Understanding the Federal Implications of House Resolution 1

What changed under House Resolution 1 (H.R.1)

• What is H.R.1? HR1 is a major federal higher education and workforce policy package that restructures several student focused programs, updates reporting requirements, and introduces new accountability measures for institutions. It changes how student financing, workforce programs, and outcomes reporting are defined and evaluated at the federal level.
• Why does it matter for Colorado? These changes affect how Colorado students access aid, the data institutions must report, and how programs are evaluated. H.R.1 also introduces new measures tied to program value and workforce outcomes, which may influence institutional planning and program design.
• Purpose of this information: This page summarizes the elements of H.R.1 most relevant to Colorado institutions of higher education from a state policy perspective. It highlights anticipated impacts on academic programs, students, and data reporting obligations so institutions can prepare for implementation and anticipate the impacts of the changes.
• View a recording of CDHE’s April 15, 2026 overview of the implantation and impacts of H.R.1
  • Link to presentation slides
  • HR1 Institutional Data Discussion: April 15 Breakout Notes and Q&A - Google Docs

Current Status: Final rules

Last Updated Aug 17, 2026 

Where things stand: H.R.1 requires federal agencies to develop detailed rules before the law can be fully implemented. The U.S. Department of Education has moved through negotiated rulemaking, proposed rules, and public comment periods and have issued final rules for Earnings Premium, Workforce Pell, and Student Loans.

Colorado’s approach: Colorado agencies, including CDHE and partner state entities, are actively monitoring rulemaking, coordinating across state systems, and soliciting feedback to the federal government. The state is focused on ensuring that implementation supports Colorado students and minimizes unnecessary administrative burden for institutions.

Visit the U.S. Department of Education for the latest updates on the rulemaking progress. 

Earnings Premium (Accountability)
H.R.1 introduces a federal “earnings premium” indicator designed to show whether program graduates earn more than individuals in the state with only a high school diploma. This earnings premium is the new accountability measure for program eligibility for federal loans. The earnings premium aligns and consolidates previous Gainful Employment (GE) and Financial Value Transparency (FVT) regulations around a single earnings test. This earnings test applies to all certificate and degree (undergraduate and graduate) programs. Programs failing to meet the earnings premium in two out of three years is considered a “low-earning program” and students in these programs lose eligibility for federal loans. 

At institutions with more than half of their Title IV recipients (students) in “low-earning” programs and more than half of their Title IV-funding volume ($ amount) in “low-earning” programs, the institution’s “low-earning programs” will lose eligibility to participate in all Title IV funds (including Pell).

National Resources

• The U.S Department of Education released final rules

  • The National Association of Student Financial Aid Administrators (NASFAA) comparison of STATS to GE/FVT regulations.
  • U.S. Department of Education (USED) Implementation Resources
    • Timeline for implementation
    • Discussion guide on Student Tuition & Transparency System (STATS) (data to be used in earnings premium calculations)
    • Negotiated Rulemaking Documentation
  • National Analyses after Negotiated Rulemaking Consensus
    • The Institute for College Access & Success (TICAS)
    • EdTrust
    • The National Association of Student Financial Aid Administrators (NASFAA)
    • National Association for the Education of Young Children (naeyc) 
  • National Analyses after Final Rules
    • Nixon Peabody 
  • National Resources after Final Rules
    1. Department of Education/Federal Student Aid Guidance on FVT/GE data reporting & STATS early implementation
    2. AIR FVT/GE and STATS Reporting Checklist
    3. AIR Guide to Federal Earnings Data
  • Continuously Updated Resources
    • The National Association of Student Financial Aid Administrators (NASFAA) 

  Colorado Resources 

  • CDHE is developing Colorado‑specific analyses to help institutions understand how the earnings premium is calculated and how programs may be affected. Links will be provided here to the Colorado report, explanatory blog post and any accompanying datasets as they are released.
  • PEER (2026) Data (Analysis of Colorado Programs) is available here. To learn more about the PEER Center, visit their website here.

   

  Workforce Pell

  Update (August 2026): The Workforce Pell application window has been extended through Friday, August 21, 2026, to provide institutions additional time to assess program eligibility, review data requirements, and complete applications.
   

• The federal Workforce Pell Grant program, established through H.R. 1, expands Pell Grant eligibility to approved short-term workforce training programs that prepare students for high-wage, high-skill, and in-demand careers. Eligible programs must meet federal requirements related to program length, completion, employment outcomes, and earnings.

  Colorado is preparing for implementation, led by the Governor's Office in partnership with the Colorado Department of Higher Education (CDHE), the Colorado Workforce Development Council (CWDC), and other state agencies.

  For Institutions

  Under the direction of the task force, CDHE conducted an initial review of publicly available institutional and workforce data to identify programs that may be eligible for Workforce Pell. Based on the preliminary analysis, some programs appeared to meet the requirements for job placement, completion rate, earnings outcomes, program length (150-599 clock hours), and alignment with eligible occupations. Other programs appeared to meet requirements for job placement, earnings outcomes, program length (150-599 clock hours), and alignment with eligible occupations, but did not appear to meet the required completion rate based on the available data. CDHE notified institutions of the programs identified in each category to support their review of potential Workforce Pell eligibility. 

  Because the state's analysis relied on publicly available SURDS data and preliminary calculations, institutions are encouraged to review their own data and apply if they believe their programs meet all eligibility requirements. 

  Application Process

  Colorado will use the Eligible Training Provider List (ETPL) as the application platform for Workforce Pell certification.

  Application Deadline: August 21, 2026
  Apply: coloradoetpl.org

  Submitting an application does not guarantee certification. Institutions must demonstrate compliance with all federal and state requirements through the review process.

  Available Support

  • Institutional Readiness Checklist 
  • Colorado Workforce Pell website (FAQs, guidance, webinar recordings, and updates)
  • Colorado Resources
  • Colorado Workforce Pell Website
  • Institutional Readiness Checklist
  • National Resources
  • U.S. Department of Education
  • Workforce Pell Final Rules
  • Overview Following Negotiated Rulemaking Consensus
  • Negotiated Rulemaking Documentation

  • GAO Review of Final Rules

    National Organizations

  • Association for Career and Technical Education (ACTE)
  • National Association of Student Financial Aid Administrators (NASFAA)
  • EdTrust
  • Online and Professional Education Association

  • National Governors Association

    Additional Resource Pages

  • NASFAA Workforce Pell Resources
  • EdTrust Workforce Pell Resources

   

  ETPL and Workforce Pell FAQs

  What PII does the State collect through the ETPL for Workforce Pell? 

  The State collects Social Security numbers (SSNs) for program participants for Program Years 2024 and 2025. SSNs are used to match participants to state administrative records and verify required Workforce Pell outcomes, including program completion and job placement. 

  Will the State share SSNs or other personally identifiable information (PII) with the federal government as part of the Workforce Pell program?

  No. The State does not submit student-level PII to the federal government as part of the Workforce Pell state certification process. The State may use PII from state data systems to verify required outcomes, such as completion and job placement. 

  For programs that are pursuing Workforce Pell only, student-level data submitted through the ETPL application platform will not be transmitted to the federal government as part of the State’s Workforce Pell certification. After a program receives state certification, the institution will receive the Governor’s completed state certification form and will be responsible for submitting the required Workforce Pell application and certification materials directly to the U.S. Department of Education through the federal E-app process for federal approval. 

  The Workforce Pell application window has been extended through Friday, August 21. 

   

  • Questions?

    Contact the Workforce Pell Implementation Team at wfpell@state.co.us.