TEGL2-07acc.pdf

ETA Advisory File Text

TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 2-07 TO ALL STATE WORKFORCE AGENCIES ALL STATE WORKFORCE LIAISONS ALL STATE WORKFORCE INVESTMENT BOARDS AND STAFF ALL LOCAL WORKFORCE INVESTMENT BOARDS AND STAFF ALL BUSINESS RELATIONS GROUP STATE LIAISONS ALL STATE RAPID RESPONSE COORDINATORS OFFICE OF APPRENTICESHIP FIELD TECHNICIANS OFFICE OF APPRENTICESHIP STATE AND REGIONAL DIRECTORS STATE APPRENTICESHIP DIRECTORS FROM EMILY STOVER DeROCCO s Assistant Secretary SUBJECT Leveraging Registered Apprenticeship as a Workforce Development Strategy for the Workforce Investment System 1. Purpose . The purpose of this Training and Employment Guidance Letter TEGL is to provide information and resources to support the use of Registered Apprenticeship by the workforce investment system as an effective approach to building a skilled and competitive workforce in regional economies. The 21 st century economy demands a workforce with postsecondary education credentials and the adaptability to respond immediately to changing economic and business needs. The public workforce system is playing a leadership role in meeting these demands by catalyzing the implementation of innovative talent development and lifelong learning strategies that will enable American workers to advance their skills and remain competitive in the global economy. Registered Apprenticeship a critical postsecondary education training and employment option available in every state in the country is an important component of these talent development strategies. Registered Apprenticeship is business- and industry-driven with more than 29 000 programs impacting 250 000 employers and almost 450 000 apprentices predominantly in high-growth industries that face critical skilled worker shortages now and in the foreseeable future. Full collaboration between the publicly funded workforce CLASSIFICATION Registered Apprenticeship Workforce Investment System CORRESPONDENCE SYMBOL OA OWI EMPLOYMENT AND TRAINING ADMINISTRATION ADVISORY SYSTEM U.S. DEPARTMENT OF LABOR Washington D.C. 20210 DATE July 12 2007 RESCISSIONS None EXPIRATION DATE Continuing -2- investment system and Registered Apprenticeship leverages each system s strengths to maximize the benefits in the context of regional talent development strategies. This TEGL provides information examples and policy guidance to support the full integration of Registered Apprenticeship into workforce system activities. The document is one of a number of products that the Employment and Training Administration ETA is releasing to assist regions in developing Workforce Investment Act and apprenticeship efforts that are mutually supportive. 2. References . The Workforce Investment Act Title I P.L. 105-220 August 7 1998 20 CFR parts 663 665 and 666 National Apprenticeship Act P.L. 75-308 The Wagner- Peyser Act 29 USC 49 et seq. Training and Employment Guidance Letter No. 17-05 Common Measures Policy for the Employment and Training Administration s Performance Accountability System and Related Performance Issues Training and Employment Guidance Letter No. 18-05 Using Workforce Investment Act Funds to Serve Incumbent Workers and Employed Workers Training and Employment Guidance Letter No. 13-06 Instructions for Workforce Investment Act and Wagner- Peyser Act State Planning and Waiver Requests for Years Three and Four of the Strategic Five-Year State Plan Program Years 2007 and 2008 Training and Employment Notice No. 17-06 Vision for 21 st Century Apprenticeship Training and Employment Guidance Letter No. 28-05 The Employment and Training Administration s ETA s New Strategic Vision for the Delivery of Youth Services Under the Workforce Investment Act WIA Expanding ETA s Vision for the Delivery of Youth Services under WIA to include Indian and Native American Youth and Youth with Disabilities and Training and Employment Guidance Letter No. 3-04 The Employment and Training Administration s ETA s New Strategic Vision for the Delivery of Youth Services Under the Workforce Investment Act WIA . 3. Overview of the National Registered Apprenticeship System . Registered Apprenticeship is a national training system that combines paid learning on-the-job and related technical and theoretical instruction in a skilled occupation. The purpose of a Registered Apprenticeship program is to enable employers to develop and apply industry standards to training programs that can increase productivity and improve the quality of the workforce. In the United States today 250 000 separate employers offer Registered Apprenticeship employment and training to almost 450 000 apprentices in such industries as construction manufacturing transportation telecommunications information technology biotechnology retail health care the military utilities security and the public sector. By providing on-the-job learning related classroom instruction and guaranteed wage structures employers who sponsor apprentices provide incentives to attract and retain more highly qualified employees and improve productivity and services. Regions that adopt robust Registered Apprenticeship programs in the context of economic development strategies create seamless pipelines -3- of skilled workers and flexible career pathways to meet current and future workforce demands. Principal Partners. The National Registered Apprenticeship system is a partnership among DOL State agencies industry leaders employers employer associations labor- management organizations primarily consisting of labor organizations and employers and educational institutions. Industries in partnership with state and federal apprenticeship offices develop and operate apprenticeship programs based on the skills and knowledge that business and industry needs from its employees ensuring that