Reading time: Five minutes

In February and March 2026, the National College Attainment Network (NCAN) surveyed its members to understand how college access and success advisors are currently engaging with students around short-term credential and workforce training programs, and how prepared the field is for the rollout of Workforce Pell. Eighty-seven members responded, representing a range of organizations, including community-based organizations, local and state agencies, K-12 institutions, and higher education. The survey explored the frequency with which students ask about these programs, advisor confidence and knowledge gaps, current advising messages, and early concerns about Workforce Pell implementation. The findings paint a picture of a field that is seeing real student interest in short-term credentials, but is still building the knowledge, tools, and frameworks needed to advise students well.

Who Responded

Eighty-seven NCAN members completed the survey, predominantly community-based organizations (49%) and local/state agencies (18%), with smaller shares from K-12 institutions, higher education, and research/policy organizations. Most respondents work with high school and postsecondary students, but 35% also work with adult learners. The vast majority (94%) expressed interest in future learning opportunities on Workforce Pell.

Student Demand for Short-Term Credentials

Demand is real but not dominant. Nearly half of respondents (47%) said fewer than a quarter of their students seek advising on short-term credential or workforce programs, yet 85% reported students ask about these programs at least occasionally, and 44% said they hear about them frequently. The most requested programs are health-related (CNA, phlebotomy, EMT), skilled trades (welding, HVAC, automotive, electrical), and commercial driver's license (CDL) programs.

Advisor Confidence and Capacity

This is a significant gap. Only about 9% of respondents said advisors feel very confident advising on short-term programs, while 40% described their advisors as not very or not at all confident. Another 49% were only somewhat confident. Knowledge of program quality is similarly limited with only 20% saying they know which programs lead to high-wage jobs, while a third said no, and nearly half said only somewhat, often noting their awareness is anecdotal or limited to community college offerings. This issue may be particularly pronounced when advising students about online programs, which have a bifurcated approval process and where information on program quality may be more limited and harder to obtain than with in-state, in-person programs.

"I think it depends on the program, but there's quite a bit of 'it's a good job' rather than data-driven advising."

"We don't have that much data, other than anecdotal information, on which programs lead to high-wage jobs."

Only 20% of advisors reported knowing which short-term programs are high-quality, with almost half saying they have some understanding. This funding suggests a need for targeted communication to counselors and advisors working directly with students.

Most organizations (65%) reported using no formal tools, data, or decision-making frameworks when advising these programs. Those who do rely primarily on O*NET, state and local labor data, and local community college information.

Current Advising Messages

Messaging is highly varied and often cautious. Many advisors frame short-term credentials as a viable but supplementary option, frequently steering students toward community colleges and stressing the importance of stackable credentials and continued education. Several advisors explicitly encourage students to complete the FAFSA now in anticipation of Workforce Pell.

"Our foundation...defines college as any education or training after high school that leads to financial stability."

"We encourage students who do not want to attend college to consider certificate/workforce programs. Currently, we encourage them to complete the FAFSA since we know Workforce Pell is coming."

Some advisors expressed concern about steering students toward lower-value programs, particularly from for-profit providers:

"I fear the for-profit schools will exploit students with useless credentials that they cannot build upon later at community colleges or four-year nonprofit schools."

Concerns About Workforce Pell

The open-ended responses on concerns were among the richest in the survey, and several themes recurred:

Eligibility uncertainty was the most common issue. Advisors don't yet know which programs will qualify, making it difficult to advise students now.

"Unclear guidance on what qualifies/doesn't and how Workforce Pell is applied depending on the program a student chooses."

Pell budget shortfalls worried many respondents, who noted the irony of expanding eligibility while the overall Pell fund faces a shortfall.

"I know that Pell grant funding is already short in the current budget proposal, so I'm worried about this being a false promise to students who can't access funds even if they now qualify."

Lifetime Eligibility Units (LEU) – the cap on how much Pell a student can receive over a lifetime – emerged as a key concern, with advisors worried that students using Pell on a short-term credential could limit their ability to access aid for a degree later.

"I worry about students not understanding LEU." "Concerned about the long-term effect on the amount the student may have available if they decide to continue their education and attend a four-year school.”

Concern about stackability and incentives for colleges emerged:

“Don't penalize the college if after training the student continues their education instead of working in the occupation they were trained for with WFP dollars.”

Confusion and implementation timing were also widespread:

"Such confusion as to when our state will actually begin this – and when will the program details be available. Surely, this is slow because of slowness at the federal level."

Bottom Line

This survey captures a field that is genuinely interested in Workforce Pell and already fielding student questions about short-term programs, but largely unprepared to advise on it with confidence. Advisors want clearer information on program eligibility, quality indicators, and how Workforce Pell interacts with Lifetime Eligibility and other student aid. The request that came through most clearly:

"Having some easily accessible and easy to understand one-pagers or slides about Workforce Pell would be helpful."

NCAN is grateful to its members who participated in this survey. We will use the results, along with focus groups and additional information we gather from partners and other stakeholders, to develop a Workforce Pell Advising Guide for college access and success programs and help the college access field prepare for the implementation of Workforce Pell.

This post was developed with AI assistance (Claude, Anthropic).

Read More:

• Congress Wisely Expanded Pell Grants, Now Funding Must Keep Up
• Three Federal Student Aid Bills Slated for Markup
• ED Releases Proposed Rules for Workforce Pell – Weigh in By April 8!

Reading time: Three minutes

The Pell Grant program is at a crossroads. Congress’s improvements to the program in the last several years have significantly expanded Pell-eligibility. Now, it is time to fully fund the program to deliver on this foundation of need-based aid for students furthest from opportunity.

If Congress fails to act this year, it will jeopardize the 2027-28 academic year Pell Grant awards and the more than 7.2 million students who have made college decisions assuming they can rely on Pell Grant support. Without additional funding, the maximum grant will need to be reduced drastically from its current $7,395 to as low as $5,000 along with changes to Pell eligibility, enrollment status, or lifetime usage that would hinder student success.

Recent Congressional Budget Office projections call for a $17 billion investment in the fiscal year (FY) 27 budget and an additional $10 billion each year that follows (see figure 1 below). The National College Attainment Network (NCAN) believes it is critical for Congress to enact this $17 billion investment before it adjourns for the November 2026 elections.

“More students receiving Pell Grants is the definition of a ‘good problem to have,’” NCAN CEO Kim Cook said. “Pell Grants are the single best investment we can make in a skilled workforce and prosperous US economy. Now Congress must appropriate the funds to match the growth in low-income students enrolling in postsecondary education.”

The Pell funding shortfall comes just as the simpler Free Application for Federal Student Aid (FAFSA) process and widened eligibility criteria enacted by the bipartisan FAFSA Simplification Act are paying dividends, with more students completing the FAFSA, applying to college, and eligible for Pell grants.

In 2024, 730,000 more students were awarded a Pell Grant than in the prior year, a 14% increase. That trend is holding strong; almost 1.7 million more students were eligible for the maximum Pell Grant in 2025-26 academic year, compared to 2023-24, based on NCAN’s analysis of data from the Office of Federal Student Aid.

Ensuring all eligible students can rely on Pell being fully funded, would take the program from a $22 billion annual appropriation to a $37 billion annual appropriation by 2035 to maintain level funding of the maximum award.

Historically, Pell Grants have enjoyed bipartisan support and supplemental appropriations when needed. As recently as January, Congress’ FY26 appropriations rejected a plan to significantly cut the maximum grant amount. However, during the fallout of the Great Recession in 2011, when the program faced a funding shortfall, Congress maintained the maximum grant ($5,500 at the time) but reduced lifetime eligibility from 200% to 150% (6 years) of degree requirements and eliminated summer term Pell Grants. It took until 2017 for Congress to reinstate summer Pell grants, and lifetime eligibility remains 150%. We cannot risk similar cuts, that may never be reversed, to happen again.

This is a critical year for a robust conversation about the long-term economic importance of investing in the Pell Grant to counter possible permanent eligibility cuts. Congress has intentionally expanded Pell Grant eligibility for workforce needs, for the lowest-income students, and for incarcerated learners because postsecondary education is the single best way to increase economic mobility and prosperity. Now is not the time to retreat on who can take advantage of this life-changing opportunity.

Support student access and success by helping NCAN spread the word to your community stakeholders that Pell Grant funding is at risk and stay tuned to NCAN communications channels for timely updates.

Figure 1

Read More: 

• ED Releases Proposed Rules for Workforce Pell – Weigh in By April 8!
• New CBO Projection Sets up Pell Grant Funding Battle 
• House and Senate Release FY26 Appropriations Bill, Pell Max at $7,395 for Third Consecutive Year

Reading time: Two minutes

On Tuesday, March 17, the US Committee on Education and the Workforce is marking up three pieces of legislation related to federal student aid. They include:

• The FAFSA Verification Efficiency Act – This bill would authorize the US Secretary of Education, in cooperation with the Commissioner of the Social Security Administration, to verify the Social Security number (SSN) and citizenship status of individuals required to provide that information for federal student aid purposes. Importantly, the bill would not change the FAFSA, or Free Application for Federal Student Aid, process for students from mixed-status families. Parents or spouses without SSNs, or whose identities are not verified through TransUnion, would still manually enter their tax information, as they do today. The bill would authorize the US Department of Education (ED) to verify the citizenship status of contributors who have SSNs, even though that verification is not required for students from mixed-status households to apply for federal student aid. The bill opens with the clause, "Notwithstanding any other provision of law," which grants ED unusually broad authority to verify FAFSA applicants' personal information. A statutory change is necessary because current law only permits the agency to verify the SSN and citizenship status of students, not contributors, such as parents. This bill would expand that authority. The National College Attainment Network (NCAN) would prefer the bill be narrower in scope, authorizing Federal Student Aid (FSA) to verify only the citizenship status of students and parents who apply for Parent PLUS loans. We will continue working with Education and Workforce Committee staff to ensure any statutory changes are limited to what is required for administering federal student aid programs.
  
  
• The No Aid for Ghost Students Act of 2026 – This bill would require ED to implement an identity fraud detection system to screen every FAFSA application submitted on or after October 1, 2026. If an application triggers reasonable suspicion of identity fraud, this bill requires ED to notify both the applicant and any colleges the student listed on their FAFSA. Those colleges would be then be prohibited from disbursing federal financial aid until they verify the student's identity through either an in-person meeting or a live video call. The US Secretary of Education would be required to establish guidelines for this verification process, report to Congress on the system's design by November 2026, and submit annual effectiveness evaluations beginning in October 2027. According to FSA, fraud detection has prevented $1 billion in Pell Grants from being disbursed already. The problem of fraud in federal student aid has grown as more online, asynchronous postsecondary programs have emerged. NCAN supports fraud detection efforts that preserve the integrity of the Pell Grant program.
  
  
• The Student Aid Fraud Oversight and Accountability Act of 2026 – This bill requires ED to identify postsecondary institutions that have disbursed federal student aid to students reasonably suspected of committing identity fraud, as determined by ED’s identity fraud detection system, exclusive of schools that have confirmed that the students did not commit identify fraud through in-person (live, or synchronous audiovisual) identity verification. ED may then use this information to inform program reviews, audits, investigations, and other oversight activities. This bill is likely to have a disproportionate impact on community college and other open access postsecondary institutions, which have been targeted for federal student aid fraud in the past.

“Income verification rates have fallen dramatically since IRS data has been imported directly to the FAFSA as a result of the bi-partisan FAFSA Simplification and FUTURE Acts. Federal Student Aid is now moving forward with identity fraud detection measures. Together, these changes should largely prevent fraudulent federal student aid from being disbursed and ensure that funding allocated to Pell goes to students from low-income families pursuing their postsecondary aspirations,” said Kim Cook, CEO of NCAN.

Read More:

• ED Releases Proposed Rules for Workforce Pell – Weigh in By April 8!
• NCAN Leadership Summit Now Open to Non-Members!
• Congress Wisely Expanded Pell Grants, Now Funding Must Keep Up

On Monday, March 9, the US Department of Education (ED) published a Notice of Proposed Rulemaking (NPRM) to implement the new Workforce Pell Grant program, opening a 30-day public comment period on the proposed regulations.

The Workforce Pell program will allow students to use Pell Grant funds to enroll in short-term, high-quality workforce training programs aligned with high-skill, high-wage, or in-demand industries.

Importantly, the proposed rule largely reflects the language developed through negotiated rulemaking. In December 2025, negotiators serving on ED's Accountability in Higher Education and Access Through Demand-Driven Workforce Pell (AHEAD) Committee reached consensus on draft regulatory text. Because consensus was reached, ED's proposed rule is closely aligned with what negotiators agreed to during that process.

The proposed regulations outline how Workforce Pell will function in practice. Among other provisions, they establish requirements for program approval by both states and ED, define the types and lengths of eligible short-term programs, and introduce accountability measures tied to completion, job placement, and earnings outcomes.

The National College Attainment Network (NCAN) has previously highlighted both the promise and the challenges associated with expanding Pell Grant eligibility to short-term workforce programs. Workforce Pell has the potential to create new pathways to economic mobility by allowing students to access federal financial aid for shorter credential programs aligned with labor market demand. However, strong guardrails and clear accountability are essential to ensure that programs provide meaningful value for students and lead to stackable credentials that can support longer-term educational and career advancement.

ED is accepting public comments on the proposed regulations until Wednesday, April 8. This comment period provides an important opportunity for practitioners, advocates, institutions, and other stakeholders to share feedback on how Workforce Pell should be implemented.

NCAN encourages its members and partners to review the proposed regulations and submit comments. Thoughtful feedback from the field will help ensure that the final rules expand access to high-quality workforce training while protecting students and maintaining the integrity of the Pell Grant program.

If you have questions about submitting comments, identifying key issues to address, or drafting your response, please don’t hesitate to reach out to me, Magnus Noble, at noble@ncan.org.

