Workforce Pell Program Monitoring and Review

All required data elements must be submitted using Committee-approved reporting templates (e.g., Excel or CSV formats), with defined data dictionaries and field-level instructions. This will include:

• Data Definitions and Methodology: Institutions must calculate and report metrics (e.g., enrollment, completion, job placement rates) in accordance with Committee-defined methodologies to ensure uniformity.
• File Naming and Version Control: Submissions must follow standardized file naming conventions that include institution name, program identifier and reporting period.
• Data Validation Checks: Prior to submission, institutions must conduct internal validation to confirm:
  • Completeness of required fields
  • Accuracy of calculations
  • Consistency across data elements (e.g., enrollment vs. completion counts)

All data must be transmitted through secure, Committee-approved systems in accordance with data security policies.

Each institution must maintain a clear and accessible audit trail to support all reported data and program outcomes. All supporting documentation must be retained for a minimum of six years following the end of the reporting period. Institutions must make all records available upon request for review by the Committee, New York State agencies or federal oversight entities.

At a minimum, institutions are recommended to:

• Retain all underlying records used to compile reported data where available, including:
  • Enrollment records
  • Attendance and completion documentation
  • Employment placement verification (e.g., employer confirmations, wage records where available)
  • Financial records related to tuition and fees
• Document Data Processes: Maintain written procedures describing how data are collected, validated, and reported, including roles and responsibilities of staff involved in data management.
• Track Data Revisions: Maintain version histories for all submitted reports, including documentation of any corrections, updates, or resubmissions.

A Governor’s approval automatically expires with the expiration of the eligible institution’s Program Participation Agreement.

Each institution will also be required to report to the US Education Secretary the published tuition and fees for the workforce program.

The Governor or Committee may for any reason, which must be stated and is subject to appeal and final determination:

• Issue a notice of concern outlining identified issues, supporting evidence and required response
• Place a program on probationary status
• Restrict or suspend new enrollments during a probation or corrective action period
• Require corrective action, for example, with a 90-day corrective action window which would include measurable benchmarks and timelines
• Revoke certification
• Impose enhanced monitoring and reporting requirements

Complaints about a program may be submitted directly to the issuing institution or to the Committee. The Committee will make every effort to address concerns and take necessary action in a timely manner, including taking the actions outlined above.

Program review and potential adverse action may be initiated based on one or more of the following:

• Credible allegations or findings of fraud, misrepresentation, or false certification
• Failure to meet established thresholds for program completion or job placement rates
• Failure to submit required reports or data in a timely, complete, and accurate manner
• Material inconsistencies or discrepancies in reported data
• Misleading marketing or inaccurate disclosure of program outcomes or costs
• Noncompliance with federal, state or institution’s own policies and regulations
• Substantiated complaints from students, employers, staff, or the public
• Patterns of complaints indicating systemic issues with program quality, delivery, or outcomes

The Committee will make all efforts to support students currently enrolled. In the event of probation, corrective action, or revocation, campuses will be required to have a plan that includes:

• Student Notification
  • Provide timely, clear, and written communication to all affected students regarding program status, potential impacts and available options
• Teach-Out Plans
  • Develop and implement a committee-approved teach-out plan that allows currently enrolled students to complete the program within a reasonable timeframe; or transition to a comparable program at the same or another institution.
• Transfer and Academic Support
  • Provide academic advising and transfer assistance, including articulation where feasible
  • Ensure recognition of completed coursework or competencies
• Financial Protections
  • Clearly disclose any financial implications to students
  • Where applicable, provide refunds, tuition adjustments, or financial aid guidance in accordance with institutional, state, and federal policies

Under regulation, if a program loses eligibility because it fails to meet completion rate or job placement rate requirements, or if it voluntarily discontinues a failing eligible workforce program, the eligible institution is prohibited from reestablishing that program’s eligibility or creating a substantially similar program with the same four-digit CIP code and leads to employment in occupations with identical SOC codes for two years following the date the program lost eligibility or the date the eligible institution voluntarily discontinues the failing workforce program, whichever comes earlier.

Institutions may also voluntarily withdraw an eligible program from Workforce Pell at any time for any reason (beyond failing performance metrics) without waiting for an official state evaluation.

Additionally, a program will become ineligible at the end of the payment period that begins following the date that the Governor acts to withdraw approval or the Governor fails to reapprove the program.

Institutions should notify the Committee immediately of their decision to discontinue any program due to the above reasons. All related program eligibility and discontinuances will be listed on the Governor’s website.