apprentices develop up-to-date and relevant skills. Program sponsors which include employers employer associations and labor-management organizations voluntarily operate and cover most or all costs of the program. The programs are registered with DOL or a federally recognized State Apprenticeship Agency SAA . Through a formal apprenticeship agreement program sponsors and apprentices agree to the requirements of the registered program. The National Apprenticeship Act NAA also known as the Fitzgerald Act enacted in 1937 authorizes the Federal government in cooperation with the states to oversee the nation s apprenticeship system. DOL s Office of Apprenticeship OA in conjunction with SAAs is responsible for registering apprenticeship programs that meet Federal and State standards issuing Certificates of Completion to apprentices encouraging the development of new programs through outreach and technical assistance protecting the safety and welfare of apprentices and assuring that all programs provide high quality training to their apprentices. DOL OA staff in 24 states and SAA staff in 26 states the District of Columbia and three territories share these responsibilities. Apprenticeship Program Structure. Registered Apprenticeship programs offer employment and a combination of on-the-job learning and related technical and theoretical instruction through a training provider. Apprentices are employed at the start of their apprenticeship and work through a series of defined curricula until the completion of their apprenticeship programs. The duration of training and the skills and competencies required for mastery are driven by industry. Traditional apprenticeship programs require a specific number of hours of on-the-job training. Increasingly industries are requiring competency-based training programs that reflect mastery of key skills and allow motivated workers to progress at their own pace. Currently the Registered Apprenticeship system approves time-based competency-based and a hybrid of time- and competency-based programs and helps industries transition to competency-based apprenticeship programs for enhanced effectiveness. Certifications earned through Registered Apprenticeship programs are recognized nationwide as portable industry credentials. The primary apprentice certification is a -4- Certificate of Completion which is awarded at the end of the apprenticeship. Many apprenticeship programs particularly in high-growth industries such as health care advanced manufacturing and transportation also offer interim credentials and training certificates based on a competency model that leads to a Certificate of Completion. There may be beginning intermediate advanced and specialty certification levels. Registered Apprenticeship programs also allow credit for previous apprenticeship-related experience. 4. Pre-Apprenticeship Strategies . For workers who may not have the fundamental skills to succeed in a Registered Apprenticeship program and youth who are exploring career options pre-apprenticeship training programs act as a bridge. These training programs which are operated by education community- or faith-based organizations can help apprenticeship candidates decide on an occupational track develop foundational skills and improve productivity once employed. Pre-apprenticeship programs operate an approved plan under which candidates participate in a short intensified training period in a school or training center with the intent to place them into Registered Apprenticeships upon completion or soon after completion of the program. Pre-apprenticeship can be used as a means of selecting apprentices under a particular program sponsor s approved program standards. DOL recognizes pre- apprenticeship programs but does not formally register them. Many pre- apprenticeship programs also operate in partnership with the workforce investment system. 5. Benefits of the Registered Apprenticeship Training Model . Registered Apprenticeship is a key component to the nation s talent development strategies in many high demand industry sectors. This unique industry-driven training is a proven effective method with many benefits. For employers benefits include Skilled workers trained to industry employer specifications to produce quality results. Increased productivity and knowledge transfer due to well-developed on-the-job learning. Enhanced retention. In FY 2006 82 percent of registered apprentices were still employed nine months after registration as apprentices. A stable pipeline of new skilled workers. Apprenticeship programs offer a predictable pipeline of program completers while established pre- apprenticeship programs provide access to the next generation of workers. An emphasis on safety training that may reduce worker compensation costs. For apprentices benefits include -5- Immediate employment in jobs that usually pay higher wages and offer career growth opportunities. In FY 2006 the average starting wage for an apprentice was 12.16. Higher quality of life and skills versatility. Portable credentials recognized nationally and often globally. Formal articulation agreements between apprenticeship training programs and 2- and 4-year colleges that create increased opportunities for college credit and future degrees. 