Read More:

• FAFSA User Experience Improvements
• New CBO Projection Sets up Pell Grant Funding Battle
• Bracing for Impact: How Medicaid and SNAP Cuts Will Reshape College Access

Reading time: Four minutes

Students have completed the Free Application for Federal Student Aid (FAFSA) since its launch in 1992. Over the past 34 years, the form and process have undergone dramatic changes — the most impactful driven by simplification. The form has evolved from a paper document students mailed in to an online application that now directly transfers applicants' and contributors' financial information from the IRS. Authentication has evolved just as significantly, moving from wet signatures to PIN numbers to FSA IDs to studentaid.gov accounts. Two key pieces of legislation set this transformation in motion: the FUTURE Act of 2019, which enabled direct IRS data transfer, and the FAFSA Simplification Act of 2020, which modified the federal need formula.

The major redesign launched with the 2024–25 FAFSA faced significant early challenges. Since then, the Office of Federal Student Aid (FSA) has worked to improve the user experience — and with notable results: the 2026 –27 FAFSA opened one week ahead of the required date, and the class of 2026 is completing it at historically high rates. The timeline below highlights key milestones in a simplification effort celebrated across the financial aid community.

Reading time: Three minutes

The Congressional Budget Office (CBO) released its long-awaited update to the federal budget baseline, revealing what close watchers of the Pell Grant program widely anticipated: a looming and growing funding shortfall.

According to the newly released projection, demand for Pell will exceed funding for the program by $5.4 billion in fiscal year 2026 and grow to nearly $11 billion in fiscal year 2027.

These changes are the result of expanded access to Pell through the revised formula enacted into law as part of the FAFSA Simplification Act, and improvements in FAFSA, or Free Application for Federal Student Aid, functionality as Federal Student Aid worked through widespread technical challenges in award year 2024-25. While CBO does not publish its methodology, these projections likely also take into account implementation of Workforce Pell, which may lead to more students receiving grants.

The National College Attainment Network (NCAN) recently released analyses showing that 1.7 million additional applicants were eligible for the maximum Pell Grant in 2025-26 when compared with 2023-2024 and that the nation is on track to achieve the highest rate of FAFSA completion in history. While unambiguously good news for students, their families, and our nation’s economy, higher rates of Pell uptake will require higher levels of investment.

"Increasing the number of students eligible for Pell Grants is something to be celebrated!” said NCAN CEO Kim Cook. “More students are submitting the FAFSA and are eligible for Pell because of the positive changes Congress made, and this president signed into law with the FAFSA Simplification Act. Congress also chose to expand the program to include Workforce Pell programs. Now, we look forward to Congress providing enough funding to support the students who have been promised they will have help to make their college dreams a reality."

Due its targeted and effective design, Pell has long enjoyed strong bipartisan support. The FAFSA Simplification Act and related FUTURE Act were crafted on a bipartisan basis and signed into law by President Trump. Congress has regularly provided funding for Pell shortfalls when they have occurred, including as recently as last summer in the budget reconciliation act, which included $10.5 billion to cover the Pell shortfall.

Still, Pell will need our advocacy. While net tuition and fees have fallen in recent years, inflation has risen dramatically. Had the maximum Pell kept pace with rising living costs, it would be $800 higher than it is today. Instead, the award has not increased in three years and covers less than a third of the cost of attendance for an in-state student at a public four-year university.

Pell is one of the greatest investments in economic mobility our country has to offer, boosting college completion rates, which bolsters earnings, state GDPs, home values, spending on automobiles, and reduces unemployment. With Workforce Pell going online, a new and improved FAFSA that takes as little as fifteen minutes to complete, and the impending state budget squeeze, adequate funding for Pell is essential for maintaining access to postsecondary education.

Read More: 

• Register for NCAN's 2026 Leadership Summit
• House and Senate Release FY26 Appropriations Bill, Max Pell Set at $7,395 for Third Consecutive Year
• FAFSA Simplification Yielded 1.7 Million More Max Pell-Eligible Students

Reading time: 19 minutes

Key Points:

• The One Big Beautiful Bill Act (OBBBA) cuts federal safety net programs by more than $1 trillion over 10 years, cuts that will grow dramatically over time and reduce spending to states.
• State higher education programs, which are often the first spending category in state budgets to be cut when budgets are tight, are at risk.
• The impact of the cuts will vary by state. In general, the 40 Medicaid expansion states plus DC - every state except Alabama, Florida, Georgia, Kansas, Mississippi, South Carolina, Tennessee, Texas, Wisconsin, and Wyoming - that seek to minimize the impact of these cuts on low-income residents will face the largest budget pressures though all states will be impacted.
• State policy decisions will determine the impact and scope of the cuts, and college access and success leaders should prepare now to influence their state’s approach and defend critical higher education investments.

Introduction and Overview of Impending Cuts to State Budgets

The OBBBA, enacted in July of 2025, made major cuts to Medicaid, SNAP, and federal student loans. These cuts will grow over time and may severely impact funding for higher education if states seek to backfill federal cuts with their own funds. The risk is particularly acute because higher education has become known as the "balance wheel" of state budgets and is often the first spending category cut during recessions. Unlike health care and K-12 education, which is guaranteed in most state constitutions, higher education funding is discretionary and institutions can raise tuition to partially offset state cuts. During the Great Recession, this pattern played out dramatically: 46 states cut per-student funding for public colleges, with 36 states cutting by more than 20%, and a decade later state support for higher education remained 16% below 2008 levels even as state revenues had recovered.

This policy brief aims to help elucidate the budget pressures that states will experience in the coming decade, how these cuts will affect state higher education budgets, and the key state policy decisions that will determine their impact. It also suggests some approaches for advocates to take in responding to them.

The bottom line: Medicaid expansion states that seek to minimize the impact of these cuts on low-income residents will face the largest budget pressures relative to other states and be forced to make the most difficult tradeoffs, shifting resources away from higher education and other areas and towards health care and food security. However, state leaders may be able to blunt some of these impacts on students by developing systems to verify students' enrollment in postsecondary institutions with minimal hassle and by maintaining funding for higher education institutions and need-based aid even under fiscal pressure. Advocates should consider the likely response of their state leadership and prepare accordingly for challenging legislative sessions to come.

Medicaid Cuts

The Congressional Budget Office (CBO) projects states will have to make up for half of the $900 billion cut from Medicaid by the OBBBA out of their own budgets, amounting to roughly $450 billion over 10 years. Given that Medicaid represents about 30% of state budgets nationwide, reductions of this magnitude will have serious implications for state finances and competing priorities like higher education. Students who rely on Medicaid are also at risk of losing their healthcare, which can impact their ability to complete college.

The impact will vary significantly across states. The 40 Medicaid expansion states and DC will see between 10 and 21% reductions in federal Medicaid payments to states, according to the National Academy for State Health Policy, while non-expansion states can expect reductions of between six and 11%. Kansas, for example, is expecting at least $150 million in revenue losses and Minnesota is predicting a $200 million reduction over the next decade. The Fiscal Policy Institute in New York estimates that cumulative funding cuts to the state will be $5.6 billion in the next fiscal year and $14.3 billion by 2030. 

According to the CBO, the largest cuts to Medicaid include:

• Work reporting requirements ($317 billion) – mandating that adults ages 19 to 64 covered through the Medicaid expansion meet work requirements (or qualify for an exemption, such as being a parent of a young child or enrollment in postsecondary education at least half-time) by the end of December 2026. CBO estimates that these requirements will drop more than five million people from coverage by 2034.
• Limits on state provider tax arrangements ($183 billion) – preventing states from increasing existing taxes on Medicaid providers and barring states from creating new provider taxes. Almost all states finance a portion of their Medicaid spending through taxes collected from health care providers.
• More frequent eligibility redeterminations ($178 billion) – blocking implementation of two Centers for Medicaid & Medicaid Services (CMS) rules that would have streamlined enrollment processes and reduced barriers to Medicare Savings Programs, and requiring more frequent eligibility redeterminations (at least once every six months instead of annually) for Medicaid expansion adults.

Together, these cuts amount to $678 billion in federal funding that states will need to replace if current Medicaid service levels are to be maintained.

Beyond the direct fiscal impact of coverage reductions, the Medicaid work reporting requirements will impose additional administrative costs on states. The law requires states to verify at application and at renewal that individuals in the Medicaid expansion group meet work requirements (or are exempted), and states can also require verification more frequently. State choices about implementation, such as how often to verify eligibility and how effectively they use existing data to automate verification processes, will significantly impact both the number of people losing Medicaid and state implementation costs.

Supplemental Nutrition Assistance Program (SNAP) Cuts

The budget reconciliation bill also cut $186 billion from SNAP, the federal program formerly known as food stamps and aimed at addressing food insecurity, over 10 years. According to the CBO, 1.1 million college students rely on SNAP and an additional 2.2 million met the criteria, but are unable to access benefits due to the complexity of the program. The budget reconciliation bill:

• Expands work reporting requirements for childless adults from an upper limit of age 54 to age 64 and introduces them for parents with children aged 14 and older. Those who do not qualify will be limited to three months of benefits per year.
• Requires for the first time a state match for SNAP benefits of between 5% and 25%, based on each state’s payment error rate, beginning in 2028. The error rate is a measure of the accuracy of each state’s eligibility and benefit determinations that includes both overpayments and underpayments.) These rates vary significantly between states, as can be seen in the FY 2024 data. Alaska, DC, Georgia, and Florida had error rates over 15% while South Dakota, Idaho, and the Virgin Islands all had rates below 4%. At their FY24 error rate, Colorado would face a $130 million cost while Florida and New York would have to pay $1 billion. 
• Halves federal funding for administrative payments from 50% to 25%.
• Eliminates tolerance for minor payment errors under $57 from calculation of the payment error rates, which will increase state error rates and likely their share of benefit costs.
• Prohibits participation by persons who are not citizens or lawful permanent residents, which will mean refugees, asylees, and Iraqi/Afghan Special immigrants will no longer be able to receive SNAP. (SNAP eligibility has never been extended to people  who are undocumented).   

Higher Education Budget Pressures

The budget reconciliation bill also cuts over $300 billion from higher education over 10 years, by eliminating Grad PLUS loans, capping Parent PLUS loans, reducing graduate student borrowing limits, and restructuring of the federal student loan repayment system. While these cuts directly affect students and institutions—not states—they will reduce institutional revenue and reshape the higher education budget landscape. 

Beyond reconciliation bill cuts, colleges and universities face additional financial pressures from:

• Proposed research cuts – The Trump Administration proposed cuts to the National Science Foundation, Department of Energy, and the National Institutes of Health while limiting indirect costs to 15%. Some public universities receive over a quarter of their revenue from federal sources (e.g., University of Michigan, University of Alabama at Birmingham). Though Congress has resisted the deepest cuts and many are tied up in court, funding uncertainty has forced institutions to freeze hiring, delay projects, and reconsider research priorities.
• Declining international enrollment – The Trump Administration delayed or withheld student visas for fall 2025, causing international enrollment to fall 17%. Since international students typically pay full tuition and often subsidize domestic student aid, this represents significant revenue loss.
• Uncertain federal student aid funding – The Trump Administration's FY2026 budget proposed eliminating TRIO, GEAR UP, and SEOG while cutting Federal Work-Study by 80%, and has withheld grant funding citing diversity concerns. While Congress has provided level funding for the last three years, this uncertainty disrupts institutional planning and threatens support services for low-income and first-generation students.

Tax Losses

In addition to federal funding cuts, many states conform some or all of their tax codes to federal definitions, meaning that without state action, the OBBBA's tax cuts will create state revenue losses beyond the federal losses. For example, the Tax Foundation estimates that the bill's business "expensing" provisions will reduce state revenues by an average of $20.7 billion annually over the next decade. The OBBBA also includes temporary individual tax provisions, such as the widely discussed "no tax on tips" policy, which expires in 2028. While automatic conformity will reduce state revenues by $1.7 billion in FY 2026, the impact could exceed $20 billion if state legislators choose to adopt these popular federal policies even where conformity is not automatic.

The authors of the OBBBA maintain that the tax cuts will increase economic growth, which would improve the fiscal outlook for states and reduce the need for cuts. To date, they do not appear to have had a major impact but perhaps this will change over the course of 2026. 

Compounding Economic Factors

The Trump administration's tariffs, widespread federal layoffs, and federal spending cuts risk slowing the economy and could further depress government revenues while increasing demand for assistance from programs like Medicaid and SNAP.  Consumers remain frustrated by inflation, which persists despite declining from pandemic-era highs, particularly with tariffs in place. This economic situation could create a particularly difficult squeeze for states since revenue declines will occur simultaneously with increased service demands. 

State by State Impacts

For state higher education advocates the critical question is: How will these cuts impact their state specifically? There are different ways to analyze this question, and a lot of factors could impact any projections made today. 

According to the KFF, Louisiana, Illinois, Nevada, and Oregon face the most severe cuts at 19% or more of their federal Medicaid spending over 10 years. The average cut nationally is 14% of federal Medicaid spending. 

In general, the 40 Medicaid expansion states and DC, particularly the largest states, will face the biggest absolute budget hits. Wisconsin, which has implemented a partial expansion where Medicaid is available to low-income adults with income below the poverty level, will face a slightly smaller budget hit. The 10 states that have not expanded Medicaid and do not have to implement the work reporting requirements will face fewer cuts. They are: Alabama, Florida, Georgia, Kansas, Mississippi, South Carolina, Tennessee, Texas, Wisconsin, and Wyoming. Wisconsin has implemented a partial expansion where Medicaid is available to low-income adults with income below the poverty level. The policy changes that apply to the expansion states will also apply to the expansion population in Wisconsin.

