What Youth Apprenticeship Practitioners Should Know About WIOA & Perkins Planning

It’s only February, but we already know 2024 will see the kinds of noteworthy events that do not roll around every year: a presidential election, the Summer Olympics, leap day – not to mention a total solar eclipse. But for the workforce development and career and technical education (CTE) fields, 2024 will be notable for another reason.

This year, states will submit new WIOA and Perkins plans, strategic documents that will inform states’ priorities for federal workforce development and CTE programs over the next four years. (WIOA stands for Workforce Innovation and Opportunity Act, and Perkins refers to Strengthening Career and Technical Education for the 21st Century Act.) These new plans are due over the next few months and will go into effect later this year. They will be the first four-year WIOA and Perkins plans developed since the pandemic reshaped the American economy and since the federal government passed the Infrastructure Investment and Jobs Act, the CHIPS and Science Act, and the Inflation Reduction Act – major legislative packages with implications for workforce development.

Because youth apprenticeship can be an effective tool for achieving WIOA and Perkins performance goals, the plans represent an opportunity for states to articulate how youth apprenticeship factors into their overall workforce development and CTE strategy. This post explains what youth apprenticeship practitioners should know about WIOA and Perkins state plans and how plans may impact and advance youth apprenticeship.

Understanding WIOA state plans

What is a WIOA state plan?

The Workforce Innovation and Opportunity Act – usually abbreviated WIOA – is the federal legislation governing the workforce development system. In order to receive WIOA funding, each state must develop and submit to the U.S. Departments of Labor (USDOL) and Education (ED) “a four-year strategy and operational plan” that outlines how its workforce development system supports workers and jobseekers, including youth. States update their plans every two years. The next state plans are due on March 4, 2024 and will be considered approved by the departments after 90 days.

Many different stakeholders are involved in developing state plans. The state workforce development board leads and coordinates the process, while governors’ offices are ultimately responsible for formally submitting the plan to the DOL. The state agencies that administer WIOA’s six core programs help draft the sections relevant to their programs. States are also required to engage different stakeholders in the development process, including higher education institutions, community-based organizations, businesses, and any other stakeholders with an interest in any of the six core programs.

What should practitioners know about WIOA state plans and youth apprenticeship?

There is no mandate for states to specifically discuss youth apprenticeship in their WIOA plans or to fund youth apprenticeship with WIOA dollars. But because youth apprenticeship is a proven education and training model that can help states reach their performance metrics, many states may incorporate incorporate pre-apprenticeship or registered apprenticeship — both of which can serve youth — as a critical component of their workforce development strategy.

Work experience in the WIOA Youth program. WIOA mandates that local workforce development boards offer a set of youth-specific workforce development programs, called the WIOA Youth program, which the federal government provides formula funding to support. Work experience is a crucial part of the WIOA Youth program: local workforce development boards must spend at least 20% of their WIOA Youth funds on work experience and USDOL requires state plans to describe how local boards will prioritize work experience, including quality pre-apprenticeships and Registered Apprenticeships (RAs), in their Youth programs. USDOL only recently clarified that spending on youth RAs counted towards the 20% spending requirement. With this new, clearer guidance, state plans may be more explicit about RA’s role in their Youth program — and therefore might offer local workforce boards another reason to direct WIOA Youth funding towards youth RA once plans are enacted.

Governor’s reserve. Youth apprenticeship practitioners should pay attention to the section of their state’s plan that describes how the state intends to spend the “Governor’s reserve.” Governors can set aside up to 15% of their WIOA Youth formula funds for WIOA-aligned programs that address specific priorities and target populations. While governors are not required to spend this money on youth apprenticeship, some may choose to do so, especially if youth workforce development is a particular focus area for their administration. Even if a governor does not set aside money specifically for youth apprenticeship, the reserve may be spent on other activities like supportive services that youth apprenticeship programs can still leverage.

WIOA alignment with Investing in America. Many state plans will likely outline strategies for leveraging new federal investments in workforce development to support WIOA programming, and there may be opportunities for youth apprenticeship programs to take advantage of this alignment. As noted above, the upcoming four-year WIOA plans are the first to be developed since the federal government enacted the Infrastructure Investment and Jobs Act, the CHIPS and Science Act, and the Inflation Reduction Act. Collectively dubbed Investing in America (IIA), these three major pieces of legislation all include workforce development funding.

