Frequently Asked Questions

Industry Recognized Apprenticeship Program

General

  • Industry-recognized credentials are those that reflect the specific competencies needed for a given industry or occupational area. 

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  • IRAPs will supplement the successful Registered Apprenticeship Program (RAP). Since the RAP model is already widespread within the construction sector, IRAPs can be developed in any sector except for construction.  

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  • IRAPs are a new and flexible form of high-quality apprenticeship programs that provides 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. 

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  • Pre-apprenticeships can be used as an on-ramp to IRAPs. Apprenticeship is an efficient and economical solution to give career seekers the skills they need for the jobs of today and the future, and to meet employer needs for skilled talent. Still, many individuals do not have proficiency in basic work-readiness, reading comprehension, or math skills to enter an apprenticeship program. Pre-apprenticeship programs are designed to prepare individuals for Registered Apprenticeship and IRAPs to meet current and future labor market demands while preparing individuals for well-paying careers. 

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  • To become an SRE, entities must demonstrate that they 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) and occupational areas listed in their SRE application. Once recognized as an industry leader and subject matter expert, the SRE is responsible for determining which credentials are industry-recognized through its own expertise and engagement with industry partners and experts. SREs are responsible for deciding how to structure their programs for imparting industry-recognized credentials. In order to receive recognition to become an SRE, SRE applicants must develop and attach the policies and procedures they plan to use to evaluate and monitor IRAP occupations and credentials and their process to ensure IRAP apprentices achieve those credentials in their SRE application. The Department’s requirement that the credential must be industry-recognized is specifically designed to ensure that the credentials are relevant beyond any individual employer. The Department will collect information from each SRE about each credential offered by its IRAPs. 

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  • No, Registered Apprenticeship Program metrics are specifically for Registered Apprenticeship Programs. There are separate IRAP metrics based on the requirements in the final rule. 

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  • The Department’s quality assurance role allows the Department to evaluate the SRE’s ability to fulfill its responsibilities to ensure that their IRAPs continue to satisfy the Department’s standards of high-quality apprenticeships. The Administrator may discharge recognition, review, suspend, and derecognize SREs.  

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  • High-quality IRAPs include the following 10 key requirements:  

    1. 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.  

    1. 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.    

    1. 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.  

    1. 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.    

    1. 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.   

    1. Equal Employment Opportunity. IRAPs must affirm their adherence to all applicable Federal, State, and local laws pertaining to EEO.  

    1. Credit for Prior Knowledge. IRAPs must provide credit for prior knowledge and experience to apprentices relevant to the instruction of the program.    

    1. 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.  

    1. Industry-Recognized Credentials. IRAPs must provide apprentices industry-recognized credential(s) during participation in or upon completion of the program.  

    1. 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).

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  • IRAPs must apply to be added to the state ETP list, as is the case with any other prospective training provider. 

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  • Examples of acceptable documentation include but are not limited to: a financial plan and/or description of the costs associated with operating as an SRE; a description of the organization’s available funding sources to support SRE operations, including the duration of the funding; and/or a summary of the organization’s most recent audit findings supporting the organization’s financial solvency. 

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  • IRAP sponsors can establish a program using their own credentials or credentials developed by another agency or industry association; however, the SRE is responsible for validating that the credential is industry-recognized. 

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  • The IRAP final rule places comprehensive EEO responsibilities on both the IRAP sponsor and the SRE, instead of requiring compliance with the provisions of 29 CFR Part 30, which applies only to Registered Apprenticeship. To be recognized by an SRE as an IRAP, a program must affirm “its adherence to all applicable Federal, State, and local laws pertaining to Equal Employment Opportunity.” 29 CFR 29.22(i) provides that the SRE must have policies and procedures that both (1) “require IRAPs’ adherence to applicable Federal, State, and local laws pertaining to EEO” and (2) “facilitate such adherence through the SRE’s policies and procedures regarding potential harassment, intimidation, and retaliation (such as the provision of anti-harassment training, and a process for handling EEO and harassment complaints from apprentices).” 