More specifically, we can think of the impact of the Medicaid cuts on state budgets by categories. Roughly in order of magnitude of impact, those categories are: 

1. Medicaid expansion states – Provisions affecting only Medicaid expansion states account for $526 billion—over half of the total gross federal spending reductions. The 40 expansion states plus DC are hit particularly hard because most of the law's Medicaid cuts specifically target the expansion population. 
2. States with large undocumented populations - The law reduces the federal match rate for emergency medical treatment of undocumented immigrants from 90% to the state's regular Medicaid match rate (50% to 76.9%). This change will results in the largest cuts to states with higher per capita incomes - and thus a lower federal match rate - and large populations of people without authorization, such as California, New York, New Jersey, and Illinois. Texas, Florida, Arizona, and other states with large undocumented populations will also see cuts for emergency services.
3. States with "Trigger Laws" – Nine states have laws requiring automatic termination of Medicaid expansion if the federal match rate drops below 90% - and the OBBBA reduces this match for the expansion population to 80%. These states face complete loss of Medicaid expansion coverage, and the federal revenue that comes with it, if they don't change their laws or invest large sums of state funds to replace lost federal revenue to maintain enrollment. These states include: Arizona, Arkansas, Illinois, Indiana, Montana, New Hampshire, North Carolina, Utah, and Virginia. 
4. States affected by provider tax restrictions – The reconciliation bill prohibits all states from raising additional state revenues through new provider taxes or increases in existing provider taxes. It also reduces the permissible size of most provider taxes in expansion states (starting October 1, 2027). 31 expansion states will be required to eventually reduce their provider taxes, according to KFF. The New Hampshire Fiscal Policy Institute estimates that if that policy, which cuts the provider tax to 3.5% by 2031, had been in place in FY24, the state would have lost $133 million in tax revenue.
5. Rural/urban hospitals –  States with large numbers of rural hospitals (and the funding those facilities receive from Medicaid) as well as states with significant proportions of urban hospitals that also serve low-income populations will face serious cuts. The budget reconciliation bill included $50 billion to bolster rural hospitals, but no comparable relief for urban facilities. Kansas has the most rural hospitals at risk in absolute numbers while states in the West and Northeast will be affected most by the cuts to urban areas, according to an analysis by Harvard University.

The bottom line is that the 40 Medicaid expansion states will face dramatically larger cuts than the 10 non-expansion states – and those cuts will deepen over the coming decade. Large expansion states like California, New York, Illinois, and Pennsylvania face the biggest absolute dollar losses, while states like Louisiana, Nevada, and Oregon see the highest percentage reductions. Rural states and states with large low-income urban populations face additional fiscal pressure from hospital closures regardless of expansion status, particularly once the $50 billion fund is exhausted.

How States Respond Will Impact Budget Cuts

How states respond to the OBBBA cuts will determine the impact the law has on their state budgets and their residents. The choices they make will significantly affect state higher education budgets now and going forward. Two areas of response will be central:

• Whether states shift funding towards covering people who lose Medicaid and SNAP – The question state leaders will face is whether and how to continue these individuals’ coverage without massive impacts to the state’s discretionary budget lines. If states choose to simply end the Medicaid expansion and allow the SNAP cuts to go into effect, they will lose federal funding for services, but they will not need to find nearly as much savings from other areas of the state budget. States with trigger laws ending Medicaid expansion with reductions in federal funds will be required to reduce funding and leave unenrolled residents out of the program, absent a change to their state laws. States that want to maintain enrollment - all or partial - will need to invest to do so.to make up for the loss in federal funding. 
• How states implement work requirements – When Arkansas tested Medicaid work requirements under a waiver, many of those impacted were unaware of the change or confused by the requirements. And as a result, thousands lost coverage. Similarly, during the recent "unwinding" of Medicaid pandemic era eligibility, as many as two-thirds of those who lost coverage did so due to procedural reasons, not because they were ineligible. Some questions state leaders will have to answer that will impact the number of people affected by the work requirements, and the cost to the state budget include:
• How much of an educational effort will a state undertake to make sure Medicaid and SNAP recipients know what they need to do to maintain coverage?
• How easy – or not – will the verification/reporting requirements be to fulfill?
• Will a state invest in new information technology and additional staff to build the necessary systems to comply with the law? 

A state’s policy choices will impact the scale of savings needed from other parts of its budget, including higher education.    

Recommendations for Higher Education Advocates

Higher education advocates have a critical role to play in protecting student access to vital benefits and maintaining higher education budgets. As a first step, advocates should partner with state and community experts to educate lawmakers about the scope and impact of impending cuts. The State Priorities Partnership—a network of over 40 nonpartisan, state-level organizations focused on budget and economic policy—may be a good place to start. With new legislators taking office in January 2027 and delayed implementation of some cuts, a window exists to educate state lawmakers about what is coming and encourage them to work with federal officials on potential changes to federal law.

Second, advocates should assess the likely response of their state leaders to the federal funding reductions, which will help clarify the scale of the challenges their state may face in the coming year. Then, we recommend tailoring advocacy activities and policy recommendations accordingly. 

In all states, even those where the fiscal impact of the budget reconciliation bill is likely to be modest, college access and success leaders should prepare to:

• Defend critical higher education investments: Advocates must prepare to defend critical higher education investments, which primarily include operational and capital support for public colleges and universities and need-based aid programs, as states confront difficult budget decisions. The fiscal pressures created by federal policy changes may lead some states to target higher education funding for cuts. Now is the time to find student success and impact stories, build coalitions, identify and cultivate champions, marshal evidence about the returns on investment in higher education, and make the case that maintaining robust support for colleges and students serves long-term state economic interests even in challenging budget environments. 
• Educate students and their families about the new rules: College attainment programs, which are trusted messengers in educating students about their postsecondary options and the availability of student aid, should prepare to explain the new rules. As states roll out new SNAP and Medicaid requirements alongside changes to higher education financing, student-serving organizations are uniquely positioned to help students understand how these policies intersect and what steps they must take to maintain benefits. Clear, proactive communication will be essential to preventing benefit loss among students who remain eligible under the new rules.

In states that are facing significant cuts and want to mitigate their impact on low-income students, we recommend college access and success programs:

• Advocate for enhanced data-sharing partnerships: Rather than placing the burden on students to obtain and submit enrollment documentation, states should work with colleges and universities to confirm half-time enrollment directly. This approach will reduce administrative barriers for students, minimize verification delays, and decrease the risk of eligible students losing benefits due to paperwork gaps. Higher education institutions already maintain accurate enrollment records and can provide reliable, timely verification through existing data systems. States have a critical role to play in synthesizing the data to ensure accuracy, including when students are enrolled at multiple colleges. Guidance from CMS requires states to first use “reliable” information available to the state prior to requiring additional information from Medicaid applicants or participants. States that establish direct data-sharing partnerships with higher education institutions to verify student enrollment status for SNAP and Medicaid eligibility can create systems that not only minimize the number of students who lose health care and food benefits, but also minimize the cost to states over time by reducing the staff time needed to process verification paperwork.
• Help state leaders prioritize the most important higher education programs and be strategic about cuts: The scale of reductions coming will force many state leaders to make difficult choices. College access and success leaders can help by making clear which programs have the greatest impact on college access and success, ideally in coalition with other higher education advocates around the state. We recommend prioritizing maintaining need-based student aid above all else, given the magnitude of the affordability challenge for students. If states need to make cuts to higher education funding, they should do so in a strategic manner. Often states implement across the board cuts that harm higher education institutions with smaller margins and fewer revenue streams, such as community colleges and regional campuses.
• Look for innovative ways to increase efficiency and raise revenue: There may be opportunities to reduce the administrative burden on students and consolidate state student aid programs, particularly if these changes can be framed as saving state dollars in a tight fiscal environment. Eliminating extraneous application and program requirements can make state need-based aid programs easier to administer as well as access and maintain. In addition, technology may offer solutions for completing rote tasks and answering basic questions that can save states money .Finally, a few states have created innovative revenue streams (e.g. the Fair Share Amendment in Massachusetts, which provides dedicated revenue for higher education, and the business and occupation tax in Washington). Other states may emulate those ideas or design other innovative approaches to mitigate state revenue losses.

The impact of the OBBBA on state budgets, higher education investments, and college affordability, will unfold over the coming decade as state and federal policymakers make consequential implementation decisions. Now is the time for college access and success leaders to start planning so they can minimize the impact on the students they serve and best support the success of all who strive to earn a higher education credential.

We are grateful to Frank Ballman, Brittany Matthews, Laura Szabo-Kubitz, Kate Tromble, Anika Van Eaton and Dustin Weeden for providing valuable feedback on a draft, and to the Joyce Foundation for supporting this work.

Read More:

• Controversial Budget Bill Protects Pell but Sharply Cuts Other Supports for Low-Income Americans
  
• Reconciliation Bill: What You Need to Know
• Senate Reconciliation Contains Quirky Pell Eligibility Modification
• AHEAD Committee Reaches Consensus on New Accountability Provisions
• Highlights from the AHEAD Committee: Workforce Pell Consensus Reached

Reading time: Two minutes

On Tuesday, January 20, the House and Senate Appropriations Committees released a bipartisan package of bills, including the Labor, Health and Human Services, Education and Related Agencies (LHHS) bill for fiscal year (FY) 2026, which passed in the House on Thursday evening. The proposal maintains level funding for many of the National College Attainment Network's (NCAN's) priorities, including the Pell Grant, TRIO and GEAR UP, Federal Work Study, the Supplemental Educational Opportunity Grant, and AmeriCorps.

The funding levels included in the bill represent a significant departure from the President’s budget request in May, and the initial House of Representatives FY26 proposal in September, both of which called for eliminating or making deep cuts to many federal higher education programs.

NCAN was relieved to see no cuts to the Pell Grant maximum. That said, a third year of level funding at $7,395 effectively erodes the grant’s value for students. While tuition and fees have largely stabilized in the last couple of years, the cost of living – including food, housing, and transportation – continues to rise. If Pell Grant funding had kept pace with inflation, the maximum award would cover approximately $7,800 today.

"A third year of flat funding is better than a cut, but it is still not adequate to cover the costs we know students are facing," said NCAN CEO, Kim Cook. "With increased access to Pell, and Workforce Pell launching this fall, it is critical that funding for the program keeps pace with growing demand."

Congress has taken steps in recent years to expand access to Pell through the FAFSA Simplification Act and the creation of a Workforce Pell Grant program, expected to open as early as July 2026. Early data suggest that in the 2024-25 academic year, 730,000 more students received a Pell Grant than in the year prior. While the full scope of Workforce Pell Grant participation is not yet clear, estimates suggest the program may cost upwards of $2 billion – all pulling down from the same pot of Pell dollars. As students continue to gain access to Pell Grants, it is imperative that Congress allocates sufficient funding to meet that demand.

In addition to maintaining funding for the Pell Grant and other key federal education programs, the LHHS bill restores funding for previous program priorities under the Fund for the Improvement of Postsecondary Education (FIPSE), and includes language designed to constrain the Administration’s attempts to reallocate key functions and grants away from the Department of Education (ED).

As the next step in the process, the Senate will need to vote on the bill before January 30. NCAN will continue to keep you informed as the FY26 appropriations process unfolds.

Questions? Please reach out to Louisa Woodhouse, Senior Associate, Policy and Advocacy, at woodhouse@ncan.org .

Read More: 

• Senate Bill Level Funds Pell, TRIO, GEAR UP, Work Study, SEOG, and AmeriCorps in FY26
• House Bill Level Funds Pell, TRIO, and GEAR UP in FY26
• Skinny Budget, Big Cuts: Trump Administration Publishes Budget Request for FY26

Reading time: Six minutes

On Friday, January 9, the AHEAD Committee reached consensus during its second session of negotiated rulemaking – this time, regarding new provisions for institutional accountability and a new earnings premium requirement implemented by the reconciliation law (also known as the One Big Beautiful Bill, or OBBB). (The AHEAD Committee also reached consensus on Workforce Pell Grant regulations and the new provisions surrounding Pell Grants for students with full-ride scholarships last month.) Now that the AHEAD Committee has adjourned, the US Department of Education (ED) will post the draft regulations for a public comment period, before finalizing the regulations, likely sometime this spring or early summer.

National College Attainment Network's (NCAN’s) Midwest Policy Fellow, Magnus Noble, returned to DC last week to serve as the alternate student negotiator on the Committee, advocating for key provisions surrounding Pell eligibility and increased transparency measures, like the debt-to-earnings test and cost of attendance information. (See below for more details on those proposals.)

All AHEAD Committee materials can be found here, including the most up-to-date publicly available version of the draft regulations. Read on to learn more about the key issues and outcomes from the second week of rulemaking.

Eliminating the Debt-to Earnings (DTE) Metric

Over the course of the week, ED was vocal about its goal of “harmonizing” the new earnings test from OBBB and accountability measures with the existing framework for Gainful Employment (GE) and Financial Value Transparency (FVT). One of the most controversial proposals was that of removing the debt-to-earnings (DTE) test from the existing GE requirements.

Currently, to remain eligible for federal student aid (not just loans), the DTE provision states that private for-profit institutions and all certificate programs must show that their graduates earn enough to manage their student loan debt. The rule requires that graduates of these programs devote no more than 8% of their annual earnings, or 20% of their discretionary earnings, to loan repayment.

The GE rule also includes an earnings test which will be revised according to the provisions in the OBBB, and applied to both GE and non-GE programs for the first time, adding an additional burden for institutions. The new earnings test requires that for undergraduate programs, completers must exceed the median annual earnings of in-state 25-34-year-old working adults with a high school diploma who are not enrolled in higher education. For graduate programs, earnings are compared to those with bachelor’s degrees in the same field of study. If programs do not meet this benchmark for two out of three consecutive years, they will lose eligibility for federal student loans. Earnings data will first be available in the summer of 2027.

ED argued that the earnings test alone would be sufficient to identify nearly all failing programs and that continuing to run the DTE test for GE programs would not be “worth the squeeze,” given the administrative burden and the cost. ED cited data showing that only 0.2% more programs are identified by the DTE metric compared to only the earnings premium.

Several negotiators, led by legal aid, called for ED to continue to require the DTE calculations. They argued that DTE captures an important affordability measure the earnings test alone misses, especially for high-cost programs where students often rely on significant borrowing, including private loans. Negotiators warned that eliminating DTE would weaken student protections, allowing programs to pass accountability standards despite leaving graduates with unmanageable debt. While ED allocated a significant amount of time debating the pros and cons of this decision, ED moved forward with plans to eliminate DTE.