6. Registered Apprenticeship Aligns with Workforce System Priorities . Registered Apprenticeship is a highly versatile training strategy that aligns with and advances the goals of key workforce investment system initiatives. Features of Registered Apprenticeship including its customized format the extensive industry knowledge of state and federal apprenticeship staff and its significant employment retention and wage outcomes make the program an effective means of meeting workforce system goals. By coordinating and collaborating with the knowledgeable professionals that make up the Registered Apprenticeship system the workforce system can increase the quality of its services to both its employer and worker customers and enhance activities in support of current workforce system priorities. Apprenticeship is an important addition to the suite of potential education and training services the workforce system provides to its customers. Below are goals of the workforce system that can be met by incorporating apprenticeship as a workforce strategy. Increasing access to workforce education and training. Adult learners with families and financial obligations frequently are unable to stop working while they gain additional education or workforce skills. Young adults may not be able to go to school full time without benefit of a job. Registered Apprenticeships are earn and learn opportunities and provide access to education and training that may not otherwise be accessible to many adults. Designing innovative programs that fuel regional economic competitiveness and create employment opportunities for career seeker customers. Registered Apprenticeship training can be a valuable tool in the broader suite of talent development approaches that support competitive regional economies and flexible talent that can adapt as jobs grow and or change. As an employer-driven model for competency development and skill mastery Registered Apprenticeship can support the development and advancement of worker pipelines for both emerging and established employers and regional industry sectors. Because apprenticeship programs include immediate employment for apprentices they are an excellent option for dislocated workers and others who are transitioning from declining industries. Registered Apprenticeship programs can also be an important part of industry growth strategies in regions where significant reskilling of the workforce needs to take place. Implementing apprenticeship and pre- -6- apprenticeship models that are aligned with growth strategies for regionally-critical industry sectors and clusters creates opportunities for workers at all levels of the career ladder to up-skill and advance to meet evolving skill needs and provides employers with the talented human capital needed for economic prosperity. Meeting the needs of at-risk youth. Apprenticeship is an important talent development option for youth as they seek postsecondary education and training that will lead to career opportunities in demand-driven occupations. Registered Apprenticeship and pre-apprenticeship programs provide many benefits that allow the workforce investment system to respond to the call of DOL s Youth Vision. In addition to the industry-driven nature of apprenticeship training apprenticeship involves high school community colleges and technical or alternative schools in the delivery of job-related classroom instruction. Apprenticeship also provides youth with the opportunity to earn while they learn offers professional development and employability skills training curricula such as that available from SkillsUSA and incorporates instruction that leads to the completion of a high school diploma or GED. 7. Call to Integrate Apprenticeship throughout the Workforce Investment System . In a demand-driven environment the public workforce system at the federal state and local levels works collaboratively with business and industry economic development education training providers and other key partners on talent development strategies and workforce solutions to provide workers with the skills businesses need. Registered Apprenticeship is a potential workforce solution that contributes to the development of industry-defined competencies and also serves as a proven industry-driven workforce education and preparation strategy for workers. The Registered Apprenticeship system is administered by ETA and represents a significant investment of knowledge systems and resources in our nation s talent development strategies. Registered Apprenticeship opportunities can and should be integrated throughout the workforce investment system as a means of leveraging resources across systems to better serve regional needs. In order to ensure that apprenticeship is consistently integrated into service delivery strategies for businesses and the workforce it is critical to support collaboration between the apprenticeship infrastructure the workforce investment system and the continuum of education at all levels. Strategies for collaboration and integration are discussed below. Specific examples of state and local collaborative efforts are provided in more detail in Attachments A and B. Attachment C provides contact information for specific models. Attachment D provides informational tools and resources to support development of new registered apprenticeship opportunities and models. WIA State and Local Strategic Planning. State and local Workforce Investment Boards WIBs have an opportunity to support integration of Registered Apprenticeship -7- through their regular strategic planning processes for WIA and the Wagner-Peyser Act. One highly effective strategy is to include apprenticeship training as a workforce strategy in the WIA state and local plans as a workforce solution for growing skills in targeted industry sectors. Business Engagement Strategies. WIBs and or One-Stop Career Centers can integrate apprenticeship into business engagement strategies by encouraging the development of new apprenticeship programs as a solution to meet business customer needs. WIBs and One-Stops can leverage business relationships and engage businesses jointly with apprenticeship staff. WIBs can further enhance strategic regional partnerships by integrating apprenticeship programming into their strategies for talent development and linking apprenticeship