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Welcome to the North Carolina Community College System Workforce Pell Toolkit. 
 
This resource is designed to help colleges navigate and implement the expanded federal Pell Grant eligibility for high-quality, short-term workforce education programs. The toolkit provides practical guidance, templates, and best practices to support colleges in aligning eligible programs, ensuring compliance, and maximizing student access to financial aid. Whether your college is beginning to explore Workforce Pell opportunities or refining existing processes, this toolkit offers the tools and resources needed to help North Carolina students gain valuable skills for high-demand careers.
NCCCS Contacts 
Dr. Andrew Gardner, Associate VP, Workforce Strategies, gardnera@nccommunitycolleges.edu 
Dr. Torry Reynolds, Associate VP, Student Services, reynoldst@nccommunitycolleges.edu

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<h3>Launch &amp; Scope</h3>
<h4>Based on <a href="https://www.congress.gov/bill/119th-congress/house-bill/1/text">H.R. 1</a>, which was signed into law July 4, 2025, Pell Grants will be extended to students in short-term workforce programs that meet specific federal requirements. These programs must be at least 150 but less than 600 clock hours, last at least eight but less than 15 weeks, lead to a credential, and articulate to academic programming. (See Appendix A.)</h4>
This is a significant shift in federal financial aid policy, as Pell has historically been limited to degree and longer-term certificate programs. The new scope acknowledges the value of short-term training in preparing individuals for high-demand jobs and provides colleges with a new opportunity to expand access. It also supports the option of further education through academic programming. Colleges must carefully review program structures to ensure they fall within the federally defined range, making curriculum adjustments if necessary to maintain eligibility.
While the timing is not certain for the federal launch of Workforce Pell, the current plan by the federal government is for Workforce Pell to be launched initially on July 1, 2026. More may be known following federal rule negotiation process, which is scheduled to take place in December 2025 and January 2026. The NC Community College System plans to do all it can to be ready and help colleges be ready for implementation by July 2026. This document is the first step in that process.
Student Aid Parity
Although this is a new category of Pell-eligible programs, the rules of Pell still apply. Students must complete the FAFSA, meet Satisfactory Academic Progress (SAP) requirements, and be enrolled in a program approved for Pell funding. Importantly, students cannot receive Pell funding for both a Workforce Pell program and a traditional Pell program during the same enrollment period (Fall, Spring, Summer terms). This prevents “double dipping” and ensures that Pell is applied correctly. Colleges must develop intake processes that check for overlapping enrollments and communicate clearly with students about which type of Pell they are receiving.
Three-Layer Eligibility
Approval for these programs operates at three levels of oversight:
<ul>
	<li>State Workforce Board, on behalf of the Governor: Confirms that programs align with labor market demand and recognized credentials. In North Carolina, the NCWorks Commission is the state workforce board, staffed by the NC Department of Commerce.</li>
	<li>Accreditor: Must recognize the program as eligible for Title IV funding. Accreditor approval is critical, as it validates the academic and quality standards of short-term workforce programs including Continuing Education.</li>
	<li>U.S. Department of Education (ED): Has final authority to grant Pell eligibility. By law, ED must render a decision within 120 days of submission.</li>
</ul>
During the transition period, interim accreditor authority may be used to prevent delays, but colleges should anticipate additional review and possible follow-up requests. This layered approach is designed to balance flexibility for colleges with accountability to taxpayers.
Data and Transparency
The new Pell authority comes with heightened reporting and transparency requirements. Colleges must submit annual data on program outcomes, including enrollment, completion, placement, and wages. These outcomes will feed into the College Scorecard, making them publicly available alongside traditional degree programs.
For students, this provides critical information about the return on investment of short-term training. For colleges, it creates a strong incentive to maintain high standards in program design and delivery. Data privacy remains essential — especially around wage reporting, which often requires matching student data to state employment records. Colleges must adopt data governance practices that comply with FERPA and state privacy laws while still meeting federal transparency requirements.
Processing Timeline
To ensure colleges can launch new programs efficiently, the Department of Education must make a decision on program eligibility within 120 days of submission. This timeline requires colleges and the System Office to be highly organized in preparing applications and documentation. Any delays in submitting complete and accurate information could result in missed opportunities for students. Colleges should plan backward from their intended program start dates, building in time for state-level vetting, accreditation considerations and approvals, and federal approval. The interim accreditor authority allows some flexibility, but permanent approval should always be the goal to minimize compliance risks.

