At Jobs for the Future (JFF), we’re deeply invested in the transformative power of apprenticeships. The proposed rule changes to the National Apprenticeship System by the U.S. Department of Labor (DOL) provide a pivotal moment to consider how these pathways can be shaped to provide opportunities for equitable economic advancement for all.

DOL’s recent Notice of Proposed Rulemaking, National Apprenticeship System Enhancements, champions “the evolution of a National Apprenticeship System that maintains the hallmarks of apprenticeship quality developed over the past century, keeps pace with the evolving needs of a growing set of industries, and incorporates flexibilities and system modernizations to facilitate the expansion and growth of registered apprenticeship.”

We commend DOL’s efforts to be responsive to the system’s need to develop an equitable workforce that meets employer demand. In preparing our public comments in response to the Notice of Proposed Rulemaking, we see great promise, particularly in how the rules work to ensure pay equity, build stronger alignment across states, center apprentices in program design, and ensure that data effectively supports continuous improvement.

We have also identified areas where we urge refinement and reconsideration based on our extensive experience in building and scaling apprenticeships nationwide. Our primary recommendations include:

• Reduce complexity and allow for iterative input: The vastness of the rules threatens to overwhelm the system and introduce confusion and unintended consequences. We urge the Department to take a simplified, phased implementation approach that allows for continuous input from all stakeholders.
• Encourage employer participation through the scaling, not elimination, of competency-based models: The popular competency-based model is especially useful in fast-moving sectors such as IT and climate/agriculture that have recently begun to look to apprenticeship as a talent solution.
• Define and codify pre-apprenticeship and youth apprenticeship: Without a system-wide definition of pre-apprenticeship and youth apprenticeship, states and organizations are left to create their own systems and programs with varying degrees of quality and effectiveness. Federal policymakers must outline a more intentional and holistic approach that bridges work and learning for all young adults, especially those disconnected from employment and education.
• Connect the proposed CTE Registered Apprenticeship model with existing systems: CTE Registered Apprenticeship shows potential to connect the education and workforce systems. DOL should consider how the model could enhance permeability by creating multiple on- and off-ramps, including employment, postsecondary education, and other apprenticeship options. In addition, CTE Registered Apprenticeships should not dilute or undermine the advances being made in youth apprenticeship.

JFF is committed to working alongside the Department of Labor, sharing insights from our work, leveraging our convening power, activating our networks and advocating for apprenticeship models that are inclusive, innovative, and aligned with the future of work. Our goal is to ensure these changes not only meet current needs but pave the way for a future where apprenticeship is a key driver of economic growth and opportunity.