Commission Policy | CPS 04-2026 Workforce Pell Grant Program Eligibility Requirements and Application Process

The following text is provided for the benefit of the reader; however, the Microsoft Word document version of the Commission Policy Statement is authoritative. 

• Date: May 13, 2026
• Subject: Workforce Pell Grant Program Eligibility Requirements and Application Process
• From: Tom B. Rabon, Jr., Chair, NCWorks Commission

Purpose:

To establish policy and procedures for the implementation and administration of Workforce Pell in North Carolina, including eligibility, program application, program approval, and oversight requirements.

This Commission Policy Statement establishes the governing framework for Workforce Pell implementation and provides initial guidance for its administration in accordance with applicable federal and state law.

Background:

The U.S. Congress H.R. 1 (2025) established the Workforce Pell Grant Program as a new federal financial aid program, falling under Title IV of the Higher Education Act (HEA), which covers federal student aid. Workforce Pell expands Pell Grant eligibility to students enrolled in approved short-term workforce training programs at eligible institutions. Federal law requires the Governor, in consultation with the NCWorks Commission, to determine eligible programs that prepare students for high-skill, high-wage, or in-demand occupations, with credentials that are stackable and portable across employers. These programs must meet other outlined criteria, including a duration of 8 to less than 15 weeks, and minimum performance thresholds of 70% program completion within 150% of normal time and 70% job placement within 180 days. Congress directed that the program be implemented beginning in July 2026.

The U.S. Department of Education (U.S. ED) convened a negotiated rulemaking committee to develop the federal regulatory framework necessary for Workforce Pell Grant Program implementation. The U.S. Department of Labor (U.S. DOL) played an integral role in the rulemaking process and has emphasized that states should align Workforce Pell implementation with existing Workforce Innovation and Opportunity Act (WIOA) systems.

Applicable federal authority includes:

• U.S. Congress. (2025). H.R. 1 — An act to provide for reconciliation pursuant to title II of H. Con. Res. 14 (Public Law No. 11921, Subtitle B, Section 83002). Congress.gov. 
• Higher Education Act of 1965, Title IV, 20 U.S.C. §§ 1070-1099d
• 34 C.F.R. Part 600

In North Carolina, Governor Stein designated the NCWorks Commission as the lead state agency responsible for the administration, coordination, implementation, and oversight of the Workforce Pell Grant Program. The NCWorks Commission has the authority to determine whether an institution’s program meets the requirements for Workforce Pell outlined in this policy.

Definitions:

CIP Code: Classification of Instructional Program (CIP) Code used for federal, state, and institutional data reporting to identify, track, and report specific programs of study in higher education.

CIP-SOC Crosswalk: A federal tool developed by the Bureau of Labor Statistics and the National Center for Education Statistics that matches 6-digit Classification of Instructional Program (CIP) Codes to 6-digit Standard Occupational Classification (SOC) Codes.

Eligible Training Provider (ETP): Provider of training services who has met the eligibility requirements to receive WIOA Title I Adult, Dislocated Worker, and Youth funds to provide training services to eligible individuals. This includes: 

• Post-secondary education institutions; 
• Registered Apprenticeship programs; 
• Other public or private providers of training, which may include joint labor-management organizations and eligible providers of adult education and literacy activities under Title II, if such activities are provided in combination with occupational skills training; 
• Local Area Workforce Development Boards (WDBs) that meet the condition set forth in WIOA Sec. 107(g)(1); and
• Community-based organizations (CBOs) or private organizations of demonstrated effectiveness that provide training under contract with a Local Area WDB.

Eligible Training Provider List (ETPL): North Carolina’s statewide list of approved providers of training services who are eligible to receive WIOA Title I-B funds.

Employer Validation: Indication that employer feedback was sought and used in the development or maintenance of the Workforce Pell Grant Program applicant. 

High Skill: Requires postsecondary education or above, NC state licensure, or a NC Workforce Credential 

High Wage: An occupation with a Star Jobs System Rating of 3 or higher. See Appendix A for methodology.

In-Demand: An occupation with a Star Jobs System Rating of 3 or higher. See Appendix A for methodology.

Participating Institution: A federal Pell Grant-eligible Postsecondary Institution designated as Title IV eligible by the U.S. ED that offers Short-term Programs in the State or enrolls students living in the State in a Short-term Program, regardless of whether it has a physical presence in the State.

Portable: A credential that is valued by multiple employers within an industry or across industries.

