Update on Workforce Pell and Course Materials

The Department of Education published its final Workforce Pell Grant regulations on May 19, 2026. The program extends federal Pell Grant eligibility to short-term training programs for the first time, opening a new source of federal financial aid for students pursuing certain workforce credentials.

In April, the Open Education Association filed a public comment identifying a gap in how the Department addressed the cost of books and supplies in its proposed rule. Workforce Pell includes an accountability requirement called the value-added earnings test, which compares each eligible program's tuition and fees against the expected earnings of its graduates to assess whether the earnings gains justify the cost. The proposed rule left ambiguous whether course material costs billed directly to students through Inclusive Access and similar programs would count toward that cap.

In the preamble to the final rule, the Department responded directly, clarifying that books and supplies count toward a program's tuition and fees when students lack a "real and reasonable" opportunity to purchase them elsewhere, or when they are bundled into institutional charges. This ensures that institutions that automatically bill the cost of course materials to students are held accountable for those costs through the value-added earnings test.

“Any costs for an eligible workforce program that would be considered part of tuition and fees, or other institutional charges (including books and supplies in certain circumstances) will be included in the amounts of tuition and fees that are subject to the value-added earnings cap on tuition and fees. Costs for books, supplies, or other course-related materials are subject to the cap if students lack a “real and reasonable” opportunity to purchase them elsewhere, or if they are bundled into tuition, because these costs are considered institutional charges.” — 91 FR 29254

This distinction matters for institutions deciding how to build their programs. With open educational resources, course material costs disappear entirely. With automatic textbook billing, institutions are held accountable for the real cost to students. Institutions that lock in commercial material costs now may find themselves squeezed between rising publisher prices and a tuition cap they cannot exceed without losing Pell eligibility. Institutions that choose OER eliminate that risk at the source.

Openly licensed materials for many of the fields these programs serve already exist and are freely available. SkillsCommons.org hosts a large collection of workforce-specific OER in healthcare, manufacturing, skilled trades, and more. Institutions building eligible workforce programs can adopt and adapt them today.