The Real Workforce Pell Risk

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The One Big Beautiful Bill Act (OBBBA, or OB3 for the cool kids) established an extension of the Pell Grants for low income students, this time for 8-14 week workforce-oriented programs. Workforce Pell has been in the works on a bipartisan basis for nearly a decade, and last week the Department of Education (ED) reached consensus during negotiated rulemaking (NegReg) on the regulatory text that will implement the OBBBA statutory requirements. Note: this is final draft text that will go through another round of public comments and revisions in early 2026 before final implementation in July 2026.

I created (using AI) a Top 10 Letterman-style list of what 1,100 public commenters asked to be addressed in these negotiations, sharing the initial list on Dec 3rd and an update on Dec 8th. Today, I’d like to compare the results of NegReg with the Top 10 Asks. You can think of this as Using AI to Rate the Government on What the Public Asked For. Or as an exercise in making arcane regulatory text negotiations understandable.

In my view, however, most commentary perceives the risk of Workforce Pell wrong. The problem is not one of too much access without accountability, it’s potentially too little access to make a difference.

Rating the Top 10 Asks for Workforce Pell Implementation

First an infographic, then the expanded text.

1. Ensure programs lead to real jobs with employer demand

Rating: Strongly addressed

What the draft text does:

Governor approval requires alignment with high-skill, high-wage, or in-demand occupations, documented employer input, SOC mapping, and recurring review. Placement must be tied to the occupation(s) for which the program prepares students.

Will it work in practice?

Mostly. This is one of the strongest sections. The weakness is not regulatory design but state capacity and LMI quality. Job-posting data and wage records are imperfect, but the requirement for employer validation and SOC-level specificity significantly raises the bar.

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