What Presidents Need to Know About Workforce Pell and AHEAD Rulemaking

by Presidents Forum | Apr 20, 2026 | Policy, Video

What Presidents Need to Know About Workforce Pell and AHEAD Rulemaking

What is changing with Workforce Pell

Workforce Pell is not just a new funding stream. It represents a shift in how institutions design and deliver programs.

The focus is on working adults, military-connected learners, and students who are re-skilling. These students are mobile, outcome-focused, and balancing multiple responsibilities. Institutions that succeed will treat Workforce Pell as an expansion of what they already do well, not as a separate initiative.

What presidents should prioritize now

Building Workforce Pell programs at scale requires three core capabilities.

First, program development must move faster. Institutions need governance models that allow for rapid iteration as workforce needs change. Second, strong employer partnerships are essential. High-quality programs depend on direct industry input to remain relevant. Third, institutions must have the infrastructure to track completion and job placement outcomes in real time.

Programs must also be designed with stackability in mind, giving students clear pathways to continue learning without losing momentum.

How accountability is shifting

Accountability frameworks are moving toward earnings and outcomes, but the design details will determine whether they work.

If metrics focus too narrowly on short-term earnings, institutions may be discouraged from supporting students who continue into additional credentials. Stackable pathways, which are central to Workforce Pell, do not always produce immediate income gains.

A student-centered accountability system must account for how working learners actually progress, including re-enrollment and continued education.

The risk of getting accountability wrong

There is a real risk of overcorrecting.

If accountability frameworks become too complex, institutions may pull back from offering Workforce Pell programs altogether. That would limit access for the very students these policies are intended to serve.

At the same time, weak accountability undermines trust in the system. The challenge is to strike a balance that protects students while preserving flexibility and innovation.

What to watch beyond Workforce Pell

The broader AHEAD rulemaking signals a long-term shift toward outcomes-based policy.

Institutions should pay close attention to how cohorts are defined, how long outcomes are measured, and whether continued education is properly accounted for. These details will shape how programs are evaluated in practice.

There is also growing concern about implementation complexity. Even well-designed policies can slow innovation if institutions lack the data infrastructure to execute them effectively.

What this means for institutional strategy

This moment is less about the direction of policy and more about execution.

Institutions that align program design, employer partnerships, and data systems will be best positioned to succeed Those that cannot adapt quickly may struggle to participate at scale.

The opportunity is significant, but so is the need to get the design right.

Transcript

Wesley Smith (02:24.214) Today I’m joined by President’s Forum Policy Director, Cam Mortenson, and Policy Fellow, Amy Glenn. We’re here to break down what presidents need to know about the ahead rulemaking. Cam and Amy, thanks for joining.

Cameron Mortensen (02:44.092) Thanks Wes, happy to be here.

Amy Glynn (02:46.029) Thanks so much for having me.

Wesley Smith (02:48.206) Hey, so let’s start with the first question right out of the box. What should presidents prioritize to build workforce Pell programs that work at scale, especially across states and for mobile and working learners? Amy, what do you think?

Amy Glynn (03:03.553) Yeah, so when I think about Workforce Pell, I don’t think about it as a new program. I think about it as a shift in how we operate and expand what we’re already doing really well. Like you said, the students that’s designed for our students who are reskilling, working adults, military connected, parenting students, right? They’re mobile, they’re balancing a lot, and they’re really outcome focused. So the questions for presidents, I really think are three key ones. Can your programs…

Can your program development model support the speed and agility that you need? Can your governance process accommodate iteration at the speed and need for the program relevance? And do you have the infrastructure to track and meet the completion and placement metrics? So this means really having flexibility in how our programs are built and revised, along with strong employer partnerships. Some of those highest quality programs rely deeply on that industry partnership and insight.

And we don’t want our policy to unintentionally limit that. It also means, like you said, consistency and engagement across states because students aren’t confined to one place. Universities that are used to leveraging NC-SARA to minimize state authorization burden are really going to need to ensure that they have a framework in place if developing those programs through distance education to meet those state unique needs.

and understand that their programs may not be authorized in all states because labor market and workforce demands are different. So like the most important thing is it’s about design with the learner in mind, stackable programs, clear pathways and strong support, which is exactly what our institutions are really great at already.

