Inside the Rulemaking Room: Ritchie Morrow’s Front-Row Recap - Day 3
📅 December 11, 2025
Dear Colleagues… Day Three Slowed Down the Room (But Not the Stakes)
By J. Ritchie Morrow, BAEd, MSEd
Financial Aid Officer
Coordinating Commission for Postsecondary Education
Editor’s Note:
You may notice a slightly different tone in today’s update. Credit and thanks to my colleague, Elizabeth McCloud (PHEAA), for capturing today’s discussions.
Dear Colleagues,
Hello from Day 3 of AHEAD, where the pace shifted, the conversations deepened, and the real work happened behind closed doors.
If Days One and Two were about laying the foundation, Day Three felt like stepping into the strategy room… with a lot happening off camera.
“Why did today feel… quieter?”
Because much of it wasn’t public.
The day opened with a review of new edits shared by ED, along with explanations of why certain proposed changes did not move forward. As with everything this week, none of this is final.
From there, the focus turned to Workforce Pell Topic 7: Losing and Regaining Eligibility, setting the stage for broader discussion.
Then came the shift.
“What were the caucuses—and why do they matter?”
After a brief open Q&A, negotiators moved into multiple caucuses—private working sessions with smaller groups representing different constituencies.
If you were watching the live stream, you probably saw long stretches of… nothing.
That “nothing” is where a lot of the real negotiation happens.
Today’s caucuses tackled some of the more complex and unresolved issues, including:
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How distance education fits within the Workforce Pell
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How to treat students who take longer than the defined program length
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How job placement rates will factor into program evaluation
These are not small details. These are the kinds of decisions that will shape how institutions build and sustain programs moving forward.
“What else surfaced today?”
A couple of items stood out:
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Consumer Information Requirements
Institutions will need to publish specific information tied to Workforce Pell programs. Details are still evolving, but transparency expectations are clearly increasing. -
Tuition and Fee Limits (and Risk)
If an institution increases tuition and fees above the value-added earnings (VAE) cap during the year, the consequences are significant:➡️ The program becomes retroactively ineligible
➡️ The institution may be liable for any disbursed Pell funds
This one landed with weight. It is not just about pricing strategy. It is about compliance exposure.
“Are we anywhere near agreement?”
At the end of the day, ED conducted a series of pulse checks across the seven Workforce Pell topics.
Not votes. No consensus. Just a temperature read.
Negotiators responded with:
👍 Thumbs up
➖ Sideways
👎 Thumbs down
And the result?
A little bit of everything.
Which tells you exactly where we are… still in it.
So… what’s the takeaway from Day Three?
Less spotlight.
More substance.
And a clear reminder that the most important conversations are often the ones you do not see.
We are getting closer on some fronts, while others are still very much in negotiation.
More to come tomorrow as the conversation unfolds.
If there are specific areas you want me to track closely, just let me know.
Day 2 - Workforce Pell Reg Changes.docxUntil the next update,
Ritchie