Cuts Act (P.L. 119-21, § 83002, signed July 4, 2025) as implemented by ED's final rule of May 19, 2026 (91 FR 29254), which creates a new subpart H of 34 CFR part 690. Watch the dates: July 1, 2026 is the statutory start of award year 2026–27, but the final rule's formal 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 Workforce Pell, learn this rule — it is the ongoing test, not a one-time application hurdle.

Test 1: The 70% completion rate

At least 70 percent of program participants must complete the program within 150% of the normal time to completion.

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.

Who calculates it depends on the year:

• Transitional years (2026–27 through 2028–29): the Governor determines and verifies the completion rate. States may set their own data systems and verification methodology.
• After 2028–29: the rate is calculated under federal methodology — the clock-hour completion calculation of 34 CFR 668.8(f).

The full mechanics, with a worked example, are in How the Completion Rate Is Calculated.

Test 2: The 70% job placement rate

At least 70 percent of completers must be employed during the second calendar quarter after program exit (34 CFR 690.94).

One correction worth internalizing, because it is the most repeated error in coverage of this rule — call it the "180-day myth." The statute says placement is "measured 180 days after" completion, but the binding regulation, 34 CFR 690.94, measures employment 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 October through December — not "day 180." A tracking calendar built on a 180-day count will check the wrong window.

What counts as "employed" tightens over time:

• Phase 1 (award years 2026–27 through 2028–29): any employment in that window counts.
• Phase 2 (starting award year 2029–30): employment must be in the occupation the program prepared the student for, or a similar high-skill, high-wage, or in-demand occupation.

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 How the Job Placement Rate Is Calculated.

The four allowable exclusions

Both rates permit exactly four categories of students to be excluded — and the exclusion applies 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 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.

The phase-in timeline

The 70/70 rule does not arrive all at once. Three distinct regimes phase in:

Two practical consequences of this table:

1. 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.
2. 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.

The third metric — the earnings test — gets its own treatment in the Value-Added Earnings Test article (section 1.5 of this handbook).

What failing costs you

A program that fails either 70% threshold loses Workforce Pell eligibility for that program. The institution then 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.

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 Falling Below 70/70: Losing Eligibility and the Two-Year Bar for the failure mechanics and early-warning practices.

Running your own numbers

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 70/70 Report Generator to see where your programs stand and what documentation gaps you have.

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 — DriverTrack is the school-management platform built to track this data for CDL programs.

What to do now

1. Compute both rates for every candidate program today, using your best available data — before your state or ED does it for you.
2. 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.
3. 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.
4. Start capturing occupation of employment now. The 2029–30 shift to occupation-aligned placement will punish programs that only tracked "employed yes/no."
5. 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.