Postsecondary Institution: An institution that qualifies as—

(i) An institution of higher education, as defined in 34 CFR § 600.4;

(ii) A proprietary institution of higher education, as defined in 34 CFR § 600.5; or

(iii) A postsecondary vocational institution, as defined in 34 CFR § 600.6.
 

Program to Credit Articulation: A formal process that results in the recognition of Short-term Programs yielding industry-recognized certificates or certifications, occupational licenses, or registered apprenticeships towards academic credit within a certificate or degree program. If the certificate or degree program results in a Recognized Postsecondary Credential, it must be different from the Recognized Postsecondary Credential earned through the Workforce Pell Grant Program. 

Recognized Postsecondary Credential: An industry-recognized certificate or certification, a certificate of completion of a Registered Apprenticeship under 29 CFR Part 29, a license recognized by the State involved or Federal Government, or an associate or baccalaureate degree.

Registered Apprenticeship Program: An industry-driven, high-quality career pathway where employers can develop and prepare their future workforce, and individuals can obtain paid work experience with a mentor, receive progressive wage increases, classroom instruction, and a portable, nationally recognized credential. Registered Apprenticeships are industry vetted and approved and validated by the U.S. DOL or a State Apprenticeship Agency. Additionally, it is registered under the National Apprenticeship Act, ensuring it meets established standards.

Related instruction: An organized and systematic form of instruction designed to provide the apprentice, who is enrolled in a Registered Apprenticeship Program, with the knowledge of the theoretical and technical subjects related to the apprentice's occupation. Such instruction may be given in a classroom, through occupational or industrial courses, or by correspondence courses of equivalent value, electronic media, or other forms of self-study approved by the registration agency, as defined in 29 CFR § 29.2.

Short-term Program: A program of study that is at least 150 clock hours of instruction, but less than 600 clock hours of instruction, or an equivalent number of credit hours, offered by a Postsecondary Institution during a minimum of 8 weeks, but less than 15 weeks.

SOC Code: Standard Occupational Classification Code is a federal statistical standard used by federal agencies to classify workers into occupational categories for the purpose of collecting, calculating, or disseminating data.

Stackable Credential:

• A credential that possesses standalone labor market value by being aligned with an occupation meeting the definition high-skill, high-wage, or in-demand as outlined in the policy, and provides learners the opportunity for immediate employment by earning the credential; or 
• A credential that is part of a defined career pathway in which combining the stackable credentials possesses additional value in the labor market. 

Star Jobs System: North Carolina Star Jobs is a simplified approach to identify promising occupations. Star ratings are assigned based on wages, projected growth rate, and projected job openings, and each occupation has a rating of between one and five stars. Occupations with five stars are considered to have much better career prospects than occupations with fewer stars. Additional details can be found here.

State Workforce Board: shall have the meaning given in Section 3 of WIOA.  In North Carolina, this is the NCWorks Commission.

Week of Instructional Time: defined by 34 CFR 668.3(b).

Workforce Pell Grant Program: means the federal program by which Pell Grants may be awarded to students enrolled in Short-term Programs, pursuant to Section 83002 of H.R. 1, also known as the One Big Beautiful Bill Act. 

Action:

The NCWorks Commission shall have the authority to determine whether a Participating Institution’s Short-term Program meets the requirements of this CPS to allow the institution to be approved at the state level and seek approval by the U.S. ED. Approval by U.S. ED authorizes intuitions to award Workforce Pell Grants to qualifying students in accordance with federal statute and regulations.

1. Prohibitions:

In order for a Participating Institution to disburse Workforce Pell Grant Program funds in North Carolina and advertise, market, or inform students about the availability of Pell Grant funds for its Short-term Program in North Carolina, its Short-term Program must be approved pursuant to this CPS and obtained all approvals and met all requirements set forth by the NCWorks Commission and U.S. ED related to the Workforce Pell Grant Program. 

2. Workforce Pell Grant Program Application Requirements:

A Participating Institution seeking a determination that any of its Short-term Programs meets the requirements of the Workforce Pell Grant Program must complete four steps for consideration for program eligibility by the NCWorks Commission.  A separate application must be made for each program at each Participating Institution.

Step One: Self-Review Program for Basic Eligibility

Participating Institutions should ensure that Short-term Programs meet basic eligibility criteria before following the steps identified below. These basic eligibility criteria are set by H.R. 1 and 34 CFR Part 600 and cannot be changed by the NCWorks Commission.