Wesley Smith (04:47.05) Right, right. like your emphasis though. I mean, this will be a little bit of something to navigate when it comes to scaled institutions that are operating in 50 states.

Amy Glynn (05:00.105) Absolutely.

Wesley Smith (05:01.56) Cam, what are your thoughts on presidents? What should they be prioritizing as they build towards Workforce Pell eligible programs?

Cameron Mortensen (05:10.32) Yeah, to play to continue on the cross state functionality piece is as as the laws written programs eligible for work for spell are going to be have to be approved by the state’s governor.

So it’s going to be really important for states and institutions to create a system where programs, especially those delivered online by institutions across the country, can be reviewed and approved so that students learning across the country are able to access these funds for programs that are relevant in more than just one state. So we’re going to need to all work together, states, governors, states, and institutions, in order to find the way to most efficient.

efficiently do that.

Wesley Smith (05:54.402) Yeah, right. mean, that’s going to be, hopefully, we can piggyback on, Sarah, or some other system that gets us essentially consensus from the states on what programs should meet these requirements and what programs don’t. I guess the tension there is

It’s really designed for local workforce as well. I don’t know if there is an easy resolution to this other than saying collaboration is really, really important as we move forward. Any thoughts on that, Amy?

Amy Glynn (06:31.062) that’s a big one to tackle. I agree with you absolutely, collaboration is key. We are already seeing states roll out proposed legislation and language that would have different accountability measures than the federal government would have different requirements. And so really trying to figure out how to find a solution that is elegant.

and well positioned to protect both students and institutions will be really important in seeing success in workforce Pell implementation.

Wesley Smith (07:10.518) Yeah, lots of work left to figure these things out, especially on 50 state operations. Let’s talk about a little bit, though. You mentioned states are working on some accountability, and the accountability framework is tough to say exactly what it should be. But tell us, we’re at the president’s forum, so we care about student-centric accountability frameworks. What does that look like? How can we do that without blocking innovation?

Amy Glynn (07:39.629) Yeah, I think the key here for the accountability conversation is about balance. We have to get the balance right. We absolutely want to protect students and ensure quality, but we also have to make sure we’re not building something so complex that institutions pull back from serving those students. And so one thing that’s really important is recognizing

how working learners actually move through education and getting our voice into the conversation about establishing these metrics. So with these programs, the goal is actually to increase access to stackability of the credentials so that students can re-enroll quickly.

their earnings won’t always show up in a straight line. So schools should not be penalized for having a student move more quickly into a subsequently related program. So if we don’t design these metrics carefully, looking at who’s included, when we measure, we risk missing the real value of the programs, especially for the non-traditional working adult. And so when you think about this,

Fairness really matters, right? Institutions serving students online or across states should not be at a disadvantage to traditional brick and mortar institutions. And right now there really is a risk of that. So at its best, accountability should create clarity and trust, but still leave room for institutions to respond to those workforce needs. And we need to work with our federal partners and the state partners in that triad to make sure that happens.

Wesley Smith (09:12.216) Well, I mean, to your point, the whole reason Workforce Pell was considered a necessity by legislators, by Congress, Congress thought, hey, we have some pathways to opportunity that aren’t necessarily four-year or bachelor’s or associate degrees. Whatever those look like right now, they’re not that. They’re short-term credentials that could work. And the idea here is to make these accessible to as many people as we can.

The risk that we run is with accountability frameworks that are too robust, do you actually discourage people from moving in that direction and programs from qualifying for those? But at the same time, you want to make sure that if you are putting federal dollars and investing those behind them, you get it right and you do have workforce opportunities that result in it. So Cam, tell us what your thoughts are on accountability. How do you strike that right balance?

Cameron Mortensen (10:11.43) Yeah, I think Amy’s point on on credential stacking is really important because if we set up an accountability system that is tracking the is always tracking the income of students right as they come out of programs, we’re going to de incentivize.

institutions that are encouraging students to continue their education after these workforce training programs. And I don’t think that’s necessarily the motive that we want to give. as Amy said, we really want to be student focused. We want to focus on we all I also think it’s really important that we have an accountability system that does focus on outputs rather than delivery method or other sorts of inputs. But there’s just really important nuances such as

the credential stacking.

that we need to make sure we get right. I think one other point is we don’t want to have a constantly, we don’t want to constantly be moving the goalposts. Let’s get, let’s set up a system and let’s stick to it and let’s take the time to make sure we get it right. Actually, I don’t want to say stick to it. I, I’m going to reset that part. let’s, let’s take our time to set up a system that we can all feel good about and is, is bringing true accountability, which, which we support, but let’s get it right. And let’s not try to

rush into something that will lead us to having to change it soon after.