Pell Eligibility for “Low Earnings” Programs

Another hot topic was the consideration of Pell Grant eligibility for programs failing to meet the new accountability standards.

Under the current rule, programs that fail to meet the GE benchmarks lose access to all federal student aid, including the Pell Grant. Notably, ED’s draft regulations stated that students in programs failing the earnings premium would only lose access to federal student loans. Many negotiators, including those representing students, taxpayers, and legal aid organizations, raised serious concerns about the prospect of allowing students in those programs to continue receiving Pell Grants.

After a long series of caucuses on Thursday, and effective advocacy from negotiators, the final draft did include a provision to address Pell eligibility for programs failing the earnings test. The provision would come into play once an institution had already been flagged for potential loss of federal student loan eligibility. Here’s how it would work:

• After two years of failing the earnings test, a program would lose access to loans and be designated as a “low earnings outcome program.”
• In year two, ED would run an additional test to determine if 50% of the institution’s Title IV aid recipients or 50% of the institution’s Title IV revenue are enrolled in or coming from the program deemed “low earnings”. If that is the case, the program is on-notice for loss of Pell eligibility.
• In the following year, if the program meets either of those criteria again, all “low earnings” programs at the institution will lose access to Pell Grant dollars.

In addition, the draft also included a provision proposed by the student negotiators that requires institutions to notify students in at-risk programs of their remaining lifetime eligibility for Pell.

Optional Teach-Out Provision for Failing Programs

Another significant area of debate centered on a provision from the negotiator representing private non-profit institutions, concerning how institutions might be able to “teach out”, or wind down, programs that failed the earnings test in year one. Negotiators recognized that in some cases, allowing students to finish their degree or credential – despite the earnings test outcome – would still benefit graduates.

ED may allow a failing program to temporarily retain Direct Loan eligibility – generally for up to three years or the normal length of the program, whichever is shorter – solely to support an orderly closure that serves students’ best interests. During this time, institutions must stop enrolling new students, place the program under warning status, notify accreditors and state authorizers, and provide enrolled students with the option to either complete the program or transfer to a comparable program that has not failed accountability requirements. Institutions must also agree not to restart the same or a substantially similar program for at least two award years after the closure. The teach out option is unavailable to programs or institutions already on probation or subject to heightened financial oversight for other reasons.

The teach out option is voluntary, and institutions must decide whether or not they plan to engage in this option within 120 days of receiving notice from ED that the program has failed the earnings test.

Cost of Attendance and Emergency Aid Proposals

Though not ultimately adopted into the draft regulations, NCAN championed a proposal from negotiators representing students, public institutions, legal aid organizations, and veterans that would require ED to report out key information about a student’s cost of attendance (COA). Specifically, the proposal would require the Secretary to report the total cost of transportation, food and housing (disaggregated by options on campus, off-campus not with family, and off-campus with family,) childcare, other miscellaneous expenses, and also, information about available emergency aid grants.

While ED seriously considered the recommendation, federal negotiators did not move forward with it, explaining that the proposal would require ED to make changes to the existing institutional data reporting requirements. ED officials did seem particularly interested in figuring out how best to communicate information about emergency aid – so, that may be coming down the line.

What’s Next?

Now that the AHEAD Committee has concluded, ED will post the draft regulation for a 30-day public comment period. While we don’t know exactly when the comment period will open, we expect that it won’t be until at least February, given that the draft regulations for the first negotiated rulemaking committee (the RISE Committee), have still not been posted for public comment. It is likely that the proposals from the AHEAD Committee’s two sessions of negotiated rulemaking will be posted separately – one for Workforce Pell and one for the accountability provisions.

NCAN will continue to keep you up to date about the new regulations and the implementation process as we approach the July 1 deadline. In the meantime, please feel free to reach out with any questions (woodhouse@ncan.org), or join us for our monthly Beltway Buzz federal policy peer exchanges.

Read More: 

• Highlights from the AHEAD Committee: Workforce Pell Consensus Reached
• Workforce Pell: You’ve Got Questions, We’ve Got (Some) Answers
• ED Abruptly Ends Student Support, Basic Needs Grants; New Competition Includes AI-Enabled Advising

Reading time: Eight minutes

The AHEAD Committee reached consensus on Friday, December 12, after a week of negotiations on two policy issues from the budget reconciliation bill: Workforce Pell and the prohibition on students receiving Pell Grants when they have a full ride. This consensus means the Committee's agreed-upon language will largely be adopted, though some policy questions remain unresolved. The Committee will reconvene January 5-9 to address the remaining higher education provisions in the budget reconciliation law. The US Department of Education (ED) will then finalize the regulation, post it for public comment, and release final regulations by July 1, 2026. National College Attainment Network (NCAN) Midwest Policy Fellow Magnus Noble served as the student alternate on the Committee, enabling him to advocate for provisions impacting students. For a complete summary of the provisions in the negotiated rule, see here. Below is a summary of key issues and outcomes that NCAN focused on during the process.

Pell Cost of Attendance Restriction

The budget reconciliation bill prohibits students from receiving Pell in excess of the cost of attendance, if they are receiving a full ride. This changes previous law that permitted Division I and II athletes to receive both a Pell Grant and a full ride from their university. Under the new law, all student aid packages, including those of DI and II athletes, will be capped at the cost of attendance (COA). The negotiated rulemaking committee’s final language states that if a student has received grants and scholarship aid exceeding the full cost of attendance, the school must reduce non-Federal aid such that the total financial aid package meets the cost of attendance or not award a Pell Grant to the student.

This interpretation of the statute means that when students receive a full ride, schools may not reduce Pell Grants. Instead, they must reduce non-Federal aid (e.g., private or state grants and scholarships) or remove the Pell grant from the student’s aid package in its entirety. By creating a strong financial incentive for schools to reduce non-Federal aid and retain Pell, this decision addresses concerns that Pell would no longer function as a first-dollar program in student aid awards.

Workforce Pell

Program Approval Process

States will lead the effort to determine which programs are eligible for Workforce Pell. Governors or their designees must design a process assessing whether programs prepare students for in-demand, high-skill, or high-wage occupations, a list that must be reviewed at least every two years in conjunction with state’s Workforce Innovation and Opportunity Act (WIOA) process. Additionally, they must confirm that programs meet the quality guardrails and requirements for demonstrating that credentials are stackable and portable, as described below. Program approval duration is aligned with each institution’s Program Participation Agreement (PPA).

ED staff provided a list of program types they anticipate being likely participants, including nursing assistants, commercial drivers’ licenses, welding and child care providers.

Quality Guardrails

The statute includes several requirements ensuring programs lead to valuable credentials for students:

Value-added earnings – Tuition and fees must not exceed the "value-added earnings" of program completers who received a Pell grant. Value-added earnings is defined as the median earnings of program completers three years after completion, adjusted for regional cost of living, minus 150% of the poverty line. Programs with more than half of students living outside the state where the program is located would be compared with the national price parity.

For example, according to ED, if the median earnings of program completers three years after completion is $25,000 and the regional cost of living is slightly below the US average (86.5% of the US median), program earnings would be adjusted to $28,902 and compared to 150% of the federal poverty threshold ($21,780). $28,902 minus $21,780 equals $7,122. Therefore, the program's tuition and fees may not exceed $7,122. Put simply, the program must yield earnings that exceed 150% of the federal poverty limit plus the program cost.

Students who die, experience a medical condition preventing them from working, or become incarcerated are excluded from the calculation. Note that students enrolled in another postsecondary education program are not excluded. This issue is discussed further below.

ED is charged with calculating the value-added earnings of each program and providing it to the institution running the Workforce Pell program. According to the draft regulations, ED must receive from the college or university a list of students who received Pell and completed the program, and must receive from the "federal agency with earnings data" the median earnings of every student on each institution's list. At least 16 students with earnings data are required for ED to calculate value-added earnings.

70/70 requirement – 70% of students must complete each program within 150% of the "normal time to completion," and each program must have a 70% job placement rate in the second quarter after students exit the program.

Starting in the 2028-29 school year, students who exit the program must be "employed in the occupation(s) for which the program prepares students…or a comparable high-skill, high-wage, or in-demand occupation."

Prior to the 2028-29 academic year, Governors can certify that programs meet these requirements using administrative data.

Governors are responsible for verifying that the job placement rate has been met, which may prove challenging. While state administrative data can usually reveal which sector someone works in, identifying their specific occupation is more difficult. Whether someone is an x-ray technician or a cardiologist, they still work in health care.

Stackability

The statute requires programs to allow students to "receive academic credit for the Workforce Pell program that will be accepted toward meeting such certificate or degree program requirements." In other words, Workforce Pell programs must allow students to accrue credit that leads to a higher degree or credential, even if the Workforce Pell program is not for credit at the time the student is enrolled.

Demonstrating that a program is stackable and portable can be difficult because most students don't build on short-term credentials to pursue higher degrees. As a result, NCAN recommended important changes to the draft regulations to ensure students understand their lifetime eligibility usage and can use Workforce Pell to advance their postsecondary education and career. The negotiated regulations now require states to develop:

• A written policy for determining if a credential is stackable and portable that establishes documented connections to additional credentials, considers, if available, data showing whether students have obtained additional credentials through career pathways, real-time labor market information, and includes a process for employer validation; and
• A written policy for institutions to establish that an eligible workforce program will ensure the award of academic credit towards a certificate or degree program upon a student’s successful completion of the eligible workforce program and enrollment in such certificate or degree program, and that such credit will be accepted at one or more eligible institutions through written agreements, including established articulation agreements, transfer-of-credit agreements, consortium or partnership agreements, or similar arrangements.

These requirements will help ensure that Workforce Pell programs can be a foothold in a postsecondary education that culminates in a degree.

Unfortunately, ED declined to exclude students enrolled in postsecondary education programs from the employment rate calculation, despite requests from multiple negotiators. As a result, if a student enrolls in a bachelor's degree program after completing the Workforce Pell program, they will count as unemployed in the job placement calculation. This decision creates a strong disincentive for colleges to develop or promote stackable credentials and seriously undermines the stackability requirement in statute.

Remaining Questions

While achieving consensus in the first week means much of the language won’t change, there are still some important questions that have not been addressed, including:

• Will states have to implement a process for checking job placement and program completion rates annually or will postsecondary institutions be responsible for certifying that they have met the requirements?
• How will states submit Governor certifications and in what (standardized?) format to ED? What will be the expected turnaround times for review, appeals, and recertification?
• How will online programs that span multiple states be considered for approval in light of the bilateral agreements that are permitted under the draft regulations?
• The draft regulations state that programs may lose and regain eligibility tied to the performance metrics, but will the final regulations add reporting burdens that would change how states structure their review?

Next Steps

The AHEAD Committee will reconvene in person and virtually the week of January 5-9 to discuss postsecondary accountability, including the new earnings premium requirement that was included in the budget reconciliation bill, financial value transparency, and gainful employment. The second session will also address the exclusion of Pell grant eligibility for students with a Student Aid Index that is twice the maximum Pell or higher.

After that session concludes, ED will release a draft regulation for a 30-day public comment period, followed by a final regulation in late spring or early summer of 2026. Once final regulations are released, states will establish their processes for approving programs, and colleges and universities will submit programs for consideration. While some states and schools may move quickly, many programs likely won't be operational until spring 2027 at the earliest.

Questions? Please don't hesitate to reach out to me at brownc@ncan.org.

Read More:

• ED Abruptly Ends Student Support, Basic Needs Grants; New Competition Includes AI-Enabled Advising
• Workforce Pell: You’ve Got Questions, We’ve Got (Some) Answers
• ED’s Proposed College Admissions Survey Raises Concerns

Reading time: Two minutes

On Monday, November 10, the US Department of Education (ED) announced that it will redirect $167 million from the fiscal year 2025 Fund for the Improvement for Postsecondary Education (FIPSE) to support a new set of priorities: artificial intelligence in postsecondary education, civil discourse initiatives, accreditation reform, and short-term workforce program development.

The reallocation of FIPSE funding discontinues several important programs—including the Basic Needs Grant, Postsecondary Student Success Grant, Centers of Excellence for Veteran Student Success, and Rural Postsecondary and Economic Development Grant—which have provided critical student success and basic needs supports for students across the country.

While the National College Attainment Network (NCAN) has advocated to reform and improve the Postsecondary Student Success Grant (PSSG), as the grant’s eligibility structure excluded many of our members, we know that the program’s elimination will impact postsecondary attainment. At a time when many students and families are struggling to cover the cost of food and housing, the loss of these funds will be felt most acutely by low-income and first-generation college students, who already face challenges to persistence and completion.

One priority in the new grant competition may be relevant for NCAN members who incorporate AI, or artificial intelligence, technology into postsecondary access and success advising. The notice inviting applications states that ED will fund projects that “improve academic instruction and student learning, including efforts designed to assess the learning gains made by postsecondary students”. Among other items, the Department is seeking proposals from organizations that partner with State Education Agencies (SEAs) or Local Educational Agencies (LEAs) “to use AI technology to provide high-quality instructional resources, high-impact tutoring, and college and career pathway exploration, advising, and navigation to improve educational outcomes.” ED expects to award 25 grants to address AI priorities, totaling $50 million, by December 31, 2025. The application deadline is December 3, 2025. This is a particularly quick turnaround for applicants.

How to Apply

Applications must be submitted through Grants.gov, following ED’s Common Instructions for Applicants to Department of Education Discretionary Grant Programs. Eligible applicants include “institutions of higher education, consortia of such institutions, and other public and private nonprofit institutions and agencies including State higher education agencies.” In the project abstract, applicants should note which priority area their proposal addresses. The application narrative should explain how the project meets the relevant priority, identify partners, and outline the target population, core activities, and expected results over the four-year grant period. ED encourages applicants to stay within a 35-page limit and to review all eligibility, formatting, and submission requirements closely to avoid technical issues, especially given the short turnaround time. For more information, please see the notice on the Federal Register.

