In June 2017, President Donald J. Trump signed an Executive Order (EO) on Expanding Apprenticeships in America. Section 4 of the EO, entitled Establishing Industry-Recognized Apprenticeships, directed the Secretary of Labor (Secretary) to consider proposing regulations that promote the development of apprenticeship programs by third parties. Section 8 of the EO directed the Secretary to establish a Task Force on Apprenticeship Expansion to identify strategies and proposals to promote apprenticeships, especially in sectors where apprenticeship programs are insufficient. In May 2018, the Task Force on Apprenticeship transmitted its final report to the President, including recommendations noting that the establishment of Industry-Recognized Apprenticeship Programs (IRAPs) could provide industry organizations and employers more tools to create high-quality apprenticeship programs and opportunities.
To address America's skills gap and rapidly increase the availability of high-quality apprenticeship programs in sectors where apprenticeship opportunities are not widespread, the U.S. Department of Labor issued a Final Rule that establishes a system for advancing the development of high-quality IRAPs.
What are Industry-Recognized Apprenticeship Programs?
IRAPs are a new and flexible form of high-quality apprenticeship programs that provide individuals with opportunities to obtain workplace-relevant knowledge and progressively advancing skills. IRAPs include a paid-work and an educational component and they result in an industry-recognized credential.
An IRAP can be evaluated by a Standards Recognition Entity (SRE) - a Department-recognized, industry-leading third-party entity such as trade group; corporation; non-profit; educational institution; union; and a joint labor-management organization. The IRAP Final Rule establishes a process for the Department of Labor's Office of Apprenticeship (OA) Administrator to recognize SREs so that they can evaluate and recognize IRAPs consistent with the Department's standards.
High-quality IRAPs include the following 10 key requirements:
- Paid Work. IRAPs must ensure that apprentices are paid at least the applicable Federal, State, or local minimum wage. The program must provide a written notice to apprentices of what wages they will receive and under what circumstances their wages will increase.
- Written Training Plan. IRAPs must have a written training plan, consistent with its SRE's requirements and standards. The written training plan, which must be provided to an apprentice prior to beginning an IRAP, must detail the program's structured work experiences and appropriate related instruction. The training plan must be designed so that apprentices demonstrate competency and earn credential(s), and provide apprentices progressively advancing industry-essential skills.
- Written Apprenticeship Agreement. IRAPs must maintain a written apprenticeship agreement for each apprentice that outlines the terms and conditions of the apprentice's employment and training. The apprenticeship agreement must be consistent with its SRE's requirements.
- Specialized Knowledge and Experience. IRAPs must train apprentices for employment in jobs that require specialized knowledge and experience and involve the performance of complex tasks.
- Safety. IRAPs must provide a working environment for apprentices that adheres to all applicable Federal, State, and local safety laws and regulations and complies with any additional safety requirements of its SRE.
- Equal Employment Opportunity. IRAPs must affirm their adherence to all applicable Federal, State, and local laws pertaining to EEO.
- Credit for Prior Knowledge. IRAPs must provide credit for prior knowledge and experience to apprentices relevant to the instruction of the program.
- Mentorship. IRAPs must provide apprentices structured mentorship opportunities throughout the duration of the apprenticeship that involve ongoing, focused supervision and training by experienced instructors and employees, to ensure apprentices have additional guidance on the progress of their training and their employability.
- Industry-Recognized Credentials. IRAPs must provide apprentices industry-recognized credential(s) during participation in or upon completion of the program.
- Disclosure of Costs and Fees. IRAPs must disclose to apprentices (before they agree to participate in the program) any costs or expenses that will be charged to them (such as costs related to tools or educational materials).
What are the criteria to become an SRE?
SREs are trusted workforce development leaders in their industry, either at a local, regional, or national level. An entity is qualified to be recognized as an SRE if it demonstrates the following:
- SREs must have the expertise to set competency-based standards, through a consensus-based process involving industry experts, for the requisite training, structure, and curricula for apprenticeship
- programs in the industry(ies) or occupational area(s) in which they seek to be an SRE
- SREs must have the capacity and quality assurance processes and procedures to ensure IRAPs comply
- with DOL standards for safety, compensation, and quality.
- SREs must have the resources to operate as an SRE for a 5-year period.
- SREs must demonstrate impartiality by disclosing partners who will be engaged in recognition activities, describing their roles, including their relationships with subsidiaries.
- SREs must be in good standing with the U.S. Federal Government. They cannot be suspended or debarred from doing business with the Federal Government.
- SREs must have policies, processes, procedures, or structures in place to mitigate any conflicts of interest.
- SREs must have the appropriate industry and occupational expertise and resources in place to recognize IRAPs in their selected geographical area (Nationwide or limited to a region, state or local area).
There are many advantages to becoming either an SRE or an IRAP. To better understand the criteria and the structure of these programs, please visit the resources listed below.