Wesley Smith (11:37.548) Right. You did say something, Kam, that every time I hear it, I want to say amen while people are mid-sentence to it. And that is we should be working with outcomes, not inputs, when it comes to accountability. We shouldn’t be telling institutions how to get the right outcomes. We should be judging them based on their outcomes. And that’s just one of the fundamental principles that the President’s Forum has been.

advocating for decades now at this point.

Let’s let me let me move us to the final question and that is I want to look beyond workforce Pell and I want to look at other aspects of the ahead rulemaking What should institutions watch for? In any other regard Let’s not let’s put workforce Pell aside and look at other issues that that ahead addressed

Wesley Smith (12:39.382) Amy, why don’t you lead on this?

Amy Glynn (12:41.182) Yeah, so as we look what’s coming through the AHEAD and the AEM negotiations, I think the president should really be focused on how accountability is taking shape in practice. We know the direction. There’s going to be a stronger emphasis on earnings and outcomes, return on investment. We’ve seen it in AHEAD, obviously, in the accountability framework. We’ve seen it in the accreditation negotiations.

But the details really matter. How cohorts are defined. How long is data aggregated? Whether we’re accounting for students who continue their education. Those are things that are really going to determine whether these metrics actually reflect reality. The other thing I’d watch for is complexity. There’s a risk of building something that’s technically sound, but really hard to implement given our outdated data structure.

And that can slow down innovation, especially for workforce programs that need to move quickly. And then just making sure that all of this aligns with how students actually progress today, especially in our stackable pathways. For me, it’s more, it’s a moment less about where policy is going and more about whether we got the design right.

Wesley Smith (13:58.776) Right. I love your point about complexity. It’s getting it right, being right theoretically is a lot different than being right practically and driving outcomes for students. And complexity has that ability to kind of suffocate innovation if we spend too much time on the complexity of measuring outcomes. So we’ve got to get that. We’ve got to have solid outcomes, but we have to do it in a way that doesn’t suffocate innovation.

Cam, tell us anything to add to that. What else should we be looking for in the ahead rulemaking?

Cameron Mortensen (14:36.848) Yeah, I mean, just as far as kind of a schedule goes, there’s obviously a lot happening right now as far as higher education regulation executive rulemaking goes. The public comment period for the workforce Pell portion of AHEAD just closed. That’s what we’ve been talking about today. We are also going to get an NPRM, a notice of proposed rulemaking on the accountability measures that were considered in the AHEAD rulemaking.

that this is published, we’ll have finished the first week of that accreditation, innovation, and modernization or AEM negotiation. And then the next session of that will be taking place in May the 18th through the 22nd. So there’s a lot going on right now, a lot that we as the President’s Forum are following and will be involved in. So definitely stay tuned and we’re always happy to hear others’ thoughts and input as well.

Wesley Smith (15:36.142) Thanks, Cam. Thanks, Amy. We appreciate you joining us and giving us some insight on Workforce Pell specifically and what’s next in the ahead rulemaking.

Cameron Mortensen (15:46.374) Thanks.

Amy Glynn (15:47.319) Thanks for having me.

Rethinking Tuition Assistance

by Presidents Forum | Mar 20, 2026 | Policy, Working Learners

Rethinking Tuition Assistance

In contemporary debates on American defense manpower and national competitiveness, military voluntary education occupies an odd intellectual position. It is normatively celebrated as a mechanism for self-improvement and transition, and it is formally justified in statute as a tool for recruiting, retention, and readiness, yet the evaluative apparatus around it remains remarkably thin. Most analyses track enrollment, course completion, and degree attainment, occasionally extending to nearterm reenlistment effects, but they seldom grapple with the deeper question of how these programs structure the flow of human capital into the nation’s critical infrastructure workforce. Against this backdrop, the Unicorn manuscript advances a more ambitious claim: that voluntary education can be reconceived as a national institute of workforce formation if we are willing to treat individual desire as a measurable construct and link it systematically to both educational capacity and industrial demand.

