Pell Grants for Short-Term Programs: Background and Legislation in the 118th Congress

August 3, 2023 – August 24, 2023 R47647

Pell Grants for Short-Term Programs:
August 24, 2023
Background and Legislation in the
Cassandria Dortch
118th Congress
Specialist in Education
Policy
The Federal Pell Grant program, authorized by Title IV of the Higher Education Act (HEA), is

the single largest source of federal grant aid supporting postsecondary education students. For
Benjamin Collins
several years, Congress and stakeholders in the higher education and workforce training
Analyst in Labor Policy
communities have promoted the possibility of expanding Pell Grants to students enrolled in

short-term programs—educational programs that do not meet the minimum durational
requirements in current law. The possible expansion would be intended to provide prospective

students with more educational and career options and employers with more skilled applicants.
Concerns about a possible expansion are generally related to historical fraud perpetrated by providers of short-term programs
and inconsistent employment returns for short-term programs.
The Pell Grant program provides grant aid to financially needy undergraduate students who have not achieved a bachelor’s
degree and are enrolled in eligible educational programs at HEA Title IV-participating institutions of higher education
(IHEs). In general, eligible educational programs are undergraduate degree programs and certificate programs of at least 600
clock hours of instruction (or the equivalent) offered over a minimum of at least 15 weeks. Title IV-participating IHEs may
include public, private nonprofit, and proprietary institutions, and they must be authorized to operate a postsecondary
educational program by the state in which they are located, accredited by an accrediting agency recognized by the U.S.
Department of Education (ED), and certified by ED.
From 2012 to 2017, ED conducted an experiment allowing select IHEs to award Pell Grants to otherwise Pell-eligible
students in educational programs that were at least 150 clock hours of instructional time, were at least eight weeks in
duration, were offered by public or private nonprofit IHEs, and met local or regional workforce needs. Over 80% of
recipients pursued programs in transportation and materials moving or health professions. Pell-eligible students demonstrated
a 10 percentage-point increase in completion when offered a Pell Grant for short-term programs. The average cost of
attendance was $16,900, and the average Pell Grant award was $1,312.
As of August 2023, three major bills have been introduced in the 118th Congress to expand Pell Grants to short-term
programs:
• Promoting Employment and Lifelong Learning Act (PELL Act; H.R. 496);
• Jobs to Compete Act (H.R. 1655); and
• Jumpstart Our Businesses by Supporting Students Act (JOBS Act; S. 161) and its companion, the JOBS
Act of 2023 (H.R. 793).
The bills share several provisions. Short-term programs would be defined as educational programs providing 150-599 clock
hours of instruction offered over 8-14 weeks. The programs would have to be in in-demand industries. Student eligibility
would be expanded to otherwise Pell-eligible students who have received a bachelor’s degree but not a postbaccalaureate
degree. The proposals would require that IHEs offering Pell-eligible short-term programs be accredited by an accrediting
agency for which ED has included within its scope of recognition the ability to assess an IHE’s Pell-eligible short-term
education programs.
Some key provisions differ between the bills. Only public and private nonprofit IHEs could offer Pell-eligible short-term
programs under S. 161/H.R. 793, while H.R. 496 and H.R. 1655 would not limit HEA Title IV-participating IHEs by
institutional control. S. 161/H.R. 793 and H.R. 1655 would require that short-term programs be on the state’s eligible training
provider list as created under the Workforce Innovation and Opportunity Act (WIOA), lead to a recognized postsecondary
credential as defined by WIOA, and provide academic credit toward related degrees and certificates. H.R. 496 and H.R. 1655
would both establish outcome metrics for the short-term programs: a 70% completion rate, a 70% employment placement
rate, and a requirement that the earnings of program completers exceed specified benchmarks. In addition, H.R. 1655 would
establish several additional quality assurance requirements for short-term programs that have no corollary in the other bills.
For example, H.R. 1655 would require that IHEs offering short-term programs have not been subject to specified adverse
actions within the past five years and that the program not be exclusively offered through distance education.
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Pell Grants for Short-Term Programs: Background and Legislation in the 118th Congress

Introduction
The Federal Pell Grant program, authorized by Title IV of the Higher Education Act (HEA), is the
single largest source of federal grant aid supporting postsecondary education students.1 In
FY2023, the Pell Grant program is estimated to make $30 billion available to over 6 million
students.2 For several years, Congress and stakeholders in the higher education and workforce
training communities have promoted the possibility of expanding Pell Grants to short-term
programs—programs with durations below the current statutory minimum. This report provides
background on this policy option and compares key provisions of three relevant legislative
proposals introduced in the 118th Congress. The comparison explains, as available, the rationale
for these provisions and similar HEA provisions.
Under current law, educational programs must meet or exceed statutory duration requirements for
enrolled students to qualify for a Pell Grant. Under proposals to expand Pell Grants to short-term
programs, a postsecondary student who is otherwise Pell-eligible but enrolled in a short-term
program would be eligible to receive a Pell Grant award prorated to the duration of the program
(short-term Pell Grants). Generally, the proposals would support students enrolled in educational
programs that provide 150-599 clock hours of instruction over 8-14 weeks, meet requirements
under Title IV of the HEA, and meet additional proposed requirements.
The meaning of short-term throughout this report varies depending on the context, statutory
provisions, regulations, and U.S. Department of Education (ED) guidance. Every effort is made to
define the term in context.
This report is intended to inform Congress as it considers legislation authorizing short-term Pell
Grants. The first section discusses current and historical context for HEA Title IV federal student
aid and short-term programs. The second section describes three proposals from the 118th
Congress that would establish a new type of Pell Grant that would support student enrollment in
short-term programs. All references to current law denote the HEA as in effect on or before July
1, 2024, as a result of amendments by the FAFSA Simplification Act (FSA; Title VII, Division
FF, P.L. 116-260 [Consolidated Appropriations Act, 2021]) and the FAFSA Simplification Act
Technical Corrections Act (FSATCA; Division R, P.L. 117-103 [Consolidated Appropriations Act,
2022]).3
HEA Title IV Aid and Short-Term Educational
Programs
HEA Title IV currently authorizes, and has historically authorized, several federal student aid
programs, including Pell Grants and student loans. Such aid has been available to postsecondary
students in variously defined short educational programs. Some have expressed ongoing concerns
regarding the value and suitability of such programs.
After a description of the Pell Grant program, this section briefly reviews the policy arguments
for and against extending Pell Grants to students enrolled in short-term programs and describes

1 For a more detailed description of the Pell Grant program, see CRS Report R45418, Federal Pell Grant Program of
the Higher Education Act: Primer.
2 U.S. Department of Education, President’s Budget Request FY2024, Student Aid Overview, pp. 3-4.
3 The amendments go into effect on or before July 1, 2024, coinciding with the beginning of the 2024-2025 award year.
For a description of the amendments, see CRS Report R46909, The FAFSA Simplification Act.
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the historical and current use of student loans and Pell Grants for short programs, as well as
related findings.
Pell Grant Program Under Current Law
HEA Title IV-eligible students who are
financially needy undergraduates may be
HEA-Specified Minimum Number of
awarded Pell Grants to defray the cost of their
Hours and Weeks of Instruction
postsecondary education while enrolled in
•
At least 600 clock hours, 16 semester or
HEA Title IV-eligible undergraduate
trimester hours, or 24 quarter hours of
instruction offered over a minimum of at
programs.4 Financial need is determined
least 15 weeks; or
through a combination of the family’s adjusted
•
At least 300 clock hours, 8 semester hours,
gross income (AGI) and the student aid index
or 12 quarter hours of instruction offered
(SAI). SAI is calculated in accordance with an
over a minimum of 10 weeks for programs
HEA-defined methodology that establishes
that admit as regular students only individuals
how much the student’s family is expected to
who have completed the equivalent of an
associate’s degree.
contribute to his or her educational costs.
An HEA Title IV-eligible undergraduate program must be offered by a public, private nonprofit,
or proprietary (private for-profit) HEA Title IV-participating institution of higher education
(IHE).5 HEA Title IV-participating IHEs must satisfy the requirements of a program integrity
triad—state authorization, accreditation or preaccreditation, and certification by ED—as well as
additional criteria. An HEA Title IV-eligible undergraduate program offered by a public or private
nonprofit institution must
• lead to an associate’s or bachelor’s degree,6
• be a qualifying postbaccalaureate teacher education program,
• be at least one academic year of training that leads to a recognized nondegree
credential and prepares students for gainful employment in a recognized
occupation (see the “Gainful Employment in a Recognized Occupation” section),
or
• meet or exceed the HEA-specified minimum number of hours and weeks of
instruction (see text box) and prepare students for gainful employment in a
recognized occupation.
If the program is offered by a proprietary HEA Title IV-participating IHE, it must either (1) be a
qualifying postbaccalaureate teacher education program or (2) meet the HEA-specified number of

4 An undergraduate student has not completed the curriculum requirements of a bachelor’s or higher degree. In
addition, undergraduate students include those enrolled in Pell-eligible postbaccalaureate teacher certificate or licensing
programs. Such programs do not lead to a graduate degree, are offered by a school that does not also offer a bachelor’s
degree in education, and lead to certification or licensure necessary for employment as an elementary or secondary
school teacher in the state. Students with a bachelor’s degree must be enrolled at least half-time in a postbaccalaureate
teacher education program. To be eligible for a Pell Grant, the student enrolled in the postbaccalaureate teacher
education program must be pursuing an initial teacher certification or licensing credential within the state.
5 34 C.F.R. §668.8(c), (d), and (h). Only students enrolled in domestic institutions may receive Pell Grants.
6 At a public or private nonprofit HEA Title IV-participating IHE, eligible programs also include programs of at least
two academic years that are acceptable for full credit toward a bachelor’s degree.
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Pell Grants for Short-Term Programs: Background and Legislation in the 118th Congress

hours and weeks of instruction (see text box) and prepare students for gainful employment in a
recognized occupation.7
Gainful Employment in a Recognized Occupation
HEA requires that some educational programs “prepare students for gainful employment in a
recognized occupation.” Prior regulations, which have been rescinded, established gainful
employment rules to operationalize the statutory phrase.8 In May 2023, ED published proposed
rules for new gainful employment regulations.9 These regulations would establish program-level
metrics relating to debt-to-earnings limits and earnings compared to high school graduates, and
the proposed rules would require the disclosure of program-level performance information (e.g.,
primary occupation, completion rate, program costs) to prospective students.
Short-Term Pell Grant Policy Arguments
Congress and higher education advocacy organizations have generally described several
justifications for extending Pell Grants to educational programs that are shorter in duration than
permitted under current law. In general, the policy is intended to benefit prospective students,
employers, and the overall economy. Suggested advantages have included the following:
• support for short-term training may increase workforce participation and lead to
the filling of vacant positions for employers,10
• not all students are interested in or have the capacity to achieve a degree,11 and
• some short-term training programs may provide equal or better employment and
earning prospects to completers and federal return on investment than some
educational programs that are Pell-eligible under current law.12
Proponents have also argued that Pell Grants may be an optimal mechanism to support short-term
training because the program is a quasi-entitlement program—for the most part, eligible students
receive the Pell Grant award amount calculated for them without regard to available
appropriations—with a stable funding stream.13