• Participating Institution: A federal Pell Grant-eligible Postsecondary Institution designated as Title IV eligible by the U.S. ED.
• Length: between 8 and less than 15 instructional weeks.
• Hours: 150 – 599 clock hours, 4-15 semester or trimester hours, or 6-23 quarter   hours.
• Delivery: Not offered via correspondence, study abroad or direct assessment.
• Previous Suspension: Ensure the program has not been subject to any  suspension or emergency or termination action by the Secretary of  Education during the five years preceding the date of the determination. 
• Limit on Instructional Partners: Not more than 25% of the Short-term Program is offered through written agreement by an entity that is not a Participating Institution, including an employer partner or a contractor that is not a Title IV institution unless the written arrangement is part of a Registered Apprenticeship Program.  If the arrangement is part of a Related Instruction component of a Registered Apprenticeship Program, entities that are not Participating Institutions will be permitted to provide more than 25 percent, but less than 50 percent through a written arrangement and with the approval of the Participating Institution’s accrediting agency.

• Program Start: Program has been in operation in its current format (length,  hours, delivery, and confirmation that the program was not previously delivered as correspondence, study abroad or direct assessment) for at least one year.

   

At Step One, participating institutions are encouraged to consult with Local Workforce Development Boards on the development and identification of potential Workforce Pell programs needed to meet employer demand. 

Step Two: Eligible Training Provider Application and Approval

The Participating Institution must apply for and be approved to be an Eligible Training Provider (ETP) in North Carolina by completing the ETP Application as outlined by the Eligible Training Provider Guidelines, Penalties, Appeal Process, and Performance Reporting Commission Policy Statement, located on the Commerce website. 

The ETP Application will be utilized as the first step a Participating Institution must complete for consideration of its Short-term Program for the Workforce Pell Grant Program. The ETP Application requests several fields also needed for determining Workforce Pell Grant Program eligibility, including but may not be limited to:

• Program in operation for 12 months prior to application 
• Program name
• Accreditation
• Program status
• CIP Codes
• SOC codes with at least one occupation meeting the definition of high-skill, high-wage, or in-demand as demonstrated in Appendix A and listed in Appendix B. 
• Clock hours
• Instructional weeks
• Cost details
• Previous completion and employment data
• Recognized Postsecondary Credential(s)

Step Three: Workforce Pell Grant Program Approval

A Participating Institution will first be considered for approval for a Short-term Program through the ETPL by the Division of Workforce Solutions. Once ETPL approved, the Workforce Pell Grant Program information will be considered by the NCWorks Commission when an institution has indicated in the ETP application system that it is interested in such eligibility. To seek Workforce Pell Grant Program approval for the Short-term Program, the Participating Institution will be required to submit additional information in the ETP application system including the following:

A. Evidence of Stackability and Portability: To meet the standards of this section a Short-term Program is required to meet to submit evidence for both a) and b). Programs are only exempt from meeting these standards if the program trains students for employment in an occupation for which there is only one recognized postsecondary credential.

• Evidence of Stackability:  
  • Written agreements, including established articulation agreements, transfer-of-credit agreements, consortium or partnership agreements, or similar arrangements indicating learners will receive academic credit for earning certain recognized credentials that could be counted or completion of the approved Workforce Pell Grant Program towards a certificate or degree, and credit will be accepted at one or more eligible institutions. Participating Institutions will be required to upload artifact(s); or
  • If the institution intends to demonstrate stackability based on progression  in a career pathway, documentation must be provided that the program is part of a clearly defined career pathway that enables learners to progress   to additional credentials over time. Acceptable evidence includes the following:
    • Published pathway maps or similar information showing progression from entry-level credentials to certificates, diplomas, or degrees that add labor market value;
    • Written evidence that the career pathway in the academic practice has been in existence for at least a year;
    • Public-facing information (e.g., published on an institution's website) outlining progression expectations, timelines, and labor market outcomes (e.g., wage gains, median wages); and

    • Information to attest/demonstrate that there are minimal administrative, institutional, or localized barriers to learner advancement for students moving between these credentials.

       

• Evidence of Portability: Verified Labor Market Information; surveys; at least two employer letters; letter with verified labor market information from the local Workforce Development Board that serves the area in which the Participating Institution is located or other similar documentation that the resulting Recognized Postsecondary Credential is valued by more than one employer in the Participating Institution’s local labor market. Participating Institutions will be required to upload artifact(s). Evidence submitted must not be older than 3 years.  

• Evidence of Only One Recognized Postsecondary Credential for the Selected Occupation, if applicable: Written evidence that for the occupation, indicated by the SOC Code in the application, there is only one primary recognized postsecondary credential, which could include a license, that prepares an individual for employment in that occupation and students are awarded the Recognized Postsecondary Credential upon completion of the program. Evidence may include state or national licensing standards.  