NCAN will continue monitoring the implementation of this competition and its implications for students and the organizations that serve them. We remain focused on ensuring that federal investments effectively support postsecondary access and completion.

Questions? Please reach out to Louisa Woodhouse, Senior Associate, Policy and Advocacy (woodhouse@ncan.org). 

Read More:

• Workforce Pell: You’ve Got Questions, We’ve Got (Some) Answers
• ED’s Proposed College Admissions Survey Raises Concerns
• What to Expect When You’re Expecting a Government Shutdown

Reading time: Eight minutes

As many National College Attainment Network (NCAN) members know, the budget reconciliation bill enacted this past July included a new program to expand Pell to short-term training programs. Effective July 2026, workforce programs of eight to 15 weeks that are aligned to high-wage, in-demand fields, and meet other criteria, will be able to offer Pell Grants.

We’ve received a lot of questions about this initiative from NCAN members in recent weeks. We want to share with you the answers that we have – and some of the questions that remain. We also recorded a peer exchange on this topic that you can access here.

What We Know

The US Department of Education (ED) has announced a negotiated rulemaking process to consider regulations for Workforce Pell (WFP) that will begin in December and conclude in early January. That process will resolve many of the lingering questions, though others will take more time to rectify. Here’s what we can say at this time based on the statute:

Program Requirements

State governors are responsible for determining whether training programs meet the following requirements:

• Programs must be between 150 and 599 clock hours and between eight and 15 weeks
• Programs must be run by accredited institutions of higher education (IHEs) and have been offered for at least one year prior to being approved as a short-term Pell program.
• For-profit programs at accredited IHEs are eligible.
• Programs must prepare students for high-skill, high-wage, or in-demand industry sectors or occupations, as determined by state workforce boards, and meet the hiring requirements of employers.
• Programs must lead to a recognized postsecondary credential that is stackable, meaning it can lead to an associate or bachelor’s degree, and portable across more than one employer.
• Programs must have a 70% completion rate and a 70% job placement rate.
• Programs must increase participants’ earnings above and beyond what they would have earned if they hadn’t participated in the program. This metric is measured by comparing the cost of the program with the median annual earnings of program completers three years prior who received federal student aid and subtracting 150% of the federal poverty line.

Student Eligibility

• Students will need to complete a Free Application for Federal Student Aid (FAFSA) to access WFP and be eligible for a Pell Grant based on their Student Aid Index (SAI).
• Students may not receive a regular Pell Grant and a WFP grant concurrently though students may receive a WFP if they have already completed an associate or bachelor’s degree, if they have unused Pell eligibility.
• Once prorated, WFP grants may fall below the $740 minimum grant of base Pell program.

Timeline

WFP will go into effect on July 1, 2026. While ED’s master calendar requirement dictates that regulations impacting the coming academic year must be in place by November 1 of the previous year, ED is permitted to implement voluntary programs early. Since IHEs are not required to offer WFP, ED can use this early adoption latitude in this scenario. In addition, because the budget reconciliation statute specifies an implementation date of July 1, ED may also be able to rely on emergency authority to adjust the normal regulatory timeline and process.

While ED is likely to release final WFP regulations by July 1, 2026, it will likely take longer for governors to interpret those regulations and develop an approved list of WFP providers in their state.  ED will also have to adjust its backend systems to ensure that all Pell awards are distributed and recorded properly so that students' lifetime eligibility usage (LEU) is tracked. This process is likely to take longer, and we may not see WFP programs launch until Spring of 2027.

What We Don’t Know

Of course, NCAN members have questions that go beyond what is specified in the statute. Here are some of those questions along with the best responses we can give at this time:

How will WFP grant amounts be determined?

The statute says the “[US] Secretary [of Education] shall award Workforce Pell Grants… in the same manner and with the same terms and conditions as the Secretary awards Federal Pell Grants…” That means, most likely, awards will be determined based on the SAI and prorated in the same way that Pell Grants for clock hour programs are determined currently, using the formula below. We don’t yet know whether IHEs will develop a separate cost of attendance (COA) for each WFP program, or if IHEs will use the same COA that they do in other programs.

• Multiply the student’s Pell award by the lesser of:
  • The number of clock hours in the WFP program (150-599) ÷ the number of clock hours in the program’s academic year (900)
  • The number of weeks in the WFP program (eight to 15) ÷ the number of weeks in the program’s academic year (at least 30 for credit hour programs, at least 26 for clock-hour programs).
• This means that a student with an SAI of 0 who is attending a WFP program that is eight weeks long and offers 160 clock hours would receive a WFP award of $1,315 because the proration amount based on clock hours (160/900=18%) is less than the proration amount based on weeks (8/26=31%).

The technical formula is not important for NCAN members to understand (we shared it for all the wonks out there), but there are some repercussions of the formula that we want to underscore. First, because WFP grants will be prorated by the number of weeks or clock hours in the program - and WFP programs cannot be more than 15 weeks and 599 clock hours - students will not be able to receive a WFP grant that’s more than 58% (15/26) of the maximum Pell. Assuming ED uses the formula above, WFP students will not be able to receive a maximum Pell Grant for a WFP program.

Second, programs that are intensive but short – for example, eight hours a day for eight weeks – will be prorated based on the number of weeks, not hours in the program. Conversely, a program that’s 15 weeks long, but only meets 10 hours a week, will be prorated based on hours. These guardrails will limit how much Pell short-term programs can award, and thus how much will be reduced from students’ LEU.

How will WFP factor into LEU?

As NCAN members know, students who are eligible for Pell Grants may use six years of Pell throughout their life.  But WFP programs may not be delivered in the same units as the standard college semester and credit hours, which raises the question of how WFP awards will be deducted from a students’ LEU.  Students with equivalent SAIs may attend WFP programs of varying durations and clock hours, and ED will need to decide how those programs will be converted into equivalent units to calculate LEU. We also wonder whether students will be able to use their entire LEU on WFP programs or whether there will be a cap or separate LEUs for the shorter programs. And finally, will students be advised of the impact on their LEU when they register for a WFP program? That step seems important.

How will programs demonstrate that the credentials they offer are stackable to an associate or bachelor’s degree?

As noted above, another requirement in the statute is that programs must lead to other degrees or credentials and be portable to more than one employer. Excepted in the statute are programs that prepare students “for employment in an occupation where there is only one recognized postsecondary credential.” But ensuring “stackability” and portability may be challenging. In some fields like health care, medical technician programs that set students up to train as nursing assistants are easy to imagine. But what about commercial driver’s licenses or HVAC technicians? What test will states use to ensure that programs are stackable and how will they maintain a high bar so that the exception does not become the rule?

What process will states use to approve WFP programs?

States are in the driver’s seat, and the process they will use to decide which programs meet the requirements is up to them. Will they rely on pre-existing labor market lists or build new ones? The statute requires the programs to be aligned with in-demand industries, as determined by the state workforce boards. Which state agency/s will be responsible for developing the list of approved programs, and what process will states go through to ensure its accuracy?  How often will the lists be reviewed and updated? Should IHEs expect priorities to change every time a new governor, with different priorities, comes into office? We have a lot of questions about this process that we hope will be addressed during the negotiated rulemaking process.

When will the first WFP students receive a grant?

Again, it’s hard to say with certainty but it might not be until the Spring of 2027.

These are certainly not the only questions we have, and we want to hear from you. What are you wondering about and preparing for as you learn more about how this program will be implemented in your state? Please reach out and share your thoughts and questions! As always, we’ll keep you posted as the process unfolds.

Read More:

• ED’s Proposed College Admissions Survey Raises Concerns
• What to Expect When You’re Expecting a Government Shutdown
• New Report: College Remains Financially Out of Reach, Students Face $1,500 Gap at Public 4-Years

Reading time: Three minutes

UPDATE: On November 13, 2025, the U.S. Department of Education (ED) posted an update on the Admissions and Consumer Transparency Supplement” (ACTS) survey component. This update essentially finalized the agency's proposal from August. The announcement says that any four-year college or university that does not admit 100% of its applicants will be sent the survey in December and expected to complete it by March 18, 2026.

The process for compiling with this requirement will be extensive, as described in a recent post by James Murphy from Class Action: "The first step in the ACTS process will be to create an anonymized file for every single person who completed an application  to a college or graduate program each year. Those files, which will not be shared with the Department of Education, will then be uploaded into the ACTS Aggregator Tool, which will then create aggregate data files for undergraduates and graduate students, which are to be downloaded and then submitted to the IPEDS Data Collection System (DCS)." Institutions that do not comply with this requirement could face fines of up to $71,545 for each violation, the announcement states.

We remain concerned about the burden that this announcement imposes and the challenges institutions may face in compiling the data that's required. 

Here is our original post on this issue:

On August 15, the US Department of Education (ED) announced its intention to add a new IPEDS “Admissions and Consumer Transparency Supplement” (ACTS) to IPEDs, the Integrated Postsecondary Education Data System that collects data from more than 1,000 schools annually. This supplemental survey would collect admissions and enrollment data at selective colleges and universities by race and sex categories. This proposal follows on the heels of the US Department of Justice’s memo describing prohibitions on diversity, equity, and inclusion initiatives.

Under the new ACTS survey, colleges would be required to report: admission test score quintiles, GPA quintiles, ranges of family income, Pell Grant-eligibility, and parental education, for institutions’ applied, admitted, and enrolled cohorts and the count of students admitted via early action, early decision, or regular admissions.

Institutions would need to submit this data not just for the current year, but for the previous five years as well, a requirement that schools provide over 100,000 data fields to in the next six months.

Greater transparency in college admissions is a worthy goal; the system is rife with inequities. But gathering more data is worthless if it can't be trusted. And ACTS, as currently proposed, is setting institutions up to submit flawed data that could have serious consequences.

President Trump's executive order directed the US Secretary of Education to "take remedial action" against institutions that submit incomplete or inaccurate data. The order doesn't define remedial action, but given the administration's recent moves, it's not hard to imagine flawed ACTS data becoming ammunition for investigations or enforcement actions. It’s also not hard to imagine accurately submitted data being weaponized against schools with gaps in admissions by race and ethnicity that the Trump Administration deems suspect.

IPEDS has a decades-long reputation as a trusted data source because changes go through a rigorous vetting process. The Paperwork Reduction Act requires federal agencies to follow specific steps before adding new data collections that are designed to minimize burden and maximize data quality. Agencies are required to provide multiple opportunities for public comment, to read and respond to all comments, and to offer a comment period longer than 60 days when the full survey isn't provided alongside the announcement. As of this writing, the proposed ACTS instrument has not been released.

For IPEDS data to be reliable, institutions need clear definitions of the data fields they are required to submit and more. Right now, ACTS raises more questions than it answers, starting with: which colleges are required to submit this supplement, and what race and income definitions should they use? Without clear answers, institutions will report data differently, making comparisons meaningless.

Asking for five years of retrospective data creates its own challenges. Many institutions don't have this data because they weren't collecting it. Others collected it in formats that don't match the new requirements. The past five years also include the COVID-19 pandemic, when many schools went test-optional, and the 2024-25 Free Application for Federal Student Aid (FAFSA) debacle. Using this period for benchmarking is comparing apples to oranges to something that might not even be fruit.

Also unknown is who will process and analyze the data collected through the survey. 90% of staff members at the Institute for Education Sciences were terminated in March and only three people are currently employed at the National Center for Education Statistics, which houses IPEDS.

If ACTS launches in December, as currently proposed, we'll get incomplete, inconsistent, and unreliable data. Institutions will face impossible burdens with unclear guidance. Furthermore, students could ultimately pay the price if flawed data triggers investigations or aid cuts.

We will be making our collective voice heard on this issue by joining an effort led by the Institute for Higher Education Policy, and we encourage you to submit an individual comment if you have the capacity. The deadline to submit comments on this proposal is October 14, 2025, and comments can be submitted here.

Questions? Don’t hesitate to reach out. As always, we will keep you informed as this issue progresses.

Read More:

• What to Expect When You’re Expecting a Government Shutdown
• New Report: College Remains Financially Out of Reach, Students Face $1,500 Gap at Public 4-Years
• Conference Panelists Call for Courage to Meet Political Moment

Reading time: Two minutes

If you’re feeling like it’s Groundhog Day, you’re not alone. Once again, we are on the brink of a government shutdown, with federal funding authority set to expire on September 30, 2025 at midnight. Congressional leaders are heading to the White House this afternoon, and the situation may change rapidly. In fact, by the time you read this blog, the crisis may have been averted. But as of now, neither side appears to be blinking.

The good news for the college access and success field is that Free Application for Federal Student Aid (FAFSA) and Pell will be largely unaffected. The US Department of Education’s (ED) shutdown plan can be found here. In brief, it states:

• FAFSA will continue operating: Students and families will be able to access and complete the FAFSA and the Office of Federal Student Aid (FSA) staff will continue processing FAFSA forms.
• The call center will continue to be staffed: Students will still be able to contact the call center to have their FAFSA and student loan questions answered.
• Pell Grants, Campus-Based Aid, and Direct Student Loans will continue to be disbursed: All federal student aid will continue to be disbursed. Pell Grants and Direct Student Loans, which are forward funded, meaning funded using the prior year appropriation, and funded with mandatory money, will not be impacted. Borrowers will be required to continue making payments.
• Other federal education programs may be impacted: ED’s plan says about 17 discretionary programs have unspent funds from FY25 that may be used in the event of a shutdown. It does not specify which programs are in that category. GEAR UP and TRIO could be on the list.
• Grantmaking will halt but grant drawdowns may continue: ED will pause new grantmaking, but grantees will be able to draw down funds they have already been awarded. The plan notes that most grantmaking occurs over the summer and most grant aid has already been drawn down.
• Budget reconciliation rulemaking will continue: FSA will not furlough employees working on budget reconciliation rulemakings necessary to meet deadlines established by the budget reconciliation bill enacted in July. The negotiated rulemaking session going on now will switch to a virtual format.
• Other activities will stop: The Office for Civil Rights will pause its investigations, and ED staff will stop developing and implementing guidance and providing technical assistance, other than those required by budget reconciliation.

