A Registered Apprenticeship Program can be a win-win for employers looking to fill high-skill roles within their company and individuals seeking an onramp to high-paying career advancement opportunities. But for these programs to succeed, Sponsors must ensure they are in compliance with State and Federal regulatory organizations.
The US Department of Labor’s Office of Apprenticeship and their State-level counterparts (State Apprenticeship Agencies) set rules, standards, and regulations to ensure apprentices are being trained and employers are providing support and wages in accordance with their Standards of Apprenticeship.
It’s vital for Sponsors to understand these regulations to avoid common pitfalls and ensure their programs are set up for long-term success. Registered Apprenticeship compliance requirements generally fall into three buckets:
- Program Records
- Apprentice Records
- Workforce Grant Records (only applicable to grant recipients)
What is a Registered Apprenticeship Program?
Registered Apprenticeship Programs are regulated, work-based learning programs that combine full-time employment, On-the-Job training, Supplemental Coursework, and a Progressive Wage Schedule to create industry-informed pathways into the workforce for apprentices, and reliable talent pipelines for in-demand roles for employers. These programs hold value whether the Apprenticeship program prepares Chocolatiers for a candy factory or Early Childcare teachers for a daycare.
The U.S. Department of Labor oversees Registered Apprenticeships, which are regulated by the Code of Federal Regulations (CFR), Title 29, Parts 29 and 30. The programs establish cost-effective, long-term solutions to help employers acquire talent through on-the-job training, technical instruction, and mentorships.
Apprentices become paid employees on their first day and progress through a wage schedule as they achieve technical competencies or based on their time in the program. They also receive a nationally recognized credential upon program completion.
Developing a skilled workforce improves employers’ productivity, profitability, and bottom line. Apprentices benefit from being paid to learn new skills and develop a stable career. Making them distinct from internships that often have a less clear end outcome, Apprenticeships are very rigorous and regulated programs. They have strict quality standards and help propel apprentices into long-term careers.
Apprenticeship Regulation and Compliance Guidelines
The benefits of a Registered Apprenticeship Program are many. But employers that cannot comply with federal and state agency regulations risk losing eligibility for incentives like reimbursement and tax credits, and even program suspension.
All Registered Apprenticeship Programs must comply with program metrics and general demographics and registration. Federal grant compliance only applies to programs that receive federal grant money.
Program Records
Companies that offer Registered Apprenticeship programs will need to keep the following program records on hand
- Standards of Apprenticeship
- Program Selection Criteria & Procedures
- Applicable HR Policies
- Affirmative Action Plans
- Inventory of Partners (Employer-Partners, RTI Providers, etc)
Apprenticeship Records
Program metrics track the tasks and goals apprentices are working toward. They examine where apprentices are in the process and how they are doing. Are they on schedule or falling behind? What are they accomplishing every month? How many hours are they working? In a random program audit, the Department of Labor or state regulatory agency will look at these things.
Keeping accurate apprentice records is vital to ensure your USDOL audits go smoothly. During an audit, your USDOL representative will ask to see:
- On-the-Job Training Progress (i.e. Work Process Schedule)
- Related Technical Instruction Progress (i.e. Courses & Grades)
- Wage Schedule Progression
- Apprentice Agreements (i.e. Form 671 or State Agreement)
- Case Notes (i.e. disciplinary actions & other notes)
- Previous Experience (OJT & RTI)
It’s a problem if an audit reveals that apprentices are not completing OJT hours, receiving RTI hours, or adhering to their wage schedule. Make sure you have a system in place to manage all of these data points to prevent problems come audit time.
Workforce Grant Records (if applicable)
Various federal funds are available to support Apprenticeship programs. If you’ve received federal workforce development grant funds through the Workforce Innovation and Opportunity Act (WIOA), your organization will need to comply with additional reporting requirements through the Workforce Integrated Performance System (WIPS).. We won’t go into too much detail about WIPS compliance in this article, but you’ll want to make sure you have a system like ApprentiScope to ensure all relevant Participant Individual Record Layout (PIRL) fields are being tracked accurately for your participants.
If you’re having trouble keeping all of this straight, you might want to reach out to a consultant or local workforce agency for assistance. These organizations can help iron out these details, establish better processes and fill knowledge gaps within your programs. They can also provide supplemental services, including ongoing program management and recruitment assistance.
Related Content: What are the Benefits and Costs of Apprenticeship Programs?
Benefits of a Registered Apprenticeship Program
Compliance can certainly feel daunting, so is it worth all the hassle? The short answer is “Yes.” The benefits of a Registered Apprenticeship Program far outweigh compliance challenges.
Employers can craft programs to address specific needs and integrate them into current training initiatives. Assigning mentors to work with apprentices on-the-job further fosters knowledge transfer that is supplemented by educational courses. The result is a well-trained and reliable worker pipeline and a safer workplace.
NationalApprenticeship.org lists a few other benefits for employers:
- Gain highly skilled employees
- Increase productivity
- Attract new talent pools
- Create a diverse workforce
- Reduce turnover costs
Partner with a Professional for Apprenticeship Compliance Management
A Registered Apprenticeship Program delivers many benefits to employers, but data tracking can get overwhelming. For this reason, many programs opt to use Apprenticeship management software to reduce administrative overhead and improve program efficacy by streamlining program management and compliance.
The stakes are high when Apprenticeship Programs fail to meet USDOL regulations. It’s critical to understand and comply with guidelines. Utilizing software to streamline the entire Registered Apprenticeship lifecycle can help avoid poor outcomes.
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