“When a man knows he is to be hanged in a fortnight," Samuel Johnson said of a condemned acquaintance, "it concentrates the mind wonderfully."
State leaders staring down an impending and critical July deadline for implementing Workforce Pell might recognize the feeling Johnson conjures with the quote above. The provision of H.R. 1, which makes short-term training programs eligible for Pell Grants, could seriously strain state data systems. Requirements for data collection, analysis and reporting can challenge even the most robust state data systems. Yet those very requirements could also give states an opportunity to create the kinds of data systems they have long strived for.
Workforce Pell throws states into the deep end. Eligible programs must last between 8–14 weeks or 150–599 clock hours, meet 70% completion and job placement thresholds, align with high-skill, high-wage or in-demand occupations, and serve as a steppingstone to further credentials. By 2029-30, states must begin reporting on the share of program completers who find jobs in fields related to their training.
As states prepare to clear that bar, they can consider the following questions:
- Do they collect basic descriptive data about short-term programs? To determine programs’ baseline Pell eligibility, states need data about their length, credential type, subject area and enrollments. They also need information about each program’s tuition and fees for U.S. Department of Education assessments.
States typically lack such information about short-term or non-degree credentials. The nonprofit Credential Engine, which focuses on credential transparency, can help states catalog and standardize data on credentials.
- Can they determine the employment outcomes of those programs? States need outcomes data to certify that 70% of students complete the programs, and 70% of those students are employed by the second quarter after completing them. To do so, they may need to link data about individual enrollment data to Unemployment Insurance (UI) wage records, which track quarterly employment and earnings for most workers.
Yet UI wage records exclude federal employees, military personnel and the self-employed. Most states also lack occupation data, which complicates the requirement to measure the share of program completers who find employment in their field of training. That requirement doesn’t take effect until 2029-30, which buys states time to enhance their wage records.
- Can they determine which programs are steppingstones to higher-level credentials? Workforce Pell requires evidence that programs lead to stackable credentials, which are building blocks to higher certificates or degrees. States will need data on transfer and articulation agreements that help secure pathways to those higher credentials.
- Can they identify high-skill, high-wage or in-demand industry sectors? Governors must certify that programs are aligned with such sectors in their states, a determination they can make at their own discretion. That discretion presents an opportunity to track workforce demands in real time as technologies, like AI-powered tools, accelerate changes to the skills employers demand. Several states are laying this foundation through the Industries of Ideas initiative, a U.S. National Science Foundation-funded effort to measure how investments in AI are affecting state and regional labor markets.
States with robust Statewide Longitudinal Data Systems are best equipped to address the data challenges, but every state has work to do. The breadth of Workforce Pell’s requirements for data collection, analysis and reporting can push any state to improve its data systems in ways that go beyond mere compliance.
By requiring governors to certify programs, Workforce Pell places responsibility at the executive level, which can foster cross-agency coordination. It will require states to create durable data governance structures that facilitate data-sharing across relevant agencies. Such structures can far exceed the goals of Workforce Pell.
There are many considerations as the federal government and states consider how to implement Workforce Pell’s requirements. Indeed, the recently released Workforce Pell Notice of Proposed Rulemaking seeks input on how to calculate, verify and prevent manipulation of the earnings, employment and cost data that establish eligibility. States must also find interim reporting methods (e.g., provider-reported employment verification, third-party credential records, etc.) until more reliable systems are functional.
Even so, Workforce Pell can help more state leaders focus their minds on data systems that better illuminate pathways to opportunity and prosperity.