7 At a proprietary HEA Title IV-participating IHE that has been continuously accredited by an ED-recognized
accrediting agency since at least October 1, 2007, and has provided the program continuously since January 1, 2009,
eligible programs also include those leading to a bachelor’s degree in liberal arts.
8 U.S. Department of Education, “Program Integrity: Gainful Employment,” 79 Federal Register 64889, October 31,
2014, as rescinded by U.S. Department of Education, “Program Integrity: Gainful Employment,” 84 Federal Register
31392, July 1, 2019.
9 U.S. Department of Education, Office of Postsecondary Education, “Financial Value Transparency and Gainful
Employment (GE), Financial Responsibility, Administrative Capability, Certification Procedures, Ability to Benefit
(ATB),” 88 Federal Register 32300-32511, May 19, 2023.
10 Republican Members of the House Committee on Education and the Workforce, “Workforce Pell Opens Pathways to
Successful Careers,” press release, November 18, 2022; and U.S. Congress, House Committee on Education and the
Workforce, Promoting Real Opportunity, Success, and Prosperity Through Education Reform Act, to accompany H.R.
4508, 115th Cong., 2nd sess., February 8, 2018, H.Rept. 115-550, pp. 203-204.
11 Republican Members of the House Committee on Education and the Workforce, “Workforce Pell Opens Pathways to
Successful Careers,” press release, November 18, 2022.
12 Republican Members of the House Committee on Education and the Workforce, “Workforce Pell Opens Pathways to
Successful Careers,” press release, November 18, 2022.
13 Wesley Whistle, Short Memories Lead to Long-Term Consequences, New America, January 11, 2021, p. 28.
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Opposition to expanding Pell Grants to short-term programs is rooted in historical abuse and
inconsistent employment returns for these programs.14 For example, federal investigations have
found various abuses by IHEs across all institutional sectors related to the provision of student
loans for shorter educational programs (see the “Student Loans for 300-599 Clock Hour
Programs” section). While completers of some short-term programs have higher wages or
lengthier employment terms than noncompleters, completers of other short-term programs do not
realize such benefits.15 The evidence of fraud and inconsistent returns have resulted in some
advocates of short-term Pell Grants proposing various limitations on the expansion, including, but
not limited to, establishing employment and earnings standards for graduates.
Student Loans for 300-599 Clock Hour Programs
Although Pell Grants are not currently available to students in short-term programs, federal
student loans have been since the 1960s. Experience with the administration of student loan
programs for postsecondary students enrolled in eligible programs of at least 300 clock hours
might inform the short-term Pell Grant policy proposals. The requirements for such student loan
programs have been modified over time in response to findings of abuse and poor outcomes.
Pre-1992 Loan Programs and Outcomes
Since at least 1965, and through 1992, student loans were available through various loan
programs for postsecondary students for the pursuit of educational programs of at least 300 clock
hours. These loan programs were intended to provide parallel access to postsecondary education
for vocational and collegiate students in recognition of diverse student objectives and preferences,
as well as workforce needs.16 The National Vocational Student Loan (NVSL) program was
available to students enrolled in vocational programs of at least 300 clock hours of classroom
instruction (or the equivalent) at public, private nonprofit, and proprietary business, trade,
technical, and vocational schools.17 The NVSL loan program was merged into the HEA Title IV-B
student loan program to simplify program administration.18 By 1970, the HEA Title IV-B student
loan program was available for programs of not less than 300 clock hours of classroom
instruction (or the equivalent).19
In the 1970s, shorter educational programs, especially those offered by proprietary institutions,
were associated with poor student outcomes and abuses. Employment and wages for program
graduates were generally poor regardless of whether the training was offered by proprietary or
public institutions. Based on a sample of 2,000 graduates from both proprietary and public
institutions, 20% of professional and technical graduates were employed in related jobs, and 80%

14 Sean Ruddy and Kevin Miller, Are Short-Term Pell Grants a Good Idea? The Need for an Expanded Pilot Study,
Bipartisan Policy Center, December 2021, p. 4.
15 Sean Ruddy and Kevin Miller, Are Short-Term Pell Grants a Good Idea? The Need for an Expanded Pilot Study,
Bipartisan Policy Center, December 2021, p. 4.
16 U.S. Congress, Senate Committee on Labor and Public Welfare, National Vocational Student Loan Insurance Act of
1965, to accompany H.R. 7743, 89th Cong., 1st sess., September 21, 1965, S.Rept. 89-758.
17 NVSL was authorized by the National Vocational Student Loan Insurance Act of 1965 (NVSL; P.L. 89-287) and the
Higher Education Act of 1965 (P.L. 89-329). U.S. Department of Health, Education, and Welfare, Office of Education,
“Part 178-Federal, State, and Private Programs of Low-Interest Loans and Direct Federal Loans to Vocational
Students,” 31 Federal Register 14942, November 26, 1966.
18 The Higher Education Amendments of 1968 (P.L. 90-575).
19 U.S. Department of Health, Education, and Welfare, Office of Education, “Part 177-Federal, State, and Private
Programs of Low-Interest Loans to Vocational Students and Students in Institutions of Higher Education,” 35 Federal
Register 16888-16896, October 31, 1970.
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of lower-level clerical or service worker graduates, excluding secretaries, barely earned minimum
wage. Training offered by proprietary institutions was found to be associated with deceptive
advertising, predatory recruiting practices, unfair refund policies, low completion rates, poor
curriculum and instructional quality, institutional financial instability and high bankruptcy risk,
and improper training for a job that may not exist.20
By the early 1990s, several concerns had been raised regarding vocational programs of 300-599
clock hours and the provision of student loans for such programs. Congressional testimony
provided prior to the enactment of the Higher Education Act Amendments of 1992 by the
Secretary of Education and other stakeholders postulated that eliminating loans for shorter
programs would reduce loan defaults and the use of student aid for programs of poor quality with
poor employment outcomes.21 In addition, congressional testimony in the early 1990s by a
student loan guaranty agency, a state licensing agency, an accrediting agency, and the ED
Inspector General indicated that some IHEs had increased the instructional duration of programs
in order for students to be eligible for loans, and such program stretching was associated with
increased debt and time to completion.22 Some Members of Congress advocated for greater
federal monitoring of these programs rather than eliminating federal student aid for them because
shorter educational programs provided greater choice among educational program offerings for
students, an opportunity to pursue training for disadvantaged students, and practical training that
led to remunerative employment.23
Higher Education Amendments of 1992
The Higher Education Amendments of 1992 (1992 amendments; P.L. 102-325), as amended by
the Higher Education Technical Amendments of 1993 (P.L. 103-208), enacted several provisions
to address reported problems of fraud and abuse in the HEA Title IV aid programs generally, and
student loans for shorter programs specifically. For example, the student loan cohort default rate
threshold was lowered for all IHEs, making it easier for IHEs to lose HEA Title IV eligibility.24
The amendments also included student protections. For example, IHEs were required to establish
a fair and equitable tuition refund policy for HEA Title IV aid recipients. Regarding student loans
for shorter programs specifically, the 1992 amendments revised the definition of HEA Title IV
eligible programs and established requirements for shorter programs for which students may
borrow Direct Loans.

20 U.S. Congress, House Committee on Government Operations, Reducing Abuses in Proprietary Vocational
Education: Twenty-Seventh Report, committee print, 93rd Cong., 2nd sess., December 30, 1974, H.Rept. 93-1649.
21 U.S. Congress, House Committee on Education and Labor, Higher Education Amendments of 1992, 102nd Cong., 2nd
sess., February 27, 1992, H.Rept. 102-447, p. 63; U.S. Congress, Senate Committee on Governmental Affairs,
Permanent Subcommittee on Investigations, Abuses in Federal Student Aid Programs, 101st Cong., 2nd sess., February
20, 26, 1990, S.Hrg. 101-659 (Washington: GPO, 1990), pp. 488-490; and U.S. Congress, Senate Committee on
Governmental Affairs, Permanent Subcommittee on Investigations, Abuses in Federal Student Aid Programs, Part 2,
101st Cong., 2nd sess., September 12, 1990, S.Hrg. 101-659, Pt. 2, p. 122.
22 U.S. Congress, Senate Committee on Governmental Affairs, Permanent Subcommittee on Investigations, Abuses in
Federal Student Aid Programs, Part 2, 101st Cong., 2nd sess., September 12, 1990, S.Hrg. 101-659, Pt. 2, pp. 121, 126,
209-211, 443, 553.
23 U.S. Congress, House Committee on Education and Labor, Subcommittee on Postsecondary Education, Oversight
Hearing on the Reauthorization of the Higher Education Act of 1965, 99th Cong., 1st sess., May 13, 1985, H.Hrg. 99-33,
pp. 10-11.
24 In general, the cohort default rate is the percentage of an IHE’s qualifying Federal Family Education Loan (FFEL)
program and Direct Loan program borrowers who enter repayment in a given fiscal year and default within three years
after entering repayment.
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Because vocational programs of 300-599 clock hours had been linked to charges of fraud, abuse,
and high default rates, the 1992 amendments established requirements that
• for purposes of all HEA Title IV aid programs, eligible undergraduate
educational programs be at least 600 clock hours, 16 semester hours, or 24
quarter hours over a minimum of 15 weeks and prepare students for gainful
employment in a recognized profession;
• for purposes of all HEA Title IV aid programs, eligible educational programs be
300-599 clock hours (or the equivalent) over a minimum of 10 weeks and require
at least an associate’s degree for admission; and
• for purposes of providing loans to students enrolled in short programs, eligible
educational programs be 300-599 clock hours and have verified completion and
placement rates of at least 70%.25
The 1992 requirements for shorter programs remain in current law, but the 1992 definition of
eligible program has been expanded to include programs offered through telecommunications and
programs that utilize direct assessment.26
Current Requirements for 300-599 Clock Hour Programs Participating in the
Direct Loan Program
Under current law, students in 300-599 clock hour programs may be eligible to borrow a federal
student loan from the William D. Ford Federal Direct Loan (Direct Loan, or DL) program.27 Such
educational programs are programs of 300-599 clock hours of instruction that are offered during a
minimum of 10 weeks and have a verified completion rate and placement rate of at least 70%.
The Secretary may establish additional requirements for 300-599 clock hour programs. Under
current regulations, the program must
• provide undergraduate training that prepares a student for gainful employment in
a recognized occupation,
• admit as regular students some individuals who have not completed the
equivalent of an associate’s degree,
• have been in existence for at least one year, and
• not be more than 50% longer than the minimum training period required by the
state or federal agency (if any) for the occupation for which the program is
intended.28 For some occupations, state and federal agencies require that entrants
receive a minimum number of hours of instruction on certain subjects.29