The conceptual pivot in Unicorn is to move from a supplyside view of education (what programs exist, how many people use them) to a demandside view anchored in person–environment fit theory. Holland’s vocational choice framework and subsequent person–environment fit literature posit that individuals seek environments where they can express their interests and values, and that congruence between vocational personality and work setting predicts satisfaction, performance, and reduced turnover intentions. Unicorn operationalizes this insight by specifying a “Desire universe” in which each servicemember is represented by a structured object comprising a multitude of dimensions. Rather than treating desire as a vague preference, the manuscript treats it as a high-dimensional data object that can be measured, aggregated, and analyzed at scale.

Once desire is formalized in this way, new analytic possibilities emerge. At the micro level, desire objects can be matched to families of occupations across the critical infrastructure landscape, from advanced and additive manufacturing to cyber defense, energy systems, logistics, and data-intensive roles. At the meso level, aggregating these objects reveals latent patterns: clusters of servicemembers whose interest–value–skill profiles align with particular sectors, regional concentrations of underdeveloped potential, or systematic mismatches between what individuals want and what existing education pathways make visible. At the macro level, these desire distributions can be compared against labor market projections in the defense industrial base, semiconductor ecosystems, and broader national security-relevant industries, where workforce shortages in the millions are now regularly cited in both government strategies and industry analyses.

However, Desire is only one of three universes in the Unicorn architecture. The second, Capacity, reframes the higher education enterprise as a programmable layer of human capital production. Here, the manuscript argues for a comprehensive mapping of programs, particularly at regional research universities (R2s), community colleges, and technical institutes, tagged not only by discipline and credential level but by their relevance to critical infrastructure workforce categories. This capacity map makes it possible to ask analytically precise questions: Where do existing offerings already intersect with observed desire clusters for cyber or energy roles? Where are there pockets of strong desire but insufficient capacity, suggesting a need for new cohorts, microcredentials, or industry embedded pathways? And where is capacity abundant but loosely coupled to both desire and demonstrable workforce demand, raising questions of allocative efficiency?

The third universe, Connection, is where Unicorn’s analytic exposition pushes most directly into institutional design. Building on the first two universes, Connection is described as an interface between individuals, educational institutions, and the critical infrastructure workforce at large. It encompasses the matching algorithms and governance structures that translate desire and capacity into concrete trajectories: from initial counseling and course selection through completion, credential stacking, and placement into roles recognized across agencies and industries alike in the critical infrastructure taxonomies. In theoretical terms, this layer operationalizes person–environment fit not just within an abstract “job” but within a national system of essential work, where resilience of energy grids, defense supply chains, cyber systems, and logistics networks are now treated in strategic documents as a core security concern.

What makes Unicorn particularly provocative for scholars of military sociology, higher education, and labor economics is its insistence that voluntary education outcomes be evaluated against this connection frame rather than against proximal educational metrics alone. Existing empirical work on tuition assistance and related programs offers mixed evidence on retention, in part because participation has unfolded in an environment where neither desires nor workforce linkages were systematically specified. By contrast, Unicorn sketches a counterfactual regime in which education benefits are intentionally used to steer desire rich populations into undersupplied critical infrastructure roles, and in which success is measured by changes in reenlistment among targeted skill communities, promotion and readiness indicators, and postservice earnings in strategically salient sectors. This is not simply a call for better metrics but for a different dependent variable: from “did the member complete a degree?” to “did the system convert desire plus capacity into durable contributions to the critical infrastructure workforce?”.

The manuscript thus offers, in condensed form, a three universe theory of how desire, educational capacity, and economic structure might be jointly modeled in the context of U.S. defense and national security. For academic readers, it opens several lines of inquiry. One could test the stability and predictive validity of the proposed Desire construct across cohorts and services. One could examine how different capacity configurations say, varying densities of R2 institutions with strong engineering programs, alter the efficiency with which desire is translated into critical infrastructure employment. And one could interrogate the normative and distributive implications of using a military education apparatus as a national workforce instrument, particularly in light of broader debates about reindustrialization, regional inequality, and the civilian–military boundary.

