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Workforce Pell’s upcoming launch represents a landmark opportunity to expand access to high-quality, short-term job training for workers who need it most. America Forward recently submitted formal comments in response to the Workforce Pell proposed rule, urging the Department of Education to institute two critical fixes that would support practical implementation while protecting quality:

• Raise the partnership cap from 25% to 49%. The proposed rule would bar high-impact non-institutional workforce providers from contributing more than 25% of a Workforce Pell program, a restriction that directly contradicts how high-performing partnerships actually work in practice. As proven providers and America Forward Coalition members NPower, Per Scholas, and Propel America attest, a 25% limit would pose enormous practical challenges. America Forward recommends applying the standard 49% threshold (with accreditor approval), consistent with other Pell-eligible programs, and capping accreditor review timelines at 30 days to ensure programs can respond to labor market conditions in real time.
• Allow regional— not just bilateral — governor’s agreements. The proposed rule limits reciprocity agreements to two states at a time, likely creating a confusing web of redundant approvals that is misaligned with how modern labor markets actually function. Many providers in the America Forward Coalition operate across multi-state regions, like the DMV (DC-Maryland-Virginia) or the New York-New Jersey-Connecticut tristate area, and should be able to partner with institutions to serve learners across those regions without navigating fragmented, duplicative approval processes.

America Forward was also proud to join an aligned set of coalition comments led by the National Skills Coalition addressing the 25% limitation alongside other key technical changes such as how students continuing their education are counted under the Workforce Pell job placement metric; data modernization to strengthen program quality and accountability; and eligibility of noncredit programs offered in clock hours.

Workforce Pell’s success will, in large part, depend on effective partnership with many of the non-government providers with the deepest employer relationships, strongest placement infrastructure, and clearest accountability for employment outcomes. We urge the Department of Education to implement this critical program in a way that matches its potential.

Read America Forward’s full comment here.