25 IHEs calculate their program-level completion and placement rates.
26 The Deficit Reduction Act of 2005 (P.L. 109-171) expanded the eligible program definition to include programs
offered in whole or in part through telecommunications and programs that utilize direct assessment in lieu of credit
hours or clock hours as the measure of student learning.
27 HEA §481(b)(2).
28 38 C.F.R. §668.8(d)(3).
29 For example, the Maryland Department of Labor requires applicants to have completed 150 hours of courses
approved by the Maryland Commission of Real Estate Appraisers, Appraisal Management Companies and Home
Inspectors and meet other requirements to become a licensed real estate appraiser; see https://www.dllr.state.md.us/
license/reahi/ (as available on March 28, 2023).
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Regardless of program length, students borrowing Direct Loans must be enrolled on at least a
half-time basis.30 The Secretary must verify the 300-599 clock hour program meets the
established statutory and regulatory requirements before the first student is eligible to receive a
Direct Loan in the program.
On April 10, 2019, there were approximately 114 ED-approved 300-599 clock hour programs for
which a student could borrow a Direct Loan. Public and proprietary IHEs offered most of the
programs—20% and 76%, respectively. Almost half (46%) of all the programs were in the
cosmetology and related personal grooming services, and an additional 14% were in the health
professions and related clinical sciences.31 The majority (65%) of programs required 400 or fewer
clock hours of instruction. Sixty percent of programs reported completion rates over 90%, and
44% of programs reported placement rates above 90%.32
A 2021 analysis by the Brookings Institution of the outcomes for 300-599 clock hour programs
for which students may borrow Direct Loans found that earnings of graduates from more than
two-thirds (70%) of such programs did not exceed the average earnings of high school drop
outs.33
History of Pell Grants for Shorter Programs
As opposed to the student loan programs, Pell Grants have not been available to students enrolled
in shorter programs. The Pell Grant program (initially known as Basic Educational Opportunity
Grants) was enacted by the Education Amendments of 1972 (P.L. 92-318). As originally
implemented, a Pell-eligible educational program had to lead to a degree or certificate, be of at
least six months in duration, and admit as regular students only high school graduates (or the
equivalent).34
The definition of HEA Title IV-eligible educational program enacted by the 1992 amendments
applied to the Pell Grant program as well as other HEA Title IV aid programs, except that 300-
599 clock hour educational programs that did not require at least an associate’s degree for
admission were not Pell-eligible.35 The 1992 eligible program requirements (see the “Higher
Education Amendments of 1992” section) generally remain in effect under current law.
ED Pell Grant Experiments with Shorter Educational Programs
Since at least the 1990s, ED has tested various statutory and regulatory changes in an effort to
improve the integrity of student aid delivery, improve services to students, and reduce
administrative burdens.36 In 2009, ED made a public solicitation for innovative strategies to

30 To be enrolled half-time, a student must be taking at least half of the course load of a full-time student. For example,
if a school sets 12 semester hours as full-time, 6 semester hours is considered as half-time.
31 The program categorization is based on ED’s Classification of Instructional Programs (CIP Codes). The
classification provides a taxonomic scheme that supports the accurate tracking and reporting of fields of study and
program completions activity.
32 Email from U.S. Department of Education, Office of Legislation and Congressional Affairs, to CRS, August 7, 2019.
33 Stephanie Riegg Cellini and Kathryn J. Blanchard, Quick college credentials: Student outcomes and accountability
policy for short-term programs, Brookings, July 22, 2021, https://www.brookings.edu/research/quick-college-
credentials-student-outcomes-and-accountability-policy-for-short-term-programs/.
34 45 C.F.R. §190.2 (1975).
35 IHEs calculate their program-level completion and placement rates.
36 Under Section 487A(b) of the HEA, the Secretary of Education has the authority to grant waivers from specific HEA
Title IV statutory or regulatory requirements to test alternative methods for administering the HEA Title IV programs.
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improve postsecondary student outcomes.37 In partial response to that solicitation, ED conducted
two Pell Grant experiments from November 2012 to June 30, 2017. Experiment #1 provided Pell
Grants to students with a bachelor’s degree, and Experiment #2 provided Pell Grants to students
in short-term programs. The experiments were intended to test whether allowing students to
receive a Pell Grant while pursuing shorter vocational training programs would address the
unemployed or underemployed status of such individuals.38 The experiments were designed with
a random assignment evaluation such that the outcomes might inform potential statutory changes.
Most of the entering participants were over age 30 with an average adjusted gross income of
$22,176.
The outcomes that were evaluated under these experiments focused on program enrollment and
completion. ED indicated that data related to employment and earnings could not be collected
during the study period and the results might not have met statistical requirements for measuring
effects.
Post-Bachelor’s Pell Grant Experiment
The post-bachelor’s experiment (Experiment #1), provided Pell Grants to otherwise Pell-eligible
students with a bachelor’s degree who were unemployed or underemployed and started the
educational program for the first time. The program had to
• meet the current law minimum durational requirements,
• be no more than one year in duration,
• be Pell-eligible, and
• meet local or regional workforce needs as determined by the institution in
consultation with employers or state or local workforce agencies.
The Pell Grant was limited to one scheduled award over no more than two award years. Actual
awards were prorated based on the program’s length and number of credits awarded. Experiment
#1 had 35 IHEs and 414 students participating. Otherwise Pell-eligible students with a bachelor’s
degree demonstrated a 20 percentage-point increase in enrollment and completion when offered a
Pell Grant for shorter educational programs. Over 50% of participants enrolled in health
professions and related programs. They completed their programs within 30 months, on average,
as many participants were not enrolled full-time. The average cost of attendance was $19,600.39
Participants received $3,577 in Pell Grants, on average. In addition, one-third of participants
received federal student loans averaging $12,950.40

37 U.S. Department of Education, “Federal Student Financial Assistance Programs Under Title IV of the Higher
Education Act of 1965, as Amended,” 74 Federal Register 55542-55543, October 28, 2009.
38 U.S. Department of Education, “Postsecondary Educational Institutions Invited to Participate in Experiments Under
the Experimental Sites Initiative,” 76 Federal Register 66698-66707, October 27, 2011.
39 The cost of attendance presented is the total price for in-state students living off campus (but not with family).
40 U.S. Department of Education, “Postsecondary Educational Institutions Invited to Participate in Experiments Under
the Experimental Sites Initiative,” 76 Federal Register 66698-66707, October 27, 2011; and J. Thomas, N. Gonzalez,
A. Wiegand, N. Paxton, and L. Hebbar, The Effects of Expanding Pell Grant Eligibility for Short Occupational
Training Programs: Results from the Experimental Sites Initiative (NCEE 2021–001) (Washington, DC: U.S.
Department of Education, Institute of Education Sciences, National Center for Education Evaluation and Regional
Assistance, 2021), http://ies.ed.gov/ncee.
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Short-Term Pell Grant Experiment
The short-term Pell Grant experiment (Experiment #2), provided Pell Grants to Pell-eligible
students in short-term programs. The educational program had to
• provide at least 150 clock hours of instructional time,
• be at least eight weeks in duration,
• be offered by a community college or postsecondary vocational institution, and
• meet local or regional workforce needs as determined by the institution in
consultation with employers or state or local workforce agencies.
The Pell Grant was prorated for the shorter instructional time.41 Experiment #2 had 28 IHEs and
2,270 participating students participating. Over 80% of these students pursued programs in (1)
transportation and materials moving or (2) health professions. Pell-eligible students demonstrated
a 10 percentage-point increase in enrollment and completion when offered a Pell Grant for short-
term programs. The average cost of attendance was $16,900.42 On average, participants received
$1,312 in Pell Grants, and 9% received federal student loans averaging $4,021.43
ED’s evaluation has some limitations. The findings may not be generalizable because the sample
sizes were small, 72% of the participating institutions were public two-year colleges, and almost
half of the institutions were in the southeastern United States. Although the analysis did not find
evidence of reduced associate’s degree completion, neither experiment examined employment or
wage outcomes, so it is unclear to what extent pursuit and completion of shorter educational
programs would benefit participants in the short- and long-term in the workforce.44
Short-Term Pell Grant Bills in the 118th Congress
Although short-term Pell Grants have bipartisan support in terms of concept, there is salient
disagreement in two policy areas—institutional eligibility and program quality assurance
mechanisms.45
This section compares three bills that have been introduced in the 118th Congress:46

