In Depth

Growing Degree Apprenticeships: Recommendations for Congress, Federal Agencies, and States

Silhouette of two people with graduation caps and gowns walking up at the top of a staircase
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This brief recommends 14 ways that policymakers in Congress, federal agencies, and states can expand degree apprenticeship from an opportunity offered in scattered locations to one available to students nationwide. Degree apprenticeship integrates Registered Apprenticeship with an associate, bachelor’s, or master’s degree to provide a pathway to a postsecondary degree and well-paying job. This model is appealing to people who must work to support themselves while they attend school. 

Introduction

With the support of the Strada Education Foundation, New America has published a series of reports on the promise of degree apprenticeship, an emerging model of career preparation that integrates Registered Apprenticeship with an associate, bachelor’s, or master’s degree. We have mapped the landscape of degree apprenticeship in the United States, identified quality principles, and explored the potential of the model to address workforce shortages and create more opportunities for people to pursue careers in teaching and nursing and allied health.    

Here we turn our attention to recommendations for policymakers that will help institutions of higher education and their employer partners expand a niche model.   

Degree apprenticeships open doors to postsecondary degrees and well-paying jobs for people who must work to support themselves while they go to school. The model holds particular appeal for adult learners but is attractive to all students who are uncertain about whether college will give them a sure footing in the economy. Finding that first family-sustaining wage job right out of school has become difficult.1 Many students do not have a clear pathway from their degree into a job in their field, and many new graduates struggle to put their degree to work right away.2 Students in degree apprenticeships can be confident of a degree-related job when they graduate because they have already started it.

Degree apprenticeship has brought into the apprenticeship system employers, institutions of higher education, and professional associations who have never worked with the Department of Labor (DOL) or state apprenticeship agencies (SAAs) before. For some degree apprenticeship pioneers we interviewed for our work, it was a bewildering experience, and they recommended making the system easier to navigate. We agree that a faster, more efficient, reliable, and transparent apprenticeship system would have many benefits, including accelerating the adoption of the model. An apprenticeship modernization agenda is beyond the scope of this brief, but we believe that policymakers should pursue it in tandem with the 14 recommendations we make below on expanding the model. 

Define the Term and Start Collecting Data

1. Federal agencies should agree on a common definition of degree apprenticeship.

Consulting closely with Congress and state apprenticeship agencies (SAAs), the Department of Labor (DOL) and Education Department (ED) should lead other agencies in developing and agreeing upon a single federal definition of degree apprenticeship that can be used in funding announcements, regulations, and legislation. A similar strategy was used to develop a single definition of career pathway that Congress added to the Carl D. Perkins Career and Technical Education Act (Perkins V),3 the Higher Education Act,4 and the Workforce Innovation and Opportunity Act (WIOA).5 

Consensus should not be difficult to achieve, because the field has coalesced around the common elements of degree apprenticeship, with New America, the Urban Institute, Apprenticeships for America, and the National Center for the Apprenticeship Degree (an initiative of Reach University) putting forward similar definitions.6 As we explained in our January 2026 report, Mapping the Landscape of Degree Apprenticeship: Expanding a Promising Model for Mobility, in degree apprenticeship, students engage in paid, mentored, work-based learning emblematic of Registered Apprenticeship. They complete coursework that complements their on-the-job learning—known as related technical instruction (RTI)—at an institution of higher education that culminates in an associate, bachelor’s, or graduate degree and a nationally recognized journeyworker credential. Graduates of degree apprenticeships hold the same higher education credential as peers who took a traditional path to a degree, but they have also earned wages and benefited from structured opportunities to apply their classroom learning on the job.

2. DOL, SAAs, and ED should collect data to track the growth and evolution of degree apprenticeship.

It is not possible to determine the number or nature of degree apprenticeship programs in the United States using federal data, and federal data cannot tell us how many degrees have been conferred through a Registered Apprenticeship. The Registered Apprenticeship Partners Information Database System (RAPIDS) administered by DOL contains data at the apprentice and program level about apprenticeship components and apprentices’ progress through the program (e.g., starting wages and the number of apprentices enrolled per program).7 While institutions of higher education may be sponsors or RTI providers in RAPIDS, there is no variable capturing whether postsecondary academic credit is earned through a given apprenticeship, or if it is integrated with a degree program. The Integrated Postsecondary Education Data System (IPEDS) does capture the number and type of postsecondary certificates and degrees conferred and the conferring institution, but IPEDS offers no way to identify which degrees earned were delivered through a Registered Apprenticeship. The National Student Loan Data System (NSLDS), an ED database that tracks students’ federal loan and grant aid, along with their program enrollment, credential attainment, and other data,8 also does not record whether students are participating in a Registered Apprenticeship. 

DOL should collect data in RAPIDS on the degrees and other postsecondary credentials earned by apprentices and identify apprenticeships that yield degrees at the program level. ED should begin collecting data through IPEDS and NSLDS on degrees and other postsecondary credentials awarded in conjunction with a Registered Apprenticeship. There should be a data crosswalk between RAPIDS and IPEDS to indicate which degree programs are associate with which Registered Apprenticeships.

Some SAAs, such as Apprenticeship Colorado,9 are already collecting data on embedded certifications and postsecondary credentials. These data allow the SAA and apprenticeship partners to answer important questions about participation in and outcomes of these programs. Other SAAs should incorporate degree apprenticeship indicators in state postsecondary and apprenticeship data systems as soon as feasible rather than awaiting federal action.