Unicorn does not claim to resolve these questions within its own covers. Instead, it offers a deliberately constructed architecture, Desire, Capacity, Connection, as a researchable object, and as an invitation. If desire is indeed measurable, and if voluntary education can be reconceived as a critical infrastructure institute rather than a peripheral benefit, then scholars and practitioners alike face a different set of design problems than those that have dominated the TA literature (such as it is) to date. The full text elaborates this architecture, populates it with empirical estimates and sectoral projections, and sketches legislative and administrative pathways for implementation. The argument, in short, is that there is a unicorn here, not in the sense of an impossible creature, but in the sense of a rare institutional configuration hiding in plain sight, waiting to be specified, measured, and built.

Expanding Opportunity for Those Who Serve

by Presidents Forum | Mar 4, 2026 | Outcomes and Accountability, Policy

Expanding Opportunity for Those Who Serve

Why it matters

Military learners balance service, family, and education under extraordinary conditions.

Higher education policy must reflect that reality.

The challenge

Military learners face:

Frequent relocations
Unpredictable schedules
Training that isn’t always recognized for credit
Complex transfer and enrollment systems

Bottom line

Military learners remind us why student-first innovation matters.

Our job is to build systems that match their commitment with opportunity.

Modernizing Support for Military Learners

by Presidents Forum | Mar 2, 2026 | Policy, Video

Modernizing Support for Military Learners

Why it matters

Military tuition assistance has been capped at $250 per credit for over 20 years.

Tuition has nearly doubled.

The impact

Fewer institutions can honor the rate
Military learners have fewer choices
Out-of-pocket costs increase

The reciprocity risk

Service members move and deploy frequently.

Stable reciprocity allows them to stop out and return without losing progress.

If reciprocity weakens, access weakens.

Bottom line

Modernizing tuition assistance is about access, recruitment, and national security.

Education is not just a benefit. It is infrastructure.

ROI Is the New Accountability

by Presidents Forum | Feb 27, 2026 | Policy

ROI Is the New Accountability

Why it matters

Higher education accountability has entered a new phase. Earnings, workforce alignment, and ROI are now central to federal policy.

The change

Through AHEAD rulemaking, the Department of Education implemented:

Workforce Pell for short-term programs
A new earnings-based accountability test
Broader workforce alignment requirements

Congress set the tone: outcomes over inputs.

The new standard

Programs must show graduates earn more three years after completion than they would have without the credential.

Cost no longer factors into the federal test.

The employer opportunity

The traditional funding model is student pays, employer hires.

That model is breaking down.

In sectors like healthcare, employers face workforce shortages and high turnover costs. Redirecting dollars from bonuses and agency labor toward tuition assistance and loan repayment can improve ROI for both employers and students.

Bottom line

ROI is now the dominant lens in higher education policy.

Institutions that lead with workforce alignment and measurable outcomes will be best positioned in this new era.

The Overlooked Risk in RISE: Enrollment Intensity, Loan Limits, and Nontraditional Academic Calendars

by Presidents Forum | Feb 23, 2026 | Policy

By Amy Glynn, Policy Fellow

As the higher education community digests the Department of Education’s proposed rules following the RISE negotiated rulemaking process, much of the attention has appropriately focused on the elimination of Graduate PLUS loans, graduate loan caps, and the distinction between graduate and professional programs.

What has received far less attention is a quieter but disruptive change: the proposal to reduce annual student loan eligibility based on enrollment intensity, using a schedule defined by the Department.

For institutions operating on traditional semester calendars with largely full-time, residential students, this may appear manageable. For institutions that serve working adults, military-connected students, parents, and other nontraditional learners, particularly those using nonstandard terms, modular formats, or subscription-based models, this provision raises serious and unresolved concerns.

From “At Least Half-Time” to Proportional Borrowing

Historically, federal student loan eligibility has operated on a relatively simple threshold: if a student is enrolled at least half-time, they may access their full annual loan eligibility for that academic year.

The RISE proposal would fundamentally change that assumption. Under the new framework, annual loan eligibility would be reduced proportionally based on enrollment intensity. A student enrolled less than full-time would be eligible for only a portion of the annual loan limit proportional to the number of credits they attempt. On its face, this seems reasonable, aligning borrowing more closely with enrollment. But complexity emerges not in theory, but in practice.

