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On May 10, the U.S. Department of Labor’s Advisory Committee on Apprenticeship voted to approve recommendations to the DOL for potential revisions to the National Apprenticeship System. The ACA is an advisory body comprised of representatives from industries, labor organizations and other members of the public that provides advice to the agency on government-registered apprenticeship programs. These recommendations will inform the DOL’s upcoming proposed rule revising the GRAP system, currently targeted for June 2023.

Included in the recommendations are suggestions for the DOL to establish a new “Quality Seal” program for GRAPs. Programs would be required to meet certain wage requirements, completion rates and apprentice-to-journeyworker ratios in order to receive the Quality Seal and accompanying preferential treatment for federal funding of GRAPs. Employer participants in Quality Seal GRAPs would receive preferential treatment in the bidding and awarding of federal and federally assisted construction projects. Additionally, some members of the ACA recommended that all GRAPs should be required to guarantee graduates such wages deemed “family-sustaining” by the DOL.

An ABC-led coalition of construction and business associations submitted a letter to the ACA expressing concerns that these proposals, while perhaps well-intentioned, may ultimately result in fewer apprentices being upskilled by making GRAPs less attractive to employers and employee participants. Specifically, the letter urged the committee to reject recommendations that would discourage providers and employers from utilizing GRAPs and instead ensure flexibility and ease of access.

The ACA’s recommendations were ultimately approved, although there was disagreement among ACA members. Bloomberg News reported that:

“Members of the advisory panel disagreed on whether to attach the “living wage” provisions to the final recommendations, with some representatives expressing concern that they wouldn’t get enough buy-in from employers.

“Initially the panel suggested using ‘MIT’s living wage calculator’ as the standard rate apprenticeship programs should pay in order to receive the special quality seal.

“Ultimately, the committee voted to define ‘living wage’ as ‘200% of the federal poverty level for a family of three, adjusted by a geographic cost-of-living differential for regions where the cost of living exceeds the federal average.’”

Stakeholders who want to provide more input on the ACA’s Quality Seal Program and living wage recommendations should consider participating in the public comment period that will accompany the DOL’s anticipated apprenticeship rulemaking, should those ACA recommendations be adopted in the proposed rule.

ABC continues to support GRAPs as one of many solutions that are part of ABC’s all-of-the-above solution to workforce development. However, recent data suggests that it would take 12 years for GRAPs to educate the more than half a million workers needed by the construction industry in 2023 alone. ABC will continue to champion inclusive workforce development policies that will avoid costly delays to critical infrastructure, clean energy and manufacturing projects.

The ABC-opposed National Apprenticeship Act introduced in Congress on April 25 would further entrench the rigid GRAP system, failing to address critical workforce needs of our nation’s construction industry and substantially restricting apprenticeship opportunities currently serving thousands of contractors. ABC instead supports the Training America’s Workforce Act (S. 1213), the Freedom to Invest in Tomorrow’s Workforce Act (H.R. 1477/S. 722) and the Jumpstart Our Businesses by Supporting Students Act (H.R. 793/S. 161).