Can Workforce Pell Support Apprenticeship? Yes, but…

At last, there’s a glimpse of a new federal funding stream for Registered Apprenticeship that we might be able to rely on: Workforce Pell.

Over a decade of investment in competitive grants by the Department of Labor (DOL) has strengthened, diversified, and expanded the field, but grants tend to run out just as programs are hitting their stride. Despite rigorous evidence of the effectiveness of Registered Apprenticeship, there is still no sustained investment that we can count on to build a real apprenticeship system in the United States.

But Pell Grants are different. They function like an entitlement, a funding guarantee for eligible students enrolled in higher education programs that meet (a lot of) federal requirements. As my colleague Wesley Whistle explained in a blog last week, early signs are that Workforce Pell could be used to support the related technical instruction (RTI) component of an apprenticeship program, so long as the RTI is delivered by a provider that is eligible to participate in federal student aid programs and the RTI meets certain criteria in the law and forthcoming regulations. We unpack each of these requirements and their implications for apprenticeship programs below.

First, though, the status of implementation: we’re only midway through the process of establishing final rules for the program. The Department of Education (ED) and student aid stakeholders negotiated draft rules in December 2025 that will be the basis for proposed regulations that it will publish for public comment early in 2026. ED will finalize the rules after the comment period in late spring 2026, and could change some of the requirements we describe here in response to the comments it receives. Also important to know is that there will be some variations across states because governors will play a large role in deciding which programs meet many of the requirements.

So, what does it take for RTI to qualify for Workforce Pell? We break it down into eight key requirements.

1. The RTI is delivered by a provider eligible for federal student aid.

To qualify for Workforce Pell, the RTI must be delivered by one of the nearly 6,000 providers that are eligible to participate in federal student aid programs under Title IV of the Higher Education Act. Colleges and universities predominate among Title IV-eligible providers, but they also include private non-profit and for-profit trade schools and some area career and technical education centers. There’s a search tool on ED’s website you can use to check whether a provider is currently Title IV-eligible.

The more than 1,600 union training centers that provide RTI for so many Registered Apprenticeships in the skilled trades typically will not be eligible under Title IV, but the training they deliver does not usually require payment of tuition because it is financed by nearly $2 billion contributed annually by construction contractors.

2. The RTI is short-term — but it doesn’t have to be continuous.

To be eligible for Workforce Pell, an RTI program must be at least 150 clock hours long, but not more than 600 hours long (or an equivalent number of credit hours) and provided for at least 8 weeks, but not more than 15 weeks. The good news for apprenticeship programs is that the RTI does not have to be delivered in a single 8- to 15-week block. It can be delivered intermittently.

National data on the length of RTI for different occupations are not available from DOL, but a 2021 evaluation of the $175 million American Apprenticeship Initiative (AIA) grant program suggests that the RTI for many Registered Apprenticeships is less than the Workforce Pell cap of 600 hours. The average duration of RTI for AIA grantees ranged from 270 hours for health care apprenticeships to 539 hours for apprenticeships in construction.

Some of the clock hours for a program eligible for a regular Pell Grant could be on-the-job learning under limited circumstances. Current Title IV regulations and longstanding ED guidance permit a provider that is not Title IV-eligible to deliver up to 25 percent of a program’s clock hours or, with specific permission of the Title IV provider’s accrediting agency, over 25 percent but less than 50 percent of the program. There must be a written agreement that establishes that the Title IV provider retains authority over instruction, assessment, and required course content. An apprentice’s completion of clock hours delivered through on-the-job learning also must be supervised by school faculty, and not the employer. Workforce Pell, however, will pay only for classroom instruction, and not on-the-job learning.

But where do these time-based requirements leave RTI that is competency-based? The RTI may be competency-based and qualify if the Title IV provider can map the program’s competencies to clock-hour equivalents that are consistent with Workforce Pell requirements.

3. The RTI results in a recognized postsecondary credential that is “stackable” and “portable across more than one employer.”