41 The Pell Grant was prorated in accordance with 34 C.F.R. §690.63(a)(3).
42 The cost of attendance presented is the total price for in-state students living off campus (not with family).
43 Department of Education, “Postsecondary Educational Institutions Invited to Participate in Experiments Under the
Experimental Sites Initiative,” 76 Federal Register 66698-66707, October 27, 2011; and J. Thomas, N. Gonzalez, A.
Wiegand, N. Paxton, and L. Hebbar, The Effects of Expanding Pell Grant Eligibility for Short Occupational Training
Programs: Results from the Experimental Sites Initiative (NCEE 2021–001) (Washington, DC: U.S. Department of
Education, Institute of Education Sciences, National Center for Education Evaluation and Regional Assistance, 2021),
http://ies.ed.gov/ncee.
44 J. Thomas, N. Gonzalez et al., The Effects of Expanding Pell Grant Eligibility for Short Occupational Training
Programs: Results from the Experimental Sites Initiative (NCEE 2021–001) (Washington, DC: U.S. Department of
Education, Institute of Education Sciences, National Center for Education Evaluation and Regional Assistance, 2021),
http://ies.ed.gov/ncee.
45 Jennifer Stiddard, “Skills Blog: Looking Back at Short-Term Pell and Future Prospects,” press release, August 1,
2022, National Skills Coalition, https://nationalskillscoalition.org/blog/higher-education/making-college-work/looking-
back-at-short-term-pell-and-future-prospects/. This article reviewed short-term Pell Grant legislation in the 117th
Congress.
46 Additional bills to authorize short-term Pell Grants have been introduced in the 118th Congress. See, for example, S.
2442 and H.R. 221. The bills compared herein have several cosponsors who are members of the committee to which
the bills were referred or are sponsored by leadership of the committee to which the bills were referred.
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• The Promoting Employment and Lifelong Learning Act (PELL Act; H.R. 496),
as introduced on January 25, 2023. This bill is sponsored or co-sponsored by at
least 10 Members of the House Committee on Education and the Workforce
(E&W), including the committee chair.
• The Jobs to Compete Act (H.R. 1655), as introduced on March 17, 2023. This
bill is sponsored by the ranking member of E&W and has at least one cosponsor
on the committee.
• The Jumpstart Our Businesses by Supporting Students Act (JOBS Act; S. 161), as
introduced on January 31, 2023. This bill has at least nine cosponsors on the
Senate Committee on Health, Education, Labor and Pensions.47 The companion
legislation, the JOBS Act of 2023 (H.R. 793), was introduced February 2, 2023,
and has at least one cosponsor on E&W.
This section briefly describes some of the major provisions included in these bills, as introduced;
it does not provide a comprehensive discussion of every provision contained in the bills.48 The
analysis related to S. 161 also applies to H.R. 793. Table 1 provides a summary of key
characteristics of the proposals.
Table 1. Comparison of Key Characteristics of Selected Short-Term Pell Grant Bills
in the 118th Congress
Characteristic

H.R. 496

H.R. 1655

S. 161a
General Characteristics
Eligible program
150-600 clock hours (or
150-599 clock hours (or
150-600 clock hours offered
duration
equivalent credit hours) offered
equivalent credit hours) offered
over 8-15 weeks, subject to
over 8-15 weeks
over 8-14 weeks, subject to
other limitations
other limitations
Eligible institutions
IHEs, including public, private
IHEs, including public, private
Only public and private nonprofit
nonprofit, and proprietary
nonprofit, and proprietary
IHEs that are accredited by an
(private for-profit) IHEs, must be
(private for-profit) IHEs, must be
institutional accrediting agency
accredited by an institutional
accredited by an institutional
recognized by ED to assess an
accrediting agency recognized by
accrediting agency recognized by
IHE’s Pell-eligible short-term
ED to assess an IHE’s Pell-
ED to assess an IHE’s Pell-eligible
education programs
eligible short-term education
short-term education programs;
programs
and IHEs must not have been
subject to specified adverse
actions within the past five years
Eligible students
Students may have received a
Students may have received a
Students may have received a
bachelor’s degree but not a
bachelor’s degree but not a
bachelor’s degree but not a
postbaccalaureate degree
postbaccalaureate degree
postbaccalaureate degree
Award Rules
Minimum grantb
Maintains current law minimum Maintains current law minimum Lowers current law minimum
Pell Grant award of 10% of the
Pell Grant award of 10% of the
Pell Grant award to 5% of the
total maximum award, but short-
total maximum award, but short-
total maximum award, but short-
term Pell Grant awards based on
term Pell Grant awards based on
term Pell Grant awards based on
SAI have no minimum award
SAI have no minimum award
SAI have no minimum award

47 The bill is similar, although pared down and modified, to Section 90305 of the America Creating Opportunities for
Manufacturing, Pre-Eminence in Technology, and Economic Strength Act of 2022 (America COMPETES Act of 2022;
H.R. 4521), as passed by the House.
48 This report does not specifically outline unique considerations for correspondence programs.
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Characteristic

H.R. 496

H.R. 1655

S. 161a
Administrative Requirements
WIOA Eligible Training Eligible programs are not
Eligible programs must be on the Eligible programs must be on the
Provider List (ETPL)c
required to be on the WIOA
state’s ETPL created under
state’s ETPL created under
ETPL but must be in an in-
WIOA; programs on the WIOA
WIOA; programs on the WIOA
demand industry or occupation
ETPL must be in in-demand
ETPL must be in in-demand
per WIOA and must meet hiring
industry sectors or occupations
industry sectors or occupations
requirements of employers in in-
demand industry sectors or
occupations under WIOA
Other relevant labor
Program must provide training
Program must provide training
Program must provide training
market requirements
aligned with “in-demand industry
aligned with “high-skil , high-
aligned with “high-skil , high-
sectors or occupations” (see
wage, or in-demand industry
wage, or in-demand industry
row above)
sectors or occupations” in the
sectors or occupations in the
state or local area, as
state or local area, as
determined by an accrediting
determined by an industry or
agency; and it must meet
sector partnership”; and it must
applicable educational
meet applicable educational
requirements for professional
requirements for professional
licensure or certification in the
licensure or certification in the
state, if applicable
state, if applicable
Credential
NA
Program must lead to a
Program must lead to a
recognized postsecondary
recognized postsecondary
credential, as defined by WIOAd
credential, as defined by WIOAd
Credit toward a
NA
Program must ensure noncredit Program shall include
subsequent educational
coursework in a completed
institutional credit articulation
program
program provides credit toward
for a student enrol ed in a
a related certificate or degree
noncredit job training program
program, and must, with
that may be applied to a
exceptions, ensure credits are
subsequent credit-bearing
acceptable toward related
certificate or degree program
certificate or degree programs
upon enrol ment in such
program at such institution
Other requirements
NA
Program cannot be exclusively
NA
online, must have been offered
for at least one year, must
provide counseling to students,
and must ensure educational
spending is at least 50% of
program tuition and fees
revenue
Outcome Metrics
Completion and
At least 70% completion rate
At least 70% completion rate
NA
placement requirements and 70% placement rate
and 70% placement rate
Earnings requirement
Value-added earnings of program Median earnings of program
NA
completers must exceed the
completers must increase by at
published tuition and fees for the
least 20%, and must exceed the
program
median earnings of adults aged
25-34 with only a high school
diploma (or equivalent) in the
state in which the program is
located
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Characteristic

H.R. 496

H.R. 1655

S. 161a
Gainful employment
NA
Program must “prepare students NA
for gainful employment in a
recognized occupation”e
Other Requirements
IHE disclosures to
NA
IHEs must disclose program
NA
enrol ed and
information such as program
prospective students
cost, program completion rate,
professional licensure pass rates,
and earnings of program
completers
IHE reporting to ED
NA
Annual reporting for each
NA
program, with information such
as overall expenditures,
educational expenditures, and
tuition and fees revenue
ED reporting to the
ED must expand the Col ege
ED must expand the Col ege
NA
public
Scorecard to report data on
Scorecard to report data on Pell-
Pell-eligible short-term programs
eligible short-term programs
such as program duration,
such as program duration,
completion rates, employment
completion rates, employment
rates, and earningsf
rates, and earnings, disaggregated
by various demographic
indicatorsf
Source: Prepared by CRS based on H.R. 496, H.R. 1655, and S. 161 as introduced in the 118th Congress.
Notes:
ETPL = the WIOA eligible training provider list.
NA = not applicable (no relevant requirement).
SAI = student aid index.
WIOA = the Workforce Innovation and Opportunity Act.
a. The companion legislation of S. 161 is the JOBS Act of 2023 (H.R. 793).
b. Under current law, to qualify for a Pell Grant award the student must qualify for the minimum grant amount
to be eligible for the program. The minimum grant amount is 10% of the maximum award. If a student does
not qualify for the maximum Pell Grant award based on adjusted gross income (AGI), the student may
qualify for a calculated award based on SAI, but the calculated award must not be below the minimum grant.
If a student does not qualify for a calculated Pell Grant award based on SAI, the student may qualify for the
minimum grant based on AGI.
c. For more information on WIOA, see CRS Report R44252, The Workforce Innovation and Opportunity Act and
the One-Stop Delivery System. For more information on the ETPL, see CRS Report R44252 and DOL Training
and Employment Guidance Letter 08-19, January 2, 2020.
d. For more details on credentials under WIOA, see Section 3(52) of WIOA, and DOL Training and
Employment Notice 25-19, June 8, 2020.
e. If the proposed gainful employment rules (U.S. Department of Education, Office of Postsecondary
Education, “Financial Value Transparency and Gainful Employment (GE), Financial Responsibility,
Administrative Capability, Certification Procedures, Ability to Benefit (ATB),” 88 Federal Register 32300-
32511, May 19, 2023) are finalized, programs would be required to meet the regulations.
f.
Col ege Scorecard is ED’s web portal intended to allow the public to search and compare col eges by their
fields of study, costs, admissions, results, and other characteristics and to compare fields of study by
credential type, salary, WIOA qualification, and other characteristics. It is available at
https://col egescorecard.ed.gov.
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General Frameworks of the Legislation
For the most part under current law, HEA Title IV-eligible educational programs are Pell-eligible
programs as long as they are undergraduate programs. As mentioned earlier, all references to
current law denote the HEA as in effect on or before July 1, 2024, as a result of amendments by
the FAFSA Simplification Act (FSA; Title VII, Division FF, P.L. 116-260 [Consolidated
Appropriations Act, 2021]) and the FAFSA Simplification Act Technical Corrections Act
(FSATCA; Division R, P.L. 117-103 [Consolidated Appropriations Act, 2022]).49
None of the three bills discussed in this report simply reduce the minimum hours for a program to
be Pell-eligible. Instead, each bill creates a new type of award within the existing authorization
for Pell Grants in HEA Section 401 and then creates supplemental criteria related to the new
award. Establishing a new type of award within the existing Pell Grant program means that these
new programs would utilize existing Pell funding streams. The supplemental criteria would
modify student eligibility, institutional eligibility, educational program eligibility, and award
rules, as well as establish additional requirements.
The next sections begin with a comparison of eligibility requirements for students, IHEs, and the
short-term programs based on current law and the three bills. This is followed by a description of
any procedures the bills would establish for the approval of Pell-eligible short-term programs.
Subsequent sections describe changes the bills would make to Pell Grant award rules, reporting
and disclosure requirements, and the Direct Loan program.
H.R. 496 and H.R. 1655 call the new awards the Workforce Pell Grants Program, and S. 161 calls
them the Job Training Federal Pell Grant Program. This report collectively refers to these new
proposed awards as short-term Pell Grants.
Eligible Students
Under current law, individuals with a bachelor’s degree (or the equivalent) are not eligible for a
Pell Grant.
Under all three bills, students who are enrolled in eligible short-term programs and otherwise
eligible for a Pell Grant would be eligible for a short-term Pell Grant. All three bills would also
establish eligibility for short-term Pell Grants to students with a bachelor’s degree but not a
postbaccalaureate degree.50
ED’s short-term Pell Grant Experiment #1 included individuals with a bachelor’s degree because
some such students are unemployed or underemployed.51 Approximately 21% of undergraduates
seeking an undergraduate certificate in AY2015-2016 had previously earned a degree.52 In
AY2019-2020, such pursuit represented approximately 22% of undergraduates with a degree.53