Build a Federal Infrastructure

3. DOL and SAAs should designate more occupations that require a degree as apprenticeable, develop model standards, and promote them.

DOL can support degree apprenticeship’s growth by systematically and proactively identifying occupations that require a degree that are suitable for apprenticeship, rather than waiting for others to submit requests as it typically does.10 The agency should take Urban Institute’s advice to identify apprenticeable occupations using Bureau of Labor Statistics (BLS) data,11 targeting occupations with Standard Occupational Classifications that BLS has determined require a degree and giving priority to those that are high-growth and pay the median wage or higher. In making apprenticeability determinations, DOL should consult employers, labor organizations, and educators, and draw on the occupational and training data it already produces, such as O*NET’s detailed occupational profiles12 and BLS employment projections and training classifications.13

DOL should support the development of consensus-driven National Occupational Frameworks (NOFs) for these degreed occupations to supply model standards that employers can customize in apprenticeship agreements. Building on work by the Urban Institute launched during the Obama administration14 and continued during the first Trump administration and the Biden administration,15 last year DOL established the Project on Apprenticeship Standards and Interoperability (PASI) in cooperation with the Alabama Commission on Higher Education and the Competency-Based Education Network (C-BEN) to produce NOFs and standards in collaboration with employers, unions, industry experts, professional associations, and educators.16 It should ensure PASI develops standards for the apprenticeable occupations requiring a degree that DOL identifies. DOL should fund outreach to employers and institutions of higher education to promote their adoption and use of the NOFs that have been developed. NOFs can greatly reduce the time required to launch an apprenticeship, but only if employers and their education partners know they exist and how to use them.

SAAs can also play an important role in driving innovation, particularly if DOL lacks the capacity or interest to lead degree apprenticeship expansion. SAAs in Alabama and Wisconsin, for example, have extended apprenticeship into occupations that require a degree, demonstrating what a difference entrepreneurial SAAs can make. SAAs should target high-growth occupations that require a degree and collaborate with employers and institutions of higher education to develop and register new degree apprenticeship programs. SAAs should reach out to their state agency partners in higher education to identify and address possible policy barriers to degree apprenticeship expansion. They can also help educate employers and higher education institutions about the degree apprenticeship model and its benefits. 

4. Federal agencies should jumpstart curriculum models that incorporate degree apprenticeship.

Expanding degree apprenticeship into new occupations requires rethinking how we prepare people for careers. Federal agencies have programmatic authorities that they can use to fund the development and evaluation of alternative approaches to professional preparation. Congress should use appropriations to direct them to use these authorities to support new program models that can bolster degree apprenticeship in three ways:

  • The Department of Health and Human Services (HHS) should provide grants to consortia of program accreditors, professional associations, and institutions of higher education to develop and test new models of health care personnel preparation that integrate ongoing, intensive clinical experience with classroom instruction, rather than presenting it after all or most academic coursework has been completed, as in occupational therapist and occupational therapy assistant programs.17 
  • The National Science Foundation should support the development of curriculum frameworks that use apprenticeship in STEM fields, starting with occupations like engineering that have high early-career attrition rates18 that might be improved by integrating apprenticeship with professional preparation.
  • Working through the Fund for the Improvement of Postsecondary Education (FIPSE), ED should partner with the Department of Commerce to offer grants to develop and evaluate alternative degree program models that combine apprenticeship with classroom instruction in business administration, entrepreneurship, and skilled trades. 

Provide Seed Capital and Incentives

5. DOL and states should award start-up funds to partnerships between employers and institutions of higher education for more degree apprenticeship programs.

Recruiting employers and engaging them in redesigning degree programs to incorporate Registered Apprenticeship is costly, requiring significant time from faculty, administrators, and, often, employers. Colleges and universities need funding to get programs off the ground. A relatively small investment from DOL, ED (using FIPSE dollars), and SAAs (using DOL-funded State Apprenticeship Expansion grants, for example) could pay big dividends. In Illinois, for example, where we found a comparatively large number of degree apprenticeships, a handful of federal grants made an enormous difference, catalyzing the development of program models that faculty and administrators from Harper College promoted and disseminated across the state. DOL and SAAs should provide grantees technical assistance when seed funding ends.  

States should invest a portion of their federal Rural Health Transformation (RHT) grants in developing and expanding degree apprenticeships in nursing and allied health fields to address the severe shortage of health professionals in many rural communities. RHT is allocating $50 billion over the next five years to all 50 states to strengthen rural health care delivery. Attracting and retaining a skilled workforce in rural communities is one of the program’s five strategic goals.19 For example, states can use RHT funds to replicate the Michigan Workforce Training and Education Collaborative’s successful strategy for delivering high-cost, low-enrollment health care programs like diagnostic imaging and respiratory therapy at community colleges in rural communities. We describe their model in our August 2026 report, Degree Apprenticeship: A Remedy for the Health Care Talent Crisis.

6. States should create affordable, structured pathways to degree apprenticeship for young people.

Degree apprenticeship has grown in North Carolina because of the state’s tuition waiver for recent high school graduates who become apprentices.20 Students who enroll in an SAA-approved pre-apprenticeship during high school and continue their studies in a Registered Apprenticeship within four months of high school graduation take community college courses for free until their apprenticeship is completed. The waiver also covers tuition for students who start their Registered Apprenticeship during high school. Community and technical colleges are reimbursed for the tuition costs (dual enrollment funding pays the related instruction costs while students are still in high school).21 For a modest $1 million a year, the policy has built a new, more affordable pathway to earning postsecondary and journeyworker credentials for youth.22 Other states should make the waiver available for enrollment in degree apprenticeships. They could start by targeting specific occupations that pay good wages and for which there is high demand among employers.   