The RTI component of an apprenticeship must lead to a “recognized postsecondary credential” to be eligible for Workforce Pell. The law uses the familiar definition of this term from the Workforce Innovation and Opportunity Act (WIOA), which apprenticeship leaders know includes a certificate of completion from an apprenticeship program. To meet Workforce Pell requirements, however, the RTI component must result in another credential that is in addition to the journeyworker certificate. This is because only the RTI component of an apprenticeship is eligible for Workforce Pell, not the entire apprenticeship.

Because, here again, national data are not available, we can look to the AIA evaluation for some insight into the extent to which RTI results in a recognized postsecondary credential other than the journeyworker certificate. The RTI offered by most AIA grantees did result in a state license or certification, postsecondary certificate, degree, or other credential, but they included some certificates that ED may not consider to be recognized postsecondary credentials under Workforce Pell, such as the OSHA-10 safety training certificate that DOL and ED guidance excludes from the measurement of the credential attainment indicator under WIOA. While ED has not indicated whether or not the OSHA-10 would count under Workforce Pell, it seems unlikely that it would view the credential differently than it does under WIOA.

The credential awarded by the RTI component must also be “stackable” toward an additional credential and “portable across more than one employer,” excluding bespoke, employer-specific credentials, unless the program prepares learners for an occupation for which there is only one credential, like a commercial driver’s license. The negotiated rules did not clarify the definition of “stackable” and “portable” or how a provider could show that its credential meets these requirements, instead punting these issues to the governor of each state to determine.

4. The RTI may be non-credit, but it must count for academic credit in at least one credit-bearing program.

The RTI can be either credit-bearing or noncredit, but, if it’s noncredit, the provider must have an articulation agreement or other arrangement through which the RTI counts as academic credit in at least one related credit-bearing certificate or degree program that is eligible for Title IV. For example, the RTI could prepare apprentices for an American Welding Society Certified Welder credential, for which a community college awards 9 credits toward an Associate in Applied Science in Welding Technology

5. The RTI is linked to a Registered Apprenticeship—or it prepares learners for “high-skill, high-wage, or in-demand sectors or occupations” (as defined by the state) and meets employer hiring needs for those sectors or occupations.

The Workforce Pell law includes requirements meant to ensure that learners who complete the program will be able to find a job at a decent wage. The program must prepare learners for “high-skill, high-wage, or in-demand sectors or occupations” as defined by and determined by each state, and the program must be geared to meet employer hiring requirements for those sectors or occupations. However, the negotiated draft rules include a “pass go” provision on these requirements for RTI for a Registered Apprenticeship program: if the RTI is part of a registered program, it automatically meets all of these requirements. An RTI program for an unregistered apprenticeship, on the other hand, will need to demonstrate to the governor that it meets these requirements.

6. The RTI program has been in operation for at least 12 months in a form that meets the core Workforce Pell requirements on program duration and the award of a recognized postsecondary credential.

The negotiated draft rules require the governor to certify that the program met requirements two through five for the immediately preceding 12 months. If a provider needs to tweak the duration of the RTI or add a credential in order to meet the Workforce Pell requirements, it may have to wait a year before the program can be eligible for Workforce Pell, though governors may have some discretion in making the call on this.

7. The RTI meets program completion and job placement standards.

To qualify for Workforce Pell, an RTI program must have a 70 percent completion rate and a 70 percent job placement rate. The completion rate standard applies to the RTI component only and not to the apprenticeship program of which it is part. Apprentices must complete the RTI within 150 percent of the normal completion time to be counted as successful completers. If the RTI normally takes 12 weeks to complete, for example, apprentices must finish it within 18 weeks.

RTI for apprenticeship programs should ace the 70 percent job placement standard. The rate is calculated as the percentage of learners who are employed 180 days after exiting the RTI (not the apprenticeship program). If a learner completes the RTI but drops out of the apprenticeship, they will still be counted in the job placement metric. Under the negotiated rules, beginning with the 2029-30 school year, learners must be employed in the occupation for which the program prepared them in order to count as a successful job placement.

8. The RTI program charges the same tuition and fees for all learners, and the price is less than the earnings boost the RTI gives learners who complete the program.