49 The amendments go into effect on or before July 1, 2024, coinciding with the beginning of the 2024-2025 award
year. For a description of the amendments, see CRS Report R46909, The FAFSA Simplification Act.
50 None of the three bills would change the current law provision that excludes individuals with a bachelor’s degree
from regular Pell Grant eligibility.
51 U.S. Department of Education, Office of Postsecondary Education, “Postsecondary Educational Institutions Invited
To Participate in Experiments Under the Experimental Sites Initiative,” 76 Federal Register 66698-66707, October 27,
2011.
52 CRS analysis of U.S. Department of Education, National Center for Education Statistics, National Postsecondary
Student Aid Study: 2016 Undergraduates (NPSAS:UG) using the following variables: DEGPRHIGH, SECTOR4, and
UGDEG.
53 CRS analysis of U.S. Department of Education, National Center for Education Statistics, National Postsecondary
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Among AY2013-2014 bachelor’s degree recipients, 5.8% pursued further education in a two-year
institution within two years of earning their degree.54
Eligible Institutions
Under current law, only HEA Title IV-participating IHEs may award Pell Grants to eligible
students enrolled in Pell-eligible educational programs.55 Domestic public, private nonprofit, and
proprietary institutions may be HEA Title IV-eligible if they meet several statutory and regulatory
requirements, including being accredited by an ED-recognized accrediting agency. HEA Title IV-
eligible IHEs that receive ED certification as HEA Title IV-participating IHEs may disburse Pell
Grants.
Under current law, there are additional requirements for Title IV-participating IHEs that disburse
Pell Grants to incarcerated students that are similar to those in the short-term Pell Grant
proposals.56 Such IHEs must not be proprietary IHEs and must not have been subject within the
preceding five years to the following unfavorable actions by ED, their accrediting agency, or the
state:
• any suspension, emergency action, or termination of programs under HEA Title
IV;
• any adverse action by the institution’s accrediting agency; or
• any action by the state to revoke a license or other authority to operate.
Under H.R. 496 and H.R. 1655, current HEA Title IV-participating IHEs from all sectors could
offer Pell-eligible short-term programs. S. 161 would restrict eligible institutions to public and
private nonprofit institutions, thus excluding proprietary IHEs.
None of the proposals would expand the types of institutions that could offer short-term programs
compared to current law. For example, the proposals would not include employers or professional
organizations as eligible institutions.
While institutions from all sectors would be eligible under H.R. 1655, the bill would exclude
institutions that have been subject during any of the preceding five years to the following adverse
actions:
• any suspension, emergency action, or termination of programs under HEA Title
IV;
• any adverse action by the institution’s accrediting agency; or
• any action by the state to revoke a license or other authority to operate.
H.R. 496 and S. 161 would not establish similar restrictions related to institutional standing.
The proposed accreditation requirements are described below.

Student Aid Study: 2020 Undergraduates (NPSAS:UG) using the following variables: DEGPRHIGH, SECTOR4, and
UGDEG.
54 National Student Clearinghouse, Snapshot Report: Two-Year Enrollment after Bachelor’s Degree, Summer 2016,
https://nscresearchcenter.org/snapshotreport-twoyearenrollmentafterbachelors24/.
55 For more information on current law institutional eligibility requirements, see CRS Report R43159, Institutional
Eligibility for Participation in Title IV Student Financial Aid Programs.
56 HEA §484(t)(1)(B).
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Role of Accreditation and Accreditors
Under current law, an HEA Title IV-eligible educational program must be evaluated by an ED-
recognized accrediting agency through one of two options. The IHE offering the Title IV-eligible
educational program may be accredited (or preaccredited if it is a public or private nonprofit IHE)
by an institutional accrediting agency recognized by ED for the purposes of Title IV aid.
Alternatively, if the IHE is a single-purpose institution (e.g., a stand-alone medical school), the
Title IV-eligible educational program may be accredited by a programmatic accrediting agency
recognized by ED for the purposes of Title IV aid.
In addition, HEA Title IV-eligible distance or correspondence education programs can only be
evaluated by those accrediting agencies that ED has recognized as having the evaluation of
distance or correspondence education programs within their scope of recognition. The IHE may
be accredited by such an institutional accrediting agency, or with respect to a single-purpose
institution, the program may be accredited by such a programmatic accrediting agency. ED-
recognized accrediting agencies may expand their scope of recognition to include distance
education by notifying ED.57 Accrediting agencies that accredit IHEs offering distance education
programs or individual distance education programs are not required to have separate standards,
procedures, or policies for the evaluation of distance education but are required to mandate that
IHEs have processes in place to verify student identities.
Regarding the recognition of specific accrediting agencies, ED considers recommendations from
the National Advisory Committee on Institutional Quality and Integrity (NACIQI). NACIQI
provides recommendations to ED for accrediting agencies that may relate to the criteria for
agency recognition, the recognition of specific agencies, and other issues. If the enrollment at an
IHE offering distance education increases by 50% or more within the institutional fiscal year,
NACIQI must review at its next meeting any change in scope for the accrediting agency that
accredits such IHE.
Each of the three proposals to expand Pell Grants to short-term programs generally would require
that IHEs offering Pell-eligible short-term programs be accredited by an institutional accrediting
agency. ED would have to include within the agency’s scope of recognition the evaluation of
IHEs based on standards “for determining if the institution has the capability to effectively offer”
Pell-eligible short-term education programs. Each bill would establish requirements for
accreditors that seek to include IHEs that offer short-term programs within their scope of
recognition. The bills would not authorize ED recognition of programmatic accrediting agencies
for purposes of Pell-eligible short-term education programs.
H.R. 496 would require that accrediting agencies recognized to assess IHEs with Pell-eligible
short-term programs ensure the short-term programs meet several requirements. The accrediting
agency would be responsible for ensuring the programs are aligned with in-demand industry
sectors or occupations, meet hiring requirements for those sectors or occupations, have been
offered for at least one year, and have verified completion and placement rates of at least 70%.
H.R. 1655 would explicitly require that each accrediting agency that is recognized to assess IHEs
with Pell-eligible short-term education programs ensure the education of the short-term program
is aligned with the requirements of high-skill, high-wage, or in-demand industry sectors or
occupations in the state or local area in which the program is provided. The accrediting agency
would have to rely on an appropriate entity (e.g., workforce development board) for determining

57 Distance education is added to an agency’s scope of recognition upon receipt of the official notification. ED reviews
an agency’s application of its distance education policies and procedures during the agency’s next renewal of
recognition.
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such alignment. The accrediting agency would also have to ensure the educational content of the
short-term program and postsecondary credential satisfy any professional licensure or state
certification standards in the state(s) in which the program is offered.
Upon enactment of H.R. 496 or H.R. 1655, ED-recognized accrediting agencies would be given
interim authority to temporarily expand their scope of recognition to include Pell-eligible short-
term education programs by notifying ED and explaining within the notification how the agency
intends to meet the additional recognition criteria. The temporary expansion in accreditation
scope would expire within five years of the bill’s enactment date unless ED were to approve the
expansion.
H.R. 496 and H.R. 1655 would each also establish additional requirements for NACIQI. They
would require NACIQI to hold meetings through 2025 to evaluate the additional criteria in the
scope of recognition for accrediting agencies that accredit IHEs offering Pell-eligible short-term
programs. If an accrediting agency so expands its scope of recognition, NACIQI would be
required to review at its next meeting the addition in scope for such accrediting agency and advise
ED on whether the agency meets the statutory criteria.
S. 161 would require that accrediting agencies recognized to assess IHEs with Pell-eligible short-
term programs ensure the educational content of the short-term program meets hiring
requirements and satisfies the educational prerequisites for relevant licensure or certification.
Characteristics of Programs Eligible for Short-Term Pell Grants
As noted previously, HEA Title IV-eligible educational programs generally are Pell-eligible under
current law as long as they are undergraduate programs. Educational programs of 300-599 clock
hours that are eligible for the Direct Loan program are not Pell-eligible. For prison education
programs (PEPs), the HEA establishes several additional requirements beyond the general HEA
Title IV educational program eligibility requirements so that enrolled incarcerated students may
receive Pell Grants.58 Some of these additional requirements have analogies in the short-term Pell
Grant proposals, which will be described below as appropriate.
Each of the short-term Pell Grant proposals would establish additional requirements for
educational programs to be eligible under the proposed new program. In many cases, the
additional requirements serve to ascertain that the educational programs supported by the new
short-term Pell Grant program provide workers with skills that are relevant in the labor market.
Generally, with the exception of the program duration requirement, these additional requirements
can be classified as emphasizing program (administrative) characteristics or participant outcomes
(performance-based metrics).
Eligible Program Duration
Under current law, a Pell-eligible program is an undergraduate program that requires at least 600
clock hours of instruction or 16 semester hours (or the equivalent) offered during a minimum of
15 weeks. Alternatively, if an associate’s degree is required for admission, an eligible program
may be an undergraduate program of at least 300 clock hours of instruction or 8 semester hours
(or the equivalent) offered during a minimum of 10 weeks.59

