RECISSION: Workforce
Innovation and Opportunity Act Policy Letter 21-03
I.Purpose
This policy letter provides the criteria for state recognition of
pre-apprenticeship programs which provide the skills and work experience needed
to be successful in a Registered Apprenticeship program. This information is meant
to promote the establishment of pre-apprenticeship programs, support the local
workforce development area’s (local area) use of pre-apprenticeship training in
Workforce Innovation and Opportunity Act (WIOA) Title I programs, and assist
local areas 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
in 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.
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.
This policy letter provides guidelines for applying the pre-apprenticeship
model in WIOA Adult and Dislocated Worker programs and Comprehensive Case
Management and Employment Program (CCMEP) activities for youth; 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.Requirements
for State Recognized Pre-Apprenticeship Programs
Pursuant to 20 CFR 681.480, pre-Apprenticeship is a program
designed to prepare individuals to enter and succeed in a registered
apprenticeship program and includes the following elements:
A.Training and
curriculum that aligns with the skills needs of employers in the Ohio economy;
B.Access to
educational and career counseling and other supportive services, directly or
indirectly;
C.Hands-on,
meaningful learning activities that are connected to education and training activities,
including exploring career options, and understanding how the skills acquired
through coursework can be applied toward a future career;
D.Opportunities to attain at least one industry-recognized
credential; and
E.A partnership with
one or more registered apprenticeship programs that assist in placing
individuals who complete the pre-apprenticeship program in a registered
apprenticeship.
Eligibility for Recognition
To be eligible for state recognition, a pre-apprenticeship program
must develop and adhere to 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 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, treatment, and training of pre-apprentices
[Name of program] 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
program] will take affirmative action to provide equal opportunity in pre-apprenticeship
and will operate the pre-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.
(C)Instructional content -- The operating
plan shall describe the details of the training, including:
(1)the apprenticeable occupation(s) or occupational
sector(s) for which participants will be trained;
(2)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.
(3)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, or, in
situations where clearly defined safety issues are recognized, and with the permission
of the Council Office, through job-shadowing;
(D)Job
readiness skills -- The operating plan shall describe a provision or referral
for services that address, where appropriate, deficits in pre-employment and soft
skills.
(E)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.
(F)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.
(G)Partnership
-- The plan, minimally, will include a statement outlining the connection of
the pre-apprenticeship instruction to the skill expectations of one or more Ohio
RA program(s) in the same occupational sector.
The statement should also include the process for informing
pre-apprentices of the procedures and assisting the pre-apprentice in entering
such program(s) should the pre-apprentice wish to continue with RA. The
director of the Ohio Department of Job and Family Services may amend the requirements
when funded under a Department of Labor grant.
Information pertaining to Ohio’s RA programs can be found at:
Ohio's Registered Apprenticeship sponsors are listed online at https://ohiolmi.com/Home/Dashboards/ApprenticeOhio_Dashboard.
For questions on in-school youth curriculum development, contact
gradrequirements@education.ohio.gov.
For USO contacts, see the list at
Ohio's Campuses | The Ohio Department of Higher
Education.
The pre-apprenticeship program must report
the following information to the Council Office regarding pre-apprentices in the
program:
(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 training 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.
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;
or
(2)reserve recognition,
pending collaboration with the applicant to remedy any perceived deficits in the
program.
For programs serving in-school youth, the Council Office may
choose to consult with the Ohio Department of Education and Workforce 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. ApprenticeOhio will identify and publicly
recognize pre-apprenticeship programs by posting the recognized programs 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.
A state-recognized pre-apprenticeship program must provide
accurate information and administer the program according to the approved
operating plan. ApprenticeOhio considers a program to have committed a
violation when a pre-apprenticeship program intentionally supplied inaccurate
information or has substantially violated any portion of this policy. If ApprenticeOhio determines that a program
has committed a violation, ApprenticeOhio will revoke program recognition and
remove the program from the listing of recognized programs on the website.
V.Collaboration
with the Local Workforce Development Area
Pre-Apprenticeship participants may be referred to the relevant
OhioMeansJobs center where appropriate access to service may facilitate
participation in the pre-apprenticeship program and prepare for registered
apprenticeship training, as appropriate.
Pre-apprenticeship programs may strategize and share information with
the OhioMeansJobs center, to streamline services for participants.
Recognized pre-apprenticeship programs qualify for the use of
WIOA-funded individualized training accounts (ITA), work experiences, and
associated supportive service funding.
For pre-apprenticeship programs to become eligible for WIOA ITA funds,
the program must become an eligible training provider by applying on the
Workforce Inventory of Education and Training (WIET). Workforce Innovation and Opportunity Act
Policy Letter (WIOAPL) 16-02.2 provides the criteria to become an eligible
training provider. Any ITA dollars left
unspent upon an individual’s completion may follow that person into a
registered apprenticeship program if the individual transitions.
Should a participant in the pre-apprenticeship program need
services that will support their participation in the program, the
OhioMeansJobs center may provide such assistance. Supportive services are available, after an
assessment of need, to provide services to alleviate barriers to participating
in the program, including but not limited to, childcare, transportation,
testing, and work attire. Additionally, the OhioMeansJobs center may make additional
referrals to community resources for any additional services, including
economic assistance, food banks, and other needs.
Local workforce development boards (WDB) should have written
policies concerning the coordination and use of pre-apprenticeship, including
related partnerships, needs assessments, and referral procedures. WDBs are encouraged to work closely with
pre-apprenticeship programs in their areas, and where such programs are
lacking, to coordinate with entities interested in developing new ones.
VI,Further
Information
VI.REFERENCES
20 CFR 681.480
Title 29 of the CFR, part 30
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)
Workforce Innovation and Opportunity Act Policy Letter 16-02.2
ATTACHMENT: State Recognized Pre-Apprenticeship Glossary