Inside the Rulemaking Room: Ritchie Morrow’s Front-Row Recap - Day 1
Key Takeaways and Early Implications from Day One of Negotiated Rulemaking
📅 December 9, 2025
Dear Colleagues … Let’s Talk About What Just Happened in Rule-making
By J. Ritchie Morrow, BAEd, MSEd
Financial Aid Officer
Coordinating Commission for Postsecondary Education
Dear Colleagues,
Pull up a chair. Day One of Negotiated Rule-making gave us a few moments that made everyone sit up a little straighter… and maybe double-check their policies on the way out the door.
Let’s start with the question quietly floating around the room:
“If a student goes over Cost of Attendance, do we always have to adjust Pell?”
Short answer: Not always. And this is where things got interesting.
The Department clarified that this only comes into play when non-federal aid meets or exceeds Cost of Attendance (COA).
Picture this:
A student has a COA of $20,000. They receive $13,000 in non-federal aid and a full Pell Grant. Then, late in the game, a $1,000 outside scholarship shows up.
Everyone holds their breath…
➡️ No adjustment needed. Pell remains intact because non-federal aid is still below the COA.
Now let’s raise the stakes.
Same student. Same COA. But this time, non-federal aid is already sitting at $19,000 before that extra $1,000 arrives.
➡️ Now we’ve crossed the line. Non-federal aid equals the COA, and the full Pell Grant must be repaid.
Institutions have options here. You can report it as an overpayment or cover it on the student's behalf, depending on your policy. But either way, this is not a partial adjustment situation. It is all or nothing.
And yes, this will apply to 2025–26 summer crossover awards, so tuck that away for later.
Then came the next wave of questions.
“What exactly is Workforce Pell… and how real is it right now?”
Answer: Real, but not ready until it is officially greenlit.
A few things became very clear:
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You cannot award Workforce Pell until the Secretary signs off, even if your Governor already has
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If a program wants to live in both Workforce Pell and Prison Education spaces, it has to meet both sets of rules
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Workforce Pell does not get to exceed COA (no surprises there)
But here is where it starts to feel familiar…
If a student does not finish the program:
➡️ You are doing R2T4
➡️ You are factoring it into SAP
Because of course you are.
Now, let’s talk about enrollment overlap, because this one will trip people up:
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A student can receive both Workforce Pell and regular Pell
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But only if the enrollment periods do not overlap
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If they do overlap?
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The student has to choose one
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No stacking. No creative interpretation. Just a clean decision.
A few more details worth keeping in your back pocket:
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Weeks of study do not have to be consecutive, which opens doors for apprenticeships
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Programs must have at least two payment periods
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Governor approval is not a one-and-done. It must be re-certified before your PPA expires
And then came the line that made the room go quiet:
➡️ If a program loses approval, there is no grandfathering.
Students can finish their current payment period… and that is it.
So where does this leave us?
Somewhere between clarity and “we’re going to need to look at our policies again.”
More is coming as the week continues, and I will keep sharing what rises to the surface.
If there is something specific you want eyes on while we are in the room, let me know.
We are all navigating this together.
Until tomorrow,
Ritchie