Despite its promises to maintain student aid services, the plan says 85% of staff at FSA and 87% of other ED staff will be furloughed. This level of impact is extensive and may result in disruptions. If a shutdown continues for a prolonged period, the impact on core services will grow. This issue will unfold over the next day and we at the National College Attainment Network (NCAN) will keep you posted on the impact should a shutdown commence.

Read More:

• New Report: College Remains Financially Out of Reach, Students Face $1,500 Gap at Public 4-Years
• Conference Panelists Call for Courage to Meet Political Moment
• House Bill Level Funds Pell Grant, TRIO, & GEAR UP in FY26

Reading time: Two minutes

Despite widespread recognition that postsecondary education is an important ladder to individual opportunity and workforce development, college remains financially out of reach for students across the country. A recent analysis from the National College Attainment Network (NCAN) finds that students at public colleges and universities – once touted as low-cost options – still face significant unmet need.

NCAN’s Affordability Gap analysis reveals that in a sample of 1,137 public community colleges and bachelor’s-granting institutions in academic year 2022-23,

• Only 35% of bachelor’s-granting institutions were affordable, on average.
• Students at these institutions faced an average affordability gap of $1,555 – slightly lower than the gap identified in last year’s report.
• Less than half (48%) of community colleges across the country were financially within reach for students, on average.
• Students at community colleges experienced an average of $486 in unmet need, nearly double the gap in the previous year.
• In 14 states, no public bachelor’s granting institutions met NCAN’s benchmark for affordability.
• In five states, no community colleges met the standard set in NCAN’s model.

In 2022-23, the states with the largest affordability gaps at public bachelor’s-granting institutions were New Hampshire ($8,239), Pennsylvania ($8,076), Ohio ($5,138), South Carolina ($4,874), and Rhode Island ($4,714). At community colleges, states with the largest average gaps included New Hampshire ($11,499), Utah ($7,689), Pennsylvania ($4,508), Maryland ($3,483), and Hawaii ($2,887).

In NCAN’s sample, public bachelor’s-granting institutions were affordable, on average, in several states. The states with the largest aid surpluses included New Mexico ($3,769), Florida ($2,856), Arizona ($1,996), California ($1,721), Montana ($1,590). States with the largest average aid surpluses at community colleges included New Mexico ($4,543), Maine ($4,052), Vermont ($3,884), Connecticut ($3,690), Kentucky ($3,366). These dollars are typically used by students to cover costs of items not included in the price, such as travel to and from campus, textbooks, and other items.

Trends in this year’s Affordability Gap analysis are likely influenced by shifts in the landscape of federal funding, NCAN says: bachelor’s-granting institutions became slightly more affordable following a historic increase to the maximum Pell Grant, yet cost barriers increased at 2-year institutions due to the loss of pandemic relief funding and rising housing costs, which most heavily impacted community college students.

“This year’s findings underscore the importance of federal student aid, and specifically, direct-to-student funding, in helping students access and pay for higher education,” said NCAN’s CEO, Kim Cook. “We know what works: investing in need-based aid helps close these gaps and puts degrees within reach for students.”

The report urgently warns of future funding challenges ahead that could foreclose postsecondary pathways to students across the country. Significant cuts to spending on higher education programs, Medicaid, and SNAP in the budget reconciliation bill signed into law this summer further threaten students’ ability to afford a degree. Despite downstream pressure from the federal cuts, “It’s imperative that states maintain or, wherever possible, bolster their investments in higher education,” says Louisa Woodhouse, NCAN Senior Policy and Advocacy Associate. “Slashing education funding to plug other budgetary holes will only widen affordability gaps for students and push postsecondary education further out of reach.” That tradeoff, Woodhouse says, is likely to have long-term negative repercussions not only for students, but for families, states, and our nation’s skilled workforce.

The Affordability Gap report is available here. The accompanying data dashboard can be found here.

Questions? Please contact Louisa Woodhouse, Senior Associate, Policy and Advocacy, at woodhouse@ncan.org. 

Read More: 

• The Affordability Gap: Assessing the Scope of Unmet Financial Need for Students and Public Colleges and Universities 
• NCAN's State Affordability Profiles 
• The Affordability Gap: Data Dashboard

Reading time: Six minutes

“If you’re scared, you can’t teach and you can’t mentor, and it’s the only reason we’re here. Do your job and do the thing you’re trained to do.” This was the counsel of Dr. Xavier Cole, President of Loyola University of New Orleans, during the “Meeting the Moment” plenary session at the National College Attainment Network's (NCAN) 2025 National Conference.

It’s a fraught time for the college access and attainment field and higher education in general, but NCAN and our members across the country are, as the title suggests, working to meet the moment.

Cole was joined by Skye Perryman, President and CEO of Democracy Forward, a national legal organization that advances democracy and social progress through litigation, policy and public education, and regulatory engagement, and Chibuzo Ezeigbo, Senior Program Officer for the Education and Economic Mobility Program at the Joyce Foundation. The panel was moderated by Catalina Cifuentes, Executive Director of College and Career Readiness, Riverside County Office of Education, Chair of the California Student Aid Commission, and President of the NCAN Board of Directors.

Cifuentes opened by noting that in recent months, the Trump administration has eliminated targeted support for students of color, slashed education research funding, and proposed eliminating federal programs like GEAR UP, TRIO, and even the US Department of Education. In the face of this, “NCAN members are leading with passion and persistence in the things we do.” She added, “The words we say matter to students – if not us than who?”

Perryman, whose organization represents NCAN in its lawsuit challenging funding cuts to AmeriCorps, noted that she was “so proud” of NCAN as a plaintiff in a case that helped secure the restoration of AmeriCorps funding. “You did that,” Perryman extolled, “No member of Congress did that. We did that bringing the case and pushing the case – it’s a win nobody can take away because the funds have been pushed out.”

More broadly, Perryman emphasized, “The cost of inaction is so much more than the cost of doing your thing and pursuing your fight. There isn’t a benefit to keeping your head down and hoping you’re going to slide off the radar. You’re involved in educating people and that’s a threat to people who don’t want a broad civil society and freedom.”

Ezeigbo noted, “Knowledge is power, especially information that’s accessible, powerful, and relevant.” It’s why the Joyce Foundation established a network for state policy advocates to get briefings from a law firm about what the executive orders mean about what might change at the state level. “It’s about getting that information and translating and forming next steps,” Ezeigbo explained. Other philanthropies have formed similar networks. “It’s one place where philanthropy has really been able to help support this effort and help grantees keep track of what has been going on.”

Philanthropy, Ezeigbo continued, “moves very, very slowly.” But recently she’s “been really excited to work with other foundations who have acted very quickly and provided last minute funding or lots of different kinds of flexibility to meet the moment.” Notably, the philanthropic community has been flexible with grantees who are doing their regular work. For example, the Joyce Foundation has converted project funding to general operating funding, extended deadlines, and removed reporting requirements. “Time and time again, I hear our CEO say we aren’t backing down on our mission of advancing racial equity and expanding economic mobility,” said Ezeigbo. “It helps to provide cover for organizations who don’t have the leeway that philanthropy does.”

Perryman offered some honest, and ominous, insight and advice to attendees, which is worth quoting at length:

The thing I want everyone to walk away from this room is the paradigm has shifted in this country. It’s hard for us to hear….The rules of the game and engagement are different when confronting that. The courage to say, ‘We are going to do what we need to do to support our programs, or we’re going to go to court’ – we are not seeing those strategies put institutions in more danger. Strength and courage are not more of a liability for institutions. It used to be that way, but it’s not where we are. We have to help ourselves and our advisors live with that reality. Being able to stand in your power is more of an asset than a liability. These are different muscles that we’ve got to use and work.

Cole touched on this idea of strength and courage in his remarks. “The one thing you have that can’t be given away is your integrity. If your personal integrity is being corrupted, you then have to say no, and then stand by whatever decision I have made. If I can stand by a decision, I’m good with it, whether it was right, wrong, hurt, helped because that’s why I was selected to lead this university.”

“There are things I believe and things my university espouses and believes,” he explained. “I have to hold both in balance. What should I fight and what should my university and those two things shouldn’t be conflated.” He criticized institutions who have complied in advance and warned that doing so “leaves you open to it happening again in the future.”

At the conclusion of the plenary, the panelists offered their advice to the audience and the field.

Perryman urged, “We have to help support organizations and their leaders to get a new mindset….The older rules of engagement aren’t working with this administration….Institutions that are able to guard integrity, protect strategies, be principled, and require [the administration] to work for it are the ones who are able to achieve the results that they have wanted…It’s how we restored AmeriCorps and $6 billion in funding. None of that came through complying in advance or capitulating. We are going to respond and force these issues.”

Ezeigbo, for her part, counseled organizations, “Consider legal risk and mission risk. Everyone here chose the profession you did for a reason. We’re here to support students. Mission risk is something that can’t be discounted in this moment. It’s admittedly a scary time. I can’t think of any type of organization in the nonprofit sector that hasn’t felt under attack. This isn’t the moment to capitulate. What might you be giving up mission wise by potentially over-indexing on the legal risk? You have to keep those two things in balance. This isn’t just a fight for the lawyers or those who work in policy/advocacy this is for those who work in direct service, districts, schools we have to form coalitions to work through this.”

Cole, lastly, advised: “Do not allow for yourself to be isolated. We are all part of networks of like people and organizations. Don’t feel compelled to respond to something in the moment. Drop back, game plan it, there’s strength in numbers…You do this together. That strength in numbers will have a larger, stronger voice and impact. Slow down, don’t feel compelled to jump when someone asks you to jump, ask why they want you to jump.”

The threats to the field and the broader higher education sector are real. The fear of students, families, and other education stakeholders is real. But so too is the power of this network. “Just you being here in the room together,” Cole said, “links us as a community the way we should’ve been before there was a crisis.”

The panel emphasized that this is not the time to retreat. It is the time to push forward and use every tool available: litigation, advocacy, organizing, teaching, mentoring. To resist isolation, to guard integrity, and to stay relentlessly focused on students.

NCAN members are already meeting the moment. The challenge now is to keep fighting.

Read More:

• Students Share Perspectives at #NCAN2025: “It's Not Easy, But It's Totally Worth It."
• Cheers to 30 Years: Highlights from NCAN’s 2025 National Conference
• FSA Shares FAFSA Successes and Policy Updates at #NCAN2025

Reading time: Two minutes

On September 1, the House Appropriations Committee released its Labor, Health and Human Services, Education, and Related Agencies (LHHS) bill for Fiscal Year (FY) 2026, which was reported favorably out of the Subcommittee markup on Tuesday on a party-line vote. The bill makes significant cuts to federal education spending overall, yet maintains level funding for several of the National College Attainment Network's (NCAN) key policy priorities, including the Pell Grant maximum, TRIO, and GEAR UP.

“We were pleased to see that the House Appropriations Committee maintained the maximum Pell Grant for FY26,” said NCAN CEO Kim Cook. “The decision to preserve Pell Grant funding demonstrates that Congress recognizes the importance of this foundational need-based aid program as a proven ladder to postsecondary attainment.”

The House bill is a clear departure from the Trump Administration’s FY26 budget request, released earlier this spring, which proposed a cut to the maximum Pell Grant, and the elimination of funds for AmeriCorps and many federal student aid programs, including TRIO, GEAR UP, Federal Work Study, the Supplemental Educational Opportunity Grant (SEOG).

In contrast to the Senate version, which maintained level funding, the House bill eliminates SEOG and reduces spending on Work Study by $451 million. The bill also proposes a $620 million cut to the Corporation for National and Community Service, including $279 million from AmeriCorps Grants, specifically. The loss of these funds would be felt most heavily by students with the highest financial need, who would lose both financial support for postsecondary education, and potentially, access to AmeriCorps-funded college advisors and support services.

The House bill also proposes changing the Workforce Pell program title to "Trump Grants," and renaming AmeriCorps the "America First Corps."

Though not yet confirmed, a full Committee markup is expected next week. The House and Senate will have to reconcile differences in the LHHS bills before one version can be passed and signed into law. If a FY26 appropriations package is not enacted by September 30, 2025, we may be headed for a shutdown or a continuing resolution (CR) to maintain funding levels until Congress can agree on a path forward.

Questions? Reach out to Louisa Woodhouse, NCAN Senior Associate, Policy and Advocacy, at woodhouse@ncan.org. 

Read More: 

• Senate Level Funds Pell, TRIO, GEAR UP, Work Study, SEOG, & AmeriCorps in FY26 Appropriations Bill 
• Skinny Budget, Big Cuts: Trump Administration Publishes Budget Request for FY26 
• Reconciliation Bill: What You Need to Know

Reading time: Two minutes

On Thursday, July 31, the United States Senate Appropriations Committee convened to markup its proposed Labor, Health and Human Services, Education, and Related Agencies (LHHS) spending bill for fiscal year (FY) 2026. The bill was reported favorably out of Committee with a bipartisan vote of 26-3.

The Senate LHHS bill provides level funding for the maximum Pell Grant, TRIO and GEAR UP, Federal Work Study, and the Federal Supplemental Educational Opportunity Grant (SEOG), and near-level funding for the Corporation for National and Community Service (AmeriCorps). The bill is a notable departure from the Trump Administration’s FY26 budget request, released in June, which called for the total elimination of many higher education funding programs, including TRIO, GEAR UP, SEOG, PSSG, and AmeriCorps, and significant cuts to spending on the maximum Pell Grant, Federal Work Study, and student aid administration.

The National College Attainment Network (NCAN) is glad to see that the Senate sustained funding for many key education programs in the FY26 bill. That said, without increases in appropriations, the purchasing power of key student aid programs will continue to erode. After historic increases to the Pell Grant in FY22 and FY23, for example, the maximum award has stayed stagnant. Currently, it covers only a third of the cost of attendance at a public bachelor’s-granting institution.

As the next step in the appropriations process, the House of Representatives and the Senate will have to pass and reconcile their bills, before a final package can be signed into law. Congress will be on recess beginning August 4 and will return in September with an ambitious goal ahead. If the FY26 spending package is not passed by September 30, 2025, we may be headed for a government shutdown or another continuing resolution -- which would provide stopgap funding until FY26 funding levels are set.

