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Committee debates credential and apprenticeship definitions for Workforce Pell
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Summary
Negotiated‑rulemaking members pressed DOE and DOL on whether the proposed 'recognized postsecondary credential' definition excludes nondegree programs, how registered apprenticeships and related technical instruction (RTI) qualify, and whether 'stackability' should be defined at the federal or state level.
Department of Education staff walked the committee through proposed definitions for the Workforce Pell subpart, reiterating intent to align with the Workforce Innovation and Opportunity Act (WIOA) and existing Higher Education Act rules. Members raised multiple concerns about circularity and excluded program types.
Aaron and other panelists asked whether the department’s definition—industry‑recognized certificates, apprenticeship completion certificates, state/federal licenses, or associate/baccalaureate degrees that meet 34 CFR 668.8—would unintentionally exclude nondegree, workforce‑focused programs that do not result in an industry certificate. "This definition ... does not seem to cover nondegree programs that do not lead to an industry recognized certificate or certification," a committee member said, urging clarification. DOE staff acknowledged the statutory constraints and said they would take the concern back.
Representatives from the Department of Labor joined the discussion to explain apprenticeship treatment. Merrick Leko, deputy assistant secretary at DOL, said registered apprenticeship programs culminate in a certificate of completion and that related technical instruction components could qualify as recognized postsecondary credentials under WIOA. He noted DOL guidance allows related instruction to be segmented across a year rather than sequentially and that interim credentials may exist.
Committee members pressed whether the statutory 8–15 week limit for workforce programs would preclude longer apprenticeship RTI, and whether multiple Pell awards could be possible if apprenticeships are segmented into interim credentials. DOL and DOE staff said segmentation and interim credentials may allow multiple awards in some circumstances but that the departments would take detailed operational questions back for further consideration.
DOE agreed to consider drafting clearer cross‑references to WIOA and DOL guidance and to revisit whether federal text should commit to interpreting credential requirements consistently with Labor guidance.