   

B. Evidence of Program to Credit Articulation: Written agreements or documented policies demonstrating that learners will receive academic credit for completion of the approved Short-term Program upon enrollment in a certificate, diploma, or degree at one or more eligible institutions. Acceptable evidence may include:

• Articulation or transfer-of-credit agreements
• Pre-assessed credit for prior learning (CPL) crosswalks
• Consortium or partnership agreements specifying credit acceptance
• Similar documented arrangements indicating learners will receive academic credit for completion of the approved Workforce Pell Grant Program, or the Recognized Postsecondary Credential, towards a certificate or degree

Credit must be accepted at one or more eligible institutions, which can include the originating institution. 

Participating Institutions will be required to upload artifact(s). 

C. High skill, in-demand, and high-wage requirements: Indicate which occupation(s), using SOC Codes, the program trains for based on Appendix A and B or demonstrates that the program serves as a Related Instruction component of a Registered Apprenticeship Program 

D. Evidence of Employer Validation: Clear evidence that the Short-Term Program was developed or maintained with local/regional/statewide employers, employer associations, sector partnerships, which may be sponsored by a local Workforce Development Board, registered apprenticeship sponsors or labor-management partnerships such as meeting agendas and minutes; at least two letters from employers, employer associations, sector partnerships, registered apprenticeship sponsors or labor-management partnerships describing the need for the program, how they will support the program or their likelihood of hiring students who complete the program. Participating Institutions will be required to upload artifact(s). Evidence submitted must not be older than 3 years.

E. Certification institution meets eligibility of HEA Title IV

F. List of any programs that were once approved for the Workforce Pell Grant Program that no longer have approval.

G. Instructional Type: in-person, distance education, or hybrid

• If distance education or hybrid, do you plan to enroll students from out of state?
• If so, see Section 3 regarding distance education

H. Expiration Date of the Institution’s Participatory Program Agreement (PPA) 

I. Anticipated Median Wages: Evidence of the anticipated median wages for the occupation(s) that the program prepares students in the Participating Institution’s local labor market. 

J. Performance: The Participating Institution will be required to submit participant data and a certification that the data is true, complete, and accurate signed by an authorized official of the Participating Institution, accompanied by any verification and supporting documentation required by the NCWorks Commission, sufficient to demonstrate that the Short-term Program has: 

• For initial application and each federal aid award year thereafter, a completion rate of at least 70%, within 150% of the normal time for completion of the program. 
• For each federal aid award year, a job placement rate of at least 70%, measured within 180 days of completion of the program, verified in a manner prescribed by the NCWorks Commission. 

The Participating Institution must submit any additional data requested at any time by the NCWorks Commission to calculate and verify performance within 15 calendar days of the request. 

Systems representing multiple institutions may analyze and submit data on behalf of an institution within that system. 

K. Limit on Instructional Partners: If any of the Short-term Program is offered by an entity that is not a Participating Institution, including an employer partner or a contractor that is not a Title IV institution, the Participating Institution must submit the written agreement with such an entity.  Not more than 25% of the Short-term Program may be offered by an entity that is not a Participating Institution, including an employer partner or a contractor that is not a Title IV institution. This applies to all Short-term Programs, with exception for Registered Apprenticeships. If the program is part of a Related Instruction component of a Registered Apprenticeship, entities that are not Participating Institutions will be permitted to provide more than 25 percent, but less than 50 percent through a written arrangement and with the approval of the Participating Institution’s accrediting agency. The NCWorks Commission may seek additional information from a Participating Institution regarding Instructional Partners, and such information shall be submitted to the NCWorks Commission within 15 calendar days.

Step Four: Federal Approval

Following approval at the state level, Participating Institutions will be able to submit their Short-term Programs for approval at the federal level to the U.S. ED. Approved programs will receive a letter of approval from the NCWorks Commission that should be used with submission to U.S. ED.

3. Distance Education

A distance education Short-term Program may enroll students from a State outside which the Participating Institution is located and approved to operate, if the Governors of the two States enter into a publicly published bilateral agreement. 

