CTE Apprenticeship: What You Should Know

Last week, the U.S. Department of Labor (DOL) proposed significant revisions to the regulations (CFR, Subtitle A, Parts 29 & 30) that govern the nation’s Registered Apprenticeship system. Teased by the department for months, the proposed ‘’system enhancements’’ include hundreds of pages of additions and modifications to the existing regulations. While some are minor or mundane, others—like the introduction of a new model of registered apprenticeship called Career & Technical Education (CTE) Apprenticeship—could have significant implications for the field of youth apprenticeship.

Though CTE Apprenticeship is not intended to serve youth exclusively, the DOL is clear that the model has been designed to ‘’strengthen the connection with secondary and postsecondary education programs by bringing together the core concepts of registered apprenticeship and CTE.’’ But how?

To begin answering that question, we lay out some of the basic components of this proposed new model below. We consider how it would compare to existing models and criteria for high quality apprenticeship and explain what happens next in the rulemaking process—including how you can weigh in.

Do the DOLs proposed new rules define youth apprenticeship? The proposed rule does not define youth apprenticeship. It does, however, do two significant things related to youth and young adults:

1. It retains language that traditional Registered Apprenticeships can enroll apprentices aged 16 years and up, and;
2. It proposes a new category of apprenticeship called Career & Technical Education (CTE) Apprenticeship, which would leverage high school and postsecondary CTE courses and pathways for related instruction in a modified program model.

The proposed rule would also adopt a definition of pre-apprenticeship to create consistency across the regulations and align with the Workforce & Innovation Opportunity Act regulations. Though not a significant change to program requirements, this revision aims to facilitate better data collection on pre-apprenticeship participants, including youth and young adults.

What does CTE apprenticeship entail? Like registered apprenticeship, CTE apprenticeship would require both related instruction (RI) and on-the-job training (OJT). CTE apprenticeship would require a minimum of 540 hours of ‘’CTE-apprenticeship related instruction,’’ which must include at least 12 postsecondary credit hours (i.e. approx. three semester-long college courses, totaling approximately 360 of the 540 required hours, based on 2021 guidance from the U.S. Department of Education). The RI must include state-approved CTE courses. In addition, CTE apprentices would need to complete a minimum of 900 hours of OJT. CTE apprentices must be paid for their OJT using a progressive wage scale.

An apprentice who completes a CTE apprenticeship would receive, at minimum, a certificate of completion from the Registration Agency (either the DOL’s Office of Apprenticeship or a State Apprenticeship Agency). Programs can be designed to include other credentials, including industry recognized credentials or degrees. However, CTE apprenticeships cannot confer journey worker’s cards, as is the case in traditional Registered Apprenticeships.

According to the notice of proposed rulemaking (NPRM), CTE apprenticeship programs could be designed for high school students, college students, or to span the transition from high school to college (e.g. start in 12th grade and continue into a college pathway for an additional year or more). In theory, CTE apprenticeships could also provide a model for the development of degree apprenticeships through which apprentices would earn an associates or bachelor’s degree, while completing training with an employer.

How are CTE apprenticeships different from Registered Apprenticeships? CTE apprenticeship programs would include all of the same basic components of registered apprenticeship, but vary in a few key ways:

• More Related Instruction, Fewer On-the-Job Hours: CTE apprenticeship would require a higher number of related instructional hours compared to Registered Apprenticeship (540 vs. 44 hours of RI). It would also require a lower number of OJT hours (900 vs 2,000 hours of OJT).
• Sponsor Eligibility: School districts, colleges and universities, state education agencies, or other state agencies that share responsibility for CTE would be eligible to sponsor CTE apprenticeships. These entities could also designate sponsorship duties to an intermediary (e.g. non-profit organizations, a joint apprenticeship and training committee, a workforce board, etc.).
• Emphasis on industry-relevant skills rather than occupationally specific training: Compared to Registered Apprenticeship, CTE apprenticeships would focus ‘‘more on foundational industry skills than on occupational proficiency,’’ which the USDOL argues is more appropriate for less experienced workers and more realistic given the ratio of RI to OJT in the model. (However, the rule would not prohibit CTE Apprenticeship sponsors from designing occupationally specific programs.)
• Data Differences: The data requirements largely mirror those for Registered Apprenticeship, but CTE apprenticeship sponsors would be required to report on CTE Apprentice outcomes, indicating whether an apprentice continued into a registered apprenticeship, enrolled in a postsecondary program, or entered employment at the time of program completion.

