The Trump Administration quietly ends quality in pre-apprenticeship programs.
The Administration has deleted important guidance for a key entry point to one of its workforce priorities.
After a morning updating grants listings to match amendments, the good news is that I do think the U.S. Department of Labor will award grants I had been concerned about for a few weeks. As I wrote earlier today, DOGE has spared DOL grants thus far1—knock on wood—and the Administration published amendments that appear to commit to awarding $130 million-plus currently out for competition. I have updated the listings for these grants in today’s regular grants post, and I will send another update around in the next day or two breaking down all the changes DOL has made.
The bad news: The updates show the Trump Administration has eliminated the main touchstone for quality in pre-apprenticeship programs. As well as any notion of “quality” for these programs.
Earlier this week, the Administration updated its funding listing for the State Apprenticeship Expansion grants, a pot of money meant to help get more workers into apprenticeships. There are many changes, but the biggest I spotted immediately is removal of any mention of “quality pre-apprenticeship programs” and reference to DOL’s pre-apprenticeship guidance.
Why would they do that? Well, for one, the Administration has killed DOL’s pre-apprenticeship guidance—something some plugged-in folks around Apprenticeship World did not know until I reached out to them this afternoon.
To give a rough explanation for the uninitiated, pre-apprenticeships2 are workforce programs used to make sure someone has the skills and preparation needed for apprenticeship programs, where someone works in a paid job while learning all the skills needed to master an occupation. Pre-apprenticeships have been exceptionally good at getting more people into Registered Apprenticeships, the federal government’s quality-controlled designation for programs that are safe and train people appropriately. In turn, pre-apprenticeships help more people access better-paying skilled employment and increase access to apprenticeship, bipartisan priorities articulated by House members at a hearing on workforce on Wednesday.
Pre-apprenticeships also have some consumer risk because DOL does not register pre-apprenticeships like it does full apprenticeship programs.3 But DOL has traditionally issued guidance defining what a good pre-apprenticeship looks like. This is key for helping other funders and participants avoid potential scammers as well as pre-apprenticeships that don’t actually route workers to full apprenticeship programs.
In addition to eliminating the pre-apprenticeship guidance, the Trump Administration explicitly deleted references to “quality”4 pre-apprenticeship programs in the updated funding listing.5 I’m sure equity content in the most recent pre-apprenticeship guidance was at least a contributing reason; there is research showing that women and people of color especially benefit from pre-apprenticeship. But as written, even if it’s a rushed mistake, this change makes it look like DOL no longer promotes pre-apprenticeship programs that are, you know, good.
The Administration also killed the text below in the funding opportunity and didn’t replace it. These deletions could have been done surgically to remove equity content and preserved several common-sense measures for which there appear to be wide bipartisan support. This also could have been done by noting that, even though the pre-apprenticeship guidance is gone, pre-apprenticeship will have these Trump-friendly quality features for the funding opportunity. Intentional or not, it sends a message that the Trump Administration erased everything below with no replacement.6
For the purposes of this FOA, pre-apprenticeship programs must include the following five elements to be considered a quality pre-apprenticeship program:
1. Partnership with RAP sponsors. Quality pre-apprenticeship programs should be designed and delivered with input from at least one RAP sponsor. A pre-apprenticeship program’s educational and pre-vocational services prepare individuals to meet the entry requisites of one or more RAPs and occupations.
2. Sustainability through partnerships. To support their ongoing sustainability, quality pre-apprenticeship programs establish partnerships with entities to collaboratively promote the use of RAPs as a preferred means for employers to develop a skilled workforce and to create quality career opportunities and pathways for individuals. Partnerships may include RAP sponsors, DOL-funded intermediaries who develop programs or provide training to programs, community and faith-based organizations, advocacy organizations that represent underserved populations, labor organizations, joint labor-management organizations, educational institutions (including high schools and community colleges), and the public workforce system.
3. Meaningful training combined with hands-on experience replicating a workplace that does not displace paid employees. Quality pre-apprenticeships provide hands-on training to individuals in a workplace, simulated lab experience, or work-based learning environment, which does not supplant a paid employee, but effectively simulates the industry and occupational conditions and standards of the partnering RAPs while observing proper supervision and safety protocols. Pre-apprenticeship programs ideally provide opportunities to obtain an industry-recognized credential, as well as potential stipends or wages when funding allows.
4. Access to career and supportive services. Quality pre-apprenticeship programs provide or otherwise ensure access to career and supportive services during the program, which may continue after a pre-apprentice enters a RAP. Services may include both financial and non-financial supports such as stipends, career counseling, career exploration, mentoring, transportation assistance, childcare, dependent care, rehabilitative services, textbooks, tools, emergency grants, and other types of services necessary for an individual to succeed in pre-apprenticeship programs and RAPs.
5. Strategies that increase Registered Apprenticeship opportunities for underrepresented or underserved populations facing significant barriers to employment in the Registered Apprenticeship labor force.
These changes run contrary to the Administration’s questionable but purported commitment to expand access to apprenticeship.
You can’t get more people in apprenticeship programs without getting more people in apprenticeship programs. Offering a vision for pre-apprenticeship that distinguishes between a scam and something worth workers’ time is a key part of that.
But definitely not contracts, which also has a terrible downstream effect on providing employers support to start and maintain Registered Apprenticeships.
For what it’s worth, the Administration has not cut every reference to “Quality Pre-Apprenticeship Programs” on DOL’s suite of sites. There is a chance that will change after this newsletter, so save what you need.
The historical reason as to why needs unpacking in a whole newsletter unto itself.
It’s possible that, because the Biden-Harris Administration made a point of promoting “Quality Pre-Apprenticeship Programs,” the Trump folks deleted any references to “quality” to make a break from the previous administration’s equity-centered work.
If so? Congratulations, new guys. You just backflipped into a messaging trap visible from space.
And as I note above, this could have been avoided easily in the amendment to the funding opportunity, if they had wanted to do so.
The original funding opportunity, on Page 4, had a header saying “Quality Pre-Apprenticeship Programs.” The Trump Administration’s amendment to the funding opportunity, on Page 2, states:
The header after the fourth paragraph is deleted and replaced with the following:
Pre-apprenticeship Programs
The quoted text above also is from Page 4 of the original funding opportunity. The amendment, also on Page 2, states: “The sixth paragraph [that addresses elements of quality pre-apprenticeship] and its five elements are deleted.”
The other big change I see in the SAEF III is what looks (to me) like actual promotion of the idea of using the money to launch an SAA.