A new federal metric asks for proof over years. Most programs are filling out the forms with a spreadsheet.

What the rule asks a program to prove, in its own words

The Department’s final rule, on public inspection May 18, 2026 and published in the Federal Register on May 19, 2026 (document 2026-10013), sets an eligible workforce program at 150 to 599 clock hours, or the credit-hour equivalent, at least 8 but less than 15 weeks of instructional time, approved by a Governor and the Secretary. Approval is not a one-time event: the program must meet completion and job placement rate requirements prior to approval and every year afterward, and an institution must report to the Governor the students who completed the program in each award year, verify the job placement rate, and report its published tuition and fees. A program’s tuition and fees may not exceed the “value-added earnings” of its completers who are working: the difference between their adjusted median earnings and 150 percent of the federal poverty guideline for a single individual, published by the Secretary each year (the Federal Register rule text). The Department’s own release states the requirement plainly: programs must “meet certain time and length requirements, completion percentages, and employment metrics, and prove they deliver a real return on investment for students as shown by data” (the Department’s release).

Read plainly, this is a data requirement with a named subject: which learners completed, whether they were hired, and what they earn, tracked by learner across the years a program stays approved. A spreadsheet can hold those numbers. It cannot show a Governor, the Secretary, or an employer where any one number came from, or let anyone outside the program check a single row without calling.

What a learner-held record adds

A record the learner holds does not replace the reporting a program owes the Governor or the Secretary. What it adds is a row, for each learner, that outlives the program’s own spreadsheet: a dated, witnessed entry for the hours completed, the credential earned, or the placement reached, sealed so its contents cannot change afterward, and verifiable by anyone at a public link with no account. “Completed the program” becomes a course row an instructor co-signed from an emailed link. “Got hired” becomes a job entry the employer can be asked to witness. Each of these carries a fact about how far the signer’s identity was checked, so a reader outside the program can tell an email address from a checked institutional one.

Because the learner holds the record and not the program, the same evidence follows a learner who takes a second short-term program, moves employers, or applies to a Registered Apprenticeship after a pre-apprenticeship, the exact path America’s Talent Strategy describes: pathways into apprenticeship aligned with “career and technical education (CTE) programs of study, youth-serving WIOA career pathways, pre-apprenticeships, and Registered Apprenticeships,” with an example that “employers could work directly with school systems and community colleges to create dual-enrollment programs that lead to an apprenticeship or job immediately after high school” (America’s Talent Strategy, page 13). A learner who carries a witnessed record across that path arrives at the next program, or the next employer, with completions an outside reader can check, not a claim the new program has to take on faith. An employer verifies the record directly, without asking the first program to vouch for it again. The same plan states the goal for how a credential gets weighed: “Credentials will be judged based on their real value in the labor market, and ineffective training providers will be removed from public funding lists” (the same report, page 9). What that requires is exactly what a witnessed, dated record produces: an evaluation grounded in who did what, not in the provider’s own account of it. More on how hours, sign-offs, and certifications are recorded today is on the record for the trades.

The interoperability path: reading the record through a provider’s own system

No provider or sponsor has to adopt a new system end to end to use a learner-held record. Chapter 11 of the specification maps a transcript, a course row, and a witness attestation, field by field, onto the W3C Verifiable Credentials Data Model 2.0, Open Badges 3.0, and the Comprehensive Learner Record 2.0, three formats a learner-record system is likely to already read. Every exported credential must link its verify URL, its receipt id and hash, and its proof URL, so a system that imports it can always point back at the source, and an export may carry no more than the public verify page shows unless the learner adds more. The bridge export that would emit these documents is planned, not built, and the chapter says so; this is the same honesty the chapter states about itself, not a claim of a working integration today. The full mapping is published at eformogi.com/spec/interop, and a provider’s engineering team can read it without contacting us.

A federal grant now names this kind of record

America’s Talent Strategy says future Perkins Innovation and Modernization grant competitions “will focus on further education and workforce alignment, including integrating apprenticeships and advancing innovation in CTE, such as advancing new models of work-based learning, learning and employment records, and skills- and competency-based education and hiring efforts” (the report, pages 14 to 15). Perkins Innovation and Modernization grants fund state agencies and eligible institutions, not a company like ours directly; whether or how a future competition could support an issuer’s onboarding onto a learner-held record is a question for the state agency or institution applying, not a claim this page makes. What the report states, in its own words, is that the federal funding stream meant to modernize CTE now names learning and employment records as one of the models it wants to advance. That is the fact; nothing here says a grant has funded, or will fund, Eformogi or any provider reading this page.

What this page does not claim

• It does not say the Department has reviewed or approved anything here. The rule and the strategy paper are quoted for what they say about eligible programs, evidence, and grant priorities; neither mentions Eformogi.
• It does not promise grant funding. Perkins Innovation and Modernization grants are competed for by state agencies and eligible institutions under terms the Department sets; this page states what the strategy paper says the program is for, and stops there.
• It is not legal advice. How a program structures its Workforce Pell application, or how a sponsor structures an issuing agreement, is a question for its lawyer, and ours.

Frequently asked questions

The metric is a lens, and the learner holds the record

A completion rate, a placement rate, a value-added earnings figure: each is a rule that reads a set of facts and produces a number a Governor or a Secretary can compare across programs. The rule will change; Workforce Pell’s own regulations are new this year and the figures the Secretary publishes change annually. What should not change underneath every version of that rule is the record of who did what, witnessed by whom, and checkable by anyone. That is why the format is published at eformogi.com/spec under a license anyone may implement, and why the learner holds the record and takes it with them from one program to the next, through every metric a future rule adds. The promises behind that are written down in the sovereignty contract.

A BOCES center or a district CTE program waits for the founder’s district approval and the counsel memo before any agreement; a union training center, an employer sponsor, or a private provider can start with a letter to hello@eformogi.com. The price list is on the pricing page.

What a receiver sees at one link

See also: a record for the trades · the Portrait page · how a program issues on the record · the interoperability chapter