Re: Comments on Accountability in Higher Education and Access Through Demand-Driven Workforce Pell: Pell Grant Exclusion Relating to Other Grant Aid; and Workforce Pell Grants
Dear Under Secretary Nicholas Kent,
The Presidents Forum appreciates the Department’s engagement through these directed questions and the opportunity to contribute to the development of Workforce Pell. As a nonprofit organization composed of innovative college and university leaders, we are committed to advancing student-centered policies that expand access and improve outcomes for working learners and other nontraditional students. 
We recognize that successful implementation will be critical to realizing the full potential of Workforce Pell. As the Department finalizes its approach, we encourage a framework that is clear, consistent, and practical for institutions to implement, and that supports expanded access and strong outcomes for students.
Where relevant, we also encourage alignment with existing regulatory approaches to promote consistency and avoid unnecessary complexity for institutions serving students across state lines, including in how student location is determined.
Directed Questions
Written Arrangements To Provide Educational Programs (§ 668.5(c))
The Presidents Forum appreciates the Department’s recognition of the role partnerships can play in strengthening eligible workforce programs. High-quality workforce programs are closely aligned with employer and industry needs, and that alignment often depends on collaboration with external partners who bring specialized expertise, training environments, and real-world application into the educational experience.
In many cases, effective workforce programs integrate instruction delivered in partnership with employers or other industry-aligned organizations. These partnerships help ensure programs remain responsive to labor market demand and that students acquire skills that translate into employment and earnings outcomes. The depth of these partnerships is often central to program quality and student success.
The proposed 25 percent limitation may unintentionally constrain the development of high-quality workforce programs by limiting institutions’ ability to fully leverage these partnerships. In some cases, institutions may be required to replicate training components that are more effectively delivered in collaboration with industry, reducing program effectiveness and increasing costs without clear benefit to students.
While we recognize the Department’s interest in ensuring appropriate oversight, we believe this can be achieved while allowing greater flexibility. The proposal is more restrictive than the framework that has historically governed written arrangements in Title IV programs, and we encourage the Department to consider a similarly flexible approach here.
Accordingly, we recommend that the Department allow written arrangements that exceed 25 percent where appropriate institutional control and oversight are maintained. This flexibility will better support innovative, employer-aligned programs that deliver strong outcomes for students.
Ineligibility Due to Grant or Scholarship Assistance (§ 690.5)
This provision effectively shifts the Pell Grant from a first-dollar to a last-dollar benefit in certain circumstances. For decades, Pell has served as the foundational source of financial aid for low-income students, with state, employer, institutional, and philanthropic support layered on top. Many of these aid programs have been designed with the expectation that Pell funding will be applied first in a student’s financial aid package.
Altering this structure, even in limited situations, may have unintended consequences for students. State and local aid programs, employer tuition benefits, and private scholarships may not be structured to adjust seamlessly to a last-dollar Pell model. As a result, students may face reduced total aid or increased complexity in calculating or determining financing for their education, particularly for working learners who rely on multiple sources of support.
Policy should encourage employer investment in education. This change may affect employer participation in workforce education programs. If employer-provided assistance reduces or eliminates Pell eligibility, it may create disincentives for employers to invest in their employees’ education or for students to utilize available employer benefits, which could undermine the goal of expanding access to demand-driven workforce programs.
The proposed requirement to recalculate aid and potentially return Pell funds when additional non-Federal assistance is identified and exceeds the student’s cost of attendance may further increase complexity and uncertainty for both students and institutions. Changes in financial aid eligibility throughout an award year may be difficult for students to navigate and could introduce administrative challenges for institutions attempting to manage multiple funding sources in real time and provide students with as much aid as possible.
Given these considerations, we encourage the Department to carefully assess the broader impacts of this provision on students and existing aid ecosystems. Any additional reporting, oversight, or enforcement mechanisms should be designed to minimize disruption to these systems, reduce unnecessary administrative burden, and avoid discouraging employer, state, or philanthropic investment in student success.