7. Federal agencies and states should identify available funding streams to support degree apprenticeships.

Institutions of higher education that have launched degree apprenticeships need help identifying federal and state funding sources that can be used to sustain these models. DOL and ED should collaborate on a single resource that describes all of the federal programs that are available to support degree apprenticeship and where and how to access these funds. Congress could also ask the Government Accountability Office to produce a government-wide inventory. DOL should also evaluate whether RAPIDS can be enhanced to better integrate apprentice intake and registration with eligibility for the GI Bill and the completion of the Free Application for Federal Student Aid. SAAs should work with state higher education offices to develop a comparable document outlining what is available at the state level.

8. Congress should examine how federal financial aid programs can better support degree apprenticeship.

The last full reauthorization of HEA, the Higher Education Opportunity Act of 2008,23 was enacted several years before the first degree apprenticeships we found in our research were launched. The next time it reauthorizes HEA, Congress should evaluate how the law can better support degree apprenticeships. 

Congress could amend the Federal Work-Study (FWS) statute to explicitly call out as allowable a Registered Apprenticeship that is part of a program of study, permit degree apprentices to work full-time in FWS positions,24 and exclude degree apprenticeship placements from the 25 percent cap on funding for jobs with for-profit employers.25 It could phase out the base funding guarantee so that more FWS funds are distributed on the basis of an institution’s current enrollment of low-income students, not how many it had in 1999.26 Public, two-year colleges, the early innovators in degree apprenticeship, enroll more than one-third of Pell Grant recipients but receive less than 20 percent of FWS dollars.27

Congress could aim the Teacher Education Assistance for College and Higher Education (TEACH) Grant program at students enrolled in teacher apprenticeships who are preparing to teach in in-demand fields at high-need schools. The TEACH program provides about $76 million in annual grants of up to $4,000 to eligible students who agree to serve as full-time teachers in mathematics, science, bilingual education and English language acquisition, special education, reading, or other in-demand fields at “a low-income school,” for at least four years within eight years of graduation. For students who do not meet the service obligation, ED converts the grants to an unsubsidized loan, with interest accruing from the date the grants were awarded.28

Research indicates that TEACH is struggling to achieve its goal of increasing the number of undergraduate teaching degrees overall and in in-demand fields.29 More than half of the students who receive TEACH grants do not meet the program’s service obligation,30 making the program, as one researcher put it, “a backdoor increase in loans.”31 Focusing the program on teacher apprentices who are already working in high-need schools would help students meet their service obligations and increase the number of skilled teachers in schools serving large proportions of students from low-income families.

In the interim, ED should use its Experimental Sites authority32 to test student aid options and ensure that they are evaluated independently by the Institute of Education Sciences (IES) so policymakers get data on their impact. Allowing students to work full time in jobs related to their academic program, including in an apprenticeship, was one of the innovations tested in the Federal Work-Study Work and Learn Experimental Site initiative launched by the first Trump administration in 2019,33 but ED cancelled an IES evaluation, so there is no information on the experiment’s results.

9. Policymakers should, in designing wage subsidies and other incentives for Registered Apprenticeship expansion, consider employer needs of employers in the public and nonprofit sectors, where teacher, nursing, and allied health degree apprenticeships predominate, as well as small businesses.

Two of the most promising industries for degree apprenticeship expansion, education and hospital-based health care, consist predominantly of public and nonprofit employers.34 A popular state strategy for incentivizing Registered Apprenticeship is offering tax rebates to employers who sponsor apprentices,35 but these incentives are not available to public entities or nonprofits because they are exempt from taxation. To make apprenticeship wage subsidies available to the tax-exempt employers, states that offer apprenticeship tax credits should make them refundable so that these employers can receive direct cash payments in lieu of tax refunds. Alternatively, states can convert their tax subsidies to direct grants, as Alabama has done.36

Registered Apprenticeship is already a heavy lift for small businesses. Adding a postsecondary degree to the mix makes it more challenging, because the related instruction costs are typically higher than in other apprenticeships. Policymakers should offer larger grants or tax subsidies to small businesses.   

Recognize On-the-Job Learning

10. ED should issue guidance and regulations to clarify that limits on instruction by outside entities do not apply to on-the-job learning when it is designed, assessed, and overseen by faculty.

Institutions of higher education need assurance from ED that awarding academic credit for on-the-job learning is permissible and not subject to the limits on outside providers. Many are uncertain whether and how much on-the-job learning can be credit-bearing.

ED regulations for student aid programs authorized by Title IV of HEA cap instruction delivered by outside entities at 25 percent of a program, or more than 25 but less than 50 percent where the institution’s accrediting agency has determined that the arrangement meets the agency’s standards and the institution and outside entity are not under common ownership and control.37 A course counts as being provided by an outside entity when that entity has authority over its design, administration, or instruction, including establishing completion requirements, delivering instruction, or assessing student learning.38 Guidance issued by ED in 2014 on federal student aid and apprenticeship (Dear Colleague Letter GEN-14-22) indicates that no federal limit applies to on-the-job learning where it is “provided by the institution,” without defining the term, and requires faculty “supervision” of such hours only in clock-hour programs, leaving it unclear what standard, if any, applies to credit-hour degree apprenticeships.”39

The advanced age of the guidance and its ambiguity discourage institutions from awarding credit for on-the-job learning, and for students eligible for Pell Grants, that reluctance can be costly. Pell Grants are prorated by enrollment intensity, so apprentices taking two three-credit courses while working 40 hours a week receive half an award.40 Credit for on-the-job learning could make them full-time students and raise their awards accordingly.

