On May 19, 2026, the U.S. Department of Education (ED) published final regulations related to various matters, including the expansion of the Title IV Pell Grant program to include a new type of eligible undergraduate educational program called an “eligible workforce program.” This program, commonly referred to as “Workforce Pell,” was initiated as part of the One Big Beautiful Bill Act that Congress passed in July 2025. The regulations will be effective July 1, 2026.

Workforce Pell eligibility is determined by ED, with significant involvement from individual states. Workforce Pell is only available to eligible institutions of higher education, as defined under federal regulations. HLC member institutions that hold candidate or accredited status generally meet this requirement.

How to Demonstrate an Undergraduate Certificate Program Is Included in an Institution’s Scope of Accreditation

The regulations themselves do not contain language specific to accreditors. However, in the preamble to the regulations, ED indicates that an “institution must be able to demonstrate that each [educational] program (including eligible workforce programs, collectively or individually) is formally accredited and included within its grant of accreditation.”

Eligible workforce programs will typically be undergraduate certificate programs. An institution that needs to demonstrate that an undergraduate certificate program that it may intend to be an eligible workforce program is included within its scope of accreditation should follow HLC’s notification and approval process for educational programs.

1. An institution should start this process by completing the certificate program screening form to notify HLC of a certificate program and determine if an application is required.
   
   The regulations require that an educational program must be operating for at least 12 months prior to qualifying as an eligible workforce program. Because the screening form relates to the educational program itself, regardless of whether the educational program will be an eligible workforce program, an institution should complete the screening form at the time that it initiates the program or shortly thereafter.
2. An institution will then request an official letter from HLC when it needs to demonstrate that an educational program is included within its scope of accreditation.

Things to Keep in Mind

• If a certificate program is measured in clock hours or credit hours, ED requires that it be included within the institution’s grant of accreditation. Programs offered by an institution that are not offered in clock hours or credit are not educational programs and are not within the scope of an institution’s accreditation. As such, they do not require HLC notification or approval. 
• If your institution is splitting an educational program into two smaller programs, this activity results in creating two new programs. An institution should complete the certificate program screening form twice in this instance.
• After completing the certificate program screening form, should the institution be required to seek approval, remember that HLC will charge a single desk review fee for every 10 applications submitted at the same time.
• If your institution decides to assign clock or credit hours to a program that was not previously measured in clock or credit hours, this activity results in creating a new educational program. An institution should complete the certificate program screening form in this instance.
• Program changes made by the institution may trigger other substantive change implications that may also require notification or approval through HLC’s substantive change processes, such as:
  • Locations (not in relation to study abroad)
  • Aggregate change of 25% or more in content of the program
  • Changing credit to clock or clock to credit hours (only if the change occurs after the program initiation)
  • Mission
  • Modality (not related to correspondence education or direct assessment)
  • New program level (if the institution is not currently offering undergraduate programs)
  • Teach out

Additional Guidelines Coming Soon

HLC is developing additional guidelines for institutions regarding how to demonstrate compliance with HLC requirements, including the Criteria for Accreditation, in the context of certificate programs, particularly certificate programs that are intended to be eligible workforce programs.

Questions? 

Contact your institution’s HLC staff liaison.