Inside the Rulemaking Room: Ritchie Morrow’s Front-Row Recap - Day 2
March 21, 2026
📅 December 10, 2025
Dear Colleague… Day Two Brought Receipts (and a Few Curve Balls)
By J. Ritchie Morrow, BAEd, MSEd
Financial Aid Officer
Coordinating Commission for Postsecondary Education
Dear Colleague,
Greetings from a surprisingly cool DC, where the temperature dropped a bit… but the conversations did not.
Day Two leaned heavily into Workforce Pell mechanics, with a mix of clarifications, early revisions, and a few signals about where things might be headed (with emphasis on might).
Let’s walk through what rose to the top.
“Are they already changing language from Day One?”
Short answer: Yes. And quickly.
The updated Workforce Pell regulatory draft reflects changes already made or under consideration in response to Day One feedback.
A couple of details worth noting:
-
Emergency Aid (Section 480(i))
➡️ Will be excluded from the calculation under 34 CFR 690.5(b) -
Pell / COA / Non-Federal Aid language (34 CFR 690.80(d))
➡️ Still actively being reworked
➡️ Translation: Do not operationalize anything yet
This one is still very much in motion.
“How will Workforce Pell actually be calculated?”
We received examples outlining how Workforce Pell awards may be calculated, along with a separate framework for Value Added Earnings (VAE).
Why does that matter?
Because VAE will ultimately help determine the maximum tuition and fees that can be charged for eligible programs.
Yes… pricing is now part of the conversation in a very real way.
“Can Workforce Pell cover apprenticeships?”
This one got a clean clarification:
➡️ Workforce Pell can cover the technical coursework tied to an apprenticeship
➡️ It cannot be used to pay for the apprenticeship itself
So think classroom, not the job site.
“What makes a program eligible?”
This was a big chunk of the day—and for good reason.
Baseline expectation:
-
A program must be in existence for at least one year
-
It must meet all state approval requirements
But here is where reality stepped in:
➡️ ED signaled some flexibility due to tight implementation timelines
For example, if minor program adjustments are needed this summer to align with Workforce Pell requirements, ED indicated that may be allowable.
Not a free pass… but not a closed door either.
“What about the 70% completion requirement?”
This sparked a lot of conversation.
The current expectation:
➡️ 70% of students must complete the program within 150% of normal time
But negotiators raised some important concerns:
-
ED may consider excluding certain student populations from the calculation (similar to FVT treatment)
-
There was strong encouragement to shift this calculation to the federal level, rather than relying on state-level data
Why?
Because if a student completes your program but gets hired out of state, that outcome may not be captured in state data… which could unfairly hurt program performance metrics.
Using federal data sources (ED, Department of Labor, and possibly IRS) would create a more complete and accurate picture.
So… where are we after Day Two?
Some clarity.
Some movement.
And a few areas where the ground is still shifting under our feet.
If Day One gave us definitions, Day Two began to shape how this might actually work in practice.
More to come as the week continues.
As always, if there is something you want me to watch closely while we are in the room, just let me know.
Until the next update,
Ritchie
Day 1 - Workforce Pell Reg Changes.docx
Calculation of Pell Grant Examples.pdf
WFP Value Added Earnings Calculations.pptx