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.

Workforce Pell and 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.”

Scope of HLC Accreditation

HLC accreditation extends to all of an institution’s educational programs. This could include educational programs that are not degree programs, such as certificate programs. It also includes educational programs that are measured in clock hours (clock hour programs), which are sometimes called “non-credit.” 

The scope of an institution’s HLC accreditation does not extend to offerings that are not educational programs.

Because programs that could be eligible workforce programs for purposes of Workforce Pell are necessarily undergraduate educational programs measured in clock hours or credit hours, they would be within the scope of an institution’s HLC accreditation, and are subject to HLC’s usual substantive change processes as applicable.

How to Demonstrate an Undergraduate Certificate Program Is Included in an Institution’s Scope 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 complete the certificate program screening form to notify HLC of the program and determine if an application is required, if it hasn’t done so already.
   
   The regulations related to Workforce Pell require that an educational program must be operating for at least 12 months prior to qualifying as an eligible workforce program. Because the certificate 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 prior to initiating the new certificate program. If an institution is currently offering a certificate program that it now intends to be an eligible workforce program in the future and it has not previously notified HLC of the certificate program, it should complete the certificate screening form.
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 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)
  • Contractual arrangements (25% or less outsourced to the other party)
  • 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.