Employers often pay for RTI, but some apprenticeship programs also or alternatively tap public funding, such as a local workforce development board’s WIOA subgrant or other federal or state grants, and sometimes apprentices are asked to contribute. As Wesley explained, institutions that want their RTI programs to qualify for Workforce Pell will need to establish a single price for tuition and fees for all students (including students who are in an apprenticeship and those who are not), regardless of the source of funding for those costs. Because Pell Grant awards vary by an individual’s financial need, some apprentices will receive larger grants while others may receive very little. RTI providers will need to pay the balance with other sources of funding. The simplest solution may be to ask employers to cover the gap, as Alabama requires of all of the Registered Apprenticeships in that state. But institutions and sponsors also might access state funding like the North Carolina tuition waiver for youth apprentices in registered programs or WIOA or other federal funding.

Workforce Pell caps the price of tuition and fees with a complex “value-added earnings” test that looks back at the earnings of cohorts of program completers (and not all learners who exited the program) from previous years. The goal is to exclude from Workforce Pell short-term programs that cost more than the earnings bump that learners receive after completing the program. The lookback period is the year following completion of the RTI component of the apprenticeship, and not the full apprenticeship. (As with job placement, the earnings of learners who complete the RTI but drop out of the apprenticeship will still be counted.) Sponsors of multi-year apprenticeships and their RTI providers will need to be mindful of this test in setting wage levels in the progressive wage schedule. Because the earnings test relies on historical earnings data, implementation of this provision will not begin until the 2029-30 school year under the negotiated rules.

But how much money are we talking about here?

The RTI providers for some apprenticeship programs will be able to meet these requirements and secure Workforce Pell grants for their apprentices. And it’s great that Pell functions as an entitlement. But how much money are we really talking about?

The Pell Grant award size will depend on the length of the program and the apprentice’s financial need. In an October 2025 blog, Wesley walks us through how Workforce Pell grants will be calculated and prorated using two examples. As he notes, the total award size for learners in an 14-week, 599-clock hour program could range from as much as $4,310 and as little as $430. For an 8-week, 150-hour program, the award size range could be from $1,260 to $125.

How does that compare to what RTI typically costs? A recent Urban Institute analysis of data from Florida estimated that college-delivered RTI typically cost between $1,500 and $3,500 per apprentice in 2022-23. The average cost was $2,807 per apprentice.

However, as Wesley also explained in his blog last week, Pell Grants are paid in installments to promote program completion and to protect taxpayers. In a clock-hour program, there must be at least two payment periods, and grants are paid only after a learner completes the hours and weeks established for each period. As Wesley notes, if the RTI is stretched over many months, so will be the payout of Pell grant installments.

What’s Next?

Keep in mind that many of these details are tentative. ED is expected to publish draft rules in early 2026 that will be based on what it negotiated with stakeholders in December 2025 (and that we’ve described here). Apprenticeship leaders will want to weigh in during the public comment period to preserve what works for them in the draft rules (like the “pass go” provisions that enables Registered Apprenticeships to bypass some of the requirements on labor market demand and job quality).

Workforce Pell could finally make apprenticeship feasible for some small- and mid-size employers who have not been able to afford to pay the costs of RTI in the past. But, rather than try to pinch and squeeze their RTI components so that they fit into the parameters of Workforce Pell, some apprenticeship sponsors and RTI providers may want to consider redesigning their pathways so that they prepare apprentices with a broader range of skills and culminate in a longer-term postsecondary certificate or degree that is eligible for a regular Pell Grant. Of course, that’s a heavier lift for community colleges that exclusively deliver noncredit RTI, but now may be time to start having a conversation about moving RTI to the credit side of the house.

Let’s celebrate Workforce Pell for how it may advance apprenticeship, but also keep it in perspective. It’s a start. It is not a substitute for the significant and sustained federal investment that is needed to expand Registered Apprenticeship and build a system at a scale that matches its potential.

According to the Congressional Budget Office, Workforce Pell will cost a total of just $298 million over eight years–and that’s for all types and varieties of short-term programs, not just RTI. Not so long ago (five years), the House of Representatives passed a bipartisan bill that would have invested nearly $4 billion over five years to create 1 million Registered Apprenticeships and establish a reliably funded apprenticeship system, but it didn’t make it over the finish line. With a President who says he’s committed to the goal of creating 1 million new active apprentices but who still needs a plan to get there, apprenticeship leaders should return their eyes to that prize and press for more investments upon which the field can rely.