May 18, 2023
Situated at the intersection of K-12, higher education, and workforce development, youth apprenticeship programs are often well-positioned to take advantage of several major federal funding streams. However, a lack of clarity around different funding sources’ allowable activities and eligible populations can burden program administrators and impede the development and expansion of youth apprenticeships.
In March and February 2023, the U.S. Departments of Labor (DOL) and Education (ED) released guidance letters regarding, respectively, the Workforce Innovation and Opportunity Act (WIOA) and the Strengthening Career and Technical Education for the 21st Century Act (Perkins V). Federal departments and agencies regularly issue guidance to clarify policies, outline priorities, and explain to the public how the department will interpret a given statute or regulation.
These recent guidance letters outline how WIOA and Perkins V can be used in more flexible and innovative ways to support youth apprenticeship. This post explains the key updates and why they matter for the funding and administration of youth apprenticeship programs.
Using WIOA Title I Youth Funding for Registered Apprenticeship
DOL’s Employment and Training Administration (ETA) released a guidance letter in March 2023 addressing the use of WIOA Title I Youth formula funds. It clarifies several WIOA Youth program policies, including some related to youth apprenticeships.
WIOA Title I Youth provides about $930 million in annual funding for a comprehensive youth workforce development program focused on out-of-school youth and young people facing barriers to employment, education, and training. Most funds go to local workforce development areas, which work with local partners to deliver services.
WIOA mandates that local areas spend at least 20% of their youth funding on work experience. The ETA guidance letter clarifies that spending on both pre-apprenticeships and Registered Apprenticeship (RA) programs for youth can count towards this requirement. This interpretation is notable because WIOA’s statutory definition of work experience doesn’t specifically mention RAs (although it does include pre-apprenticeship programs), so local areas may have been unsure if their spending on registered youth apprenticeship programs would go toward meeting that expenditure requirement.
Practitioners and program administrators can learn more at an ETA webinar on Wednesday, May 24, 2023 at 3:30 PM ET. ETA staff will review the major updates featured in the guidance letter and answer participant questions. Attendees may also submit questions in advance to firstname.lastname@example.org.
Using Perkins V Funding for Registered Apprenticeships
ED’s Office of Career, Technical, and Adult Education (OCTAE) issued a program memo in February 2023 on RA programs and Perkins V funding. In the memo, OCTAE affirms that Perkins V dollars can be spent on: 1) RA programs, 2) RA components like related technical instruction (RTI) or on-the-job learning, and 3) RA prerequisites like pre-apprenticeships. This includes RA programs for high-school-age youth.
Perkins V is the core federal program supporting career and technical education (CTE), providing about $1.4 billion annually in state formula grants for CTE for both youth and adults. Though the term “Registered Apprenticeship” does not appear in the legislation itself, OCTAE confirms that RA programs meet Perkins’ definition of CTE and can be supported with Perkins funding.
Every year, each state receives an allocation of Perkins funds. The law requires that the bulk of this money (85%) be given to local education agencies (LEAs) and postsecondary institutions, but states may use up to 10% of their grant on activities to improve CTE statewide. Both local formula and state leadership funds can be spent on RA programs.
For example, an LEA receiving local formula funds can use that money to cover transportation costs that low-income students incur when participating in an RA program, or a community college may spend their Perkins funds to develop the RTI curriculum for an RA program. (However, in many instances, Perkins funding already supports youth RA programs that incorporate CTE courses into the RTI.) Similarly, states may put their leadership dollars towards creating and scaling RA or pre-apprenticeship programs for high-school-age youth. They can also use those funds to partner with an experienced intermediary organization to build out RA programs statewide.
The full program memo provides additional examples of allowable uses for both local and statewide Perkins funds.
Using Perkins V Funding for Educator Preparation Apprenticeships
In March 2023, OCTAE released additional Perkins-related guidance focused on using Perkins funds to address nationwide educator shortages. As explained in the previous section, states may spend up to 10% of their total Perkins grant on state leadership activities, including recruiting, training, and retaining CTE teachers. In the guidance letter, OCTAE explains that states can use their Perkins leadership dollars to fund Registered Apprenticeship educator preparation programs (EPPs) for CTE teachers.
Though OCTAE’s letter does not explicitly use the term “youth apprenticeship,” the guidance provided would allow Perkins dollars to be spent on an RA EPP beginning in high school. Below are a few key clarifications OCTAE makes regarding allowable uses of Perkins dollars (both state leadership and local formula) that may be relevant for states and program leaders interested in implementing or expanding youth apprenticeship programs:
- States may allocate state leadership funds to developing an RA EPP as a statewide program of study.
- Secondary and postsecondary institutions may use their Perkins subgrants on CTE programs of study that train participants to be teachers. Programs may begin in high school and continue into postsecondary education.
- Perkins dollars may be spent on dual enrollment and work-based learning opportunities for high school students.
- Community colleges are allowed to spend Perkins subgrants on a) the development of RA EPPs and b) related training and instruction expenses for an RA EPP administered by another organization.
More details can be found in pages 11 through 14 of the full letter, available here, as well as additional information about other ways Perkins funding can be used to prepare young people for careers as educators. Practitioners and policymakers can also learn more at an upcoming webinar, Leveraging Federal Resources for Career-Connected Learning to Advance Youth Apprenticeship, at 2 PM ET on Tuesday, May 23, 2023, featuring Luke Rhine, Deputy Assistant Secretary of OCTAE. The webinar is hosted by New America and Advance CTE and will elevate opportunities to leverage federal resources to support youth apprenticeship and work-based learning as part of a broader career preparation ecosystem.
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