Program Identification
The first step in implementing Workforce Pell for short-term continuing education is identifying which courses meet federal and state requirements. An initial review of System data from 2024-25 has identified more than 90 Workforce Continuing Education courses that have had some course sections offered within the 150–599 clock-hour range, have a credential associated with the course, that meets state labor market criteria, and can be completed in eight to (less than) 15 weeks.
Colleges should treat this list as a starting point. These courses form a strong baseline inventory, but each must undergo further review at the college level to determine courses offered locally within the required time frame; identify articulation of credit for each potential program; and confirm that they meet workforce demand, accreditation standards, federal eligibility criteria, and labor force outcome requirements. Additional programs may be added as industry needs evolve. The Governor’s Office has indicated its intent to use the NC Workforce Credentials List as the guiding source for determining eligibility.
Alignment with the NC Workforce Credentials List
Federal law requires that Workforce Pell programs lead to industry-recognized credentials with proven labor market value. Recognized postsecondary credentials include academic credentials, occupational licenses, and third-party, industry-recognized credentials. A subset of short-term academic credentials (e,g., Certificates) might qualify if the credit hours required are equivalent to the 150-599 clock hour Workfoce Pell requirement and the program is run in less than 15 weeks. In North Carolina, all eligible Workforce Continuing Education programs must align with the NC Workforce Credentials List, which is maintained in collaboration with employers, workforce boards, and state agencies.
This alignment is not a procedural formality; it is a critical accountability measure that ensures Pell dollars are only used for programs that:
<ul>
	<li>Lead to nationally or state-recognized credentials (ranging from state licensing to industry-recognized credentials such as NCCER, CompTIA, CDL, AWS).</li>
	<li>Are validated by employers as valuable for hiring and promotion.</li>
	<li>Demonstrate strong return on investment through wage and employment outcomes.</li>
</ul>
Through this requirement, Workforce Pell investments are safeguarded to support high-demand, high-value training pathways that matter to both students and employers.
Community colleges are encouraged to review existing credential lists as Workforce Pell implementation nears: the NC Workforce Credentials list and the NCCCS WCE (Colleague) Credential list. 
<ul>
	<li>When the <a href="https://nccareers.org/credentials/credentials-list">NC Workforce Credentials list</a> is referenced with regard to student support, it is a subset of credentials -- the “List of Essential and Career Credentials”-- that is deemed to meet criteria for most CE scholarships and will be considered for Workforce Pell.</li>
	<li>The existing NCCCS (WCE) Credentials list includes all credentials that colleges are authorized to attach to Workforce Continuing Education courses in Colleague : <a href="https://wordpress.nccommunitycolleges.edu/wp-content/uploads/2025/09/WCE-Credentials-List-Sep-2025.pdf">WCE-Credentials-List-Sep-2025.pdf</a></li>
</ul>
A collaborative effort among System Office staff, colleges, and relevant stakeholders will ensure that the NC Workforce Credentials List remains current, relevant, and aligned with high-value credentials that colleges actively deliver. At the same time, processes are being streamlined:
<ul>
	<li>Colleges may submit proposed new credentials directly to the System Office using the standard WCE Colleague Credential <a href="https://wordpress.nccommunitycolleges.edu/wp-content/uploads/2023/12/11_wce_request_form_-_combined.colleaguecredentialrequestform.pdf">Request Form</a>. These will then be forwarded to the NC Workforce Credentials Advisory Council for consideration and possible addition to the NC Workforce Credentials List.</li>
	<li>Employers will continue to submit proposed credentials through the <a href="https://nccareers.org/credentials/faqs">NC Workforce Credentials Master Submission portal (via FAQ page)</a>. These will also be reviewed by NCCCS for possible inclusion in the Colleague credential database for Workforce Continuing Education.</li>
</ul>
This dual submission structure creates a more efficient and seamless process for colleges while preserving employer input into the state’s credential priorities.
Federal Hour Restrictions
Early federal guidance makes clear that programs that are 600 clock hours or more are not eligible for Workforce Pell. This limitation directly impacts high-hour programs such as Basic Law Enforcement Training (BLET). Splitting programs into Part A and Part B does not resolve the issue unless Part A independently leads to a qualifying credential.
Pre-Screened Eligible Programs
Appendix B displays a table of pre-screened Workforce Continuing Education courses and credentials that fall within the 150–599 clock-hour window and are currently included on both the NC Workforce Credentials List and the NCCCS (WCE/Colleague) credential list.
This table is intended to serve as a practical reference tool for colleges as they take the first step to identify programs that may qualify for Workforce Pell. Please note: This list is preliminary and subject to change. In addition, all courses connected to a registered Apprenticeship are also eligible, provided they meet the federal clock-hour requirements.
After considering the number of clock hours and credential alignment, colleges would still need to review potential workforce programs against other program eligibility criteria, including number of weeks the program is run, student completion and labor market data, and other factors delineated in the law. See Appendix C: Checklist for Workforce Pell Program Eligibility.
Workforce Pell and Credit Programs
Although the majority of eligible programs in North Carolina are expected to be noncredit (Workforce Continuing Education) programs, academic programs with a workforce focus, a “recognized postsecondary credential” built into the program, stackable credentials, and time windows that meet Workforce Pell requirements may also be part of colleges’ Workforce Pell portfolio. The System Office will be on standby to help community colleges explore this avenue as well as Workforce Continuing Education program options.

