One Does Not Simply Implement Policy
What will it take to make Workforce Pell a reality?
This summer, Congress expanded Pell Grants - which go to low-income students - to short-term, workforce-oriented programs as part of the One Big Beautiful Bill Act, and today, the Department of Ed started its rulemaking process for Workforce Pell (WFP). The whole story of WFP is interesting to me in that:
It’s a proposal that has been around for quite some time,
It became bipartisan (which is pretty rare in these circumstances), even though
A whole lot of people still hate it, in spite of pretty strict quality controls in the law, and
It is going to end up being one of the more complicated policies to implement.
While all of the politics and questions around the policy itself are noteworthy, I have to say that I am (maybe not surprisingly) most interested in how states are going to navigate the implementation of this thing. While the Pell Grant program and the associated student and program rules are largely grounded in ED’s policy lane, many of the definitions and decisionmaking structures are based in Department of Labor policies, including the Workforce Innovation and Opportunity Act. There are a lot of things the federal government could be better at, but perhaps the biggest is interagency coordination. And given the um, significant staffing reductions across most agencies, I keep wondering what the coordination between ED and Labor is on this thing. But that’s just the tip of the iceberg. Once we get out of the federal level and into states, there are so so so many entities that are going to be involved, the implementation person in me can’t help but echo Boromir in thinking, “One does not simply implement Workforce Pell.”
In the implementation of complex policies - especially ones where there are so many powerful and opinionated stakeholders - sometimes the most mundane factors can have a huge impact on an initiative’s success. Take, for example, the project I managed at FSA, where we needed to make new loan servicing contract awards to keep the repayment system up and running (and also try to, you know, address some intractable problems at the same time). The effort had failed 4-6 times before I took it on, depending on how you count.12 And one of the major reasons that it failed over and over again was because Congress kept amending FSA’s appropriations language (basically the parameters it draws around how FSA spends the money it gets from Congress) to make it so they couldn’t do the procurement effort that FSA intended to do. And that happened because the former president of MOHELA had buddied up to Roy Blunt, who was for a long time the Republican chair of the Senate Appropriations Committee.3 And when it came time each year for the approps bill to come out, MOHELA got to provide pretty substantial input, and MOHELA really didn’t like the way FSA was conceiving of the new servicing system, so they kept adding language that shut FSA’s latest strategy down. In hindsight, I think MOHELA was right, that FSA was trying to do too much too fast, and that ultimately, many of those efforts wouldn’t have been successful. But this demonstrates how much factors that exist totally outside of a policy’s language can influence its outcome.
And I think the mundane will definitely create a whole bunch of stumbles - if not all out brawls - here. We have governors, employers, workforce development boards, public/private/for-profit colleges, state legislatures, data providers, higher education coordinating boards, licensing bodies, accreditors, faculty, labor unions, and more holding a piece of the puzzle on WFP, with a truly mind-boggling configuration of operational and political structures across 50 states. So while the DC lot are focusing on some of the more wonky questions around this thing, my inclination is to think more about the players, personalities, and “little p” policies and politics that states will have to navigate.
To that end, I wrote a blog post over on Bellwether’s site today on this very topic. I mentioned in a previous post that I love working at Bellwether because we offer a wide variety of services - from strategic planning to financial modeling to convenings to implementation support to quantitative and qualitative evaluations (and more!) - across all of education. But we also don’t take organizational positions, which lets us take a step back and really consider how to make just about any approach successful in service of students, who are at the core of our mission. It’s nice to approach WFP from a place of possibility, and I’m seeing a lot of connections between how this policy could evolve and some of the intractable issues we see in higher ed and career training. But that’s a few years out, and for now, it will be interesting to see how states navigate this thing in the coming weeks and years. I won’t be doing a ton of cross-posting like this, but I thought there was a nice synergy between what I do here and what I just published over there, so check it out if you have a chance.
That’s it for today. I have a bunch of half-written things in the hopper for On Detail, so stay tuned to your inbox for more soon (including a post on the professional degree loan limits that have been making so much noise on social media).
Until then, I appreciate you!
There was the Obama effort (1), which Trump 1 revised to oblivion (2?), then that was cancelled and the first Next Gen was announced and included 2 different systems (so is that one failure or two?), then those all got pulled down in favor of the BPO/EPS/OPS scheme (and we could say BOTH EPS and OPS failed), then ISS, then USDS. So 4. Or 6. I’ll let you decide.
I appreciate the prior footnote means nothing to anyone save about 100 people on the planet. One day I’ll write a whole history of how those various procurement efforts went down, but that’s probably more like a book…
I don’t mean for this to sound nefarious - it’s smart government relations, and Ray was a fantastic leader who very much cared about doing the right thing for borrowers. He would even take calls with borrowers and required his senior staff to do the same.