Yes, SREs can recognize their own programs as IRAPs. The Department is aware that having an SRE recognize its own IRAP could present conflicts of interest. Accordingly, in the final rule, the Department requires that all SREs demonstrate that they can effectively mitigate such conflicts of interest. As part of the SRE application process, the Department requires, at a minimum, that each entity disclose potential conflicts and provide a firewall between SRE and prospective IRAP staff or assign key tasks to an independent third party. The Department expects that a firewall will prohibit program designers from involvement in recognition decisions and will prohibit SRE personnel who receive complaints from being subject to the same supervisory channels as IRAP managers.
To ensure that SREs are recognizing apprenticeship programs that adhere to the standards of high-quality apprenticeships, the Department requires SREs’ recognition, quality control, and suspension and derecognition processes and procedures to be designed and administered to treat any nonaffiliated IRAPs equitably. The U.S. Department of Labor intends to enforce such processes, procedures, or structures involving potential conflicts of interest through the quality assurance process outlined in 29 CFR 29.23 and the review process outlined in 29 CFR 29.26 of the final rule.