58 HEA §484(t)(1)(B).
59 Undergraduate programs are defined as programs designed to lead to a certificate or degree at or below the
baccalaureate level and also include qualifying postbaccalaureate teacher certification programs. Students with a
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H.R. 496, H.R. 1655, and S. 161 would all authorize short-term Pell Grants for otherwise HEA
Title IV-eligible programs of 150-599 clock hours offered over 8-14 weeks.60 H.R. 496 and H.R.
1655 would permit programs measured in credit hours. Under all three bills, hour and week
requirements would apply to undergraduate, graduate, and professional programs.61
H.R. 1655 and S. 161 would establish an additional maximum program duration based on state
requirements. They would require that the short-term program not exceed by more than 50% the
minimum training period required by the state (if applicable) for such program. This requirement
would closely mirror the regulatory requirement for 300-599 clock hour programs that are
eligible for the Direct Loan program.
Administrative Requirements for Programs Eligible for Short-Term Pell
Grants
Each of the three bills would establish required components of eligible programs. Generally, these
components would be in addition to existing requirements for HEA Title IV-eligible programs
(e.g., they must be offered by a Title IV-participating IHE).
Labor Market Relevance
Under current law, with the exception of PEPs, the HEA does not require Pell-eligible educational
programs to be aligned with specific occupations or to demonstrate labor market relevance.62
PEPs must satisfy any applicable educational requirements for professional licensure or
certification in the state where the correctional facility is located or, in the case of a federal
correctional facility, in the state in which most of the incarcerated individuals will reside upon
release.
Each of the three bills has a general directive that the training programs supported by the new
grant would meet hiring requirements of employers in in-demand industries. H.R. 496
specifically refers to employer hiring requirements in in-demand sectors under the WIOA.63 H.R.
1655 refers to employer hiring requirements in high-skill, high-wage sectors or in-demand sectors
under the WIOA.64 S. 161 includes a more general reference to meeting the hiring requirements

bachelor’s degree must be enrolled at least half-time in a postbaccalaureate teacher education program. Half-time
enrollment is at least six credit hours in a standard semester. A postbaccalaureate teacher education program does not
lead to a graduate degree, is offered by a school that does not also offer a bachelor’s degree in education, and leads to
certification or licensure necessary for employment as an elementary or secondary school teacher in the state. To be
eligible for a Pell Grant, the student enrolled in the postbaccalaureate teacher education program must be pursuing an
initial teacher certification or licensing credential within the state.
60 Strictly speaking, the upper bounds for eligible programs under H.R. 1655 would be “less than 600 clock hours” and
“less than 15 weeks.” The upper bounds in H.R. 496 and S. 161 are specified as “not more than 600” clock hours and
“not more than 15” weeks.
61 Students with a bachelor’s degree but not a postbaccalaureate degree would be eligible for short-term Pell Grants;
and students in postbaccalaureate programs would be eligible for short-term Pell Grants as long as they did not have a
postbaccalaureate degree.
62 To the extent that the IHE establishes objectives of labor market relevance for a particular program, the accrediting
agency is expected to ensure that the program is of sufficient quality to achieve the program’s stated objective (34
C.F.R. §602.17(a)). In addition, accrediting agencies must develop school assessment standards, which could include,
as appropriate, consideration of state licensing examinations and job placement rates, as long as the accrediting
agencies apply the standards consistently to all IHEs (34 C.F.R. §602.16(a) and 602.18).
63 H.R. 496 would require the accrediting agency to determine whether the short-term program meets the hiring
requirement.
64 H.R. 1655 would require the IHE to determine whether the short-term program meets the hiring requirement after
validation of that determination by an appropriate third-party entity (e.g., an industry or sector partnership).
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of employers.65 H.R. 1655 and S. 161 each specify that eligible programs must provide training
“aligned with the requirements of high-skill, high-wage, or in-demand industry sectors or
occupations” in the state or local area, but the determination would be made by the accrediting
agency under H.R. 1655 and by an industry or sector partnership under S. 161.66
Beyond meeting hiring requirements, H.R. 496 does not specify any requirements related to
licensure. H.R. 1655 and S. 161 both specify that eligible programs would be required to meet
any applicable educational requirement for professional licensure or certification in the state.67
Integration with WIOA ETPL
WIOA is the primary federal workforce development legislation and supports job training for
eligible workers.68 The statute authorizes formula grants to states that are administered at the
federal level by the U.S. Department of Labor (DOL). As a condition of receiving WIOA funds,
states must conduct a labor market analysis to identify in-demand industries and occupations, and
eligible training programs under WIOA must be in such industries and occupations. States
identify eligible training providers through the development and publication of an ETPL.
Providers on the WIOA ETPL must report on participants’ participation and outcomes.69
H.R. 496 would not require that programs be on the ETPL to qualify as an eligible short-term Pell
program. The bill requires that programs “provide an education aligned with the requirements of
in-demand industry sectors or occupations” as defined in WIOA.
H.R. 1655 and S. 161 would both require an eligible short-term Pell program to be on the ETPL
created under WIOA for the state in which the program is located. Inclusion of a program on the
ETPL implies that the state has determined the training program to be in an in-demand industry or
occupation.
Credential Requirements
Under current law, Pell Grants can support programs that lead to a degree or certificate.
H.R. 1655 and S. 161 would both require an eligible short-term Pell program to lead to a
recognized postsecondary credential, as defined by WIOA.70 H.R. 496 does not have a similar
requirement.

65 S. 161 would require the IHE to determine whether the short-term program meets the hiring requirement after
validation of that determination by an industry or sector partnership. S. 161 would prohibit ED from approving the
program without a certification from the state board that it meets the requirements.
66 S. 161’s subsequent requirement that eligible programs be on the Eligible Training Provider List (ETPL) could
therefore require that the program meet WIOA in-demand industries’ criteria.
67 H.R. 1655 and S. 161 would require the IHE to determine whether the short-term program meets licensure or
certification requirements after validation of that determination by an appropriate third-party entity (e.g., an industry or
sector partnership).
68 For more information on WIOA, see CRS Report R44252, The Workforce Innovation and Opportunity Act and the
One-Stop Delivery System.
69 For more information on the ETPL, see CRS Report R44252, The Workforce Innovation and Opportunity Act and the
One-Stop Delivery System; and DOL Training and Employment Guidance Letter 08-19, “Workforce Innovation and
Opportunity Act (WIOA) Title I Training Provider Eligibility and State List of Eligible Training Providers (ETPs) and
Programs,” January 2, 2020, https://www.dol.gov/agencies/eta/advisories/training-and-employment-guidance-letter-no-
08-19.
70 WIOA defines a recognized postsecondary credential as “a credential consisting of an industry-recognized certificate
or certification, a certificate of completion of an apprenticeship, a license recognized by the State involved or Federal
Government, or an associate or baccalaureate degree.” See WIOA Section 3(52), 29 U.S.C. §3102(52).
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Articulation Requirements
Under current law and regulations, PEPs must offer credits that may be transferred to at least one
IHE in the state where the correctional facility is located, or, in the case of a federal correctional
facility, in the state in which most of the incarcerated individuals will reside upon release. In
addition, PEPs must “be operating in the best interest of students,” as determined by the
appropriate correctional agency.71 The best interest determination must include, among other
requirements, an assessment of whether all formerly incarcerated students are able to fully
transfer their credits and continue their programs at any location of the IHE that offers a
comparable program.
H.R. 496 would not require that programs eligible for short-term Pell Grants be part of an
articulation agreement.
S. 161 and H.R. 1655 would both require that short-term Pell programs have mechanisms through
which credits earned can be applied to a subsequent program. S. 161 and H.R. 1655 would
require that eligible programs include means by which noncredit programs may be applied to
credit programs.72 H.R. 1655 also has a more general requirement that eligible programs ensure
“the acceptability of the credits received under the workforce program toward meeting
[subsequent] certificate or degree program requirements.” H.R. 1655 would establish an
exception to this requirement for a program that “prepares students for employment in an
occupation for which there is only one recognized postsecondary credential.”
Other Requirements
H.R. 1655 would establish several additional requirements for the short-term Pell Grant programs
that may be intended to ensure the quality of the program or improve student outcomes:
• The program could not be offered exclusively through distance education or a
correspondence course except as a temporary response to a disaster or
emergency.
• The program must have been offered by an IHE for not less than one year prior to
becoming a short-term Pell program, as determined by the IHE’s accrediting
agency. This provision would be similar to one of the regulatory requirements for
300-599 clock hour programs that are eligible for the Direct Loan program.
• One-half of the amount of tuition and fees revenue for the program could not
exceed the amount of educational spending for the program for each of the three
most recent fiscal years.
• The program would have to provide counseling to students to help them achieve
their educational and career goals.