Components Determined by Governors (§ 690.93)
The Presidents Forum supports the Department’s goal of ensuring that eligible workforce programs are aligned with labor market demand.
As the Department implements this requirement, it will be important that the process for state approval is clear, efficient, and capable of operating at the scale required to meet workforce needs. Workforce demand is often regional or national in nature, particularly in high-demand sectors where employers operate across state lines and where remote work is increasingly common. Many workforce programs are designed to prepare students for employment opportunities that extend beyond a single state.
Given these realities, the structure and execution of the approval process will be critical. If the process is overly complex or time-intensive, it may limit institutions’ ability to expand access to high-quality programs through distance education in a timely manner. This could reduce opportunities for students, particularly working learners, who depend on flexible access to programs aligned with in-demand careers.
We encourage the Department to prioritize the development of a streamlined and scalable approach for state approval that enables coordination across multiple states where appropriate. A clear and efficient framework will better support the expansion of high-quality workforce programs while maintaining alignment with labor market needs and preserving appropriate state involvement.
Value-Added Earnings: Interim Value-Added Earnings Metric (§ 690.95(a))
The Presidents Forum encourages the Department to prioritize clarity, stability, and effective implementation as it develops the value-added earnings framework for eligible workforce programs.
As the Department considers whether to introduce interim measures or additional layers of accountability, it is important to avoid creating a system that is overly complex or difficult for institutions to implement. Workforce Pell has the potential to expand access to high-quality, demand-driven programs, but that potential depends on a regulatory framework that institutions can navigate efficiently and consistently.
An overly complex or rapidly evolving accountability structure may create uncertainty for institutions, limit their willingness to develop new programs, and ultimately reduce the availability of opportunities for students. This is particularly important for programs designed to serve working learners, where flexibility, speed to market, and alignment with employer needs are critical.
We encourage the Department to focus on developing a clear and sustainable long-term approach to measuring student outcomes, rather than introducing additional interim requirements that may complicate implementation. A streamlined and well-understood framework will better support institutional participation, program innovation, and improved outcomes for students.
Value-Added Earnings: Exclusion of Certain Students in the Completer Cohort (§ 690.95(a))
The Presidents Forum supports the Department’s commitment to developing a value-added earnings metric that meaningfully reflects program outcomes while maintaining fairness across diverse student populations. As the Department considers the composition of the completer cohort, we believe it is both appropriate and necessary to exclude students who are actively enrolled in postsecondary education at the time earnings are measured.
This consideration is particularly important for nontraditional students, including working adults and military-connected learners, who often pursue education through incremental, stackable pathways. Workforce Pell programs are designed not only to support immediate employment outcomes, but also to enable continued educational progression through credentials that are transferable and build toward higher levels of degree attainment. As a result, many students will intentionally re-enroll in subsequent programs shortly after completion as part of a planned pathway to career advancement.
For these students, short-term earnings may not accurately reflect the value of the initial program, as they may be balancing employment with continued education or temporarily deferring full labor market participation to complete additional credentials. Including actively enrolled students in the value-added earnings calculation could therefore understate program effectiveness, particularly for programs intentionally designed to support upward mobility through continued learning.
Excluding currently enrolled students is also consistent with the Department’s longstanding approach in other accountability frameworks, including the 2023 Gainful Employment regulations and earnings metrics reported through the College Scorecard. Maintaining this consistency will support clearer interpretation of outcomes and provide a more accurate comparison across programs and institutions.
We recognize the Department’s concern that exclusions may introduce unintended incentives. However, in this context, the risk of distortion is greater if actively enrolled students are included, as doing so may discourage institutions from designing programs that promote continued education and credential progression. Such an outcome would run counter to the goals of Workforce Pell, which emphasizes alignment with workforce needs while supporting long-term economic mobility.
From an administrative perspective, excluding students who are actively enrolled should not create a significantly additional burden. The Department already has access to enrollment data through its existing systems, and applying a consistent exclusion across accountability measures may reduce complexity for institutions by aligning expectations across frameworks.