Program Setup in Colleague
To ensure compliance with federal requirements, continuing education (CE) programs must be entered into Colleague as Title IV–eligible clock-hour programs. This requires careful setup of program attributes such as program length, credential outcome, and clock-hour equivalency. Each program should be tagged with a unique identifier or program group code to separate CE Pell programs from traditional degree programs. This distinction will simplify reporting, auditing, and troubleshooting. Additionally, accreditor approval must be documented in Colleague and maintained in institutional records, ensuring a clean audit trail if reviewed by the Department of Education.
Cost of Attendance (COA) &amp; Pell Proration
The traditional COA model must be adapted for short-term CE programs. Because these programs often last just a few weeks or months, the COA must be prorated to reflect the shorter instructional period. Eligible costs typically include tuition and fees, books, supplies, tools, exam fees, and transportation. Colleges should publish standardized COA tables by program length (150–299 hours, 300–449 hours, 450–599 hours) to ensure consistent calculations across campuses. Pell awards will be prorated based on the number of clock hours and weeks of instruction, requiring financial aid staff to apply formulas consistently and document calculations clearly in student files.
Aid Packaging &amp; Intake
Unlike traditional programs with semester-based cycles, CE programs start at multiple points throughout the year. This creates a rolling intake for Pell packaging. Colleges must design intake processes that align financial aid packaging with program start dates rather than term start dates.
During intake, students must complete program-specific disclosures that outline the credential offered, program costs, expected completion timeline, and projected wage outcomes. These disclosures should be stored in the student’s financial aid record to demonstrate compliance with federal consumer information rules.
Attendance &amp; Disbursement
Because CE Pell operates in a clock-hour or modular format, attendance is not only a matter of recordkeeping but also a condition of disbursement. Institutions must implement systems that verify attendance before Pell funds are released. Disbursements should follow modular schedules, with funds released at the midpoint of the program or at specified clock-hour thresholds. Withdrawal processing must follow Return to Title IV (R2T4) rules, which require calculating the portion of aid earned based on the student’s actual hours attended. Colleges should create standardized R2T4 templates to avoid errors, since clock-hour R2T4 calculations are often more complex than term-based ones.
Consumer Information
Federal law requires that students be informed of key program details prior to receiving Pell funds. Colleges must publish CE program disclosures online, including program costs, length, completion rates, median wages, and certification/licensure requirements. These disclosures should be updated annually and made easily accessible to prospective students. Additionally, colleges should establish a confirmation process (such as an electronic acknowledgment in Colleague or a signed disclosure form) to document that students received and understood the information. Retention of these confirmations is critical for compliance audits.
Student Support Models
Recognizing that CE students often face unique barriers, the financial aid process should be paired with wraparound student support services. Colleges are encouraged to adopt navigator or case manager models that provide individualized assistance with enrollment, financial aid, and external supports such as childcare, transportation, and exam fee coverage. These navigators serve as a single point of contact for students, ensuring they can persist through short but intensive programs. Where possible, colleges should partner with local workforce boards, social service agencies, and employers to supplement institutional resources and remove barriers to program completion.