While we don’t have a crystal ball, we will keep you informed, as always, as the process unfolds. For questions, reach out to Louisa Woodhouse, Senior Associate, Policy and Advocacy, (woodhouse@ncan.org) or Catherine Brown, Senior Director, Policy and Advocacy (brownc@ncan.org).

Read More:

• Reconciliation Bill: What You Need to Know
• Controversial Budget Bill Protects Pell but Sharply Cuts Other Supports for Low-Income Americans
• Senate Reconciliation Contains Quirky Pell Eligibility Modification

Reading Time: Seven minutes

The Budget Reconciliation Bill was signed on Independence Day earlier this month. Now, we have to sort through the implications of the bill for the students we serve and the colleges they are enrolled in. The National College Attainment Network’s (NCAN) Beltway Buzz webinar series, an iteration of which was offered yesterday, gave our members the chance to learn more about the major impact of the bill and get answers to some of their questions. Most of the higher educatin provisions in the bill are slated to take effect on July 1, 2026. These changes will impact the 2026-27 Free Application for Federal Student Aid (FAFSA) and academic year. 

We do not know how all changes will be implemented – or in what order the US Department of Education (ED) will address them – but there are some things you can count on: 

• FAFSA is slated to begin beta testing in the next couple weeks  
  and will open on October 1, 2025, thanks to that functional area being adequately staffed 
• Pell Grants will be fully funded at $7,395, and the reconciliation bill provides funding to address the program’s funding shortfall, ensuring that maximum award is fully funded for the next two academic years 
• Subsidized loans for undergraduate students will continue at current levels 
• PLUS loans will continue at current levels 
• TRIO, GEARUP, and AmeriCorps will be funded for the coming year 
• International student visas are facing higher scrutiny and could reduce revenue to institutions as their enrollment levels drop 
• Postsecondary students may experience a loss of scholarships that included race as a factor, based on ED's interpretation of the U.S. Supreme Court's decision about consideration of race in admissions 
• Research funding cuts and other grant terminations may impact college budgets, leading to less availability of financial aid and other student support, and finally, 
• FAFSA completion rates for the Class of 2025 were much higher than last year, which we believe should lead to increased postsecondary enrollment this fall. 

NCAN will monitor these areas in the lead up to the next academic year. We have concerns about the aggressive implementation timeline in the statute, and ED’s capacity to thoughtfully meet all the mandates. At this point, we do not have answers to questions about the following issues, among others: 

• Pell Grant awards and the maximum award level for 2026-27 
• TRIO, GEARUP, and AmeriCorps funding in Fiscal Year (FY) 26 
• SEOG and work-study funding in FY26 

These questions will be answered as Congress works its way through the FY26 federal budget. The President’s budget proposal eliminates TRIO, GEARUP, AmeriCorps, and SEOG, and greatly reduces work-study funding. However, the President’s budget proposal is never enacted precisely as proposed, and Congress still holds the “power of the purse.” 

To implement the requirements in the reconciliation bill, ED will have to issue clear guidance and, in many cases, go through a negotiated rulemaking process. Loan repayment changes, implementation of the new Workforce Pell program, and the new accountability framework, or earnings test, are likely to go through negotiated rulemaking, which could delay their implementation beyond July of 2026. We will closely monitor these issues as ED begins making changes: 

• The asset exemption for family farms and small businesses will be reinstated. This exemption category has been expanded to include family commercial fishing businesses. We should see this question adapted on the 2026-27 FAFSA. 
• Students that receive grants and scholarships from non-federal sources that exceed their full cost of attendance will not be eligible to receive a Pell Grant though otherwise eligible. While the universe of students receiving non-federal grant aid covering their full cost of attendance is small, ED will need to provide guidance to colleges to explain this requirement. At this point, there is no timeline for when guidance will be provided.  
• The GRAD PLUS loan program is being eliminated. Current borrowers will be able to continue borrowing under this program for three years or until their program is completed. 
• PLUS loan borrowing limits will change to only allow parents to borrow up to $20,000 per year per child with an aggregate of $65,000 per child. 
  Loan repayment programs will be reduced to one “regular” loan payment program and one income-driven payment program which will always require at least a $10 monthly payment. ED has announced that students enrolled in the SAVE program will have to begin paying interest, starting on August 1, 2025. ED will need to work out the many details of how to transfer borrowers from SAVE and other existing programs into the new repayment programs, once they are created.  This topic will likely be a top priority for the Trump Administration.  
• Student loans will now need to be prorated based on the students’ enrollment level. ED will need to provide guidance on the credit hour enrollment categories. An example will likely be that a student who is enrolled half-time (six-to-eight credit hours per term) will only be eligible to receive half of their loan maximum for that term. We expect this to have a significant impact on part-time students, especially at community colleges. 
• The reconciliation bill will establish a Workforce Pell Grant program for programs between 150-600 clock hours that run between eight and 15 weeks in length. The programs have to lead to a portable, stackable credential. The program must be approved by the governor of the state and aligned with in-demand jobs. The program has to have already existed for at least one year. Students cannot receive a regular Pell Grant and workforce Pell at the same time. Some types of course work will not be eligible for funding-remedial, correspondence, English language learning, and study abroad. Unaccredited institutions will not be able to participate. Establishing a new program such as this will also require the negotiated rulemaking process to be utilized. 
• Individual programs at institutions are going to be held to new accountability requirements. Under the statute, the average annual earnings of program graduates four years out from graduation must exceed those of high school graduates between the ages of 25 and 34 within the state (or nation if the college or university enrolls more than 50% of students from out of state). Average earnings of graduate programs will have to exceed those of the same occupation in the state. Programs that do not meet the earnings standard in two out of three consecutive years will not be able to award student loans to students in those programs. They will still be able to award Pell and campus-based aid. This accountability framework differs from the current Gainful Employment (GE) framework, which requires that students earn enough to repay their student loans. This new framework is focused solely on earnings. ED will need to decide whether to enforce both accountability requirements or suspend the GE regulations in lieu of the earnings data. We suspect programs that typically produce low-wage earners, such as education and social work, are most in danger of losing access to the federal loan. 
• While not directly related to higher education, the reconciliation bill makes cuts to federal safety net programs that will have a direct impact on state budgets.  
  • In Medicaid expansion states, the bill includes strict requirements that people regularly prove that they are employed or going to school half time (looking for work does not count) to receive Medicaid, and limits states’ ability to tax health care providers to fund Medicaid. Medicaid is administered differently across states, and this law will be implemented differently, so it is impossible to project how much funding states will lose. We believe that each state will have to decide how they will implement the new law in their state and determine how it might impact their annual budgets. 
  • States will also be responsible for at least 5% of SNAP benefits. Those with high payment error rates will have to pay up to 25% of the cost of benefits. 

Read More: 

• Controversial Budget Bill Protects Pell but Sharply Cuts Other Supports for Low-Income Americans
• Senate Reconciliation Contains Quirky Pell Eligibility Modification 
• Senate Heeds Call to Protect Pell

Reading Time: Seven minutes

After a protracted and at times contentious legislative process, the budget reconciliation bill has passed in the US Congress by one vote in the Senate and four votes in the House of Representatives. President Trump is expected to sign it into law tomorrow.

The law includes three National College Attainment Network (NCAN) advocacy priorities: (1) maintaining current maximum Pell Grant credit eligibility requirements, (2) providing $10.5 billion to avoid cuts to grant amounts, and (3) maintaining the subsidized undergraduate federal student loan program. These are important victories for students from low-income backgrounds. Nevertheless, this legislation makes large cuts to other critical supports for low-income families to provide tax cuts for wealthy Americans and dramatically increases spending on immigration enforcement.

“NCAN thanks Members of Congress who understand that Pell Grants and subsidized federal student loans are this country’s best economic mobility strategy,” NCAN CEO Kim Cook said. “But we know that meeting the basic needs of students and their families—food, health care, and a fundamental sense of safety—is also critical to ensuring that low-income students can enroll, persist, and complete education after high school. In the wealthiest country in the world, we should not be trading off the maintenance of Pell Grants and federal student loans against health insurance and anti-hunger assistance so millionaires and billionaires can pay lower taxes.”

The higher education title of the legislation closely resembles the version proposed by the Senate HELP Committee on June 10. NCAN members worked hard to educate members of Congress about the importance of protecting Pell Grants, and Congress delivered, rejecting the House proposal that would have increased the number of credits required to receive a maximum Pell award and providing $10.5 billion to address the Pell shortfall. Congress also rejected the House proposal to eliminate subsidized student loans, another key NCAN advocacy priority.

Although we appreciate these improvements relative to the House bill, unfortunately the legislation cuts more than $300 billion from federal student aid, which will almost certainly negatively affect postsecondary access and completion. The following provisions are particularly problematic:

• Under current law, student borrowers may opt into income-driven repayment programs that provide loan forgiveness after 20 or 25 years. The new bill extends the repayment period to 30 years before students can receive forgiveness.
• The bill prorates student loans based on enrollment intensity. This provision could make it harder for part-time students to meet their expenses, leading to more dropouts.
• The bill eliminates GRAD Plus loans and places limits on graduate borrowing, which will make it more difficult for many students to go to graduate school, particularly professional programs like law and medical school.

On balance, though, NCAN’s greatest concern about this bill is not the higher education provisions; it’s the net effect of this legislation on the lives of low-income students and the future young people will confront. This legislation cuts taxes for the wealthy, spends $350 billion more in border security and the military, including $45 billion for migrant detention, and terminates most federal support for clean energy, while slashing safety net programs to fund these investments. According to the Congressional Budget Office (CBO), this bill will result in 11.8 million people losing health insurance and end food assistance for 2.9 million people, representing the largest cut to the U.S. safety net in decades. The bill also endangers economic growth by adding $3 to $5 trillion to the national debt, according to CBO and the nonpartisan Committee for a Responsible Federal Budget.

These massive cuts to the safety net will reduce access to health care and healthy food and likely cause states to cut funding to public colleges and universities, where the vast majority of NCAN students enroll. At a time of peak wealth inequality, this bill represents the largest transfer from the poor to the well-off in American history. NCAN’s vision that “all students—especially first-generation students, students from underrepresented racial/ethnic backgrounds, and those from low-income backgrounds—have an equitable opportunity to achieve social and economic mobility through higher education” is set back by this bill.

Still, we are deeply grateful to the NCAN community for its strategic, effective, and relentless advocacy on behalf of our students. Whether you wrote an op-ed, met with your Member of Congress or their staff, signed a coalition letter, talked to the media, or activated your community to take action, you made a difference. And thanks to your dedication and hard work, and the work of many of our partners, Congress came to understand that the Pell changes proposed by the House were unworkable and that the reconciliation process represented the best vehicle to address the Pell shortfall. Sometimes the most significant advocacy wins are bad things that do not come to pass. NCAN’s team will continue to provide updates, analysis, and opportunities to make our voices heard as the Trump Administration implements this legislation.

The table below provides a side-by-side comparison of existing law, the original House and Senate bills, and the final bill. 

Read More:

• Senate Heads Call to Protect Pell
• Senate Reconciliation Includes Quirky Pell Eligibility Modification
• Talking Points: Act Now to Save Pell Grants

The recently introduced Senate Reconciliation bill contains far less detrimental changes to the Pell Grant program than the House version. The Senate version does not modify current enrollment requirements, which has allowed students and aid administrators to breathe a sigh of relief for now. However, the Senate version contains a modification that seems to target and punish a very limited number of students. The provision indicates that: “a student shall not be eligible for a Federal Pell Grant under subsection (b) during any period for which the student receives grant aid from sources other than under this title, including other Federal sources, States, institutions of higher education, or private sources, in an amount that equals or exceeds the student’s cost of attendance for such period.” The good news here is that there are very few student aid packages issued every year that contain grant aid equal to a student’s full cost of attendance. The baffling issue with this is that the Pell Grant program is an entitlement program and if the student meets all federal aid eligibility requirements, the student should receive the funds.

Perhaps the quirkiest modification that accompanies this change is this: “the maximum period during which a student may receive Federal Pell Grants under paragraph (5)(A) shall be reduced by any period during which a student is not eligible for a Federal Pell Grant under subparagraph (A).’’ In other words, the student’s lifetime eligibility would be reduced for each term their cost of attendance was covered, but they were ineligible to use their Pell Grant. This is a most perplexing concept that will leave aid administrators and students with puzzled looks.

Institutions consider the Pell Grant program as the cornerstone of financial aid packages for students who qualify. Colleges’ packaging strategies are designed to build upon a student’s federal and state aid eligibility before adding institutional funds so that no aid package exceeds the cost of attendance. Therefore, this proposed change would have little if any impact on most Pell eligible students. Students that receive a full athletic scholarship for Division 1 or 2 colleges may be most impacted if any of those students are Pell eligible. Current regulations do allow Pell eligible students to utilize their Pell Grant in addition to the athletic scholarship and that total can exceed the cost of attendance. Often full scholarship athletes may have limited work opportunities so utilizing Pell Grant funds for low-income students is a much-needed option for these students. Cost savings for this group would be very limited.

The Senate and House agree on adding foreign income to AGI (adjusted gross income) and eliminating the reporting of small business and family farm assets when calculating Pell eligibility. Both chambers also recommend eliminating Pell Grant eligibility to students who may have qualified using the Poverty Chart method but have an SAI (student aid index) that is larger than twice the maximum Pell Grant for that year. This provision will help ensure that these grant dollars are awarded to students with significant financial need.

Now the process begins to negotiate the final version for reconciliation. The National College Attainment Network (NCAN) will continue to advocate for changes that support students receiving the most impactful financial aid dollars to meet their cost of college. 