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  • IRAPs are high-quality apprenticeship programs recognized by industry and/or workforce leaders known as SREs. IRAPs were designed to give the additional flexibility necessary to expand the apprenticeship model and to address the diverse workforce needs of different industries and occupations. A RAP is a proven model of apprenticeship that has been validated by the Department of Labor or State Apprenticeship Agency. RAPs are known for their structure, rigor, and quality and are designed for organizations interested in receiving the DOL or state seal of approval and funding opportunities made available by DOL. The U.S. Department of Labor has created a helpful side-by-side document comparing the two programs.

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  • State and local WDBs can combine IRAPs and WIOA services as they would in the case of any other training provider. Eligible Training Providers (ETPs) receive funding through an Individual Training Account (ITA) for training services, and they must be included on a state ETP list. Under WIOA, a significant amount of autonomy is given to the States and localities to determine criteria for inclusion on ETP lists.  

    In order to support the related training component of an IRAP using a WIOA Individual Training Account, these programs would still have to apply for status as an ETP on a state ETP list. Once on the ETP list, local American Job Centers (AJCs) can refer WIOA participants to an IRAP and use ITAs to pay for the training costs of a participant who enrolls in those IRAPs that are taking applications (i.e., openings are or will become available). 

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  • While the IRAP regulation does not establish a minimum age, the Fair Labor Standards Act sets the minimum ages and occupations in which youth can be employed in agricultural and nonagricultural employment.  

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Standards Recognition Entities (SREs)

  • 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.  

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  • 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).  

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  • An entity that has been denied recognition as an SRE will receive notice of a denial of recognition and may request administrative review within 30 calendar days of receipt of the notice.  An SRE will receive notice of suspension or derecognition and may request administrative review within 45 calendar days of receipt of the notice. 

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  • No, there is no limit on the number of SREs in a specific geographic area or industry. The Department believes that having multiple SREs within any given industry or state will help apprenticeships thrive in emerging industries and expand to new and innovative occupational areas. In addition, the presence of multiple SREs will provide prospective IRAPs and employers with an opportunity to assess and determine which SRE is best suited to meet the needs of their programs. 

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  • A list of required documents and other requirements for prospective SREs can be found in the SRE pre-application checklist.

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  • Following its SRE’s derecognition, an IRAP will maintain its status until 1 year after the Administrator’s decision derecognizing the IRAP’s SRE becomes final, including any appeals. At the end of 1 year, the IRAP will lose its status unless it is recognized by another approved SRE. Once derecognized, the Administrator will update the online list of SREs to reflect the derecognition, and the Administrator will notify the SRE’s IRAP(s) of the derecognition. 

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  • No, the SRE can only recognize programs in the geographic area, industry, and/or occupational area for which it is approved by DOL to recognize IRAPs. For example, if an SRE applied for recognition in a certain state, it can only recognize programs in that state. If the SRE recognizes an IRAP sponsor with programs located in several states, the program(s) in the state for which the SRE is approved to recognize IRAPs will be recognized. If the SRE wants to recognize programs in additional states, including nationally, it must update its application and wait for approval from DOL before expansion can begin. SREs are encouraged to carefully consider the geographic areas in which they want to recognize IRAPs before submitting their application. 

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  • Yes, SREs are likely to be in the best position to offer services to IRAPs to help them provide high-quality apprenticeships. SREs are required to address conflicts of interest arising from offering services when they apply to become an SRE. This requirement applies to any type of advice, assistance, or consultation for which the SRE seeks compensation. 

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  • Each year, an SRE must report to the Administrator, in a format prescribed by the Administrator, and make publicly available the following information on each IRAP it recognizes: 

    1. Up-to-date contact information for each IRAP; 

    1. The total number of new and continuing apprentices annually training in each IRAP under an apprenticeship agreement; 

    1. The total number of apprentices who successfully completed the IRAP annually; 

    1. The annual completion rate for apprentices. Annual completion rate must be calculated by comparing the number of apprentices in a designated apprenticeship cohort who successfully completed the IRAP requirements and attained an industry-recognized credential with the number of apprentices in that cohort who initially began training in the IRAP; 

    1. The median length of time for IRAP completion; 

    1. The post-apprenticeship employment retention rate, calculated 6 and 12 months after program completion; 

    1. The industry-recognized credentials attained by apprentices in an IRAP, and the annual number of such credentials attained; 

    1. The average earnings of an IRAP’s former apprentices, calculated 6 months after IRAP completion; 

    1. Training cost per apprentice; and 

    1. Basic demographic information on participants. 

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  • The Office of Apprenticeship will review SRE applications quarterly in batches, and it will provide a denial of recognition with the reason(s) for denial. The notice will tell the applicant what it needs to do differently before resubmitting its application. The notice will also explain that a request for administrative review must comply with the service requirements contained in 29 CFR part 18.The Administrator will refer any requests for administrative review to the Office of Administrative Law Judges.

