National Skills Coalition and Seven Other National Organizations Express Concern in Public Comments about IRAP Proposal

August 27, 2019

Washington, D.C. — National Skills Coalition – along with New America, Advance CTE, CLASP, Jobs for the Future, National Association of State Workforce Agencies, National Association of Workforce Boards and National Fund for Workforce Solutions – today submitted public comments on the Trump administration’s Industry-Recognized Apprenticeship (IRAP) proposal.   

“The undersigned organizations affirm the importance of reforming federal regulations to increase employer participation in apprenticeship, especially in nontraditional apprenticeship occupations. However, we are concerned that the creation of a parallel system of Industry Programs may further fragment our national apprenticeship system and introduce programs of widely varying quality,” the eight organizations wrote. All eight are members of the Apprenticeship Forward Collaborative – a network of national organizations committed to expanding apprenticeship – which recently released a set of principles for expanding quality apprenticeship.

The group submitted the following seven recommendations to the Department of Labor on the role of Standards Recognition Entities (SREs) in expanding industry programs:

  1. Ensure industry programs are created in response to strong business demand for apprentices. The Department should support the documentation and dissemination of evidence on how apprenticeship can help meet business’ demand for skilled workers, highlight businesses that have successfully used apprenticeship to build their worker pipeline, and support the development of apprenticeships for companies of all sizes, in all industries, and for nonprofit and government employers.
  2. Ensure industry programs advance the livelihood of U.S. workers. The Department should require SREs to ensure programs provide valuable related instruction, wage increases, mentoring and safety training requirements. Apprenticeships should also include occupational standards that describe the competencies apprentices must achieve to gain certification and how apprentices will contribute to the production of goods or services within their on-the-job training.
  3. Support partnerships between local businesses, the workforce and education systems, human services organizations, labor and labor-management partnerships, and other community-based organizations. The Department should ensure SREs engage with state, local and regional partnerships and stakeholders to expand industry recognized apprenticeship opportunities. These partnerships ensure industry programs will align with current workforce, education and human services programming in which federal, state and local governments and the private sector currently invest.
  4. Ensure access into industry recognized programs for new and incumbent workers that supports the success of a diverse pipeline of apprentices. The Department should ensure SREs work with industry programs to provide underrepresented populations with access to new and existing apprenticeship opportunities, support measures to improve gender and racial/ethnic diversity in apprenticeable occupations and invest in supports that improve retention and enable success for workers with barriers to employment while providing businesses with a return on investment.
  5. Maximize alignment between industry programs and K-12 and postsecondary educational opportunities to support lifelong learning and skill attainment. The Department should support the integration of higher education into industry recognized apprenticeships to create transferable, for-credit credentials that meet business and worker demand. Programs should also expand pathways that reach into our high schools to offer more American students high-quality dual enrollment opportunities through the apprenticeship model.
  6. Support data collection and dissemination to continuously improve outcomes for business and workers. The Department should require and support the collection and distribution of disaggregated data on industry program enrollment, completion and outcomes, promote research on the return-on-investment of programs, and empower state integration of outcomes with state longitudinal data systems to foster equitable access to and completion of quality apprenticeships.
  7. Ensure industry programs build on innovative state and local practice. The Department should highlight and bring best practices from across the country to scale, including those developed throughout our country’s history with Registered Apprenticeship.

Read the complete comments here