How State LMI Agencies Can Become Essential Partners Under Workforce Pell

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Workforce Pell is about to change the operating environment for short-term workforce programs in higher education. LMI agencies need to be at the center of that change.

Universities and community colleges are preparing to launch or scale programs that meet new federal performance thresholds tied to completion, job placement, occupational alignment, and earnings. As they do, they face a critical question: Do we have the data infrastructure to qualify and stay eligible?

For state LMI agencies, this moment presents a strategic opportunity. Institutions cannot meet Workforce Pell requirements using campus systems alone. Much of the data needed to qualify and maintain eligibility lives inside state workforce data systems.

LMI agencies should seek to move from being viewed as data providers to engaging as core infrastructure partners in Workforce Pell implementation.

Why Institutions Need You

Workforce Pell eligibility depends on:

  • Demonstrating strong completion rates
  • Verifying employment in the second quarter after exit
  • Aligning programs with state-defined in-demand occupations
  • Showing earnings outcomes that justify tuition and fees
  • Maintaining ongoing reporting capacity

Governors or their designees certify eligible programs, but institutions must supply the evidence. To do so, they need access to unemployment insurance wage records, official occupational projections, recognized methods to benchmark wages, and an independent assessment of regional labor demand.

If your LMI agency wants to increase its relevance to higher education under Workforce Pell, focus on five areas.
  1. Make Wage Record Matching Accessible

Employment verification is foundational. Institutions must show that graduates are employed in the second quarter after exit and track earnings over time.

LMI agencies can:

  • Offer standardized wage record matching services
  • Develop clear timelines and service-level expectations
  • Produce aggregated outcome reports that institutions can rely on
  • Create secure, repeatable data-sharing processes

For many institutions, especially those offering short-term and noncredit programs, this is the single most important partnership.

If wage matching feels complex or opaque, universities will struggle. If it feels structured and predictable, they will find your agency indispensable.

  1. Lead the Definition of “In-Demand”

Workforce Pell requires programs to align with occupations the state identifies as high-skill, high-wage, or in demand. This is definitely in the LMI agency’s wheelhouse.

Tapping occupational projections, high demand industries, useful SOC-CIP crosswalks, and relevant wage and employment trends, LMI agencies can be a “go-to” resource.

To become indispensable:

  • Publish clear, transparent in-demand occupation frameworks
  • Provide guidance on mapping academic programs to SOC codes
  • Offer technical assistance sessions for institutions
  • Supply standardized demand documentation templates

When colleges and universities design new credentials, they should begin with your data.

  1. Help Institutions Navigate Earnings Tests

Workforce Pell introduces earnings-based cost considerations. Programs must demonstrate that participant earnings justify tuition levels.

Because LMI agencies should consider how they can help

  • Provide regional median wage benchmarks
  • Adjust for geographic variation
  • Supply occupation-level earnings distributions
  • Offer scenario modeling for emerging industries

The focus at first will be on strategic program planning. Institutions deciding whether to launch or expand short-term credentials need wage intelligence early, not after a program fails an earnings threshold.

  1. Clarify Data Limitations Before They Become Problems

We all know that UI wage records do not capture data about the self-employed individuals, federal workers, military personnel, or certain gig workers.

Let’s not try to oversell LMI. LMI agencies should:

  • Clearly communicate coverage gaps
  • Provide interpretive guidance
  • Recommend supplemental data sources when possible
  • Help institutions avoid misclassifying strong programs as underperforming

You are uniquely positioned to explain what the data shows—and what it does not.

  1. Build Durable Governance, Not One-Off Reports

Workforce Pell is not a one-time certification. It is an ongoing accountability system.

Institutions will need repeatable reporting cycles. Governors and their workforce boards will require consistent documentation. Federal aid systems will continue to evolve.

LMI agencies can position themselves as long-term partners by:

  • Establishing formal data-sharing agreements
  • Participating in state workforce data governance discussions
  • Creating joint dashboards with higher education agencies
  • Embedding LMI economists in program planning and review processes

This shifts the relationship from transactional to strategic.

Why This Matters for LMI Agencies

Workforce Pell elevates the importance of labor market data in higher education decision-making. For LMI agencies, this represents an opportunity to:

  • Increase visibility with higher education leadership
  • Improve alignment between workforce and higher education systems
  • Demonstrate the applied value of state labor market analysis
  • Embed LMI expertise in regional economic development strategy

Colleges and universities are being asked to demonstrate measurable labor market return. You provide the data that makes that possible. As you offer these additional services and products, consider cost recovery and don’t save it until the end of the conversation.

A Strategic Play for LMI Leaders

If you want to become essential to institutions leveraging Workforce Pell:

  1. Convene a briefing for higher education leaders explaining Workforce Pell data requirements.
  2. Publish a clear “LMI Support Menu” outlining available wage matching, projections, and analytical services.
  3. Create a simple occupational crosswalk toolkit for institutions.
  4. Offer structured consultation for institutions developing new short-term credentials.
  5. Coordinate with governors’ offices, state workforce boards, and higher education leadership to ensure consistent definitions and documentation standards.

The institutions that succeed under Workforce Pell will rely heavily on state data systems. LMI agencies that act early will not just support compliance, they can become central to how Workforce Pell strengthens regional competitiveness and supports worker engagement with higher education.

By taking leadership now, LMI agencies can ensure they remain at the center of the state’s critical workforce policy decisions and gain the credibility needed to sustain ongoing state support for LMI.