Agreements must meet the following conditions: 

• A. Eligible Occupations or Sectors - The Governor of the State where the student resides, in consultation with the State Workforce Board, must include the relevant occupation(s) or sector(s) on the State’s list of approved occupations developed under the process outlined in 34 CFR 690.93(b)(1)(i).
• B. Program Eligibility - The Governor of the State where the institution offering the program is located must determine, in consultation with the State Workforce Board, that the program meets the eligibility requirements described in 34 CFR 690.93(a).
• C. Data Sharing - The bilateral agreement must include provisions for data sharing between the States to support the calculation of program completion and job placement rates.

A Participating Institution must request the development of such bilateral agreement by letter sent via email to WorkforcePell@ncworks.gov. Letters must include the following:

• A. Eligible occupation(s) under Appendix B which are relevant in the State the agreement is requested with. 
• B. If the Short-term Program prepares a student for licensure, indication that the program fully prepares the student for licensure in the State. 
• C. Proposal for how the States can share necessary student completion and employment data. 
• D. Evidence of state and federal approval of the Short-term Program for the Workforce Pell Grant Program in which the institution is located. 
• E. Letter of support from the State outside which the Participating Institution operates for entering into such agreement. 

4. Continued Eligibility

A. Annual Renewal Submission Following Initial Approval

Each subsequent year after the Short-term Program is approved, Participating Institutions must:

• i. In the manner prescribed by the NCWorks Commission, submit a list of all students who entered the Short-term Program with social security numbers that completed during the award year and the information necessary for the NCWorks Commission to verify the job placement rate and earnings for such award year; and
• ii. Report the published tuition and fees for the Short-term Program through a process determined by the U.S. ED Secretary.
• iii. Maintain eligibility on the ETPL.

B. Requirements of Institutional Notification

Participating Institutions with Short-term Programs approved by the state of North                           Carolina must notify the NCWorks Commission when:

• i. The state-approved Workforce Pell Grant Program application for a Short-term Program is submitted to U.S. ED;
• ii. They receive a decision from U.S. ED on a Short-term Program and the nature of that decision; and
• iii. If they voluntarily decide to stop offering a failing program.

If a Participating Institution loses eligibility based on the U.S. ED Secretary’s determination that the program’s completion rate or job placement rate failed to meet the requirements under 34 CFR § 690.94(a)(2) or voluntarily discontinues a failing eligible Short-term Program, the Participating Institution may not reestablish that Short-term program or a substantially similar program, sharing both the same four-digit CIP code and identical SOC Codes according to the CIP SOC Crosswalk until two years after the date the Short-term program loses eligibility.

All notifications must occur within 10 calendar days.

5. Review Process 

Applications will be reviewed and approved by the NCWorks Commission. The NCWorks Commission will review applications on a quarterly basis. The quarterly schedule is available here. Applications will be reviewed once complete. The NCWorks Commission is prioritizing reviewing applications as quickly as possible.

6. Appeal Hearing Process

A Participating Institution whose Short-term Program’s eligibility is denied or terminated will have 15 calendar days from the date of that determination to submit an appeal in writing to the NCWorks Commission. The Participating Institution must specify the reasons they believe the denial is not justified, including evidence and documentation pertaining to the program that support the appeal.

Following receipt of the appeal, an Appeals Review Panel will be appointed by the Chair of the NCWorks Commission. The Appeals Review Panel will provide its recommendation to the NCWorks Commission and a final decision will be issued by the chair of the NCWorks Commission within 30 calendar days of receipt of the appeal. 

The NCWorks Commission and the Appeals Review Panel will only review the information submitted by the Participating Institution in writing in making the final decision. The Participating Institution should ensure all necessary information is included with its appeal.

All appeals must be forwarded, via email, to the following address: 

workforcepell@ncworks.gov.

The NCWorks Commission does not have the ability to issue exceptions to the law, regulations, or this CPS governing the Workforce Pell Grant Program, and such appeals will not be accepted.

7. Disclosures:

Any information submitted to the NCWorks Commission pursuant to this policy may be disclosed in accordance with N.C.G.S. Chapter 132.

8. Policy Amendments Due to Legal or Regulatory Changes:

This CPS is subject to immediate change at any time to comply with applicable federal law, regulation, or regulatory guidance.  Should such laws, regulations, or guidance change, the NCWorks Commission reserves the right to revise this policy accordingly, without notice, and authorizes the staff of the NCWorks Commission to make such changes.

Effective Date:

Immediately effective upon approval from the NCWorks Commission and the issuance of the final regulations at 34 C.F.R. Part 600 by U.S. ED, whichever is later.

Expiration:

Indefinite

Contact:

NCWorks Commission

Attachments:

• Appendix A – Workforce Pell Eligible Occupations Methodology
• Appendix B – Workforce Pell Occupations