ED should update guidance so that academic credit for on-the-job learning in a Registered Apprenticeship, through a course in which the apprentice enrolls during the term does not trigger the limitations on instruction provided by outside entities, so long as three conditions are met:

  • A faculty member serves as instructor of record and determines the grade, based on the institution’s own evaluation of the apprentice’s learning, which may include input from worksite mentors and apprenticeship sponsors.
  • The institution conducts periodic worksite evaluations, in person or remotely, either directly by faculty or through a worksite mentor trained by the institution who evaluates the apprentice using instruments the institution provides.
  • The institution aligns course learning outcomes with the work processes set out in Registered Apprenticeship standards approved by DOL or an SAA. 

These conditions mirror established practice in clinical education in health programs, where state licensure requirements and program accreditors define required competencies, institution-trained preceptors provide day-to-day oversight, and a faculty member provides the grade. These arrangements are treated as exempt from the limits on outside entities,41 as on-the-job learning in a Registered Apprenticeship should be. 

At its next opportunity for negotiated rulemaking, ED also should amend 34 CFR 668.5(h) to exclude Registered Apprenticeship on-the-job learning from the outside entity limitations, in a new paragraph (h)(3), comparable to the existing exclusion for internships and externships.42 While the guidance we recommend will be helpful, amending the Title IV regulations would provide greater assurance to risk-averse institutions.

11. State public higher education systems should adopt rules authorizing academic credit for on-the-job learning completed concurrently in a Registered Apprenticeship.

Institutions of higher education do not usually award academic credit for concurrent on-the-job learning in a Registered Apprenticeship. If they do, they design a policy themselves, and the on-the-job learning credit may not transfer to another institution. Some institutions award credit retrospectively for on-the-job learning through a credit for prior learning policy.43

Retrospective credit helps advance student-apprentices through a degree program, but it doesn’t generate federal student aid. Pell Grants are prorated by enrollment intensity, as are some state need-based aid programs. Time spent in on-the-job learning does not count toward determining enrollment status unless credit is awarded concurrently, so student-apprentices in a degree program who need to take less than a full course load to accommodate their on-the-job learning receive smaller Pell awards than they would if that learning were recognized with credit. 

The North Carolina Community College System allows Registered Apprentices to apply up to 16 semester hours of work-based learning credit, earned concurrently at one semester hour per 160 hours of work, toward a diploma or an associate in applied science degree.44 The policy accepts a Registered Apprenticeship agreement in place of the measurable learning outcomes and other documentation otherwise required.

States can include formulas for converting work hours to credit.45 Establishing a system-wide or model policy for concurrently awarding credit for the on-the-job learning in a Registered Apprenticeship would give schools the tools they need to recognize on-the-job learning as instruction and unlock federal student aid for student-apprentices in degree programs. It would also signal that on-the-job learning is equal in value to classroom instruction.

Create Fertile Conditions in Key Industry Sectors

12. DOL should support technical assistance to help states and institutions of higher education develop and sustain degree apprenticeship programs in education and nursing and allied health.

States and institutions of higher education need more than a list of funding streams that support degree apprenticeship. They need to know how to secure them and how to use them to develop, launch, and sustain a degree apprenticeship. Colleges new to degree apprenticeship often don’t know what quality looks like and how to design and implement their programs with quality elements in mind. In the places where degree apprenticeships are new, technical assistance and guidance is crucial to getting strong, effective programs off the ground expediently.  

The Biden administration recognized this need and, in 2024, launched the Educator Registered Apprenticeship Intermediary (ERA).46 The ERA provided coaching and technical assistance to states, school districts, institutions of higher education, and others building teacher apprenticeship programs, serving 80 partners in 35 states in the two years it operated.47 Many of the practitioners we spoke with for our August 2026 report, Living Up to Its Promise: Three Ways to Make Teacher Degree Apprenticeship Programs Work, said that the ERA provided critical support in developing and implementing their programs. The Trump administration canceled the ERA contract in 2025.48 

DOL should reinstate the ERA and work with the Department of Health and Human Services to stand up a similar intermediary for nursing and allied health apprenticeships. Intermediaries represent a relatively small investment for the departments but help support both quality and expansion at degree apprenticeship programs nationwide. By focusing on two high-growth industries where workforce shortages abound, DOL can ensure its dollars are spent efficiently and on programs that address critical workforce shortages.

13. States and Congress should end requirements that students in nursing and allied health degree programs participate in clinical experience without compensation.

Many nursing and allied health degree programs require students to work unpaid clinical experiences, which has stymied degree apprenticeship expansion in health care. This mandate is sometimes embedded in state licensure or certification requirements and standards for professional preparation. In other cases, institutions and their workforce partners can compensate students but choose not to do so, sometimes in the belief that pay will diminish the educational nature of the experience.49

Degree apprenticeship will struggle to gain traction in health care until this practice ends. Conscripting students to work for free is inequitable. It locks out low-income people who need to work to support themselves and their families from good jobs. It also may depress completion rates in programs that need to be as efficient as possible to address workforce shortages.

