The universal outreach and recruitment provision requires sponsors to send advance notice of all program openings to the recruitment sources on its outreach and recruitment list. A sponsor that has continuous open enrollment should send its position postings to its recruitment sources regularly, as well as whenever there is any change to the apprentice position posting or description. Generally speaking, a sponsor will satisfy this requirement by sending out the posting on a quarterly basis (and any time the posting changes). When evaluating a sponsor’s compliance with this requirement, the Office of Apprenticeship will take into account circumstances in which quarterly postings may not be cost-effective (e.g., for a very small program where there are hardly any openings) or might not be sufficient (e.g., for a program that has a very large number of openings every month).
How can a sponsor that accepts applications for enrollment in its apprenticeship program on a continuous basis (sometimes called “open enrollment”) satisfy the universal outreach and recruitment requirement?
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As a general rule, sponsors should engage in broad-based advertising efforts to ensure that their recruitment efforts extend to all persons available for apprenticeship. Sponsors must provide recruitment sources advance notice, preferably 30 days, of apprenticeship openings and must include their equal opportunity pledge in their opportunity announcements.
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Sponsors are allowed to select apprentices through any selection method, as long as it does not discriminate on any of the protected bases and complies with the requirements for selection devices under the Uniform Guidelines on Employee Selection Procedures and the Americans with Disabilities Act. Additionally, selection methods must be uniformly and consistently applied to all applicants and apprentices and be facially neutral with respect to the protected bases. Read Selecting Apprentices for Registered Apprenticeship Programs for more details on this topic.
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Sponsors should make good faith efforts to seek alternative or additional sources that are more effective at referring diverse qualified applicants. The Office of Apprenticeship has provided information and online resources to sponsors regarding recruitment sources. During compliance reviews, sponsors would only be expected to describe their good faith efforts to recruit diverse apprentices.
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If the requirement to have a driver’s license impacts any protected group adversely, such a requirement should be validated to ensure it is job-related and consistent with business necessity. For example, an apprenticeship program that involves traveling to different sites may require apprentices to use personal or company transportation to these sites. If driving is not an essential function of the job, the requirement to have a driver’s license may not be consistent with business necessity and may adversely affect certain individuals with disabilities or other protected groups.
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