programs to other economic development entities and school district administrations alternative education programs adult basic education programs prisons and city county and state governments. An important asset that can be marketed to employers is the ability of apprenticeship staff to develop competency models which break the skills needed for any particular task into learning objects that then become the foundation for classroom curricula and training. This ensures that apprentices achieve the right skills to meet industry needs. Expanding Available Eligible Training Providers for ITAs. The WIA statute and regulations explicitly provide for flexibility in determining registered apprenticeship training programs as initially eligible providers of ITA-funded training services. This enables expanding the available training options to ITA recipients. Specifically the WIA regulations at 20 CFR 663.505 b 2 ii identify entities that carry out programs under the National Apprenticeship Act NAA as potential eligible providers of training services and the WIA regulations at 20 CFR 663.515 b empower local WIBs to determine the eligible training provider application procedures for apprenticeship programs registered under the NAA. As such apprenticeship programs may benefit from streamlined processes for becoming initially approved as eligible providers of training to ITA recipients without having to undergo the standard State agency review process 20 CFR 663.515 d . One-Stop Career Center Operations. At the One-Stop Career Center level a range of programmatic and operational activities can support closely integrated and coordinated functions. Career Guidance Strategies. Referral to apprenticeship and pre-apprenticeship programs can be routinely integrated into the career guidance and career exploration services offered through the One-Stop Career Center system both virtually and as part of staff-assisted services. Service Delivery Design. Co-locating apprenticeship staff in One-Stop Career Centers allows them to work collaboratively with WIA case managers and veterans representatives to place career seekers with apprenticeship sponsors -8- and to market and establish programs. Even when programs are not co-located One-Stop Career Center and Registered Apprenticeship staff can be encouraged to work together to market apprenticeship and refer appropriate candidates. Coordinated Education and Career Outreach. One-Stop Career Centers can co- sponsor career fairs and other outreach activities related to education and career opportunities with local representatives of the Registered Apprenticeship system and can market apprenticeship opportunities to both employers and workers. Coordination for Pre-Apprenticeship. One-Stop Career Center staff can coordinate the development of pre-apprenticeship or training venues between participating Registered Apprenticeship programs and community-based organizations committed to provide related work experience to prepare candidates for Registered Apprenticeship. Policy Development and Funding Strategies. Collaboration with apprenticeship can be further enhanced through the development of policies that facilitate and encourage partnership. For instance states may issue policy to provide guidance around the operation of such partnerships and to highlight models of successful collaboration. States and local areas may organize regular roundtables or other policy forums in which workforce system apprenticeship system education and employer stakeholders are brought together to discuss policy issues and explore collaborative opportunities. State and local workforce system leaders may explore opportunities for leveraging existing workforce system funding with other funding sources to support and advance apprenticeship models. A more detailed discussion of opportunities to leverage funding follows. 8. Funding Sources to Support Registered Apprenticeship . Historically employers industry associations and labor-management organizations have been instrumental in developing and funding Registered Apprenticeship programs. The public workforce system has an important role to play in leveraging and advancing these investments. This can be accomplished both through workforce system funding strategies and through the system s unique position as the convener and catalyst of a broad array of workforce and economic development partners all of whom have a stake in the acceleration of competency-based education and training models that enable workers to meet the evolving skill needs of the 21 st century work environment. Workforce system leaders with their education and employer partners can play the critical role of identifying and aligning funding that may support both theoretical and practical education advancing skills upgrading models and supporting workers career advancement based on increasing mastery of the skills required in current and emerging workplaces. In today s economy states and economic regions must continuously identify new approaches to ensuring that the education levels of the current and projected workforce align with the anticipated skill and competency needs -9- of both established and emerging industries. The workforce system can support these efforts by ensuring that the full complement of education employer and economic development partners including new or non-traditional partners are at the table and involved in discussions related to the alignment and commitment of resources to support innovative training and advancement models. Leveraging Workforce Investment Act Funding . Ensuring that apprenticeship is included as part of the full complement of education and training resources provided to job seekers and employers presents multiple opportunities for the public workforce system to leverage