As community colleges prepare for Workforce Pell at their institution, leaders at various levels will need to assess their college’s capacity in areas such as eligible program identification, employer engagement and hiring, credit for prior learning pathways, program development, student outreach, student outcome follow-up, and research and IT systems. Staffing and funding may need to be concentrated in these various areas.
<ul>
	<li>Program identification: Determine local workforce programs that are likely to qualify currently or may be positioned to be successful Workforce Pell programs in the future.</li>
	<li>Assessment and expansion of data and related IT, for more robust tracking of students and program completers and collecting the specific data called for in the law.

<ul>
	<li>May need to develop partnerships with other state and federal agencies or private contractors to be able to meet federal reporting requirements.</li>
</ul>
</li>
	<li>Adequate Staffing: In Financial Aid, workforce programming, and research/IT areas, additional staff time may need to be devoted to meet student needs, complete additional processes, and fulfill reporting requirements.</li>
	<li>Employer Engagement: Input from advisory councils and individual employers is needed to validate demand and commit to hiring from Workforce Pell programs.</li>
	<li>CPL Matrices: Colleges will need to map CE into credit-bearing pathways, within their college or with other institutions in the System.</li>
	<li>Access: Financial Aid/Student Services, WCE, CTE, and the Foundation will need to coordinate messaging/guidance about Workforce Pell as part of a portfolio of support.</li>
	<li>Implementation Planning: Coordination will be needed across academic affairs, WCE, Financial Aid, Student Services, Institutional Research, and the Business Office.</li>
	<li>Continuous Improvement: Throughout, it will be important to collect and apply feedback from faculty, staff, and students.</li>
</ul>

In putting together this toolkit, the System Office has been careful not to overstate what is known about federal expectations and processes. There are many concepts that were raised in previous versions of Workforce/Short-term Pell proposals that are not written in the law passed in July 2025, and the negotiations about federal regulations for Workforce Pell will not start until December. To follow are examples of the questions that remain:
<ul>
	<li>Will colleges be responsible for producing all data needed for accountability, or might some data come from other government (state or federal) sources? Examples include completers’ job placement statistics (given that the law stipulates a very specific 180 days after completion for figures are to be collected) and median earnings, adjusted for state and regional differences.

<ul>
	<li>Might there be encouragement from the federal government for state workforce agencies with employment data to collaborate more closely with higher education institutions in sharing data?</li>
	<li>Will the federal government provide formulas for median earnings adjustments?</li>
</ul>
</li>
	<li>What can Workforce Continuing Education leaders expect when accreditation applies to their programs as well as academic programs?</li>
	<li>What evidence of articulation of credit from CE to CU will be needed to satisfy the articulation requirements of Workforce Pell?</li>
	<li>Will the federal government offer data analysis tools to states, as it sometimes has in Financial Aid in the past?</li>
	<li>Given language in the law about credential attainment “upon completion” of the Workforce Pell program, will credentials need to be embedded in the programs for programs to qualify? Will this limit the scope of programs that can easily qualify for Workforce Pell?</li>
	<li>What professional development will be available from the Department of Education or consultants on its behalf? How will federal staffing cuts affect federal timelines and available technical assistance?</li>
</ul>
The System Office will continue to monitor federal guidance and government affairs offices of major national partners, participate in input on rulemaking, and keep communicating with NC Congressional offices throughout the development and rollout of federal guidance.

<a href="https://www.congress.gov/119/plaws/publ21/PLAW-119publ21.pdf">Public Law 119-21</a> (H.R. 1 as signed into law on 7/4/2025) Section 83002: Workforce Pell Grants (pp. 280-283)

Some Potentially Eligible Course/Credential Combinations
This table shows courses within the 150–599 clock-hour window that can be run with credentials that are on both the NCCCS WCE Credential List and the NC Workforce Credentials List. Courses on this list would need to be further vetted in terms of the number of weeks the program may be offered at a college, the ability to articulate credit to academic programs, student completion outcomes, and completer labor market outcomes. In addition, there may be other courses that lead to credentials that have not yet been considered for WCE or NC Workforce Credential lists and would be good future additions.
<a href="https://wordpress.nccommunitycolleges.edu/wp-content/uploads/2025/10/Appendix-B-Courses.ods">Appendix B Courses</a>