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    • SREs are responsible for recognizing or rejecting IRAPs in a timely manner. 

    • SREs must notify the Office of Apprenticeship within 30 days when they have recognized, suspended, or derecognized an IRAP, and include the name and contact information of the program. 

    • SREs are responsible for providing program and performance data to the Office of Apprenticeship in a timely manner. 

    • SREs are responsible for only recognizing high-quality IRAPs as set forth by the Department in the IRAP Final Rule. 

    • SREs must establish policies and procedures for recognizing, and validating compliance of, programs that ensure that SRE decisions are impartial, consistent, and based on objective and merit-based criteria. 

    • SREs will review programs and validate that they meet the high-quality criteria of an IRAP at initial recognition and on an annual basis. 

    • SREs must remain in an ongoing quality-control relationship with the IRAPs they have recognized, to include periodic compliance reviews and consideration of apprentices’ credential attainment, program completion, retention rates, and earnings. 

    • SREs must publicly disclose the credential(s) that apprentices will earn during their participation in or upon completion of an IRAP. SREs are responsible for developing policies and procedures for the suspension or derecognition of an IRAP that fails to comply with the SRE’s requirements. 

    • SREs are responsible for developing policies and procedures that require IRAPs’ adherence to applicable Federal, State, and local laws pertaining to EEO and reflect comprehensive outreach strategies to reach diverse populations. 

    • SREs are responsible for having policies and procedures for addressing complaints filed against their IRAPs. 

    • An SRE must notify the Administrator and must provide all related material information if: 

    • It makes any major change that could affect the operations of the program, such as involvement in lawsuits that materially affect the SRE, changes in legal status, or any other change that materially affects the SRE’s ability to function in its recognition capacity; or 

    • It seeks to recognize apprenticeship programs in additional industries, occupational areas, or geographical areas. 

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  • No, there are no limitations or guidelines on fees that SREs can charge. However, an SRE must publicly disclose any fees it charges to IRAPs (29 CFR 29.22(n)). 

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  • Yes, under 29 CFR 29.22(a)(4) the SRE is charged with recognizing and maintaining the recognition of IRAPs that meet the requirements in 29 CFR 29.22(a)(4)(i) through (x). These regulations put potential SREs on notice regarding the Department’s expectations for high-quality, high-performing programs. If the IRAP does not continue to fulfill its obligations, the SRE will hold the IRAP accountable as appropriate under the framework established by the Department. Additionally, 29 CFR 29.23 covers the Department’s quality assurance role in holding SREs accountable. 

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  • Yes, a new reporting system has been created for IRAP SREs. SREs that have been recognized by the U.S. Department of Labor will receive instructions on how to access the reporting system. The IRAP SRE reporting system is similar to RAPIDS but does not include individual-level data on each apprentice since SREs are only required to provide aggregate-level data for each program they recognize.

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  • The types of entities that can become SREs include, but are not limited to:  

    • Trade, industry, and employer groups or associations;  

    • Corporations and other organized entities;  

    • Educational institutions, such as universities or community colleges;  

    • State and local government agencies or entities;  

    • Non-profit organizations;  

    • Unions;  

    • Joint labor-management organizations;  

    • Certification and accreditation bodies or entities for a profession or industry;  

    • A consortium or partnership of entities such as those above.  

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  • The Administrator may suspend an SRE for 45 calendar days and may initiate review of an SRE if it receives information indicating that: (1) The SRE is not in substantial compliance with this subpart or; (2) The SRE is no longer capable of continuing as an SRE.

    The notice will include an explanation of the Office of Apprenticeship’s decision, including identified areas in which the SRE is not in substantial compliance or an explanation why the SRE is no longer capable of continuing as an SRE, or both, and necessary remedial actions, and must explain that the Administrator will derecognize the SRE in 45 calendar days unless remedial action is taken or a request for administrative review is made. 