WIA funds in innovative and creative ways. The Workforce Investment Act provides the workforce system with significant flexibility to implement responsive training and education solutions and state and local workforce system leaders are urged to consider ways in which their existing WIA training resources may be invested strategically to support apprentices and apprenticeship sponsors. For example while most Registered Apprenticeship programs are funded by program sponsors the workforce system can help to expand apprenticeship programs regionally by strategically deploying WIA funds to temporarily offset training costs for employers who might need to understand the potential returns on their investment before undertaking significant training costs. See Attachment B for specific examples of how states are using WIA funds to offset training costs. Individual Training Accounts ITAs ITAs described at 20 CFR 663.400 663.440 are training and education financing accounts established on behalf of eligible adults and dislocated workers that enable these individuals to purchase training for in-demand occupations and careers from eligible providers of their own choosing. Both employed and unemployed adults and dislocated workers may be eligible to receive ITAs though employed individuals must be determined to be in need of training services to obtain or retain employment that leads to self-sufficiency in order to receive ITAs see 20 CFR 663.220 b 20 CFR 663.230 and 20 CFR 663.310 as well as the Preamble to the Final Rule for WIA 65 Fed. Reg. 49294 49326 Aug. 11 2000 . As the primary method of training service purchase and delivery in the public workforce system ITAs can provide eligible apprentices with financial support for the related instruction portion of their apprenticeships. In addition ITAs may be used to provide eligible individuals with access to pre- apprenticeship training in preparation for formal apprenticeships. The use of ITAs to support the related instruction e.g. classroom and distance learning portion of apprenticeship training or pre-apprenticeship training may be advantageous for a number of reasons. ITAs support customer choice in selecting training providers empowering apprentices and pre-apprentices to make informed education and career decisions. WIA funded training must be directly linked to employment opportunities in the local area 20 CFR 663.310 c . This can be a useful -10- tool to support Registered Apprenticeships focus upon employer-driven training design and delivery. When WIBS and One-Stop Career Centers use ITAs as a mechanism to support apprenticeships it is important to remember the eligibility requirements associated with the WIA Adult and Dislocated Worker programs. Another consideration to keep in mind is that ITAs are only available to eligible individuals who are unable to obtain grant assistance from other sources to pay for education and training such as State- funded training funds Pell Grants and Trade Adjustment Assistance or who require assistance beyond that which is available from other grant sources in order to pay for the costs of training see 20 CFR 663.310 d and 20 CFR 663.320 a 2 . The intent of these limitations is to ensure that complementary education and training resources are leveraged to the greatest extent possible and to reduce duplication in service provision. Thus in designing education apprenticeship program sponsors and local WIBs should jointly identify the full complement of education and training funding available in the area. Customized Training Models When working with employers on training and workforce solutions WIBs and One- Stop Career Centers may find it valuable to utilize customized training to subsidize the classroom training portion of an apprenticeship model. For example a local WIB could offer a particular course of training for apprenticeship sponsors in a targeted sector such as advanced manufacturing across a region whose economic base revolves around this sector. Local WIBs could also offer linked courses of training across connected industry sectors such as construction and transportation to more broadly support the economic clusters driving job growth in that particular region. This approach provides the ability to leverage employer investments with WIA funding to increase the skilled labor pool in a regional economy. Customized training is typically based upon a contractual agreement between a local WIB and an employer or group of employers to provide specialized training to employees. Under WIA both potential new hires and incumbent employees may participate in customized training though incumbent employees must be determined by the local WIB to not be earning self-sufficient wages in order to participate 20 CFR 663.720 a and their training must be related to the introduction of new technologies in the workplace skills upgrading for new jobs or other related purposes 20 CFR 663.720 c . Customized training arrangements entail the commitment by the employer to hire trainees after successful training completion or to continue to employ incumbent -11- employees after successful training completion 20 CFR 663.715 b . In addition employers that enter into customized training agreements under WIA typically pay for at least 50 percent of the cost of the training 20 CFR 663.715 c though ETA has granted waivers of this matching requirement to allow for employer match on a sliding scale based upon business size. Under the waiver the following scale is permitted in two targeted categories of business with 100 or fewer employees No less than 10 percent match for employers with 50 or fewer employees and No less than 25 percent match for employers with 51 100 employees. WIA-funded customized training models offer several operational advantages that facilitate