PEER Center Comments: AHEAD Regulations on Workforce Pell

Through the One Big Beautiful Bill Act (OBBBA), lawmakers extended Pell Grant eligibility to short-term (8- through 14-week and 150- through 599-clock-hour) programs. The U.S. Department of Education proposed regulations to implement this change in March 2026. Our comments on these proposed rules address several of the guardrails included in the proposed regulations, in an effort to ensure those measures – and particularly the outcomes-based measures included – are as effective as possible in their implementation.

In this comment, we provide feedback on several topics throughout the proposed regulations, including:

• Strengthening accountability by requiring states to calculate an interim earnings measure;

• Providing technical feedback on the construction of the median earnings and value-added earnings (“tuition-to-discretionary-earnings”) measures, particularly to ensure consistency with the earnings measures under the forthcoming earnings-based accountability rules, including recommendations to:

  • Use a three-year earnings measurement period for the median earnings of Workforce Pell programs;

  • Exclude currently enrolled students and certain other types of students from the median earnings metrics;

  • Clarify the use of regional price parities in the final rules; 

  • Streamline the aggregation of small programs through a two- or four-year cohort structure; and 

  • Measure Workforce Pell programs separately from other undergraduate certificate programs;

• Support for the enhancement of state unemployment insurance wage records, with additional federal assistance for states;

• Ensuring the ongoing use of state administrative data, rather than self-reported data on completion and job placement rates; 

• Preventing loopholes for programs that fall short on accountability metrics, including tuition-to-discretionary-earnings, by preventing those Workforce Pell programs from restarting programs in the same four-digit CIP code as a failing program;

• Extending the period of ineligibility for failing programs from two to three years; and 

• Ensuring transparency through a commitment that the Department will publish information received or produced about Workforce Pell programs.