    If the SRE does not take remedial action or request administrative review of the suspension, the Administrator will derecognize the SRE, notify the SRE in writing, and specify the reasons for the derecognition. The SRE may request administrative review within 45 calendar days of receipt of the notice. 

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  • Consistent with the IRAP Final Rule, prospective SREs that intend to recognize IRAPs must first apply for recognition by submitting the information requested in the application to the Administrator. Applications should be submitted electronically using the Department’s online application on www.apprenticeship.gov. The application must include all required policies and procedures. Based upon the information submitted, the Administrator will determine whether the applicant is qualified to be recognized as an SRE of IRAPs under the IRAP Final Rule. DOL’s Office of Apprenticeship will notify the applicant. An SRE will be recognized for 5 years and must reapply at least 6 months before the date that its current recognition is set to expire if it seeks re-recognition.  

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  • No, the SRE applications will not be made publicly available; however, some of the information provided in the application will be made public once the SRE is recognized. The confidentiality statement in the SRE application states that: “Under this collection, the name of a potential Standards Recognition Entity will be posted on https://www.apprenticeship.gov if the U.S. Department of Labor issues a letter of approval with respect to the entity.

    While the information collected by this application is generally subject to public disclosure under the Freedom of Information Act (FOIA), Exemption #4 of FOIA (at 5 U.S.C. §552(b)(4)) affords protection to submitters (such as Standards Recognition Entities) that are asked to furnish commercial or financial information to the Federal Government. The Department will keep as private and confidential, and will not disclose, unless required by law, any commercial or financial information provided to the Department under this section that is both customarily and treated as private by the SRE or IRAP. The Office of Apprenticeship will provide an applicant notice and an opportunity to object before disclosing information from the applicant. For more information, see 29 CFR part 70, ‘Production and Disclosure of Information or Materials,’ especially 29 CFR § 70.26, ‘Confidential commercial information.’”  

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  • The Office of Apprenticeship does not have a template, form, or sample policies and procedures currently. However, we have developed an SRE Technical Assistance Guide to help applicants with creating an account, uploading documents, and submitting your application.  Additionally, Office of Apprenticeship staff are located across the country and are available to help if you have any questions.   

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State Apprenticeship Agencies

  • Yes, SAAs and local government agencies or entities are eligible to apply to become SREs and IRAP sponsors, and must apply in the same application process as any other entity. 

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  • Yes, subject to any limitations in state law, State Apprenticeship Agencies that are approved as SREs can charge and accept fees for IRAPs, but only in their capacity as an SRE. 

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  • No, IRAPs and RAPs will work on parallel tracks with the support of the Department. The Registered Apprenticeship system has produced successful results in many industries for over 80 years and it will continue to do so. The industry-led, market-driven approach outlined in the IRAP final rule will give employers and other stakeholders the additional flexibility necessary to expand the apprenticeship model into new industries where registered programs are less prevalent and to address the diverse workforce needs of different industries and occupations. IRAPs provide a new apprenticeship pathway that lets industry organizations take the lead in identifying high-quality apprenticeship programs and opportunities based on the needs in their industry. 

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  • No, State Apprenticeship Agencies (SAAs) are not responsible for recognizing SREs that operate in their states. The IRAP final rule establishes a process for the U.S. Department of Labor’s Office of Apprenticeship Administrator to recognize qualified third-party entities, known as SREs, which will, in turn, evaluate and recognize IRAPs consistent with the Department’s standards. SAAs and local government agencies or entities are eligible to apply to become an SRE, but with that recognition an SAA has no authority to recognize SREs. The Department notes, however, that IRAP sponsors are required to abide by state and local laws. 

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Sponsors

  • Following an SRE’s derecognition, an IRAP will maintain its status until 1 year after the Administrator’s decision derecognizing the SRE becomes final, including any appeals. At the end of 1 year, the IRAP will lose its status unless it is recognized by another approved SRE. Once the SRE is derecognized, the Administrator will update the online list of SREs to reflect the derecognition, and the Administrator will notify the SRE’s IRAP(s) of the derecognition. 

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  • An IRAP Sponsor is the entity responsible for administering the Industry-Recognized Apprenticeship Program. IRAP Sponsors are entities such as trade and industry groups, corporations, non-profit organizations, educational institutions, unions, and joint labor-management organizations. 

