The U.S. Department of Labor (DOL) requires every sponsor to develop Apprenticeship standards that will guide an Apprenticeship program. But developing standards is only the beginning of this important process.
Once in place, Apprenticeship standards become legally binding documents for employers to follow. Adhering to these standards ensures the Apprenticeship complies with all state and federal regulations. It also holds the key pieces of what the U.S. DOL will be looking for during an audit.
The U.S. DOL uses audits to track Apprenticeship compliance. These audits evaluate how well employers adhere to Apprenticeship standards and other regulations. If their exam shows a failure to comply with requirements, programs can lose their eligibility for incentives, such as reimbursements and tax credits, or worse, approval for the program itself.
What is a Department of Labor Audit?
It is crucial for employers to understand the audit process and prepare for one before the U.S. DOL shows up at their door.
U.S. DOL audits can vary in frequency and scope, depending on the current administration's funding levels. It’s best to prepare for quarterly audits and keep all records up to date.
Employers can ask for more time to gather records during an audit. But the auditor decides how much time is given. A better approach is to have records ready for audits at all times.
The U.S. DOL has many compliance boxes for Apprenticeships to check. An audit looks for missing checks or gaps in compliance, particularly around Apprenticeship hours worked and adherence to wage progressions. The entire program may be in violation if the U.S. DOL spots these problems in an audit.
Program metrics set in Apprenticeship standards track an apprentice’s progress. Is the apprentice on schedule? What progress is the apprentice making monthly? How many hours is the apprentice working? Is the apprentice’s wage schedule progressing appropriately? In an audit, the U.S. DOL will review these things.
Keeping accurate records ensures U.S. DOL audits go smoothly. During an audit, the U.S. DOL will ask to see:
- On-the-Job Training (OJT) Progress (i.e., Work Progress Schedule)
- Related Technical Instruction (RTI) Progress (i.e., Courses and Grades)
- Wage Schedule Progression
- Apprenticeship Agreements (i.e., Form 671 or State Agreement)
- Case Notes (i.e., disciplinary actions and other notes)
- Previous Experience (OJT and RTI)
Our blog "Apprenticeship Program Regulations: What Your Organization Needs to Know” shares a comprehensive list of records to keep for an audit.
Problems arise when an audit reveals apprentices are not completing OJT hours, receiving RTI hours, or adhering to the progressive wage schedule. It is important to have a system in place to manage these data points throughout the program.
Apprenticeship Management Software makes compliance easier. An intuitive software solution tracks critical aspects of the Apprenticeship, from the time apprentices spend in OJT and RTI, performance evaluations for skills progression, wage increases, and case management, and simplifies pulling reports during an audit.
How to Plan for an Apprenticeship DOL Audit
The U.S. DOL requires sponsors to have all data in place for an audit. Getting notified about an audit isn't great news, but it's far less stressful when employers and sponsors have their ducks in a row.
Most of the time, audits are random. Sometimes they are triggered by a complaint or a history of violations. Most often, audits occur every six months.
Employers can take five steps to prepare for an audit and prevent headaches later on.
- Get Disciplined about Data. Put systems in place to organize data. It is vital to have data readily available for auditors. The entire program may be at risk if there is no data. Using Apprenticeship Management Software helps track key metrics throughout the program and ensures employers can pull records quickly during an audit.
- Stick to Standards of Apprenticeship. Periodically pull and review all Standards of Apprenticeship documents and apprentice agreements to make sure everything complies with that original—and legally binding—document.
- Know the Law. Have a full understanding of federal and state laws and regulations for Apprenticeships to ensure the program complies with them.
- Track Hours and Pay. Track wage progressions and apprentice hours and keep data up to date and aligned with the original Apprenticeship agreement and standards. Auditors will zero in on hours and wage progressions. They look for 2,000 hours of OJT, 144 hours of related instruction per year minimum and whether an apprentice’s current wage is on track with the wage progression set in the Apprenticeship standards.
- Conduct Self Audits. Track the entire program with regular self-audits. Take corrective action if the self-examination identifies areas of concern.
How an Apprenticeship Software Management Tool Can Help Prepare for Audits
An Apprenticeship program has many moving parts, and the U.S. DOL expects employers to track all of them. Spreadsheets, emails, and paper forms can track this information, but these methods are not perfect and can reflect poorly on the program during an audit.
An Apprenticeship Management Tool, in contrast, can automate record keeping, helping Apprenticeships pass U.S. DOL audits with flying colors. These tools keep all program records in a central location and offer reporting tools to put information in easy-to-understand reports.
A quality Apprenticeship Management System offers key tools to track the most critical aspects of the Apprenticeship program, including hours worked, wage progressions, and more. Certain key tools and features of a good software solution help employers find an easy-to-use system that offers needed tools to track critical aspects of Apprenticeship programs.
Related Content: 10 Records Apprenticeship Sponsors Need to Keep
Takeaway: Audits are a Given, So Be Ready for Them
No one likes to be audited, but audits are part of running a Registered Apprenticeship Program. Being ready for a U.S. DOL audit before one comes your way can remove the stress and worry that surrounds them.
The key metrics that auditors zero in on are OJT, RTI, and wage progressions. Tracking these critical records in Apprenticeship Management Software keeps them up to date and ready to pull when an auditor asks for them.
Audit worries can keep you awake at night. But when records are up to date in a software tool, you can rest easy knowing the information auditors need is easily accessible and ready for review.
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