their use in the Registered Apprenticeship context. Customized training may be designed and delivered for multiple employers such as in an industry sector or for groups of targeted employees of a single employer creating the opportunity to develop economies of scale that truly maximize and leverage the contribution of the workforce system and participating employers. In addition while providers of customized training must meet the performance requirements outlined at 20 CFR 663.595 they are not subject to the other requirements for eligible training providers outlined in 20 CFR 663 Subpart E or in WIA Section 122. These streamlined requirements for eligible providers of customized training may facilitate the ability of apprenticeship sponsors to collaborate with the public workforce system in the design and delivery of programs of customized training. Finally in states that have obtained waivers to permit small- and medium-sized employers to fund customized training on a sliding scale below the mandated 50 percent customized training provides a flexible model for assisting these smaller businesses in expanding their talent pool and upgrading the skill levels of current employees. On-the-Job Training OJT Defined at WIA Section 101 31 OJT can be a useful training methodology for employers wishing to upgrade the skills of new hires and incumbent workers and keep workplaces current with the evolving skill and technology demands of the 21 st century economy. Under traditional OJT partnerships employers fund and deliver skills upgrade training at the workplace to participating employees and the public workforce system leverages employers training investments by contributing up to 50 percent of the OJT participants wages in recognition of the costs associated with providing the training 20 CFR 663.710 . Like customized training models OJT may provide apprenticeship sponsors with a talent development strategy that supports apprentices increasing mastery of technical skills. Furthermore because the content of OJT is largely designed by employers the workforce system may find that this training model is an attractive tool for increasing and expanding its partnership with Registered Apprenticeship programs. -12- Similar to WIA-funded customized training models OJT also offers several operational advantages that may facilitate workforce system and Registered Apprenticeship collaboration. Like providers of customized training providers of OJT may take advantage of the streamlined eligible training provider requirements outlined at 20 CFR 663.595. In addition ETA has granted waivers to states to increase their capacity to offer OJT as a talent development strategy for small- and medium-sized businesses. Under this waiver approved states may match employers training contributions up to 75 percent for businesses with 100 or fewer employees which may provide an attractive incentive for smaller apprenticeship sponsors to partner with the public workforce system in the design and delivery of the OJT component of Registered Apprenticeship. WIA State-wide Reserve and Other State Funding Sources Governor s statewide 15 percent funds reserved under WIA Section 128 a for statewide activities provide the most flexible WIA funds available to states. Up to 15 percent of funds allotted to states for adult dislocated worker and youth activities may be reserved by the Governor for statewide workforce investment activities and may be combined and used for any of the activities authorized in WIA Sections 129 b 134 a 2 B or 134 a 3 A which are further described in 20 CFR 665.200 and 665.210 regardless of originating funding streams. The Act and the regulations identify required statewide activities and other optional activities these lists however are not all-inclusive. States have considerable flexibility to develop and implement these and other activities including apprenticeship and pre-apprenticeship models using reserve funds as long as these activities are consistent with the purpose of WIA. Because individuals served with Governor s 15 percent reserve funds are not subject to the eligibility requirements of the respective funding streams from which the reserve is drawn these funds offer a particularly flexible way to develop and grow training and education partnerships for pre-apprentices and apprentices. Local activities funded with WIA Adult and Dislocated Worker program formula funds must conform with the eligibility requirements associated with these funding streams. States may want to seek waiver authority to allow greater flexibility in using funds to support apprenticeships. ETA has granted waivers to states to enable local areas to use up to 50 of their Adult and Dislocated Worker funds as though it were state set-aside funding which makes the funding much more flexible and eliminates the need to determine eligibility. In addition incentive funds received by states under WIA Title V General Provisions Sections 503 a and 503 b and described at 20 CFR 666.200 and 666.210 are also highly flexible and provide an opportunity for states to implement creative programs in partnership with apprenticeship sponsors. States may use these funds to carry out innovative programs under WIA Titles I and II and the Carl D. Perkins Vocational and Technical Education Act regardless of which Act is the source of the incentive funds. -13- Should states wish to modify their approved incentive grant plans and corresponding grant documents to incorporate models for leveraging incentive funding for pre- apprenticeship and or Registered Apprenticeship the Department will work with states to make any necessary and allowable modifications. State workforce system leaders and apprenticeship stakeholders are strongly encouraged to consider other state funding sources to support and advance innovative pre-apprenticeship and Registered Apprenticeship. Other potential sources of funding for apprenticeship programs include state general revenue funds as well as other funds appropriated by state legislatures such as state education monies targeted for career and technical education. 