Making Workforce Pell Work for Registered Apprenticeships

Last month, the U.S. Department of Education held its negotiated rulemaking committee to establish the regulations for Workforce Pell. The committee reached consensus on the proposed regulatory text, and we should expect a proposed rule early this year.

If there was one unmistakable takeaway from last month’s negotiated rulemaking committee, it is this: the Department clearly wants Workforce Pell to work for Registered Apprenticeships. This piece takes a deeper look at where Registered Apprenticeships (RA) stand in the Workforce Pell rulemaking at this point. Beyond the regulations, this piece also reviews what institutions should know as they consider whether and how to leverage Workforce Pell in RA programs.

The first obstacle for RA programs hoping to be eligible for Workforce Pell is that the program must be provided by an eligible institution under the Higher Education Act, which requires that the institution providing the instruction be accredited and meet all other Title IV requirements. (Up to 25 percent of the program’s instruction can be provided by an ineligible institution under the written arrangement regulations.) This can be a challenge as many RA programs are provided by ineligible institutions, including labor unions. However, for those offered by an eligible institution, the Department’s draft consensus regulations include several explicit provisions to integrate Registered Apprenticeships into Workforce Pell.

Excluding On-the-Job Training from the Length of the Program

The Department’s proposed regulations provide that a Registered Apprenticeship program can qualify for Workforce Pell even if the full apprenticeship (including the on-the-job-training component) exceeds statutory limits on length, so long as the related technical instruction (RTI) portion independently satisfies the requirements of law and regulation. This includes several critical elements:

• The RTI must independently meet the clock-hour, weeks-of-instruction, completion and job placement rates, and the value-added earnings requirement.
• The RTI alone must lead to a recognized postsecondary credential. All RA programs culminate in some type of credential, but not all RTI curricula inherently produce them; institutions will need to verify this alignment so that the RTI portion alone leads to the proper credential because the credential for the whole apprenticeship program will not meet this requirement.
• The RTI must prepare students for further education and guarantee academic credit. Under the law and the proposed regulations, the Governor cannot approve an eligible workforce program unless completing students will receive academic credit that counts toward a related certificate or degree program, should they decide to pursue one.

The Department’s approach is pragmatic: it recognizes that Registered Apprenticeships are structured differently from traditional training programs but ensures that only the instruction—not the on-the-job training—is subsidized through Workforce Pell. In effect, the Department is threading a needle: respecting the structure of Registered Apprenticeships while ensuring that any Pell-funded portion looks and operates like any other Workforce Pell program.

RA programs automatically satisfy the “in-demand / employer hiring” requirement.

Under the law and the proposed regulations, Governors must determine whether a Workforce Pell program aligns with high-skill, high-wage, or in-demand industries and meets employer hiring needs. But the rule establishes an important shortcut by allowing RAs to automatically meet those requirements. This is an important recognition that apprenticeship programs that go through the RA process are themselves employer-validated and tied to in-demand occupations.

RA programs can use non-continuous instructional delivery.

During the public comment period following the Department's announcement of its intent to establish a negotiated rulemaking committee, some commenters requested clarification from the Department that RA-related technical instruction can be delivered intermittently throughout the year, rather than in a continuous 8–15-week block. Commenters noted that RA instruction often occurs in “on-again/off-again” formats aligned with OJT progression.

ED confirmed this is already allowed under existing Title IV rules and would continue to be so in Workforce Pell:

• Pell can be disbursed over multiple payment periods, even if those periods span different award years.
• Non-continuous enrollment is permissible so long as the instructional weeks and clock hours required by the Workforce Pell statute are satisfied.

While the regulations lay helpful groundwork, institutions considering Workforce Pell for RA programs need to understand several Title IV rules that still apply. Below are the two biggest areas where institutions should pay attention as they consider how they might be able to benefit from Workforce Pell.

Charging Tuition in Registered Apprenticeships

Several public comments urged the Department to allow RA programs to count as “offered” for the one-year existence rule before introducing tuition. They correctly noted that many apprenticeship programs do not tend to charge students tuition. Employers often cover the cost of both related instruction and the apprentice’s wages. In many cases, apprentices should not be asked to pay tuition at all.

Employer investment is a fundamental component of Registered Apprenticeships, but some employers may not participate in an apprenticeship program because the cost of both the instruction and training may be prohibitive for them. Therefore, allowing Workforce Pell to cover certain components of RA RTI could attract more employers who might otherwise be deterred by the combined cost of wages and training. For small and midsized employers, these costs can be a real barrier to expanding apprenticeship pathways. This means that many more people could benefit from an affordable program that leads to a good-paying job.

However, some comments about how programs will have to begin charging tuition raise some concerns for institutions and programs to consider. Title IV has strict rules about tuition. Under the Higher Education Act and longstanding FSA regulations, if an institution participates in Title IV, it must charge the same tuition to all students in a program, regardless of whether they receive federal aid. An institution cannot waive tuition for apprentices while charging tuition only for Pell recipients. That is a prohibited Title IV practice. This is one reason why many RA programs historically operated outside Title IV—they didn’t have tuition structures.

