I.Purpose
This policy letter is issued as guidance to local workforce development
areas (local areas), regarding the criteria for state recognition of effective pre-apprenticeship
programs that prepare individuals to succeed in Registered Apprenticeship training.
This information is meant to assist in the development of local area policies on
the use of pre-apprenticeship training in WIOA, in the Comprehensive Case
Management and Employment Program (CCMEP), in other employment and training services,
and in fulfilling state standards for secondary education attainment.
II.Effective
Date
Immediately
III.Background
Registered Apprenticeship (RA) is a training model combining on-the-job
training with related classroom instruction. RA has a long history of effectiveness
providing the skills that workers need to compete successfully in technical occupations.
RA programs for certain occupations have historically had difficulty
enrolling and graduating enough apprentices to meet the labor demands of employers.
The apprentice shortage is caused in part by a lack of public awareness about the
benefits of RA training, and by gaps in the preliminary skills necessary to qualify
for enrollment. Pre-apprenticeship combines basic skill instruction, work experience,
pre-occupational training, and public and private supportive services, to maximize
individual chances of successful apprenticeship training.
Ohio is a national leader in identifying and promoting best practices
for pre-apprenticeship. In response to the need for qualified training applicants,
Ohio RA sponsors have been active in building local pre-apprenticeship programs.
Their experience and that of other experts nationwide, enabled the Ohio State Apprenticeship
Council (OSAC) in 2012 to formulate procedures and criteria for state recognition
of high-quality pre-apprenticeship programs. That OSAC action forms a basis for
the present policy letter.
This letter relates and expands on the OSAC criteria, and provides
resources and guidelines for applying the pre-apprenticeship model in WIOA and
CCMEP activities for youth and adults; in Career and
Technical Education (CTE) systems; and in federally funded career services including
but not limited to those connected with Temporary Assistance for Needy families
(TANF), Trade Adjustment Assistance (TAA), Rehabilitation Services, the Community Services Block Grant (CSBG), Housing and
Urban Development Employment and Training (HUD E&T) programs, and
Department of Agriculture (USDA) Supplemental Nutrition Assistance Program
Employment and Training (SNAP E&T).
IV.State
Requirements
The State of Ohio is committed to facilitating its citizens' access
to the proven advantages of Registered Apprenticeship training. Quality pre-apprenticeship
programs can provide an important bridge to apprenticeship for Ohioans.
The goal of State Recognized Pre-Apprenticeship is to provide the
skills and work experience needed to be successful in a Registered Apprenticeship
program.
Though pre-apprenticeship training is not subject to laws governing
the Registered Apprenticeship system, it has a direct effect on stakeholders in
that system. For the benefit of those stakeholders - the workers, employers, and
apprenticeship sponsors of Ohio - the Ohio Department of Job and Family Services
(ODJFS) establishes the following means to identify and publicly recognize quality
pre-apprenticeship training. The procedures described are to be overseen by the
Department's ApprenticeOhio Unit, which is also identified in state rules as the
Council Office.
Eligibility for Recognition
To be eligible for state recognition of quality training, a pre-apprenticeship
program must be conducted in conformity with an operating plan that describes the
program's objectives and practices, and that meets the following criteria.
(A)Equal
Employment Opportunity (EEO) -- The plan must contain the following equal
opportunity pledge as defined in OAC 5101:11-5-01 for Registered Apprenticeship
programs, to be applied to trainees of the applicant pre-apprenticeship program,
and must also include provisions for ensuring fairness and affirmative action in
recruitment, selection, and treatment of trainees.
"In the recruitment, selection, employment, treatment, and training
of apprentices [Name of sponsor] will not discriminate based on race, color, religion,
national origin, sex (including pregnancy and gender identity), sexual orientation,
genetic information, disability, Hispanic ethnicity, or age above forty years. [Name
of sponsor] will take affirmative action to provide equal opportunity in apprenticeship,
and will operate the apprenticeship program as required under Title 29 of the Code
of Federal Regulations, part 30, and the equal employment opportunity regulations
of the state of Ohio."
(B)Enrollment
-- The operating plan must state the criteria for eligibility to enroll in the program,
and describe the application, selection, and enrollment procedures. All methods
used in, and leading to, the selection of applicants for pre-apprenticeship, shall
be applied consistently and fairly, and shall be subject to approval by the Council
Office.