Read More:

• Senate Heeds Call to Protect Pell
• CBO: 15 Credit Full-Time Estimate Costs $7.1B, How Does It Impact States?
• Judge Orders Restoration of AmeriCorps Funding in Lawsuit Challenging Grant Cancellations

Reading time: Nine minutes

Late last night, the Senate Health, Education, Labor and Pensions (HELP) Committee released its reconciliation bill. In contrast to the House version, this bill does not make major, detrimental changes to Pell. Protecting and strengthening the Pell Grant program was the National College Attainment Network's (NCAN) highest priority in this process, and NCAN members delivered effective and powerful grassroots advocacy.

“The Senate HELP reconciliation bill affirms that the longstanding bipartisan support for Pell remains intact. We appreciate that the bill provides $10.5 billion to address the Pell shortfall and does not increase the requirement for receiving a maximum Pell Grant to 30 credit hours, a provision that would have made it harder for low-income students to afford college, said Kim Cook, NCAN CEO. “It’s imperative that Congress include these provisions if the bill advances.”

The bill also maintains the subsidized loan program for undergraduate students, another NCAN priority, does not cap federal student aid at the median cost of college program nationwide, and does not include risk sharing, which could have created a disincentive for colleges and universities to enroll students from low-income families. Instead, the bill excludes programs that produce low-earning graduates from participating in the federal student loan programs.

The Senate and House bill have some provisions in common, indicating that there is consensus in Congress on these issues and they are likely to be included if a bill moves forward. These provisions include:

• Establishing a Workforce Pell Program for short-term programs
• Excluding students with a high Student Aid Index (SAI) from receiving Pell
• Including foreign income in the Pell calculation
• Excluding small business and farm income from the aid eligibility calculation
• Streamlining federal student loan repayment options and
• Capping graduate and parent borrowing.

There are also some provisions in the Senate bill that raise questions, including:

• Eliminating some categories of non-US citizen /eligibility for federal student aid without including a grandfather clause for students who are currently enrolled. This approach could force some students to stop out abruptly because they can’t afford to complete their education and prevent others from enrolling at all
• Prorating student loans for students who are enrolled less than full-time but still have to meet their living expenses
• Excluding from Pell eligibility students who received scholarships covering the full cost of attendance, which could have an unintended effect on some low-income students, and
• Repealing the Borrower Defense and Closed School Discharge regulations, which provided help to students who had been defrauded by postsecondary education institutions.

The Committee press release states that this bill “saves taxpayers at least $300 billion.” The Congressional Budget Office (CBO) should provide a detailed breakdown of the cost associated with each provision soon, which NCAN will share with its members.

Here is a detailed table of the Senate bill in comparison with current law and the House-passed reconciliation bill. Rows in yellow represent areas of rough consensus between the two bills.

Read More: 

• CBO: 15 Credit Full-Time Estimate Costs $7.1B How Does It Impact States?
• Talking Points: Act Now to Save Pell Grants
• House Reconciliation COA Proposal Raises Questions

Reading time: Seven minutes

The House of Representatives’ reconciliation bill narrowly passed before Memorial Day and it’s now up to the Senate to respond to that bill or propose their own version. As we’ve noted, the House reconciliation bill increases the number of credits per semester required for students to receive a maximum Pell Grant from 12 to 15.

The Congressional Budget Office (CBO) “estimates that enacting this provision would reduce direct spending outlays by $7.1 billion over the 2025‑2034 period.” That’s nationwide, but this analysis examines what states stand to lose under this proposal.

The estimated $7.1 billion in outlays over 10 years (which represents a savings to the US Treasury and a cost to students pursuing postsecondary education) calculated from this provision by CBO is an underestimate for at least two reasons:

• First, CBO assumes that the maximum Pell Grant will remain the same as it is today for the coming decade even though the maximum Pell Grant has risen by about 3% annually in nominal terms over the last decade, during periods of bipartisan leadership in Congress. While the maximum Pell Grant, which is set annually by Congress, may remain the same, it may also fall, as the President proposed in his fiscal year 2026 budget, or rise to reflect inflationary increases, as it has in the recent past.
• Second, this provision will also result in discretionary savings that are impossible to estimate given currently available public information. The mandatory "add-on" funding included in CBO's score disproportionately funds Pell Grants for students from the lowest income families who are receiving the maximum award, but the distribution of credit hours that students are currently taking by award level is not available. Nevertheless, millions of students whose Pell Grants are funded largely or entirely by discretionary funds will see their awards drop if this provision is enacted, significantly increasing the savings to the US Treasury and cuts to Pell for students trying to afford college.

The table below shows states’ shares of Pell Grant recipients, their proportionate share of the $7.1 billion that CBO estimates states will lose annually and in total over the next 10 years, and the estimated number of students in the 24-29 credit range who could be impacted by this policy change. A methodology section appears at the end of this post.

The Center for American Progress also examined the potential impacts on Pell Grant recipients resulting from changes in the reconciliation bill. Dr. Sara Partridge estimates that 4.4 million Pell Grant recipients, representing “nearly two out of three recipients” who “could lose some or all their federal grant aid.” The analysis above borrows Dr. Partridge’s methodology to identify the number of Pell recipients taking 24-29 credits (“part time, formerly full time”) by state.

The National College Attainment Network (NCAN) opposes the proposal to require students to take 15 credits to receive a full time Pell Grants. Increasing the credit requirement from 12 to 15 would result in a $1,479 cut to the maximum Pell Grant of $7,395 for any student taking 12 credits, approximately a quarter of Pell recipients. Those students’ Pell award would drop to $5,916 if this bill is enacted. This proposal takes effect during the 2026-27 school year and continues for the 10 subsequent years, changing the value of student aid offers made throughout this year.

While there is evidence that students who take 15 credits per semester complete a degree faster than those who do not, millions of students are unable to do so due to work or caregiving obligations, or because taking 15 credits is too heavy a load, especially in their first semester as they adjust to college. According to the US Department of Education, 40% of full-time college students work while enrolled to afford the full cost of attendance. NCAN’s 2024 Growing Gap analysis found that the average Pell student faces an affordability gap of $1,690 and two-thirds of BA-granting institutions are not affordable for these students. 

Methodology

The table above estimates the amount of Pell Grant dollars lost and the number of Pell Grant recipients impacted by moving the definition of “full-time enrollment” to 15 credits from 12. We first estimate the share of Pell Grant recipients by state using the number of Pell Grant recipients by home state from the Office of Federal Student Aid’s “Pell End-of-Year Reports: Table 22: Distribution of Federal Pell Grant Recipients by State of Legal Residence and Control of Institution Award Year 2022-2023” and dividing each state’s total number of recipients by the national total of recipients for AY 2022-23. We multiply that resulting percentage of Pell Grant recipients by the number of students by home state by the total number of Pell Grant recipients for academic year 2024-2025 (6,852,746) from the “Aid Recipients Summary: Award Year 2024-2025 Recipient Summary.” This yields an estimated number of Pell Grant recipients by state.

To obtain an estimate of the number of Pell Grant recipients impacted specifically by the move to a 15-credit full time definition, we multiply the estimated number of Pell Grant recipients in 2024-25 by the 28.5% of Pell Grant recipients taking 24-29 credits in the 2011-12 academic year. This figure comes from the Center for American Progress’ analysis of National Center for Education Statistics, “Beginning Postsecondary Students (BPS): 2012/2017” (retrieval code ‘wjdqqk’) and data from the Integrated Postsecondary Education Data System (IPEDS). See Table 1: https://www.americanprogress.org/article/congressional-republicans-proposed-budget-reconciliation-bill-imperils-4-4-million-pell-grant-recipients/.

To obtain an estimate of the number of Pell Grant dollars lost over the period 2025-34, we multiply the calculated share of Pell Grant recipients by state by the $7.1 billion CBO estimates will be lost in direct spending outlays over this period.

Assumptions we make in this analysis include:

• National enrollment patterns by credit hour from the 2011-12 academic year are still applicable in 2024-25 nationally and across states.
• States’ shares of Pell Grant recipients in the 2022-23 award year are the same in the 2024-25 award year.

Acknowledgments

The authors are grateful to Dr. Sara Partridge at the Center for American Progress for her work in this area, from which this analysis draws sources and inspiration. The authors are also grateful to Nick Lee at Bellwether for his insight in the development of this post.

Read More:

• Judge Orders Restoration of AmeriCorps Funding in Lawsuit Challenging Grant Cancellations
• Talking Points: Act Now to Save Pell Grants
• House Reconciliation COA Proposal Raises Questions

Reading time: Two minutes

On June 5, a federal judge in a US District Court in Maryland ruled that the Corporation for National and Community Service (CNCS) violated the Administrative Procedures Act when it failed to engage in notice-and-comment rulemaking and must restore grant funding and rehire the AmeriCorps members in 24 states and the District of Columbia who were laid off per its April 25 order. At least 50 National College Attainment Network (NCAN) member organizations use AmeriCorps members to provide postsecondary advising and success services to students.

The ruling comes in a case filed in April by 24 states and DC against the Trump Administration following the abrupt cancellation of AmeriCorps grants, which impacted states, students, and NCAN member organizations across the country. The lawsuit alleged that the termination of $400 million in grants and 85% reduction in the workforce effectively halted AmeriCorps’ ability to operate volunteer service programs.

The lawsuit was filed by the attorneys general of Arizona, California, Connecticut, Colorado, Delaware, the District of Columbia, Hawaii, Illinois Maryland, Maine, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Rhode Island, Vermont, Washington, and Wisconsin, and the governors of Kentucky and Pennsylvania. Attorneys reviewing the ruling report that it appears the preliminary injunction applies not only to the termination of the plaintiff States’ grants, but to the closure of all AmeriCorps programs in those states.

Although this ruling is an important step to address the unlawful termination of programs, there is more advocacy to do to protect future funding for AmeriCorps. NCAN encourages interested members to consider participating in Save AmeriCorps District Days during the month of June led by Voices for National Service.

Shortly following the lawsuit brought by the state attorneys general, NCAN joined 14 other nonprofit organizations as a plaintiff in a related case on behalf of our members. If a preliminary injunction is also issued in that case, it will provide similar relief to AmeriCorps programs located in states not covered by the June 5 ruling. The lawsuit in which NCAN is a plaintiff is ongoing. There is a hearing scheduled for June 18.

NCAN will continue to share timely updates as this process unfolds. Please don’t hesitate to reach out to Catherine Brown, Senior Director, Policy & Advocacy, at brownc@ncan.org, with any questions. 

Read More:

• Talking Points: Act Now to Save Pell Grants
• House Reconciliation COA Proposal Raises Questions
• Skinny Budget, Big Cuts: Trump Administration Publishes Budget Request for FY26

Reading time: Two minutes

National College Attainment Network (NCAN) members, students, and friends can make a difference right now by speaking up about the transformational importance of the Pell Grant program. Below we’ve gathered some talking points for you to use with the media, K-12 and higher education partners, influential community members, and policymakers. The highlighted text below also shows where to add your own customized message. Please share widely!

• Congress is working quickly to pass a budget reconciliation bill, and Pell cuts may be on the table. At this point, the House and Senate must conference their proposals to agree on a final version of the reconciliation bill, which they are hoping to pass by July 4th.
• The House proposal would slash the Pell Grant to fund tax breaks for the wealthiest Americans—a move that would devastate the ability for millions of students to afford and complete education after high school. We strongly encourage Congress to pass the provisions as written in the Senate bill, which prevent massive cuts to Pell, and provide a $10.5 billion infusion to put the Pell Grant program on a fiscally sustainable path. 
• If Congresses passes the Pell provisions as written in the House bill, an estimated 20% of current recipients would lose access to the Pell Grant entirely.
• In total, more than 50% of Pell recipients would see their award reduced or eliminated.
• Our message to Congress: Don’t cut Pell Grant award amounts or student eligibility. 
• If enacted, this House provisions would be the biggest cut to Pell Grant eligibility in its 50+ year history.
• Each year, the Pell Grant helps nearly seven million students achieve their education and career goals. Most Pell Grant recipients come from families with annual incomes of $40,000 or less.
• In STATE/DISTRICT, XX,XXX students depend on Pell each year, to fund their choice of education after high school—whether that is an associate’s degree, a high-value credential, or a bachelor’s degree. [Find your number of Pell Grant recipients at this link.]
• Share an anecdote about how Pell cuts might impact a student working to pay for college, or one with other responsibilities at home, or who wouldn’t be able to borrow more to make up the difference.

You can stop here or find additional key facts below.

• This dangerously shortsighted bill will cause long-term harm to the education and competitiveness of the US workforce. These drastic cuts to Pell Grants could lead to double-digit declines in postsecondary enrollment, result in lower rates of US postsecondary credential and degree completion, thwart the economic mobility of millions of low-income Americans, and increase the shortage of educated workers the US economy is already experiencing.
• In fact, we need exactly the opposite federal policy: Increase Pell Grant award amounts and approve budgets with enough funding for all students who qualify under current eligibility rules.
• By 2031, 66% of good jobs will require a bachelor’s degree, 19% will require some postsecondary education, and only 15% will be available to workers with just a high school diploma.
• Pell Grants pay for themselves in just 10 years through the higher income taxes paid by more educated workers. By reducing Pell Grants, we are sacrificing future economic growth, a strong tax base, and the opportunity for more Americans to earn a family-sustaining income.
• This legislation will further erode the purchasing power of the Pell Grant, which currently covers less than one-third of the average cost of attending a public four-year college. The bill would more than double a low-income student’s unmet need at these institutions.
• The Pell Grant is the foundation of federal student aid and has garnered bipartisan support for over 50 years. It leverages billions of additional dollars in need-based aid and scholarships from states, higher education institutions, and private philanthropy. These sources will not be able to make up the dollars lost from Pell Grants under this legislation.

Questions? Please contact Catherine Brown, Senior Director, Policy and Advocacy, at brownc@ncan.org, or Louisa Woodhouse, Senior Associate, Policy and Advocacy, at woodhouse@ncan.org. 

Read More:

• House Reconciliation COA Proposal Raises Questions
• Skinny Budget, Big Cuts: Trump Administration Publishes Budget Request for FY26
• Eliminating Subsidized Loans Will Increase Undergraduate Student Debt by $6,000