Therefore, an institution offering a Registered Apprenticeship program for Workforce Pell will need to establish a tuition rate that applies to all students, regardless of whether they receive a Workforce Pell Grant or not. Furthermore, not all Workforce Pell students will receive the same grant amount. (See more about how the grant amounts are calculated and some estimates of the ranges of grant amounts in my first edition of the newsletter.)

A recent example illustrates how a college attempted to benefit from increased Pell Grant amounts, but ultimately ran afoul of federal rules and regulations. The trouble began with Eastern Gateway Community College’s (EGCC) “Free College Benefit” program, which offered tuition-free enrollment to union members and their families nationwide. The school used federal Pell Grant funds to cover tuition for Pell-eligible students, while non-Pell students paid nothing — a structure the U.S. Department of Education determined violated Title IV’s requirement that all students in a program be charged the same tuition, regardless of aid receipt. That misuse of Pell funding triggered an enforcement action in 2022, spurred a protracted legal and financial crisis, and ultimately contributed to the college’s accreditation probation, financial insolvency, and closure — an all-too-cautionary example of what can happen when aid rules are ignored.

ED suspended EGCC’s ability to disburse Pell Grants after finding that students receiving Pell were systematically charged more than non-Pell students, an illegal differential tuition policy. EGCC had attempted to run a zero-cost program for non-Pell students while using Pell to subsidize the cost for others. The Department classified this as a prohibited inducement and a violation of cost-of-attendance and Title IV pricing rules.

Once an institution chooses to bring an RA program under Title IV, it must establish a tuition structure that applies to all students in the program, not just those receiving Workforce Pell. And because Pell awards vary by student, some apprentices will receive larger grants while others may receive very little, meaning any remaining tuition balance must be covered somehow.

A few options that programs could pursue include:

• Students may have to pay the difference out of pocket;
• Employers may choose or be required to cover the gap, as they are in the “last dollar” tuition policy in Alabama; or
• The institution or program sponsor will need to identify other aid sources (state funding like the North Carolina tuition waiver for youth apprentices in RA programs), philanthropic support, GI Bill, etc.) to avoid creating financial barriers.

The takeaway for RA sponsors and institutions: If you want Workforce Pell funds, you must introduce tuition for all students in the RA’s instructional component. This is not a policy preference; it is a statutory and regulatory requirement.

Non-Continuous Enrollment: How Pell Actually Works

As discussed already, many commenters will be pleased that ED has indicated it intends to allow registered apprenticeship RTI to count even when it is not delivered in a single continuous 8–15-week block. However, depending on the program, this might not be as beneficial as some might expect.

Workforce Pell disbursements for clock-hour programs are tied to payment periods, which are defined by two thresholds: students must complete half of the total clock hours and half of the total weeks of instruction before they can receive the second disbursement. For Registered Apprenticeship programs with related technical instruction (RTI) spread intermittently over many months, these requirements can make payment periods unusually long. The “weeks of instruction” component stretches the timeline significantly, creating long delays before institutions can release the second half of a student’s Pell Grant. At the same time, because Workforce Pell awards are prorated according to program length, the grant amounts for short RTI programs are often quite small. For apprenticeship programs, where RTI hours may be limited and spread out across long intervals, the combination of prorated Pell and extended payment periods means the financial impact may be more modest than many expect.

In short, non-continuous RA instruction can qualify under Pell rules, but the actual benefit may be smaller and slower to disburse than programs anticipate.

As institutions and sponsors think about how Workforce Pell fits into Registered Apprenticeships, they should not lose sight of another, often underappreciated option: making apprenticeship programs credit-bearing so they can qualify for the traditional Pell Grant program. For many Registered Apprenticeships—particularly those with substantial instructional components or longer timelines—traditional Pell may ultimately provide more stable and meaningful support than Workforce Pell alone.

Importantly, existing federal student aid guidance already creates a pathway for this. Under longstanding Department of Education guidance, institutions may award academic credit for portions of an apprenticeship program, including certain on-the-job training. This matters because many Registered Apprenticeships are simply too long—or too instructionally diffuse—for Workforce Pell to be the best solution. Traditional Pell may be better suited for programs that span multiple terms or award more substantial credentials. Designing apprenticeships for credit can also strengthen stackability, improve transferability, and create clearer pathways from apprenticeship into further postsecondary education—goals that align squarely with both workforce and higher education policy objectives.

Workforce Pell can and should play an important role in expanding access to Registered Apprenticeships. But it should not be treated as the only lever. Institutions that take a longer view—by aligning apprenticeship instruction and validated on-the-job learning with credit-bearing credentials—will be better positioned to leverage the full Pell Grant program, support apprentices more effectively, and build apprenticeship models that are sustainable, scalable, and fully integrated into the postsecondary ecosystem.