(C)Instructional
content -- The operating plan shall describe the details of training, to
include:
(1)the apprenticeable
occupation(s) or occupational sector(s) for which participants will be trained;
(2)a definition of
progressive stages of training and criteria for enrollment at any of those stages;
(3)a procedure for
periodically evaluating each pre-apprentice's progress in the program, including
his/her performance in work activities and related instruction, and for keeping
adequate records of this progress.
(4)an instructional
design that:
(a)is aligned with
prevailing industry standards for one or more targeted career cluster(s) as defined
by the Bureau of Labor Statistics (BLS) and reflected in the ONet occupational data
system (links to related details are provided in the "Further
Information" section below);
(b)specifies the competencies
that the program will impart, categorized by type (e.g., basic academic, technical,
job-readiness, etc.) and defined in terms of the Knowledge, Skills, Abilities (KSA)
framework (see "Further Information" section);
(c)describes the basic
format(s) of instruction, with a general break-down by practical instruction (hands-on,
work experience, labs, etc.) and theoretical instruction (classroom, reading, etc.);
(d)presents an evaluation
methodology detailing the selection and use of skill assessment tools to be used
before, during, and at the end of training;
(e)describes formal
structured work experience in the occupation(s) or occupational sector(s) addressed
by the program, to be delivered through paid or unpaid internships or, in situations
where clearly defined safety issues are recognized, and with the permission of the
Council Office, through extensive job-shadowing;
(D)Job
readiness skills -- The operating plan shall describe provision or referral
for services that address, where appropriate, deficits in pre-employment and soft
skills.
(E)Supportive
services -- The operating plan shall describe partnerships with programs
that provide, or refer participants to, support services such as economic assistance,
childcare, transportation, food banks, and other resources for meeting practical
needs that might affect participation. Potential partner programs include, but are
not limited to, WIOA, CCMEP, and non-profit service organizations.
(F)OhioMeansJobs
Centers -- The plan shall ensure participant referral to the relevant OhioMeansJobs
Center(s) where appropriate for access to services that may facilitate preparation
for RA training. The plan shall describe how the program provider will coordinate
with the OhioMeansJobs Center(s) in terms of strategy and information sharing, to
stream-line services for pre-apprenticeship participants. Contact information
for OhioMeansJobs is provided in the “Further Information” section.
(G)Participant
status -- The operating plan shall provide clear procedures for reporting
to the Council Office regarding pre-apprentices in the program, including:
(1)information about
each trainee at the point of enrollment, including name, age, education level, and
in what stage of training the individual will be placed;
(2)notice of each trainee's
exit from the program, along with their raining status (completed, suspended, or
canceled before completion);
(3)documentation of
skill attainments in the program, based on the competencies and progressive stages
outlined in the details of training.
(H)Safety
and welfare -- The plan shall state specific provisions for training all
pre-apprentices in safety practices appropriate to their occupation(s), and for
ensuring that all equipment and facilities used in the program are adequate and
safe.
(I)Program
administration -- The plan shall include:
(1)the official name
and contact information for the provider organization;
(2)the name, title,
and contact information for the person authorized to represent the program provider
in matters relating to state recognition.
(J)Linkage
-- The plan shall include a linkage statement attesting to and describing the following
forms of cooperation with partner entities.
(1)The program and
instructional content must be approved by, and developed in collaboration with,
one or more Registered Apprenticeship sponsor(s), and
(a)for programs serving
in-school youth, the curriculum experts of the joint vocational educational agency
and/or local education agency;
(b) for programs serving adults and/or out-of-school youth, the
University System of Ohio (USO).
(2)The work experience
component of training must be approved by one or more Registered Apprenticeship
sponsor(s).
(3)The program must
engage in ongoing collaboration with one or more Registered Apprenticeship sponsor(s)
in the relevant industry(s) for the purpose of:
(a)ensuring the relevance
of pre-apprenticeship instruction to the skill expectations of the Registered Apprenticeship
sponsor(s);
(b)familiarizing pre-apprentices
with the procedures for entering and completing such programs;
(c)ensuring continued
appropriateness and safety of activities in the pre-apprentice's work experience
component of the training.
The linkage statement shall be signed by the authorized representative(s)
of the cooperating Registered Apprenticeship sponsor(s).