States should scrub unpaid clinical experience requirements from their licensure and certification regulations. The field also needs a vigorous push from the federal government to end the practice where state regulators do not require it, but the practice persists. Congress should amend Titles VII and VIII of the Public Health Service Act, which authorize grants for allied health profession and nursing workforce development programs,50 respectively, to require grantees to provide stipends or wages to students during their clinical experiences and to give preference to institutions of higher education that do so through degree apprenticeships.

14. Congress should defray the costs of sponsoring teacher degree apprenticeships by letting SEAs tap more federal educator preparation dollars.

State education agencies (SEAs) or statewide intermediaries often sponsor teacher degree apprenticeships to ensure that all districts, especially small and medium-size districts in rural and higher-poverty communities, can participate. Interest in “growing your own” teachers is strong, but some districts don’t have the staff or resources for the administrative burden of sponsorship, which is where SEAs or other intermediaries step in. But sponsorship also strains the capacity of the SEAs, higher education institutions, and nonprofit organizations who take on the role, since they are often short-staffed themselves.51 A reliable funding stream is needed to support the work.

Allowing states to tap a larger share of the funds they receive under the Supporting Effective Instruction State Grants program for these activities would help. Authorized by Title II, Part A of the Elementary and Secondary Education Act, the $2.2 billion formula grant program supports a wide range of services and activities to prepare teachers and principals,52 including teacher apprenticeship.53 States keep 1 percent of the allotment for administrative costs and 4 percent for activities like reforming educator certification or licensing standards, helping districts implement educator evaluation and support systems, and providing pre-service educator preparation and in-service professional development. The remaining funds are distributed to school districts.54 Congress could amend Title II, Part A to permit SEAs to draw from the state allotment an additional 1.5 percent or $300,000 (whichever is less), to offset the costs of sponsoring teacher apprenticeships, giving priority to high-need schools and in hard-to-staff subjects with persistent teacher shortages, such as special education. Funds could be used for personnel to manage the effort and, at the state’s option, the development of resources that will be useful to school districts and higher education institutions implementing educator apprenticeships. This would generate about $162,000 in the smallest states and $300,000 in the largest ones,55 amounts sufficient to support one or two employees and their activities. SEAs could use the funds themselves if they wish to be sponsors or subgrant them to institutions of higher education, local educational agencies, teacher unions, intermediaries, or other nonprofit organizations that take on sponsorship for their state. 

Conclusion

Degree apprenticeship is a promising way to promote economic mobility, but it needs policy infrastructure to support its growth. Smart, creative people have launched degree apprenticeships in scattered pockets of the country and demonstrated their power. We need policymakers to expand the model. As policymakers look to advance an agenda that delivers for working Americans, degree apprenticeship offers a bipartisan opportunity to expand access to good jobs while helping employers build the talent they need to fix critical workforce shortages.

Acknowledgments

We are grateful to the Strada Education Foundation for generously supporting our work on degree apprenticeships and the insightful conversations we have had with its team over the course of this project. Lancy Downs was an important partner in identifying our policy recommendations. This brief was made stronger by the thoughtful guidance of Taylor White and Iris Palmer. Sabrina Detlef’s editorial comments made our writing sharper, and we thank Katherine Portnoy, Mandy Dean, Maggie Navracruz, and Kelley Gardner for their support on production and dissemination. The findings and conclusions contained in this brief are those of the authors and do not necessarily reflect positions or policies of the foundation.

We would also like to thank the 12 members of the advisory committee for this degree apprenticeship project: 

  • Nicole Kendall Arrighi, Assistant Dean, Educator Preparation, Education Practice and Leadership, Tennessee State University
  • Anthony Caison, Former Vice President of Workforce Continuing Education, Wake Technical Community College
  • Andrew Cortés, Founder, President, and CEO, Building Futures, Apprenticeship Rhode Island
  • Eric Dunker, Chief Business Development and Strategy Officer, WorkForward
  • Juanita Glanton, Medical Assistant Apprentice, Arapahoe Community College
  • Steve Jurch, Associate Vice President, Center for Policy and Practice, Association of Community College Trustees
  • Casey Kilpatrick, Director of Learning Services, Colorado Education Association
  • Deborah Kobes, Senior Fellow, Apprenticeships and Labor Markets, Urban Institute
  • Tyler Sturdivant, Associate Dean of Nursing, Coastal Alabama Community College
  • Jason Trotter, Head of Talent Acquisition & Apprenticeship Program, Aon
  • Darice Trout, Senior Director of Workforce Solutions and Job Placement, William Rainey Harper College
  • Katrina Vigil, State Apprenticeship Director, New Mexico Department of Workforce Solutions