Accordingly, we recommend that the Department exclude students who are actively enrolled in postsecondary education at the time earnings are measured from the value-added earnings cohort. This approach will better reflect the realities of nontraditional student pathways, support the design of stackable and transferable workforce programs, and ensure that accountability metrics accurately capture both immediate and long-term value for students.
Value-Added Earnings: Process for Combining Multiple Cohorts (§ 690.95(h))
The Presidents Forum recognizes the Department’s goal of ensuring that value-added earnings metrics can be calculated for a broad set of programs, including those with smaller enrollment levels, by combining multiple cohorts to meet minimum sample size thresholds. We support the objective of increasing transparency and consistency in accountability measures while reducing the need for data suppression.
At the same time, as the Department considers the appropriate structure for cohort aggregation, it is important to ensure that the resulting metric remains timely, accurate, and reflective of current program outcomes, particularly for workforce programs that primarily serve nontraditional students, including working adults and military-affiliated learners.
These student populations often engage in education through flexible, iterative pathways that are responsive to changing workforce demands. Programs designed for working learners are frequently updated to reflect employer needs, incorporate new technologies, or align with evolving industry standards. Additionally, many Workforce Pell-eligible programs are intentionally structured as stackable and transferable credentials that encourage re-enrollment and continued skill development over time.
In this context, aggregating earnings outcomes across multiple years may unintentionally blend results from materially different program structures, labor market conditions, and student experiences. Older cohorts may reflect prior versions of a program or different economic environments, which could limit the ability of the metric to accurately capture the value of current program offerings. This may be particularly pronounced for programs serving military-connected students, where mobility, deployment cycles, and transition periods can also influence both enrollment patterns and early earnings outcomes.
We also note that nontraditional students often experience more gradual earnings progression as they balance employment, education, and other responsibilities. As a result, the timing of earnings measurement and the cohorts included can significantly influence how program value is reflected in accountability metrics.
While cohort aggregation can improve statistical reliability, extending the aggregation window too far may reduce the responsiveness of the metric and create misalignment with the pace at which workforce programs evolve. This could, in turn, discourage innovation or delay program improvements if institutions perceive that outcomes will not be reflected in accountability measures for several years.
From an administrative perspective, a clearly defined and limited aggregation approach can help balance the need for sufficient sample size with the importance of maintaining a metric that is understandable and actionable for institutions, students, and policymakers.
Accordingly, we recommend that the Department maintain a reasonable and limited cohort aggregation window of no more than the three most recent award years, avoiding the inclusion of older cohorts that may not reflect current program design or labor market conditions. This approach will support the calculation of stable earnings metrics while preserving their relevance for workforce programs serving nontraditional learners.
We further encourage the Department to consider safeguards or contextual indicators where programs have undergone significant changes, to ensure that accountability measures accurately reflect current performance. A balanced approach to cohort aggregation will better support transparency, program innovation, and the continued development of high-quality, workforce-aligned educational opportunities for working adults and military-affiliated students.
Value-Added Earnings: Programs Serving Out-Of-State Students (§ 690.95(k))
As the Department finalizes its approach to adjusting earnings for geographic differences, it is important that the methodology does not disadvantage programs that serve students across state lines, particularly through distance education.
Many workforce programs are designed to reach students beyond a single state, including working learners who rely on online and hybrid models to access education. These programs play a critical role in expanding access to training aligned with in-demand careers. An approach that applies different earnings adjustments based on the geographic distribution of students may unintentionally penalize these models, even when they produce strong outcomes.
Programs serving a broader, multi-state population should not be evaluated under a framework that places them at a disadvantage relative to programs serving primarily in-state students. Differences in methodology should not result in unequal treatment based on delivery model or student geography.
We encourage the Department to adopt an approach that ensures consistent and equitable evaluation of programs, regardless of whether they serve students locally or across state lines. Maintaining neutrality across delivery models will be important to preserving access, innovation, and student opportunity within Workforce Pell.
Sincerely,
Wesley Smith
Executive Director
Presidents Forum