Thanks to the One Big Beautiful Bill Act becoming law this summer, workforce Pell is now a reality and federal aid dollars are expected to flow to low-income students in short-term programs as soon as next July.

But now comes the hard work of figuring out which programs are eligible—and some states aren’t ready, according to a new report from the State Noncredit Data Project, which helps community college systems track data related to noncredit programs. Not all states collect the data needed to make that determination, and some offer programs that wouldn’t make the cut, the report concluded.

Under the legislation, short-term programs need to meet certain requirements to qualify for Pell money. For example, state governors need to verify they align with high-skill, high-wage or in-demand jobs. Programs also must be able to build toward a credit-bearing certificate or degree program and be “stackable and portable across more than one employer” unless preparing students for jobs with just one recognized credential. They have to exist for at least a year and meet outcomes goals, including completion and job-placement rates of at least 70 percent. And programs can’t charge tuition higher than graduates’ median “value-added earnings,” or the degree to which their income exceeds 150 percent of the federal poverty line three years out of the program.

But some states collect more data than others on community colleges’ noncredit education, which encompasses many of the programs likely to qualify for workforce Pell, according to the report. It based its findings on course and program-level data from eight states: Iowa, Louisiana, Maryland, New Jersey, Oregon, South Carolina, Tennessee and Virginia.

“What we’re going to see is varying degrees of difficulty” for different states, said co-author Mark D’Amico, a higher education professor at University of North Carolina at Charlotte. “States that have more robust data on noncredit community college education are going to be at a little bit of an advantage.”

The report found that most states track basic metrics such as the length of a program. But two out of the eight states had no state-level data on noncredit credential outcomes. Half of the states didn’t collect any data on labor market outcomes like earnings and employment rates. And multiple states didn’t keep track of whether students completed credentials or went on to pursue credit-bearing programs. The report emphasized that while individual institutions might have more detailed data on their programs, gaps in statewide data could create challenges as states work with institutions to prove their programs’ eligibility for workforce Pell.

“Most states have some of the fundamental data,” D’Amico said, “but I think when it comes to the credentials’ labor market outcomes, completion, stackability, those are going to be a little bit more difficult to identify.”

The report predicted that some states, like Iowa, Louisiana and Virginia, may have an easier time proving which programs meet the criteria because they already have state funding for noncredit programs that requires colleges to report relevant data. For example, Iowa includes noncredit education in its state funding formula for workforce training programs, and Louisiana has a state scholarship for such programs.

Co-author Michelle Van Noy, director of the Education and Employment Research Center at Rutgers University, said states’ data infrastructure for noncredit programs is still a “work in progress,” but she’s seen “quite a progression” in recent years. She’s optimistic they’ll continue to improve.

“It is my hope that Workforce Pell implementation can be done in a way that will support the broader development of data and quality systems for noncredit education and nondegree credentials within states,” Van Noy wrote in an email to Inside Higher Ed.

But data isn’t the only issue. The report also found that typical noncredit programs weren’t necessarily long enough to meet the standards for workforce Pell. Except for lengthier workforce programs at the Tennessee Colleges of Applied Technology, the median number of hours for occupational training programs ranged from 15 hours in New Jersey to 100 hours in Virginia, falling short of the 150-hour, eight-week threshold. Institutions could group their courses into longer programs in the coming months. But it’s not yet clear if making such a change would affect the requirement that programs exist for at least a year.

“Anyone that may be thinking that all of a sudden, all noncredit programs are going to be eligible, the data show that’s not the case,” D’Amico said. “We’ll see what happens over time.”

The report offered a set of recommendations for how states can ready themselves for workforce Pell. For example, it urged state officials to take stock of which metrics they still need to collect to fall in line with the policy’s guardrails and encouraged state and college officials to work together to start identifying programs that could be eligible. The report also suggested colleges consider reconfiguring programs so noncredit offerings serve as on-ramps to credit-bearing programs and meet other structural requirements.

Further details about how workforce Pell will work are going to be hashed out in a negotiated rule-making process this fall, but D’Amico said states shouldn’t wait for that.

“I would use the guardrails now, use the data that they have now, to begin to do that pre-identification” so they have “a little bit of time to begin to fill some of those gaps in existing data,” D’Amico said.

He also hopes states’ preparation for workforce Pell pushes forward “a larger conversation” they’re already having about the quality of short-term noncredit programs over all.

The overarching goal is “ensuring that noncredit programs are designed well, have credentials associated with them linked to further education and are really designed in a way that’s going to be beneficial to students and ultimately help the local and state economies that these programs are going to serve,” D’Amico said.