More About the Authors

Braden Goetz
Braden Goetz headshot
Braden Goetz

Senior Policy Advisor, Center on Education & Labor

Ivy Love
E&W-LoveI
Ivy Love

Senior Policy Analyst, Center on Education & Labor

Citations
  1. Gad Levanon, Matt Sigelman, Mariano Mamertino, Mels de Zeeuw, and Gwynn Guilford, No Country for Young Grads: The Structural Forces That Are Reshaping Entry-Level Employment (Burning Glass Institute, July 2025), 13, https://www.burningglassinstitute.org/research/no-country-for-young-grads.
  2. Andrew Hanson, Carlo Salerno, Matt Sigelman, Mels de Zeeuw, and Stephen Moret, Talent Disrupted: College Graduates, Underemployment, and the Way Forward (Burning Glass Institute, February 2024), 6, https://www.burningglassinstitute.org/research/underemployment.
  3. Carl D. Perkins Career and Technical Education Act of 2006, as amended, § 3(8), 20 U.S.C. § 2302(8) (incorporating the definition in WIOA § 3(7), 29 U.S.C. § 3102(7)), https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap44-sec2302.pdf.
  4. Higher Education Act of 1965, as amended, § 484(d)(2), 20 U.S.C. § 1091(d)(2), https://www.govinfo.gov/content/pkg/USCODE-2024-title20/pdf/USCODE-2024-title20-chap28-subchapIV-partG-sec1091.pdf.
  5. Workforce Innovation and Opportunity Act, Pub. L. 113-128, § 3(7), 29 U.S.C. § 3102(7), https://www.govinfo.gov/content/pkg/USCODE-2020-title29/html/USCODE-2020-title29-chap32.htm.
  6. New America uses the term degree apprenticeship, while others describe the model as apprenticeship degree. We are agnostic on word order. What is important is that the field and policymakers agree on a common definition.
  7. U.S. Department of Labor, Office of Apprenticeship, “What is RAPIDS?” https://www.apprenticeship.gov/help/what-rapids.
  8. U.S. Department of Education, Federal Student Aid, “National Student Loan Data System (NSLDS®),” https://fsapartners.ed.gov/financial-aid-delivery/nslds.
  9. Courtney Phillips (Operations Manager, Colorado Department of Labor and Employment), personal communication with authors, May 27, 2025.
  10. U.S. Department of Labor, Employment and Training Administration, Bureau of Apprenticeship and Training, “Apprenticeability Request Process,” Circular No. 94-06, June 22, 1994, https://www.apprenticeship.gov/sites/default/files/bulletins/Circular_94_06_Apprenticeability_Request_Process.pdf.
  11. See also Deborah Kobes, John Marotta, and Julia Payne, Setting the Stage for Scaling Apprenticeship Degrees: Priorities for Research, Policy, and Practice (Urban Institute, May 2026), 24, https://www.urban.org/research/publication/setting-stage-scaling-apprenticeship-degrees.
  12. National Center for O*NET Development, “About O*NET,” O*NET Resource Center, sponsored by the U.S. Department of Labor, Employment and Training Administration, last modified October 6, 2026, https://www.onetcenter.org/overview.html. Occupational profiles are available through O*NET OnLine, https://www.onetonline.org/.
  13. U.S. Bureau of Labor Statistics, “Table 5.4: Education and Training Assignments by Detailed Occupation, 2025,” Employment Projections, https://www.bls.gov/emp/tables/education-and-training-by-occupation.htm; and U.S. Bureau of Labor Statistics, “Measures of Education and Training,” Employment Projections, last modified August 27, 2026, https://www.bls.gov/emp/documentation/education/tech.htm.
  14. American Institute for Innovative Apprenticeship, “About Us,” https://innovativeapprenticeship.org/about-us/.
  15. Urban Institute, “The Urban Institute Announces New $7 Million Funding Award to Establish a Registered Apprenticeship Technical Assistance Center of Excellence,” press release, July 19, 2021, https://www.urban.org/press-releases/urban-institute-announces-new-7-million-funding-award-establish-registered. See also Urban Institute, National Occupational Frameworks: A Guide to Using the Frameworks to Develop and Register High-Quality Apprenticeship Programs (Urban Institute, May 22, 2023), https://www.urban.org/apps/national-occupational-frameworks.
  16. U.S. Department of Labor, “U.S. Department of Labor Continues Aggressive Expansion of Registered Apprenticeship Program with Alabama, Colorado Partnerships,” press release, September 23, 2025, https://www.dol.gov/newsroom/releases/osec/osec20250923.
  17. Braden Goetz and Ivy Love, Degree Apprenticeship: A Remedy for the Health Care Talent Crisis (New America, August 2026), 10, https://www.newamerica.org/insights/remedy-for-the-health-care-talent-crisis/.
  18. According to the National Science Foundation’s 2023 National Survey of College Graduates, about 45 percent of individuals with engineering degrees who graduated within the past one to five years were not working in engineering roles in 2023. Authors’ weighted tabulations from the National Center for Science and Engineering Statistics, “National Survey of College Graduates, 2023: Public-Use Data Files,” September 11, 2025, https://ncses.nsf.gov/explore-data/microdata/national-survey-college-graduates.
  19. U.S. Department of Health and Human Services, Centers for Medicare & Medicaid Services, “Rural Health Transformation,” https://www.medicaid.gov/resources-for-states/rural-health.
  20. Downs, Goetz, and Love, Mapping the Landscape of Degree Apprenticeship, 12, https://www.newamerica.org/insights/mapping-the-landscape-of-degree-apprenticeship-expanding-a-promising-model-for-mobility/ii-landscape-scan.
