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July 1 is finally here, and Workforce Pell is ready to launch. But states are at very different stages of building their approval processes. They must determine whether a program aligns with an eligible occupation, meets employer hiring requirements, is stackable and portable, and articulates to a credit program. How they require colleges to validate these standards varies considerably. I analyzed final policies from eight states and proposed policies in three states (CO,, , , MD, , , , , TN,), and here are the key themes.*

Most states are creating lists of eligible occupations, to be updated every two years to align with WIOA planning as required in the Workforce Pell regulations. Colleges will then identify which approved occupation their program leads to during the application process.

States are using a variety of methods to build these lists. Most, including Ohio and Michigan, require occupations to meet high-skill, high-wage, or in-demand criteria. Some, like Tennessee, fold a wage requirement into the in-demand definition. Others, like Texas and Minnesota, require occupations to meet all three: high-skill, high-wage, and in-demand. Several states also create a strategic priority override that a workforce board or the Governor can invoke for occupations tied to documented economic-development priorities, with examples including Maryland’s Governor’s Strategic Designation, Tennessee’s Strategic Priority Exception, and Minnesota’s Drive for 5 sector designation.

In-demand Criteria. States that published new in-demand criteria for Workforce Pell, rather than relying on an existing rating system, use a range of methods for determining in-demand status. At the most permissive end, Michigan qualifies any occupation with more than the median annual job openings. Pennsylvania adds a floor of 100 projected annual openings statewide, and Colorado raises the bar slightly by requiring both a minimum of 40 annual openings and a 10-year growth rate above the statewide average. 

Maryland and Tennessee are the most selective. Maryland would require an occupation to simultaneously rank in the top 30 percent of statewide job openings and meet or exceed the average projected job growth rate. Tennessee goes further, stacking a wage floor, an employment-size floor, and a requirement that at least two of three hiring-activity indicators (job postings, hires, or projected openings ratios) exceed regional medians. 

High-wage Criteria. For high-wage definitions, Pennsylvania has the lowest standard, with an entry-level wage set at 150 percent of the Federal Poverty Level. Colorado and Minnesota use below- or at-median thresholds, 90 percent of the median for Colorado and a regional cost-of-living floor for Minnesota. Maryland, Michigan, and Texas share at or above the statewide median as their benchmark. Tennessee stands apart with a benchmark at 120 percent of the regional median, the only state requiring a wage premium.

High-skill Criteria. For high-skill, the criteria start with occupations only requiring a high school diploma plus on-the-job training in Texas and Pennsylvania. Another band of states with more moderate criteria (Tennessee, North Carolina, Minnesota, Michigan) require a postsecondary credential or equivalent. And Maryland and Colorado’s requirements are at the most structured end, both requiring , which means it requires at least a medium level of preparation.

Most states also carve out exceptions for occupations that miss the statewide bar: an institution can submit a letter from the chair of the relevant local Workforce Development Board attesting to regional demand, accompanied by supporting labor market data. Maryland, Minnesota, and Colorado all allow this.

All of this diversity leads to significant differences in the lengths of approved occupational lists, but another factor also drives list length: the education level required to enter an occupation. Some states, like Iowa, don’t filter their approved occupational lists by required education level, which means they include occupations that require far more education and training than a Workforce Pell program will provide, such as pharmacists and lawyers. Others don’t want to exclude occupations that might benefit from a post-graduation certificate, like registered nursing. The upshot is that a longer occupational list doesn’t necessarily mean less accountability.

*Note that states without links were draft policies out for public comment.

Almost all states require two or three letters from employers or groups of employers attesting that the program meets hiring requirements. Others accept alternative forms of evidence. Colorado, for instance, accepts a credential’s presence on its annually updated List of Qualified Credentials, advisory committee minutes showing multi-employer participation, or a multi-employer letter of support. Ohio and Iowa keep this more open-ended, accepting job postings, employer letters, or advisory board minutes.

Portability and stackability can generally be demonstrated with the same evidence used for employer hiring requirements and articulation, and many states have grouped them accordingly.

For portability, the most commonly required documentation is the same set of multi-employer letters used for employer validation. Texas, Colorado, and Michigan explicitly allow the same evidence to serve double duty, streamlining the application process for colleges.

For stackability, common evidence includes articulation agreements, transfer-of-credit agreements, or consortium and partnership agreements. Several states supplement this with pathway-based evidence, including published pathway maps, credential progression data, or wage-progression data when no formal agreement exists (Maryland, Tennessee, North Carolina, Minnesota, Texas, Iowa). That said, if a program meets the articulation standard, it should clear the stackability bar as well. Connecting the two makes sense.

Most states require a written articulation agreement or a credit-for-prior-learning crosswalk specifying which college or program agrees to accept the program for credit and how much credit it will grant. Colorado has a particularly strong articulation requirement, including a public-facing disclosure of how the program articulates and how the credit applies within the receiving program, whether as required coursework, major or technical electives, or general elective credit.

Ohio offers colleges a shortcut: if a credential sits within a pre-built statewide articulation pathway (its ), the articulation requirement is automatically satisfied without a bespoke agreement.

Florida is taking a very different route from most states. It has built a centrally approved program list using its Master Credentials List and existing Targeted Occupations List (TOL). Institutions only need to certify that their program appears on rather than proving each criterion from scratch.

There has also been considerable discussion around using the Eligible Training Provider List (ETPL) to establish Workforce Pell eligibility in multiple states, both to align Workforce Pell with WIOA and to reduce duplicative state processes. Allowing states to use wage data from the State Wage Interchange System (SWIS), the interstate wage data exchange run by DOL, to calculate the job placement metric will most likely require programs to be on the ETPL. However, community colleges and other public institutions are often not on the ETPL, and getting listed can be an administrative burden. Of the processes I reviewed, Maryland, Colorado, Michigan, North Carolina, Iowa, and Minnesota all explicitly require that Workforce Pell programs be on, or approved through, the state’s WIOA Eligible Training Provider List.

States are coalescing around a common set of standards and required evidence for Workforce Pell program approval. As they begin approving programs, we’ll see how these standards hold up in practice. Refinements will likely be needed as we work to help Workforce Pell reach its potential.