9. WIA Performance Measures and Apprenticeship . Apprenticeship strategies offer the opportunity for states and local WIBs to enhance their performance under the Workforce Investment Act. Apprenticeship is a proven model for effectively educating and training workers promoting retention and advancing the apprentice s career and earnings. Below is information related to performance measurement that may be useful to consider when integrating apprenticeship as an employment or training opportunity provided under WIA and or Wagner-Peyser. Registered Apprenticeship as Employment. WIA and Wagner-Peyser clients who receive core and intensive services resulting in their entry into a Registered Apprenticeship program become employees of the Registered Apprenticeship sponsor and can be tracked against Common Measures associated with employment. Registered Apprenticeship as Training. Apprentices who receive WIA services after enrollment in Registered Apprenticeship to support classroom or on-the-job training or to provide other services should be treated as incumbent workers. Retention and earnings outcomes should be tracked in this case but not the placement outcome. Identifying the Point of Exit. For the purposes of tracking and common measures WIA and Wagner-Peyser clients associated with apprenticeship programs should be exited from the workforce system after the completion of WIA Wagner-Peyser associated activities. It is not necessary to track apprentices through to the completion of their apprenticeship program unless they are supported by workforce system resources for the entire duration. Thus an apprentice who receives workforce system resources to support specific portions of classroom training may be exited from the program upon completion of that training even if they continue in the apprenticeship program for a longer period of time. Tracking Earned Credentials. The workforce system should track only those credentials that are earned by an apprentice while they are enrolled in WIA or Wagner-Peyser. -14- Where tracking of earned credentials is required the workforce system should track the interim credential earned by the apprentice while co-enrolled. For example apprentices in competency-based programs may receive a Certificate of Training upon completion of each level working towards a Certificate of Completion. Additionally many apprenticeship sponsors have negotiated articulation agreements with community and technical colleges that give college credit for the related instruction component of the program. All of these interim credentials may be recorded as appropriate credentials for the purposes of reporting under the Common Measures. Please note that the DOL Office of Apprenticeship OA tracks cohorts of apprentices throughout their participation in the Registered Apprenticeship system for the purpose of reporting outcomes and drawing conclusions about program effectiveness. The Common Measures are also used for this purpose. 10. Action Required. Registered Apprenticeship is a critical component of talent development strategies across the country. With the combination of on-the-job learning related instruction and mentoring the apprenticeship model is a powerful tool for addressing the skill shortages that many industries face. It also provides the grounded expertise and knowledge individuals need to do their jobs well and advance in their careers. The model offers an efficient flexible training strategy responsive to new technology that will keep workers up-to-date on skills they need to do their jobs. In the current environment of global economic competition it is critical that the workforce investment system integrate the resources of the Registered Apprenticeship system into its talent development strategies. ETA urges state and local leaders to consider the benefits of Registered Apprenticeship while developing their workforce investment systems plans and programs and to fully utilize apprenticeship as a unique model that incorporates employment postsecondary education and training. Some next steps to consider include. Mapping existing Registered Apprenticeship programs in your region. Strengthening collaborative relationships between WIBs and apprenticeship staff to explore opportunities to leverage Registered Apprenticeship as a significant workforce development strategy. Educating One-Stops Career Centers and WIBs about Registered Apprenticeship including how to collaborate with apprenticeship staff how to use WIA funding in support of Registered Apprenticeship and how Registered Apprenticeship applies to performance outcomes under the Common Measures. -15- Discussing apprenticeship as a workforce tool with leaders focused on workforce issues such as legislators governor mayors county executives council members and department heads and sharing with them the concepts addressed in this TEGL. Adopting policies and procedures to better integrate Registered Apprenticeship training as an option offered by the workforce investment system using but not limited to the examples found in this TEGL. Encouraging Registered Apprenticeship sponsors to contact their local WIBs to inform them about their training programs inquire about becoming eligible training providers and discuss opportunities for collaboration and partnership. 11. Inquiries . Questions should be directed to the appropriate ETA Regional Office Office of Apprenticeship Regional Director or State Director. Contact information can be found in Attachment D.