Scheduled Enrollment vs. Actual Enrollment

Financial aid is awarded based on scheduled enrollment. New regulations, however, would have us look at actual enrollment.

Under the proposed rules, a student could:

Be awarded loans based on full-time enrollment,
Receive a disbursement at the start of a term,
Remain enrolled and academically eligible,
Complete fewer credits than anticipated due to work obligations, caregiving responsibilities, military service, or health issues.

If annual loan eligibility is recalculated based on actual enrollment, institutions may be required to retroactively reduce a student’s annual loan amount, after funds have already been disbursed and used for educational expenses.

This creates a new and unfamiliar compliance scenario:

No withdrawal
No failure to meet satisfactory academic progress
No Return of Title IV (R2T4) calculation, yet the student loses access to loan funds in a future term.

Now, Let’s Look at a Real-World Example

Consider a working adult student enrolled in a modular, term-based undergraduate program.

The student registers for 12 credits in Term 1, meeting full-time enrollment requirements. Based on this scheduled enrollment, the institution awards the student their full annual Direct Loan eligibility, and the first loan disbursement is released at the start of the term. Tuition and fees for the full term are assessed and covered as expected.

Midway through the term, the student experiences an unanticipated life disruption, such as a change in work schedule or loss of childcare, and withdraws from Module 3. The student does not withdraw from the term or the institution, remains academically eligible, and completes 9 credits in Term 1. No R2T4 calculation is triggered, and the student remains in good academic standing.

In Term 2, the student enrolls full-time, with tuition and fees assessed accordingly. However, under the proposed enrollment-intensity-based loan limits, the student’s annual loan eligibility is recalculated based on the prior term’s actual enrollment. Because the student attempted fewer than 12 credits in Term 1, their annual loan limit is reduced.

As a result, the second loan disbursement is prorated, leaving the student with an unexpected balance owed in Term 2, despite full-time enrollment and continued academic progress.

From the student’s perspective, this outcome is both confusing and destabilizing. The student did not withdraw, did not fail academically, and did not change programs, yet a temporary and unavoidable life circumstance has resulted in reduced loan access for a future term.

For institutions serving working adults, military-affiliated learners, and student parents, particularly those using modular or nontraditional academic calendars, this scenario is not hypothetical. It reflects the lived reality of students whose enrollment intensity may fluctuate even as they persist toward completion. Without clear regulatory guardrails, a framework designed to align borrowing with enrollment risks, turning flexibility into a financial penalty.

Why Nontraditional Calendars Are Especially Exposed

This issue is amplified for institutions that operate outside the traditional semester model.

In modular or term-based programs:

Enrollment intensity may vary intentionally across modules
Students often accelerate, decelerate, or pause between modules

In subscription or competency-based models:

Progress may not align neatly with credit-based enrollment status
Enrollment is continuous, but intensity fluctuates

In these environments, enrollment variability is not an exception. It is the design.

Applying proportional annual loan reductions without clear safeguards risks penalizing students for the very flexibility that allows them to persist. This creates an administrative burden that is exponentially higher while ultimately obfuscating the funding journey and complicating student advisement.

The Equity Implications Are Real

Students most likely to be affected include:

Working adults balancing full-time employment
Student parents navigating caregiving responsibilities
Military-affiliated students facing deployment, training, or relocation
First-generation students managing unpredictable life demands

These students are often continuously enrolled, academically engaged, and progressing toward completion, but not always at a consistent credit load.

A policy that permanently reduces annual loan eligibility based on a single term of reduced enrollment could unintentionally undermine access and persistence for the very populations Title IV is meant to support.

Why This Moment Matters

This is not a question of whether enrollment intensity should matter but how it matters, and whether the rules recognize the realities of nontraditional students and nontraditional academic models.

If implemented without flexibility, this provision risks creating confusion for students, imposing administrative burdens on institutions, and unintended barriers to completion.

If implemented thoughtfully, it could align borrowing with enrollment without undermining access.

That balance is worth getting right. It requires colleges and universities, along with their financial aid professionals, to elevate this conversation so that students are not the victims of unintended consequences.

« Older Entries

Next Entries »