NAICU Offers Comments on Workforce Pell Framework

NAICU, joined by more than three dozen state and mission-driven associations, submitted comments to the Department of Education regarding the agency’s Notice of Proposed Rulemaking on Workforce Pell. NAICU noted that the proposed framework for Workforce Pell was “largely sound,” but highlighted multiple areas of concern for private, nonprofit institutions, and responded to several of the directed questions the department posed to stakeholders.

While the comments highlighted the Department’s implementation of the largest expansion of the Pell Grant program in years, they also proffered suggestions for ways the agency could build on its proposal to further incentivize institutions to take part.

NAICU detailed some of the challenges the private, nonprofit sector will face when deciding whether to start up new programs for short-term credentials. The most pointed critique targeted the job placement rate metric, which NAICU argues would create a structural conflict at the heart of the program's own design.

The Workforce Pell program was designed to achieve two specific goals: 1) prepare students to enter the workforce; and 2) prepare students to continue their education. This is why any program in Workforce Pell must provide a credential that is both stackable and portable, meaning that it must articulate to a higher-level credential and be transferrable to another program. In NAICU’s view, a successful Workforce Pell program must lead to one of those two outcomes.

However, under the proposed rule, students who complete a workforce program and immediately enroll in a longer credential program, rather than enter the labor market, do not appear in wage records and therefore count against the institution's placement rate. This directly penalizes the stackable credential pathway the statute and regulation simultaneously require programs to provide. Because a program's annual job placement rate must be at least 70% to remain eligible for the Workforce Pell program, it places institutions in the undesirable position of having to somehow discourage their students from continuing their education lest they lose eligibility in the following year.

The letter offers two alternative approaches: 1) count enrollment in a directly related credential program as a positive placement outcome; or 2) exclude from the denominator any completer enrolled at least half-time in a Title IV-eligible program during the measurement period, which is similar to exclusions elsewhere in Department of Education earnings data.

For more information, please contact:
Justin Monk