71 34 C.F.R. §668.241. The determination must include an assessment of the comparability of the PEP’s instructors,
credits, advising services, and credit transferability to non-PEP programs and may include an assessment of other
relevant factors.
72 A dichotomy exists between programs made up of credit course(s) and noncredit programs (those structured as a
series of noncredit courses). However, courses in the same field of study with the same vocational objective and
industry recognition may be offered for credit at one institution and noncredit at another, or even within the same
institution. All degree programs are credit programs. Credit programs are most often approved by an accrediting entity
and may have more stringent student entrance or prerequisite requirements. Generally, individuals who successfully
complete credit courses and programs earn credits that may be transferred or used as currency toward the completion of
other credit programs. Although noncredit programs may offer continuing education units (CEUs) or vocational
certificates to program completers, the programs do not generally proffer students currency toward the pursuit of credit
programs or noncredit programs in other fields.
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• The program would have to provide counseling to students that reveals the
industry sectors and occupations for which the program prepares students, the
related certificate and degree programs for which the program prepares students,
and sources of financial assistance.
• The program would have to be a career and technical education program as
defined under the Carl D. Perkins Career and Technical Education Act (Perkins
Act), wherein career and technical education is defined as organized educational
activities that provide technical skills and academic content that lead to an
industry-recognized credential, a certificate, or an associate’s degree, or to further
education.
In addition to the administrative requirements described above, S. 161 would establish an
additional requirement for a short-term Pell program:
• The program would have to be a career and technical education program, but S.
161 would not define the term.
Outcome Metrics for Programs Eligible for Short-Term Pell Grants
With the exception of 300-599 clock hour programs that are eligible for the Direct Loan program,
neither HEA Title IV nor regulations establish program-level completion and employment
outcome requirements for Title IV-eligible programs offered at IHEs. The best interest
determination for PEPs may include an assessment of whether earnings, completion rates, and job
placement rates exceed established thresholds. ED publishes outcome data on resources like the
College Scorecard, but these outcome metrics, by themselves, have no direct effect on
institutional or program eligibility for student aid programs. The College Scorecard allows the
public to search for and compare colleges by their graduation rates, the median earnings of former
students, and the median earnings of program completers by field of study and other
characteristics.73 The proposed gainful employment rules (see the “Gainful Employment in a
Recognized Occupation” section) would establish program-level metrics relating to debt-to-
earnings limits and earnings relative to high school graduates. Some provisions in the short-term
Pell Grant proposals are similar to some of the proposed gainful employment rules.
In practice, institutions and programs often set their own standards for student learning outcomes,
depending on a variety of factors such as the level of education offered and the skills and
competencies required of graduates in different fields, and these standards may be guided by
accrediting agency policies. Accrediting agencies then evaluate the appropriateness of those
standards and whether institutions and programs use information gained from student learning
outcomes to improve student learning.74
H.R. 496 and H.R. 1655 have distinct earnings requirements but somewhat similar requirements
related to completion and placement. In addition, H.R. 1655 would require that Pell-eligible
short-term programs meet gainful employment requirements.
S. 161 does not include outcome metrics in the program eligibility requirements and is therefore
not discussed in this section.

73 The portal is available at https://collegescorecard.ed.gov/.
74 See Council for Higher Education Accreditation, The Value of Accreditation, June 2010, p. 5. See also, for example,
Higher Learning Commission, “Criteria for Accreditation” CCRT.B.10.010, Criterion 4, Revised September 1, 2020,
https://www.hlcommission.org/Policies/criteria-and-core-components.html.
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Earnings Requirements
H.R. 496 would establish a “value-added earnings” metric and require that it is equal to or
exceeds the published tuition and fees for the program. The metric would be calculated for
students who received HEA Title IV aid and completed the program three years prior. The metric
would be calculated as the difference between (1) the median earnings of such students, as
adjusted by the state and metropolitan area regional price parities and (2) 150% of the federal
poverty line applicable to single individuals.75
H.R. 1655 would establish two earnings metrics. Eligible programs would be required to meet
both.
• The first metric would be a “median earnings increase requirement” of at least
20%. This metric would be calculated on the basis of the median earnings of
students approximately six months after completing a program compared to the
median earnings of the students prior to enrollment. The bill would establish that
programs must report these metrics within 18 months of being approved as an
eligible program.
• The second metric involves program completers exceeding the earnings of a
comparison group. The bill would specify that the median earnings of program
completers must exceed the median earnings for adults aged 25-34 with only a
high school diploma (or equivalent) in the state in which the program is located.
The value-added earnings metric in H.R. 496 would not directly consider a participant’s earnings
prior to program participation. Instead, it would focus on earnings relative to program cost.
S. 161 would not establish an earnings metric that affects program eligibility.
Completion and Placement Rates
H.R. 496 and H.R. 1655 would establish similar requirements for completion and job placement.
Both bills would require
• a verified completion rate of at least 70%, calculated so as to ensure that a
student would be counted as a completion if the student finished the program
within 150% of the normal time for completion,76 and
• a job placement rate of at least 70%.77
Neither bill defines placement. For example, it is unclear if a program participant who is
subsequently employed in a field unrelated to their training would be considered a successful
placement.
S. 161 would not establish requirements related to completion and placement.
ED Approval Procedures for Programs
Under current regulations, in most instances, an HEA Title IV-participating IHE may self-certify
that a new educational program is an eligible program before disbursing Title IV funds to students

75 In 2023, 150% of poverty for a single individual in the contiguous 48 states and the District of Columbia is $21,870.
76 34 C.F.R. §668.8(f).
77 H.R. 1655 would require “a verified employment placement rate of at least 70 percent, as determined in accordance
with the regulations of the Secretary,” while H.R. 496 would require a “verified a job placement rate of at least 70
percent.”
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enrolled in it. To self-certify, an IHE must obtain any required state and accrediting agency
approvals and ensure the program meets all statutory and regulatory requirements. Some Title IV-
participating IHEs and programs require written approval from ED before disbursing Title IV aid
to students in new educational programs.78 For example,
• an IHE must await approval if the new educational program is an undergraduate,
300-599 clock hour program that is eligible for Direct Loans79; and
• an IHE must await approval of the first PEP at the first two correctional
institutions.80 Before approving the PEP, ED is to review the approvals granted
by the entity overseeing the correctional institution, the state, and the accrediting
agency, and ensure other program requirements are met.
All three short-term Pell Grant proposals would require a Title IV-participating IHE to apply for
and await ED approval for each new short-term program before disbursing Pell Grants to enrolled
students.
Under H.R. 496, ED could consider a program that was not previously a Title IV programs to be
an eligible short-term Pell Grant program for a provisional eligibility period of no more than three
years. To qualify for the provisional eligibility period, the program would have to meet the hour
and week durational requirements, receive accrediting agency approval, and meet the value-added
earnings metric (see the “Earnings Requirements” section).81 If the earnings data were determined
to be inaccurate, the IHE would be required to return any HEA Title IV aid funds received
following the provisional approval. H.R. 496 would not establish requirements for approvals
following the provisional approval period.
Under H.R. 1655, ED would be required to approve or disapprove each new short-term program
within 120 days of receiving an application. Before approving the program, ED would have to
receive state certification that the program meets three criteria:
1. it aligns with the requirements of high-skill, high-wage, or in-demand industry
sectors or occupations;
2. it fulfills the applicable WIOA requirements; and
3. it leads to a recognized postsecondary credential that satisfies employment
requirements.
H.R. 1655 would establish an initial approval period of two years and subsequent approval
periods of three years. If ED were to determine that the program no longer met the approval
requirements, ED would be required to deny a subsequent approval application, ensure enrolled
students receive transcripts, and prohibit the approval of substantially similar programs. ED could
immediately withdraw approval of the program.
Under S. 161, ED would be required to approve or disapprove each new short-term program
within 60 days of receiving an application. Before approving the program, ED would be required

78 34 C.F.R. §600.20(c); and FSA Handbook 2022-2023, Volume 2, Chapter 5.
79 34 C.F.R. §600.10(c)(1)(iii).
80 34 C.F.R. §600.10(c).
81 The value-added earnings metric for provisional approval would require median earnings of individuals who
completed the program three years prior, less 150% of the poverty line for single individuals, to equal or exceed
published tuition and fees for the program. This threshold would mirror the bill’s value-added earnings metric for Pell-
eligible short-term programs except that it measures all program completers rather than program completers who
received Title IV aid.
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to receive state certification that the program meets all of the short-term program requirements. S.
161 would not establish approval periods or disapproval procedures.
Award Rules
Under current law, the amount of an eligible student’s Pell Grant award is determined on the basis
of a set of award rules. A student’s Pell Grant scheduled award—the maximum Pell Grant aid a
full-time, full-academic-year student can receive—is determined based primarily on either AGI or
SAI:82
• A student whose AGI is below specified thresholds may be eligible for a
scheduled award equal to the maximum Pell Grant.83
• A student who is not eligible for the maximum Pell Grant based on their AGI
being below specified thresholds may be eligible for a scheduled award based on
SAI as long as the scheduled award is no lower than 10% of the total maximum
award, also known as the minimum scheduled award.
• A student whose AGI is not below specified thresholds and who is not eligible
based on SAI may be eligible for a scheduled award equal to the minimum award
if their AGI is between specified limits.
Students who are enrolled less-than-full-time, less than a full academic year, or in less-than-full-
academic year programs do not receive their scheduled award. Instead, they receive a
proportionally reduced amount. Under the lifetime eligibility limit, a student may receive no more
than the equivalent of 12 full-time semesters of Pell Grant awards. Each of the proposals would
use the same general award rules, with some exceptions to the lifetime eligibility limit and
minimum award rule.84
H.R. 1655 and S. 161 would address the lifetime eligibility limit, while H.R. 496 would not.
Under H.R. 1655 and S. 161, a student would be eligible for no more than 12 full-time semesters
(or the equivalent in part-time educational pursuit) in aggregate of short-term Pell Grants and Pell
Grants. H.R. 496 would not establish a lifetime eligibility cap for short-term Pell Grants or an
interaction between short-term Pell Grants and Pell Grants.
All three proposals would eliminate the minimum award for students whose scheduled award is
based on SAI if such students are pursuing Pell-eligible short-term programs. In other words, the
scheduled award for such students could be as small as $1. For a more detailed description and
examples related to the elimination of the minimum award rule, see the Appendix. In addition, S.
161 would lower the minimum scheduled award from 10% to 5% of the total maximum award for
students who are eligible for
• a scheduled Pell Grant award based on SAI and are not pursuing Pell-eligible
short-term programs, and
• a scheduled award equal to the minimum award because their AGI is between
specified limits regardless of the hours and weeks in the educational program.

