In a night class at Saint Paul College in Minnesota, students spend their evenings learning the essential work of caring for other people: positioning a bedpan, emptying a catheter bag, rehearsing the skills that will earn them a nursing credential and, soon after, a job at a care facility down the road. It is precisely the kind of fast, affordable, job-connected training that Congress had in mind when it created Workforce Pell, the long-awaited expansion of federal financial aid to short-term programs.
There’s just one problem with Saint Paul’s program: it doesn’t qualify for Workforce Pell. At 112 hours, it falls short of the 150-hour minimum the new rules require, and it isn’t alone. In fact, not a single one of St. Paul College’s workforce programs currently meets the criteria.

In many ways, Workforce Pell represents a triumph for the higher education community. For more than a decade, colleges and policymakers on both sides of the aisle argued that a student in a 12-week phlebotomy course deserved the same shot at federal aid as a student in a two-year degree. When the policy was written into law, it attempted to include crucial guardrails designed to ensure quality in these shorter-form programs: to earn and keep eligibility, a program must place 70% of its graduates in jobs, graduate 70% of the students who enroll, and prove that what students pay is justified by what they go on to earn. For the first time, federal aid for workforce training would be judged by whether it actually improves a student’s career trajectory.
That approach could have been an example of a small policy change having a big impact. It should have started a national conversation about outcomes. Instead, in these first months, the conversation has been far more about compliance.
Tallying totals
Walk into almost any community college today and you’ll find administrators not debating how to improve student results through Workforce Pell, but counting instructional hours, tallying week totals, and trying to decode which of their programs fit – or could fit – inside a narrow federal box. Many are discovering that their strongest offerings are too short, too long or otherwise out of bounds. Due in large part to the challenge of compliance, the rollout has been uneven and slow: as the program opened its doors, only 12 states had even published the frameworks that define which occupations qualify. Those lists vary wildly, from a few dozen certificate programs in one state to hundreds of eligible occupations in another. Most colleges lack the data systems to track whether their graduates find work at all, and have been left surveying former students by hand to document the outcomes the law demands.
Here is the most worrisome part. Faced with a maze of state and federal approvals, data requirements they can’t yet meet, and hour thresholds that disqualify programs that plainly work, some institutions will quietly conclude the effort isn’t worth it. Instead of using Workforce Pell as a catalyst to build new job-aligned programs, they won’t build those programs at all. The students whom the policy was designed to serve will never know the door was supposed to open for them. A policy designed to expand access could, through sheer administrative friction, end up narrowing it.
Of course, none of this should come as too much of a surprise. It is the oldest story in higher education: a reform conceived around outcomes hardens into an exercise in compliance before it ever reaches a student. The guardrails themselves are never the problem. The problem is letting the gates of quality crowd out the very outcomes they were built to protect, and foreclose the opportunities they were designed to expand. When a 112-hour course that leads to a real job is an automatic “no,” while the harder and more important question – is it working? – goes unasked, we have built a policy that optimizes for the wrong thing.
Making adjustments
The good news is that it’s early enough to fix this problem. First and foremost, that means treating the first year of Workforce Pell as a pilot rather than a verdict, and as a chance to learn what to simplify. In reflecting on the successes and failures of the program so far, policymakers and institutions should question the hour-and-week cutoffs that screen out effective programs, and explore ways to let the measures that matter – completion, placement, earnings – better carry the weight. States should start the hard work of harmonizing their frameworks so that a strong program isn’t eligible in one state and invisible across the border in the next. And for any of this to work, states need to invest in shared data infrastructure, so colleges compete on results rather than on their capacity to fill out forms.
Saint Paul College’s own response is instructive. Rather than give up, its leaders are redesigning by combining their nursing course with a second credential so that a longer, qualifying program can emerge. Other states and institutions are following suit: Colorado, New Jersey and Connecticut just became the first three members of a new initiative the Education Design Lab launched focused on building the infrastructure to translate federal policy into on-the-ground practice and programs. This work is a promising reminder that Workforce Pell’s real impact won’t really be in the new programs it supports. It’ll be the way it creates a forcing mechanism for states and schools to build a better, clearer understanding of which programs actually lead to positive outcomes for their learners.
This instinct – to design toward the ultimate goal of access and success for students – is the one this entire field needs right now. But to really fulfill the promise of Workforce Pell, the change needs to be a systemic one rather than program-by-program. Let’s use this moment to build a system where the question that decides funding is the only one that ever mattered: did the student end up better off?