Checklist for Workforce Pell Program Eligibility
Qualifying program must meet ALL of the following requirements:
<ul style="list-style-type: circle;">
	<li>Workforce program of at least 150 clock hours but less than 600 clock hours (or equivalent number of credit hours)</li>
	<li>Offered for at least 8 weeks but less than 15 weeks</li>
	<li>Leads to a <a href="https://www.dol.gov/agencies/eta/Performance/resources/credential-attainment">recognized postsecondary credential</a> that is stackable and portable across more than one employer, or the only recognized postsecondary credential for an occupation</li>
	<li>Articulates to academic credit in a certificate or degree program (at least one institution accepts credit)</li>
	<li>Is not a correspondence course (see definition at <a href="https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-600/subpart-A/section-600.2">eCFR: 34 CFR 600.2 -- Definitions.</a>)</li>
	<li>Has been offered for at least a year</li>
	<li>Verified completion rate of at least 70% (achieved within 150% of normal time to completion)</li>
	<li>Verified job placement rate of at least 70% (measured 180 days after completion)</li>
	<li>Value-added earnings &gt; program tuition and fees (adjusted median earnings of students who had completed program three years earlier minus 150% of <a href="https://aspe.hhs.gov/sites/default/files/documents/dd73d4f00d8a819d10b2fdb70d254f7b/detailed-guidelines-2025.pdf">FPL for single individual</a>) must be greater than program tuition and fees</li>
</ul>

Proposed Rule, U.S. Department of Education Public Hearing; Negotiated Rulemaking Committees
34 CFR Chapter VI [Docket ID ED-2025-0151] – 7/25/2025
Discusses Department of Education plans to hold a public hearing on August 7, 2025 and collect written comments providing advice and recommendations. It describes two negotiating committees, one to address loan issues (Reimagining and Improving Student Education, or RISE Committee) and another to address Pell issues including Workforce Pell (Accountability in Higher Education and Access through Demand-driven Workforce Pell, or AHEAD Committee).
As written in the proposed rule:
Negotiated Rulemaking
We announce our intent to develop proposed Title IV, HEA program regulations by following the negotiated rulemaking procedures in section 492 of the HEA (<a href="https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapIV-partG-sec1098a.pdf">20 U.S.C. 1098a</a>). That section requires that, after obtaining advice and recommendations from individuals and representatives of groups involved in the Title IV, HEA programs and before publishing any proposed regulations to implement programs authorized under Title IV of the HEA, the Secretary prepare draft regulations and submit such regulations to a negotiated rulemaking process. We intend to choose members for two rulemaking committees from individuals nominated by groups involved in the Title IV, HEA programs. We will select participants with demonstrated experience in the relevant subjects under negotiation, in accordance with section 492(b)(1) of the HEA (<a href="https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapIV-partG-sec1098a.pdf">20 U.S.C. 1098a</a>).
…
The AHEAD Committee will meet in-person for two multi-day sessions on the following dates:
Session 1: December 8, December 9, December 10, December 11, and December 12, 2025.
Session 2: January 5, January 6, January 7, January 8, and January 9, 2026.
…
The proposed issues for negotiation in the AHEAD Committee include:
1. Changes in institutional and programmatic accountability measures, including loss of Direct Loan eligibility for certain programs with low earnings outcomes for 2 out of 3 years, and Financial Value Transparency and Gainful Employment.
2. Establishment of program eligibility requirements for a new Workforce Pell Grant for students enrolled in programs that last a duration of 8-15 weeks, are transferable to a recognized postsecondary credential or degree, are approved by the state governor, and have strong outcomes.
3. Exclusion of Pell Grant assistance for students who receive grant or scholarship aid covering their entire cost of attendance or for students with a Student Aid Index in excess of twice the maximum Pell Grant award. 4. Other provisions included in <a href="https://www.govinfo.gov/content/pkg/PLAW-119publ21/pdf/PLAW-119publ21.pdf">Public Law 119-21</a> that are effective upon enactment, on July 1, 2026, on July 1, 2027, or on July 1, 2028

DRAFT: NCCCS Workforce Pell Resources

DRAFT: Workforce Pell Toolkit

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