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  • IRAPs must ensure that apprentices are paid at least the applicable federal, state, or local minimum wage and must notify apprentices of circumstances under which wages will increase. Thus, apprentices will have the information necessary to make informed decisions about IRAPs and compare wage offerings of different IRAPs. IRAPs are not required to have a progressive wage structure because different IRAPs will likely vary in duration and will represent a broad spectrum of industries with different market wage trends. Further, a progressive wage structure could limit employer participation in IRAPs, particularly for employers that would offer IRAPs that are limited in duration. This, by extension, could reduce or eliminate choices for individuals seeking apprenticeship opportunities. 
     

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    • Assess your workforce needs, consider how this new flexibility in apprenticeship could offer the right talent development solution, and develop a program. 

    • Familiarize yourself with the DOL standards for high-quality IRAPs. 

    • Identify trusted national industry leaders in your industry sector and encourage them to apply for recognition as an SRE. 

    • Monitor DOL’s IRAP website for up-to-date information about recognized SREs. 

    • Seek recognition from an SRE in your industry or occupational area. 

    • IRAPs that seek to train apprentices to perform construction activities cannot be recognized by SREs. 

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  • SREs are responsible for setting competency-based standards, for the training, structure, and curricula for apprenticeship programs in the industry(ies) or occupational area(s) for which they have been approved to recognize IRAPs. Once those standards are in place, SRE’s are responsible for assisting prospective IRAP sponsors with the development of their programs based on their requirements and standards. Please review the SRE fact sheet for more information on the roles and responsibilities of SREs. 

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Funding

  • Yes, there are several sources of potential funding. For example, Workforce Innovation and Opportunity Act (WIOA) funds can be used to offset costs associated with IRAPs. SREs and IRAP sponsors can apply to be added to the state Eligible Training Provider (ETP) list, as is the case with any other prospective training provider. Once on the ETP list, local American Job Centers (AJCs) can refer WIOA participants to IRAP sponsors and use Individual Training Accounts (ITAs) to pay for the training costs of participants who enroll in those IRAPs. 

    In addition to ITAs, the AJCs can fund portions of the on-the-job training (OJT) component of the IRAP using contracts, based on local policies. WIOA allows for OJT to be paid for with contracts, which can be made with providers that are not on the ETP list. WIOA OJT contracts can be used to fund OJT for one or more eligible participants and can be used to reimburse employers for the extraordinary costs of training at a level of up to 75% of the participants’ wages in certain circumstances. WIOA funds can also be used for supportive services such as transportation, books and supplies, and child care. We strongly encourage potential SREs and IRAP sponsors to partner with the workforce system and vice versa. 

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  • It is important that apprenticeship grantees and contractors pay attention to what their funding can be used for. American Apprenticeship Initiative grants, State Apprenticeship Expansion grants, National Industry and Equity contracts, and Youth grants were designed specifically for Registered Apprenticeship expansion and cannot be used for IRAPs. Scaling Apprenticeship grants and Closing the Skills Gap grants can be used for apprenticeship activities in general, including IRAPs, if such activity is included in the grantee’s Statement of Work. 

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Complaints

  • Yes. An SRE must have policies and procedures for addressing complaints filed by apprentices, prospective apprentices, an apprentice’s authorized representative, a personnel certification body, or an employer against each IRAP the SRE recognizes. An SRE must notify the public about the right of an apprentice, a prospective apprentice, the apprentice’s authorized representative, a personnel certification body, or an employer, to file a complaint with the SRE against an IRAP the complainant is associated with, and the requirements for filing a complaint. 

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  • Yes. A complaint arising from an SRE’s compliance may be submitted by an apprentice, the apprentice’s authorized representative, a personnel certification body, an employer, or an IRAP to the Administrator for review. The complaint must be in writing and must be submitted within 180 calendar days from the complainant’s actual or constructive knowledge of the circumstances giving rise to the complaint. It must set forth the specific matter(s) complained of, together with relevant facts and circumstances. The complaints against an SRE are addressed exclusively through the review process outlined in § 29.26. Additionally, nothing precludes a complainant from pursuing any remedy authorized under Federal, State, or local law. An SRE must notify the public about the right to file a complaint against it with the Administrator. 

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