CTE apprenticeships would be registered with the U.S. DOL or State Apprenticeship Agencies through a process similar to standard registration. States will need to create and define a relationship between the state agency that administers Perkins funding and its Registration Agency to implement CTE apprenticeship. While the rules provide wide latitude for states to divide responsibilities detailed in the proposed rule, this partnership is new and unique to CTE apprenticeship. Importantly, however, the proposed rule does not require states to adopt CTE apprenticeship, nor does it preclude them from continuing to use a pre-apprenticeship or registered apprenticeship model to serve high school age youth.

How does CTE apprenticeship compare to PAYA’s definition of youth apprenticeship? The proposed CTE apprenticeship model includes the four core elements in PAYA’s definition of a high-quality youth apprenticeship, but would add specific requirements around those elements, as detailed in the table below:

In one key difference, CTE apprenticeship would not exclusively serve high school aged-youth. Colleges could use the model to partner with employers to train adult learners and workers as well, for example. 

How soon will these changes take effect? Rulemaking is a notoriously slow process. It could be many months—even years—before any of the proposed changes become final rules and take effect. For now, there is no reason to begin making changes to existing programs or to halt development of soon-to-launch models. It would be worthwhile to consider the extent to which your programs are leveraging local and state CTE systems and to begin thinking about opportunities to improve alignment. Whether or not CTE apprenticeship becomes a reality, this is an important best practice for youth-serving apprenticeship programs.

What does New America think of this concept? In our initial read, there are aspects of the proposed rule that we think are promising and others that merit further consideration and revision. As New America continues to digest the proposed rule and collect input from various stakeholders, including our PAYA Partners and Network, we will share and publish our analysis.

Are there other things I should care about in the NPRM? Yes. There are other significant proposed changes that may be relevant to your work, especially if you operate or support Registered Apprenticeship programs. Resources to learn more about these changes are linked in the FAQ document below.

Why is DOL engaging in this rulemaking effort? The rulemaking effort reflects the Biden Administration's ambition to ‘’strengthen, expand, modernize and diversify the National Apprenticeship System’’. It includes changes intended to enhance worker protections, promote equity, improve apprenticeship program quality and data, and further clarify the roles of DOL’s Office of Apprenticeship and State Apprenticeship Agencies. Many of the changes seek to create a ‘’broader apprenticeship pathways system’’ by introducing greater consistency and transparency, and by aligning apprenticeship with the education system. While some of the changes are minor and non-controversial, others are already generating lively debate.

What happens next? How does rulemaking work? Federal agencies issue regulations to guide the implementation of laws enacted by Congress through a structured rulemaking process. A key step is the issuance of the NPRM, which explains the agency’s goals and rationale for rule changes and introduces the revisions. 

DOL’s proposed rule was published in the Federal Register on January 17, 2024. Until March 18, 2024, the public has the opportunity to submit written comments in response to the proposal. This is an important period for stakeholders to share feedback, questions and concerns with the issuing agency. While agencies are not required to address each and every comment in their final rule, they often make changes as a result of expert and practitioner feedback, new data, or compelling arguments for or against aspects of their proposed changes.  

It can take several months for an agency to review and respond to comments and to issue final rule language. Typically, final rules go into effect 30 days after publication in the Federal Register. And once that happens, another phase focused on compliance, interpretation and review begins. A detailed explanation of the federal rulemaking process is available here. 

What if I have other questions? The PAYA team at New America has developed a shareable FAQ document to respond to questions we have received or anticipate receiving from members of the PAYA Network and the field of youth apprenticeship more broadly. Please note that the responses in that document represent our interpretation and analysis of the NPRM and are not intended to be official guidance. We will update this document periodically as we receive new questions and information.

To submit a question that you would like us to answer or to help us improve an answer provided herein, please email paya@newamerica.org. We’ll do our best to respond.