82 SAI, as established by the HEA, is an indicator of what the student’s family is expected to pay for the student’s
higher education based on information provided on the Free Application for Federal Student Aid (FAFSA).
83 For the 2023-2024 award year, the maximum Pell Grant is $7,395, as established by the HEA and the FY2023
appropriations act providing funding for ED.
84 For more information, see CRS Report R46909, The FAFSA Simplification Act.
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Reporting and Disclosure Requirements
Under current law, to participate in the HEA Title IV aid programs, institutions must disclose
various information to the public and report other information to ED.85 The information to be
reported to ED includes, for example, institutional characteristics and operations, student
enrollment and completions, financial aid, counseling for students receiving HEA Title IV loans,
and disclosures for HEA Title IV loans and private education loans. With respect to their
educational programs, IHEs must disclose to prospective and enrolled students
• whether completion of educational programs meet the educational requirements
for specific licensure or certification needed for employment if the educational
program is designed to meet or is advertised as meeting such educational
requirements in the applicable states, and
• estimated costs associated with educational programs.
As mentioned earlier, the proposed gainful employment regulations would require the disclosure
of program-level performance information (e.g., primary occupation, completion rate, program
costs) to prospective students in applicable programs. If an institution fails to make the required
disclosures or reports, ED may impose sanctions including limiting the institution’s participation
in HEA Title IV student aid programs, terminating the institution’s participation in HEA Title IV
student aid programs, or imposing monetary civil fines.
IHEs report the aforementioned information to ED through the Integrated Postsecondary
Education Data System (IPEDS) and National Student Loan Data System (NSLDS). ED compiles
data from IPEDS, NSLDS, and administrative tax records maintained by the Department of the
Treasury into the College Scorecard, which is made available to the public through a web portal
and downloadable data files. The College Scorecard allows the public to search and compare
colleges by their costs, admissions, results, and other characteristics, as well as their fields of
study by credential type, salary, WIOA qualification, and other characteristics. The fields of study
are categories of programs defined by subject area (e.g., accounting and business/management)
and credential level (e.g., undergraduate certificates or diplomas).86
While H.R. 496 and H.R. 1655 would increase the reporting and disclosure requirements, S. 161
would not establish additional requirements.
H.R. 1655 would require that IHEs offering Pell-eligible short-term programs provide disclosures
about the program to prospective students. The disclosures would include information related to
institutional charges, estimates of grant aid, a program’s completion rate, the pass rate for
applicable professional licensure or certification examinations, and the employment rate and
earnings of program completers. Prospective students would have to sign an enrollment
agreement that includes the disclosures. The IHE would also have to publish the disclosures on its
website.
H.R. 496 and H.R. 1655 would require ED to expand the College Scorecard to report data on
Pell-eligible short-term programs. Both bills would require data on each program’s hour and week

85 34 C.F.R., Part 668-D.
86 The fields of study do not necessarily map directly to educational programs advertised in institutional course
catalogs. The categorization is based on ED’s Classification of Instructional Programs (CIP Codes). The classification
provides a taxonomic scheme that supports the accurate tracking and reporting of fields of study and program
completions activity. The CIP titles and program descriptions are intended to be general categories into which program
completions data can be placed, not exact duplicates of specific majors or field of study titles used by individual
institutions. Data are presented in a manner to provide protection for privacy purposes and to reduce the risk of
disclosure of confidential or identifying information.
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durational requirements, completion rates, and employment rates. Both bills would require
earnings data as well, but the specific presentations would differ. For example, H.R. 496 would
require information on the percentage of completers who have earnings above 150% of the
federal poverty line for single individuals within three years of completion.87 H.R. 1655 would
require information on median earnings of completers within six months of completion. It would
also require additional data on student demographics and re-enrollment in higher education.
Under H.R. 1655, ED would be required to coordinate with the Secretary of Labor and IHEs to
provide the requisite data.
In addition, H.R. 1655 would require that IHEs offering Pell-eligible short-term programs provide
disclosures about the programs to ED. The IHE would be required to provide information
annually for each program on overall expenditures, educational expenditures, and tuition and fees
revenue.
Effect on Direct Loans for Students Pursuing 300-599 Clock Hour
Programs
The Direct Loan program allows eligible students in educational programs of 300-599 clock
hours of instruction over at least 10 weeks to borrow from the HEA Title IV Direct Loan program
(see the “Current Requirements for 300-599 Clock Hour Programs Participating in the Direct
Loan Program” section). The DL program supports Title IV-eligible students regardless of family
income. The Pell Grant program supports lower-income Title IV-eligible students.
H.R. 496 and S. 161 would not amend the DL program for students pursuing 300-599 clock hour
programs. Lower-income students would be able to combine the Pell Grant and Direct Loan
while pursuing educational programs of 300-599 clock hours over at least 10 weeks. Lower-
income students in shorter programs (i.e., 150-299 clock hours over 8-9 weeks) would only be
eligible for Pell Grants.
H.R. 1655 would require that 300-599 clock hour programs be Pell-eligible short-term programs
for enrolled students to receive Direct Loans. The ability of students in 300-599 clock hour
programs that meet the current law requirements to receive Direct Loans would sunset within 60
days of ED approving the first short-term Pell Grant program.

87 The applicable poverty line is as determined under Section 673(2) of the Community Services Block Grant Act (42
U.S.C. §9902(2)).
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Appendix. Calculation of Pell Grant Award
Amounts for Shorter Clock Hour Programs
The amount of an eligible student’s Pell Grant award is determined on the basis of a set of award
rules. The scheduled award, based primarily on adjusted gross income (AGI) and student aid
index (SAI), is the maximum Pell Grant aid a full-time, full-academic-year student can receive.88
The scheduled award is prorated for the student’s enrollment rate (if applicable) and the
program’s length (if applicable). The award may not exceed the cost of attendance (COA).
For clock-hour and credit-hour nonterm programs,89 the scheduled award is prorated for the
program’s length (see the text boxes below). The amount of the scheduled award is prorated
based on either the weeks of instruction or clock hours of instruction in comparison to the
academic year minimums. The HEA academic year minimum for clock-hour programs is 900
clock hours over 26 weeks of instructional time. For credit-hour programs, the academic year
minimum is 24 semester credit hours (or 36 quarter credit hours) over 30 weeks.
In addition, the Pell Grant award for shorter programs must be paid in a minimum of two
installments over the course of the program. Generally, the proration is the lower of either (1) the
hours in the payment period divided by the weeks in the academic year or (2) the weeks in the
payment period divided by the weeks in the academic year.90
Sample Pell Grant Award for
Shorter Clock-Hour or Credit-Hour Nonterm Programs:
Maximum Scheduled Award
Student A has an AGI at the federal poverty guidelines for her family characteristics, a zero SAI, and a COA of
$16,000. She enrol s in a 500 clock-hour program that lasts 14 weeks. The IHE describes a payment period for the
program as 250 clock hours and 7 weeks. The IHE defines an academic year as 900 clock hours over 26 weeks.
The scheduled award for Student A is the maximum Pell Grant award. In AY2023-2024, the maximum Pell Grant
award is $7,395. The amount for each payment period is prorated by the lesser of two fractions:
•
the hours in the payment period divided by the hours in an academic year (250 / 900 = 0.2777) or
•
the weeks in the payment period divided by the weeks in an academic year (7 / 26 = 0.2692).
The Pell Grant payment for each payment period is $1,990.73 ($7,395 x 0.2692). Student A may receive a total of
$3,981.46 ($1,990.73+ $1,990.73) in Pell Grant funds for the program over the two payment periods.
For a student whose scheduled award is the minimum Pell Grant award, the scheduled award is
also prorated for the program’s length (see below).

88 The SAI is a metric established in the HEA that synthesizes personal and financial characteristics to estimate the
ability, as measured in dollars, of a student to pay for postsecondary education.
89 In a nonterm academic calendar, classes do not begin and end within a set time frame, such as a term.
90 Generally, the payment period is the academic term. However, for nonterm programs of one academic year or less in
length, the first payment period is the period in which the student successfully completes half of the credit or clock
hours and half of the weeks of instructional time in the program. The second payment period is the period in which the
student completes the remainder of the program. Most HEA Title IV aid disbursements must be made on a payment
period basis.
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Sample Pell Grant Award for
Shorter Clock-Hour or Credit-Hour Nonterm Programs:
Minimum Scheduled Award
Student A has an AGI at 250% of the federal poverty guidelines for her family characteristics, an SAI of $6,656, and
a COA of $16,000. She enrol s in a 500 clock-hour program that lasts 14 weeks. The IHE describes a payment
period for the program as 250 clock hours and 7 weeks. The IHE defines an academic year as 900 clock hours
over 26 weeks.
The scheduled award for Student A is the minimum Pell Grant award. In AY2023-2024, the maximum Pell Grant
award is $7,395 and the minimum award is 10% of the maximum, or $750.91 The amount for each payment period
is prorated by the lesser of two fractions:
•
the hours in the payment period divided by the hours in an academic year (250 / 900 = 0.2777) or
•
the weeks in the payment period divided by the weeks in an academic year (7 / 26 = 0.2692).
The Pell Grant payment for each payment period is $201.90 ($750 x 0.2692). Student A may receive a total of
$403.80 ($201.90 + $201.90) in Pell Grant funds for the program over the two payment periods.

Author Information

Cassandria Dortch
Benjamin Collins
Specialist in Education Policy
Analyst in Labor Policy

Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
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under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
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91 The actual minimum award amount differs from 10% of the maximum award because of rounding rules and because
ED uses midpoints for both the expected family contribution (EFC) and the COA in the annual award rule.
Congressional Research Service
R47647 · VERSION 5 · UPDATED
27

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Education Policy

Report Type: CRS Report

Source: CRSReports.Congress.gov

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