  21. N.C. Gen. Stat. § 115D-5(b)(16) (2025), https://www.ncleg.gov/EnactedLegislation/Statutes/HTML/BySection/Chapter_115D/GS_115D-5.html. See also North Carolina Community College System, “Invest in Your Future with a Registered Youth Apprenticeship,” https://www.nccommunitycolleges.edu/businesses/apprenticeships/unique-pathways/youth-apprenticeships.
  22. Downs, Goetz, and Love, Mapping the Landscape of Degree Apprenticeship, 12, https://www.newamerica.org/insights/mapping-the-landscape-of-degree-apprenticeship-expanding-a-promising-model-for-mobility/ii-landscape-scan/ .
  23. Higher Education Opportunity Act, Pub. L. No. 110-315, 122 Stat. 3078 (2008), https://www.govinfo.gov/content/pkg/PLAW-110publ315/pdf/PLAW-110publ315.pdf.
  24. The law requires an institution’s Federal Work-Study agreement with ED to “provide for the operation by the institution of a program for the part-time employment, including internships, practica, or research assistantships as determined by the Secretary, of its students” in work for the institution itself or for a public agency or private nonprofit organization. The parallel provision for private for-profit employers refers to “a program of part-time employment of its students.” See Higher Education Act of 1965, § 443(b)(1), 20 U.S.C. § 1087-53(b)(1), https://www.law.cornell.edu/uscode/text/20/1087-53.
  25. Higher Education Act of 1965, § 443(c)(2), 20 U.S.C. § 1087-53(c)(2), https://www.law.cornell.edu/uscode/text/20/1087-53.
  26. The law directs ED to first give each participating institution the same FWS amount it received in 1999, before taking into account the needs of current students. See Higher Education Act of 1965, § 442(a), 20 U.S.C. § 1087-52(a), https://www.law.cornell.edu/uscode/text/20/1087-52.
  27. Tristan Stein, Assessing Alternative Allocation Strategies in Campus-Based Financial Aid (Bipartisan Policy Center, December 2024), 6, https://bipartisanpolicy.org/wp-content/uploads/2024/12/BPC_Campus_AID_R03-002.pdf.
  28. U.S. Department of Education, FY 2027 Department of Education Justifications of Appropriation Estimates to the Congress, Volume II, “TEACH Grants” (U.S. Department of Education, 2026), 1, https://www.ed.gov/media/document/fy-2027-congressional-justification-teach-grants-113542.pdf. Low-income school is generally a school eligible for assistance under Title I, Part A of the Elementary and Secondary Education Act where more than 30 percent of students are low-income, or a Bureau of Indian Education or tribal school. See 34 C.F.R. § 686.2(d) (2026), https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-686/subpart-A/section-686.2.
  29. David J. Peyton, Wilhelmina van Dijk, and Loretta Mason-Williams, “Meeting the Moment: Impact of TEACH Grant on US Undergraduate Education Degree Completion in High-Need Content Areas,” Higher Education Policy 36, no. 3 (2023): 431–56, https://doi.org/10.1057/s41307-022-00263-3.https://link.springer.com/article/10.1057/s41307-022-00263-3. See also Daniel Sparks, Why Do So Many Colleges Decline to Participate in a Federal Grant Program for Teachers? (Urban Institute, March 28, 2024), https://www.urban.org/research/publication/why-do-so-many-colleges-decline-participate-federal-grant-program-teachers; and Wesley T. Morris, Financial Aid for Future Educators: Assessing a Federal Grant’s Impact on Students’ Postsecondary Decisions, EdWorkingPaper 25-1278 (Annenberg Institute at Brown University, September 2025), https://doi.org/10.26300/tqkk-a126.
  30. U.S. Department of Education, “TEACH Grants,” 4.
  31. Sparks, Why Do So Many Colleges Decline, 8, https://www.urban.org/research/publication/why-do-so-many-colleges-decline-participate-federal-grant-program-teachers.
  32. See U.S. Department of Education, “Experimental Sites,” https://experimentalsites.ed.gov/index.html.
  33. U.S. Department of Education, “Notice Inviting Postsecondary Educational Institutions to Participate in Experiments Under the Experimental Sites Initiative; Federal Student Financial Assistance Programs Under Title IV of the Higher Education Act of 1965, as Amended,” Federal Register 84, no. 100 (May 23, 2019): 23779–83, https://www.federalregister.gov/documents/2019/05/23/2019-10811/notice-inviting-postsecondary-educational-institutions-to-participate-in-experiments-under-the.
  34. U.S. Bureau of Labor Statistics, “Learning about Educational Services Employment for American Education Week,” TED: The Economics Daily, November 18, 2024, https://www.bls.gov/opub/ted/2024/learning-about-educational-services-employment-for-american-education-week.htm; and American Hospital Association, “Fast Facts on U.S. Hospitals, 2026,” February 5, 2026, https://www.aha.org/statistics/fast-facts-us-hospitals-2017.
  35. U.S. Department of Labor, “States That Offer Tax Credits for Hiring Apprentices and Tuition Support for Registered Apprentices,” Apprenticeship.gov, https://www.apprenticeship.gov/employers/state-tax-credits-and-tuition-support.
  36. Downs, Goetz, and Love, Mapping the Landscape of Degree Apprenticeship, 19, https://www.newamerica.org/insights/mapping-the-landscape-of-degree-apprenticeship-expanding-a-promising-model-for-mobility/ii-landscape-scan/.
  37. See 34 C.F.R. § 668.5(c)(3) (2026), https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.5. See also U.S. Department of Education, “Written Arrangements Between Title IV-Eligible Institutions and Ineligible Third-Party Entities Providing a Portion of an Academic Program,” Dear Colleague Letter GEN-22-07, June 16, 2022, https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2022-06-16/written-arrangements-between-title-iv-eligible-institutions-and-ineligible-third-party-entities-providing-portion-academic-program.
