Updated: December 16, 2025

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Workforce Pell: A High-Level Update

Workforce Pell, established through the One Big Beautiful Bill Act (OBBBA), is set to be implemented on July 1, 2026. This initiative marks a significant change in federal financial aid policy. The U.S. Department of Education (ED) is currently in the process of developing the rules for these short-term, Pell-eligible workforce programs as part of the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee negotiated rulemaking process. Although the goal is to broaden access to career-focused training, the structure of Workforce Pell introduces new program approval requirements, accountability standards, and data collection expectations that were not specifically designed for correctional environments. For higher education in prison (HEP), this policy intersects with an environment that is already adjusting to new Prison Education Program (PEP) rules following the restoration of Pell Grants in 2023.

According to ED’s 2025 AHEAD discussion draft, Workforce Pell applies to programs lasting between 8 and 15 weeks, providing 150 to 599 clock hours, and must be aligned with high-skill, high-wage, or in-demand sectors (U.S. Department of Education [ED], 2025a). Eligible programs must culminate in recognized postsecondary credentials and are prohibited in correspondence or direct assessment formats—modes of delivery that have traditionally been used in prison settings. This requirement indicates that significant adaptations will be necessary for institutions in carceral settings seeking Workforce Pell approval.

The draft regulations establish a two-stage approval process that is notably different from existing PEP rules. In the first stage, state Governors must determine whether programs meet criteria such as labor-market alignment, employer hiring needs, credential portability, and academic relevance (ED, 2025a). Only after this state-level approval can ED evaluate whether a program meets federal criteria related to completion rates, job placement, and value-added earnings. This dual approval process highlights that Workforce Pell is not only a funding tool but also acts as a gatekeeping mechanism, which may require HEP programs to engage with workforce agencies, governors’ offices, and corrections departments in new ways.

One of the most frequently discussed aspects of Workforce Pell is the “70/70 rule.” According to statute and materials from ED and independent analysts, programs must achieve a minimum 70 percent completion rate within 150 percent of the expected program duration and a 70 percent job placement rate in the second quarter after program exit (ED, 2025a; Richmond Federal Reserve Bank, 2025). Organizations observing the rulemaking process, such as The Institute for College Access & Success (TICAS), have clarified this requirement and emphasized the need for strong guardrails and student protections, given the high stakes for short-term training programs (TICAS, 2025a). For HEP, this raises important concerns, as incarcerated learners often face classroom interruptions, facility transfers, lockdowns, and unpredictable release schedules, all of which affect enrollment continuity. After release, early employment outcomes are influenced by structural barriers such as delays in obtaining necessary documentation, parole conditions, occupational licensing restrictions, and employer discrimination—factors that can impact job placement rates independently of program quality.

Additionally, the proposed value-added earnings test requires that graduates’ median wages—adjusted for regional price levels and compared to poverty benchmarks—exceed program tuition and fees (ED, 2025a). TICAS highlights that this measure carries risks, as it relies on state wage-record systems that may not capture informal or transitional work and may disadvantage students facing systemic exclusion from the labor market (TICAS, 2025b). This issue is especially significant for individuals reentering society after incarceration, who often face substantial barriers to stable employment and wage advancement.

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What National Organizations Are Saying

Although few organizations have addressed Workforce Pell and prisons directly, several have produced analyses that inform how the HEP field might interpret the policy’s implications. Jobs for the Future (JFF), in its public comments to ED, argued for the inclusion of prison-education and reentry expertise in the rulemaking process. JFF emphasized that transfers between facilities and post-release challenges complicate the interpretation of completion and placement data and urged ED to ensure that accountability metrics do not unfairly penalize programs serving incarcerated learners (Jobs for the Future, 2025). This reflects a broader understanding that outcomes for justice-impacted learners cannot be accurately assessed without considering the unique conditions of incarceration.

TICAS has offered the most detailed explanation of Workforce Pell’s accountability measures, data requirements, and the statutory basis for the 70/70 rule. TICAS’s work stresses that Workforce Pell draws from students’ limited lifetime Pell eligibility, thereby raising the stakes for the quality and stackability of short-term programs (TICAS, 2025a). The organization also points out the limitations in short-term program data infrastructure, which complicate accountability even outside prison settings; for HEP providers, who often face even more limited data capacity, these challenges are expected to be even greater (TICAS, 2025b).

