In proposed apprenticeship amendment, Congress might join DOL in putting the cart before the horse

On June 12th, the House of Representatives will vote on an amendment to the FY 2020 Labor, Health and Human Services, Education, and related agencies appropriations bill that would make “Industry-Recognized Apprenticeship Programs” (IRAPs) eligible for federal funding. The amendment, proposed by Rep. French Hill (R-Ark.) would apply to a proposed $250 million appropriation to support the expansion of apprenticeship programs. The bill’s current language limits grant eligibility to Registered Apprenticeships; the Hill amendment would remove that restriction, allowing the Department of Labor (DOL) to fund the development of IRAPs through discretionary grant programs as well.

The problem is we don’t know precisely what IRAPs are or how they will work. The Trump administration still has not issued any clear guidance on what makes an apprenticeship “industry-recognized.” As a result, the Hill amendment would open up federal funding to an as-yet-undefined type of apprenticeship program.

Registration isn’t perfect, but the proposed IRAP system could sacrifice some important quality assurance measures and apprentice protections to create a small amount of flexibility in program design. Rules requiring that apprentices earn higher wages as they gain skills—one of Registered Apprenticeship’s biggest benefits to learners—could be weakened or eliminated. Quality assurance could be delegated to private entities, some without any experience in program evaluation and monitoring. And Registered Apprenticeship’s equal employment opportunity requirements might not apply to IRAPs at all.

Once removed, those safeguards would be hard to win back. But the truth is that it’s hard to do an effective side-by-side comparison of IRAPs and Registered Apprenticeships. Though IRAPs have been in the works for two years under the Trump administration, DOL still hasn’t begun the rulemaking process that will define what IRAPs are and how they will work.

Taking into account all we know (and don’t know) about IRAPs so far, guaranteeing these programs access to taxpayer dollars seems like a bad idea. The following FAQs explore the Trump administration’s IRAP concept so far and how it differs from Registered Apprenticeship. For a deeper dive into our concerns about the model, you can read our submissions for the first and second public comment periods for an information collection request issued in support of IRAPs late last year.

What is an Industry-Recognized Apprenticeship Program?

An Industry-Recognized Apprenticeship Program (IRAP) is a proposed new type of apprenticeship program that would exist alongside the Registered Apprenticeship model that has been used for over 80 years. The Trump administration’s June 2017 executive order on Expanding Apprenticeships in America called for the establishment of IRAPs.

Like Registered Apprenticeships, IRAPs would include a paid-work component and a class-based educational or instructional component. Other proposed quality criteria include mentorship, safety provisions, and the ability to earn industry credentials. However, no regulations have been drafted to formalize the specific requirements of IRAPs, nor how these requirements would be enforced.

What is the difference between an IRAP and a Registered Apprenticeship program?

Though IRAPs could share some characteristics of Registered Apprenticeships, they would not include a contractual agreement between apprentice and sponsor, and do not guarantee progressive wages for apprentices as their skills increase. Current regulations do not establish a formal minimum time to complete a Registered Apprenticeship, but they do recommend that programs last no less than one year; we’ve seen no evidence yet of any such guideline for IRAPs. Additionally, regulations that pertain to equal employment opportunity do not yet apply to IRAPs.

Why was the IRAP model developed?

Relatively few Americans train for work using apprenticeships. Though there are complex reasons for low apprenticeship utilization in the United States, some employers and industry associations argue that procedures for registering apprenticeships discourage new sponsors from starting up programs, especially outside of industries that have traditionally used apprenticeship. IRAPs aim to increase apprenticeship availability by reducing government oversight of apprenticeship programs. However, it is unclear whether the IRAP model on its own will substantially increase the number of quality apprenticeship programs that employers provide.

Who can develop and deliver an IRAP?

Like Registered Apprenticeships, IRAPs could be developed and delivered by a variety of organizations, including trade and industry groups, companies, non-profit organizations, educational institutions, unions, and joint labor-management organizations.

What quality assurance processes apply to IRAPs?

In the procedural guidelines it has published so far, DOL has suggested that all IRAPs would be certified by a new type of industry accrediting body. These bodies could include industry associations, employer groups, labor management organizations, educational institutions, and community-based organizations. It’s unclear whether an organization providing IRAPs can also serve as an accreditor for its programs—a situation that would create possible conflicts of interest.

On July 27, 2018, DOL released a Training and Employment Notice (TEN), a form of non-regulatory guidance, that provided a framework for IRAP accreditation. An information collection request (ICR) issued in September 2018 provides further hints as to how IRAP quality assurance would work, but in the absence of formal regulations, it remains impossible to say what IRAPs would look like in practice.

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