  38. See 34 C.F.R. § 668.5(g) (2026), https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.5.
  39. U.S. Department of Education, “Apprenticeships and the Federal Student Aid Programs,” Dear Colleague Letter GEN-14-22, December 18, 2014, https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2014-12-18/gen-14-22-subject-apprenticeships-and-federal-student-aid-programs. The guidance predates the 2020 and 2026 rulemakings that produced the current text of the regulation.
  40. U.S. Department of Education, 2026–2027 Federal Student Aid Handbook, vol. 7, The Federal Pell Grant Program, chap. 3, “Pell Grant Enrollment Intensity and Cost of Attendance,” https://fsapartners.ed.gov/knowledge-center/fsa-handbook/2026-2027/vol7/ch3-pell-grant-enrollment-intensity-and-cost-attendance.
  41. Federal regulations exempt from the written-arrangement rules internships and externships that are governed by accreditor standards, for which the institution is responsible and in which students are monitored by qualified institutional personnel. This describes the structure of clinical education in nursing and other health programs. See 34 C.F.R. § 668.5(h)(2) (2026), https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.5.
  42. 34 C.F.R. § 668.5(h)(2) (2026), https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.5.
  43. Downs, Goetz, and Love, Mapping the Landscape of Degree Apprenticeship, 21, https://www.newamerica.org/insights/mapping-the-landscape-of-degree-apprenticeship-expanding-a-promising-model-for-mobility/ii-landscape-scan/.
  44. The community college code defines work-based learning as the development of job skills and an opportunity for career exploration, providing a student with employment coordinated with the educational program. It permits institutions to award credit of one semester hour for each 160 hours of work-based learning, capping the credits that may be awarded at two hours for certificates, four for diplomas, and eight for associate in applied science (AAS) degrees, except that Registered Apprentices may use up to 16 hours in diploma and AAS programs. See 1D N.C. State Bd. of Cmty. Colls. Code 400.10(e)(6)(A) (amended effective Feb. 1, 2022), https://wordpress.nccommunitycolleges.edu/sites/default/files/legal/sbccc/subchapter/subchapter_400_curriculum_01feb22_emended_03-20-2022.pdf.
  45. Until ED issues the guidance described in our previous recommendation, state policy should treat credit awarded for on-the-job learning as instruction provided by the employer for purposes of the federal limits on outside entities. Such credit should not exceed 25 percent of a program, or it may exceed 25 percent but must remain under 50 percent only if the institution’s accrediting agency has specifically determined that the arrangement meets its standards and the institution and employer are not under common ownership or control. See 34 C.F.R. § 668.5(c)(3), (g) (2026), https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.5. Once ED clarifies that these limits do not apply to on-the-job learning in a Registered Apprenticeship, states can remove this restriction.
  46. Disclaimer: New America was a subcontractor on the ERA project, which was led by RTI International.
  47. Evie Blad, “Trump Admin. Defunds a Program to Help Launch Teacher Apprenticeships,” Education Week, May 15, 2025, https://www.edweek.org/teaching-learning/trump-admin-defunds-a-program-to-help-launch-teacher-apprenticeships/2025/05.
  48. Blad, “Trump Admin. Defunds a Program,”  https://www.edweek.org/teaching-learning/trump-admin-defunds-a-program-to-help-launch-teacher-apprenticeships/2025/05.
  49. Goetz and Love, Degree Apprenticeship, 14, https://www.newamerica.org/insights/remedy-for-the-health-care-talent-crisis/.
  50. Public Health Service Act, tit. VII, 42 U.S.C. §§ 292–295p, https://www.law.cornell.edu/uscode/text/42/chapter-6A/subchapter-V; and Public Health Service Act, tit. VIII, 42 U.S.C. §§ 296–298d, https://www.law.cornell.edu/uscode/text/42/chapter-6A/subchapter-VI.
  51. Lancy Downs and Amaya Garcia, Living Up to Its Promise: Three Ways to Make Teacher Degree Apprenticeship Programs Work (New America, August 2026), https://www.newamerica.org/insights/living-up-to-its-promise/.
  52. U.S. Department of Education, FY 2027 Department of Education Justifications of Appropriation Estimates to the Congress, “School Improvement Programs” (U.S. Department of Education, 2026), 9, https://www.ed.gov/media/document/fy-2027-congressional-justification-school-improvement-programs-113538.pdf.
  53. Kirsten Baesler, Office of Elementary and Secondary Education, U.S. Department of Education, “Dear Colleague,” (U.S. Department of Education, February 9, 2026), 3, https://www.ed.gov/media/document/guidance-strategic-staffing-under-title-ii-part-113188.pdf.
  54. U.S. Department of Education, FY 2027 Department of Education Justifications of Appropriation Estimates to the Congress, “School Improvement Programs,” 9, https://www.ed.gov/media/document/fy-2027-congressional-justification-school-improvement-programs-113538.pdf.
  55. The smallest state allocation in FY 2026 was $10,837,184 and the largest was $230,667,172. See U.S. Department of Education, “Supporting Effective Instruction State Grants (Title II, Part A),” https://www.ed.gov/grants-and-programs/formula-grants/school-improvement-grants/supporting-effective-instruction-state-grants-title-ii-part#funding-status-awards.
Growing Degree Apprenticeships: Recommendations for Congress, Federal Agencies, and States