Ithaka S+R adds important context through two research briefs. “Pell Restoration and Approval: Following the Data” details the complexities of PEP approval, the need for collaboration among multiple agencies, and the reliance on data for making “Best Interest” determinations (Ithaka S+R, 2025a). “Why Data and Why Now?” discusses ongoing gaps in data collection in prison education, including challenges in tracking enrollment, retention, and comparability—issues that predate Workforce Pell and may complicate its implementation (Ithaka S+R, 2025b). While these findings do not address Workforce Pell directly, they underscore the practical difficulties HEP programs face when new accountability metrics depend on underdeveloped data systems.

The Vera Institute of Justice’s report, “The First Year of Pell Restoration,” provides an overview of state-level readiness and shows that PEP implementation is still uneven across the country (Vera Institute of Justice, 2024). Workforce Pell is being introduced into a landscape where many systems are still building the necessary infrastructure for degree-bearing programs, and the capacity to take on another approval and accountability framework may vary widely.

The Richmond Federal Reserve Bank offers a broad perspective on the legislative and regulatory aspects of Workforce Pell, noting that outcomes will be heavily influenced by state interpretation, employer validation, and the ability of institutions to report the required data (Richmond Federal Reserve Bank, 2025). This aligns with concerns in the HEP field that state-level gatekeeping could create equity challenges for incarcerated learners, whose access may depend on the priorities of governors and workforce agencies.

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Conclusion

Workforce Pell is still in the development phase, but its framework, accountability requirements, and dependence on both state and federal approval processes present important considerations for higher education in prison. The national commentary reviewed here does not reflect outright opposition or uncritical support; rather, this Explainer offers a synthesized overview of the evolving landscape for the field’s awareness and reflection. Despite significant uncertainty and many unanswered questions, there is widespread recognition that the impact of Workforce Pell will depend on how well its metrics and mechanisms are adapted to the realities of incarceration and reentry. As rulemaking continues, practitioners and advocates within the HEP field will need to continue to raise critical questions around program credentials and sustainability, access to the labor market, data preparedness, and the interactions between PEP and Workforce Pell systems. 

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References 

Ithaka S+R. (2025a, September 30). Pell restoration and approval: Following the data. https://sr.ithaka.org/wp-content/uploads/2025/09/SR-Brief-Pell-Restoration-and-Approval-20250930.pdf 

Ithaka S+R. (2025b, August 20). Why data and why now? The importance and challenges of data for higher education in prison. https://sr.ithaka.org/publications/why-data-and-why-now/ 

Jobs for the Future. (2025, August 27). JFF public comments on Workforce Pell legislation in OBBBA. https://www.jff.org/blog/jff-public-comments-on-workforce-pell-legislation-in-obbba/ 

Richmond Federal Reserve Bank. (2025, December 4). Workforce Pell is (Finally) law. Now what? https://www.richmondfed.org/region_communities/regional_data_analysis/community_college_survey/community_college_insights/2025/workforce_pell_finally_law_now_what 

The Institute for College Access & Success. (2025a, October 23). Preparing to implement Workforce Pell Grants: States should legislate to solidify student protections. https://ticas.org/accountability/workforce-pell-state-model-legislation/

The Institute for College Access & Success. (2025b, December 3). Opening Workforce Pell to noncredit programs will leave students worse off and waste taxpayer dollars. https://ticas.org/accountability/noncredit-workforce-pell-blog-dec-2025/ 

U.S. Department of Education. (2025a, December 8–12). AHEAD: Discussion draft of proposed Workforce Pell regulations. https://www.ed.gov/media/document/2025-ahead-discussion-draft-112625.pdf 

U.S. Department of Education. (2025b, August 7). 2025 negotiated rulemaking – Afternoon session. https://www.ed.gov/media/document/2025-negotiated-rulemaking-8725-afternoon-110529.pdf 

Vera Institute of Justice. (2024, June). The first year of Pell restoration. https://www.vera.org/publications/the-first-year-of-pell-restoration