USDOL and the ED have issued guidance encouraging states to use this planning process to align their WIOA programming with the new IIA funding. Many of IIA’s workforce development provisions include pre-apprenticeship and Registered Apprenticeship as an allowable activity, and some specifically require them. Practitioners should review state plans to understand how their state will coordinate WIOA programming with IIA opportunities and contact their local WDB for more information about leveraging IIA funds.

Understanding Perkins state plans

What is a Perkins V state plan?

The Strengthening Career and Technical Education for the 21st Century Act (known colloquially as “Perkins” or “Perkins V”) supports CTE programming for both youth and adults through $1.4 billion in federal formula grants to states. Like WIOA, Perkins requires state planning, though these plans can take a slightly different shape from their WIOA counterparts.

This year, to receive their Perkins grant, each state must submit either 1) a four-year state plan outlining their state strategy and priorities for CTE programming, or 2) revisions to their state-determined performance levels, indicators that measure the state’s progress towards its established CTE goals. States may also choose to incorporate their Perkins planning into their state’s WIOA plan to create a WIOA combined plan. WIOA combined plans are due March 4, 2024, and Perkins-only plans and performance levels revisions are due May 10, 2024. No matter which submission option states choose, they must still engage stakeholders through a public comment process and extensive consultation.

What should practitioners know about Perkins state plans and youth apprenticeship?

Like WIOA, Perkins does not require state plans to specifically address or include youth apprenticeship, though states may choose to do so. Youth apprenticeship stakeholders should pay attention to some specific plan elements, outlined below, that can affect youth apprenticeship programming.

Comprehensive local needs assessment. In their four-year plans, states may provide updated guidance around the comprehensive local needs assessment (CLNA), a key aspect of Perkins’ implementation. The CLNA is a collaborative process in which local eligible Perkins recipients assess how their CTE programming stacks up against a set of indicators, including alignment with local labor market needs. They must conduct this assessment in consultation with local stakeholders, which can include youth apprenticeship programs and their employer partners. Youth apprenticeship practitioners should review state plans for updated information about their state’s CLNA requirements. Engaging with a CLNA process provides youth apprenticeship leaders the opportunity to better understand which occupational pathways are viable given their local area’s labor market information. It also offers employer partners a chance to advocate for programs that are aligned with their talent needs.

Program quality indicators. Perkins mandates that states select (at least) one of three program quality indicators against which their secondary CTE programs are measured. States can choose to measure the percentage of CTE concentrators graduating from high school who have either 1) participated in work-based learning (WBL) 2) attained a postsecondary credential or 3) earned postsecondary credit. States then create performance-level targets for their chosen indicator. Youth apprenticeship leaders should review their state’s plans for the indicators and targets, which can provide insight into state CTE priorities.

Practitioners should also make sure they know how youth apprenticeship can help schools reach those state benchmarks. For example, in the 27 states that have selected WBL as an indicator, youth apprenticeship leaders should connect with their state CTE agency to ensure that youth apprenticeship counts as a form of WBL under the state’s definition. High schools in these states need to create WBL opportunities for their students, so youth apprenticeship practitioners should be able to explain to education partners how youth apprenticeship will support them in reaching the WBL participation target. This positioning helps schools clearly understand the value-add youth apprenticeship can offer their institutions.

Funding priorities and opportunities. State plans often provide a big picture overview of how the state’s Perkins grant is allocated. Youth apprenticeship leaders should review this information to understand state and local funding priorities and potential opportunities to align funding with their own program. For example, many registered youth apprenticeships will be able to leverage local Perkins funding by incorporating existing CTE classes into the apprenticeship’s related instruction. State plans might also discuss how the state intends to braid Perkins funding with other state or federal funding streams to support CTE. Youth apprenticeship leaders should be aware of these plans for resource alignment so they can understand the funding opportunities for which their program may be eligible.

Getting involved in state plan development

Youth apprenticeship practitioners who are interested in informing their state’s WIOA plan can contact their state and local workforce boards to learn about opportunities for public comment before the plan’s submission. Similarly, practitioners can connect with their states’ CTE agency and their local education agency to learn about the public comment process and avenues for stakeholder engagement. Even if it’s too late to engage in WIOA and Perkins planning processes in their state, youth apprenticeship stakeholders should still understand what the final plans include – and connect with their workforce boards and CTE agencies to explore opportunities for supporting the state goals articulated in the plans.

Many thanks to our colleagues Jordan Morang of National Governors Association and Steve Voytek of Advance CTE for providing input and guidance that shaped this article.