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3. Rigorous Administrative Approval Process

Another approach to assuring Pell Grants only support quality CCL programs is through a rigorous administrative process by which they would become eligible. All three major pieces of Short-Term Pell legislation already introduced require at least two administrative boxes for quality be checked:

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  • Accredited—Only providers who have been appropriately accredited to provide the workforce development programs they offer would be eligible
  • Meets In-Demand Industry Requirements—A program must provide training that meets the hiring requirements for employers in in-demand industries

Beyond that, differences remain on what, if any, additional administrative approval criteria should be included. Below is a list of some of the most important ones that have been proposed.

Additional Administrative Criteria

  1. Leads to a Federally Recognized Postsecondary Credential—The Workforce Innovation and Opportunity Act (WIOA) provides federal definitions of credentials for various industries and occupations. This proposal would require a program meet these definitions so that graduates obtain a credential that will be recognized throughout the country.
  2. On State and Local Eligible Training Provider List (ETPL)—While there is wide agreement that Pell eligible programs must meet the hiring requirements for employers in in-demand industries, there are a range of proposals for how rigorous the administrative process should be to verify this. One proposal would require the entity who provides a skills education program be on a state’s and local area’s ETPL which must be maintained under WIOA. To get on the list, a program must first go through a formal process with the workforce board for the state in which it is offered. Then, it must also be approved by the local workforce board. The primary criteria by which state and local workforce boards are supposed to determine whether to include a program on the ETPL is whether there are sufficient high-skill, high-wage jobs available in that state or local area to justify the program.
  3. Administrative Determination that Provides Training in “high-skill, high-wage, or in-demand industry sectors or occupations” found in the State or Local Area—This proposal would require an additional administrative determination to the ETPL requirement above that programs provide skills for high-skill, high-wage, or in-demand jobs found in that state or local area. The House’s Jobs to Compete Act would require this determination to be made by the accrediting agency, while the Senate’s JOBS Act would require the determination be made by an industry or sector partnership.
  4. Meets Applicable State Requirements for Professional Licensure—Each state establishes criteria that must be met to obtain a license required to be legally employed in many occupations. This proposal would require a career development program fulfill a state’s applicable educational requirements for professional licensure.
  5. No Administrative Adverse Action in Past Five Years—This provision would require a determination that the program hasn’t been found sufficiently inadequate. For example, a program would only qualify if it has not been suspended or terminated in the last five years by the federal government under provisions of the Higher Education Act, by the state, or by the relevant accreditation agency.
  6. Must Provide Counseling—This proposal would require programs to provide participants with career counseling to help them achieve their educational and occupational goals. Counseling would include providing information about the industries, occupations, and certificates for which it prepares students, and about sources of financial assistance.
  7. At Least Half of Tuition and Fees Go to Educational Spending—Some program providers in the past have spent more than half the money earned from tuition on items other than the direct costs of providing the education. In the case of for-profits, much of the revenue has often gone to providing a larger profit for owners. This proposal would ensure this doesn’t happen with Pell eligible programs.

Criteria 1-4 above are included in both the Senate’s JOBS Act and in the House’s Jobs to Compete Act. In part because the Jobs to Compete Act includes for-profits (while the JOBS Act prohibits them), its sponsors thought it important to add criteria 5-7 as well. The Jobs to Compete Act also includes direct performance indicators discussed below. The PELL Act does not include any of the seven criteria listed above, instead emphasizing the outcome performance requirements discussed below.

Case For

Supporters of the additional administrative quality criteria argue they each have a self-evident quality to them. Look at each measure, they suggest. Would we really want to pay federal taxpayer dollars to subject students to programs that couldn’t meet each of them, they ask. They observe that a Pell Grant will only cover a portion of the costs of the program. The students will be responsible for paying the rest. Advocates argue students’ interests are advanced by attempting to ensure they aren’t left paying for programs that don’t place them in higher paying jobs but do saddle them with debt. 

Case Against

Opponents of the administrative criteria approach suggest that, while each of the proposed requirements may sound good in theory, the challenge comes in the practical implementation. They note each additional administrative criterion would require federal, state, local government, and/or accreditation agencies to develop new regulations, procedures, data collection, reports, and forms to comply with them. They suggest one should then imagine all the time and effort it would take from thousands of government and accreditation agency workers to execute the administrative processes once they’ve been put in place.

More importantly, opponents suggest, imagine program administrators and teachers who are already busy and stretched thin. First, they would need to complete all the steps to apply for their program. If successful, they would then need to continue to collect data and file reports to stay eligible. Opponents observe even some early Short-Term Pell supporters who helped craft the initial bills introduced several years ago now express concern over the number and complexity of criteria that have been added. They worry fewer programs are going to apply than we want if all or most of the additional criteria are adopted, well-intentioned as they may be.

Opponents also argue some of the criteria are redundant. For example, they suggest the requirement a program be on the ETPL (#2) and the requirement of an additional administrative determination that the program provides training for high-skill, high-wage jobs found in the area (#3) are duplicative.

Finally, opponents suggest this approach leads to a heavy administrative burden for institutions even though the input criteria are only indirect indicators that cannot guarantee quality outcomes for students. Better, they suggest, to directly measure the desired outcomes like graduation rates, job placement rates, and earnings increases.

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