Ohio's Registered Apprenticeship sponsors are listed online at https://ohiomeansjobs.ohio.gov/job-seekers/practice-your-skills/occupation-search.
For questions on in-school youth curriculum development, contact
gradrequirements@education.ohio.gov.
For USO contacts, see the list at https://www.ohiohighered.org/workforce/career-services.
Recognition Procedure
(A)An organization
seeking program recognition shall submit a request to the Council Office via e-mail
attachment, addressed to pre-apprenticeship@jfs.ohio.gov:
(B)The Council Office
will assess whether the plan meets the criteria specified in this policy and
will either:
(1)grant recognition;
(2)reserve recognition,
pending collaboration with the applicant to remedy any perceived deficits in the
program; or
(3)deny recognition,
unless and until a request is filed that demonstrates sufficient program quality.
For programs serving in-school youth, the Council Office may
choose to consult with the Ohio Department of Education to evaluate the
alignment of curriculum with state standards, prior to granting recognition and
in the collaboration that occurs in the “reserve recognition” stage.
(C)The Council Office
shall record every program recognition. The list of recognized programs shall be
posted online at https://apprentice.ohio.gov/pre-apprenticeship/
(D)Any modification
or change to a recognized program shall be promptly submitted to the Council Office
and, if approved, shall be acknowledged and recorded as an amendment to such program.
V.Local
Workforce Development Area Collaboration
In several Training and Employment Notices (TENs) and Guidance Letters
(TEGLs), the US Department of Labor (DOL) provides guidance on the benefits of pre-apprenticeship
and how they can be applied to WIOA participants. (See References section for links.)
Pre-apprenticeship programs that meet national standards of best
practice - standards reflected in this Policy Letter - qualify for the use of WIOA
Individual Training Accounts (ITAs) and the associated supportive service funding.
Any ITA dollars left unspent upon an individual's completion, may follow that person
into an RA program and be applied toward its technical instruction component. In
addition, the DOL TEGL 13-16 recommends using pre-apprenticeship for the 20% of
WIOA youth funds required to be spent on work experience. In Ohio, all WIOA youth
are served through the CCMEP program. CCMEP combines funds from WIOA and TANF
and provides coordinated case management and assistance to eligible participants
in both programs who range in age from fourteen through 24.
Other funding and in-kind resources for pre-apprenticeship include,
but are not limited to, Perkins Act Career and Technical Education grants and
federal programs such as SNAP E&T, HUD E&T (including Section 3 Covered
Financial Assistance), Community Services Block Grant, and others cited in the Background
section above. See TEGL 13-16, concerning Registered Apprenticeship, for details
about training partnerships with these and other programs. The ultimate source
of information and contacts for resources in any local area, is the OhioMeansJobs
system, which can be accessed through links under "Further
Information" below.
Please note that while RA programs automatically qualify for inclusion
on the state eligible training provider (ETP) list known in Ohio as the
Workforce Inventory of Education and Training (WIET), pre-apprenticeship programs
must apply for inclusion and meet all state-defined criteria listed in WIOAPL 16-02.1.
Local Workforce Development Boards (WDBs) are encouraged to make
full use of this program model by working closely with high-quality pre-apprenticeship
programs in their areas, and where such programs are lacking, to coordinate with
RA sponsors in the development of new ones. WDBs are urged to apply the best-practice
knowledge found in DOL issuances on the subject and in other resources listed below.
WDBs should have written policies concerning the use of pre-apprenticeship,
including related partnerships, coordination, needs assessment, and referral procedures.
Further Information
Further details of interest regarding pre-apprenticeship programs,
are available from the following sources:
VI.REFERENCES
TRAINING AND EMPLOYMENT
NOTICE NO. 13-12 - Defining a Quality Pre-Apprenticeship Program and
Related Tools and Resources
TRAINING AND EMPLOYMENT
NOTICE NO. 04-15 - Expanding Registered Apprenticeships and Pre-Apprenticeships
to Create a Pathway to Good Middle Class Jobs for Youth and Adults with Disabilities
TRAINING AND EMPLOYMENT
GUIDANCE LETTER No. 13-16 - Guidance on Registered Apprenticeship Provisions
and Opportunities in the Workforce Innovation and Opportunity Act (WIOA)