What to Know About DOL’s New Pre-Apprenticeship Guidance

Back-to-school season means brand-new notebooks, freshly sharpened pencils, and…federal guidance on pre-apprenticeship? We’ll admit that the final item in that list isn’t a typical hallmark of the new school year, but just last week, the US Department of Labor (DOL) released Training and Employment Notice (TEN) 05-26, its new guidance on pre-apprenticeship. DOL and other federal agencies regularly issue policy statements through guidance documents, such as TENs, which articulate the agency’s priorities and preferences but are not legally binding. 

TEN 05-26, which replaces DOL’s 2024 guidance on pre-apprenticeship, focuses on three core areas: 

• DOL’s new five-part framework for effective pre-apprenticeship. Components include: (1) direct pathways into Registered Apprenticeship (RAs) through partnerships with RA sponsors and employers; (2) industry-driven training and curriculum aligned to RA standards; (3) hands-on, work-based learning and career exposure; (4) broad workforce and education partnerships to expand access and leverage available resources; and (5) outcomes tracking and continuous improvement.
• Considerations for pre-apprenticeship in different settings, including high schools and institutions of higher education.
• Information on how federal funding streams including WIOA Youth and Perkins V can support pre-apprenticeship.

Below, we outline three key takeaways from TEN 05-26.  

DOL’s New Framework Components Provide Practical, If Familiar, Direction

In the absence of a federal registration process for pre-apprenticeships, these programs vary wildly in design and quality. Those that are well-designed and -resourced can put learners on a clear, articulated trajectory to a Registered Apprenticeship. But those that aren’t risk becoming dead-end pathways for participants.  

In TEN 05-26, DOL puts forth its “Framework for Effective Pre-Apprenticeships” that identifies the quality elements the department sees as essential for ensuring pre-apprenticeships create a true pathway into RA programs. These components—many of which are similar to those in the 2024 pre-apprenticeship guidance—make good sense. For example, the framework emphasizes that pre-apprenticeships should be built in partnership with RA employers, articulate a clear path into a RA, and provide learners with hands-on learning opportunities aligned with the skills RA employers need. The framework cites best practices, like the ability to earn credentials or certifications and develop employability skills, that can be particularly important for youth. These opportunities set them up for continued success in an affiliated RA while still ensuring the pre-apprenticeship was a value-add if they choose not to continue. 

The Guidance Underemphasizes Pre-Apprenticeship as an Equity Strategy

Pre-apprenticeship is not just a nice-to-have stepping stone into a full-fledged apprenticeship. It is a key tool for bringing talent from underrepresented and underserved populations into Registered Apprenticeships. Unlike the 2024 guidance, TEN 05-26 does not discuss how pre-apprenticeship programs can effectively recruit and serve participants from historically marginalized communities, nor does it emphasize the importance of supportive services for pre-apprenticeship participants. Holistic supports like transportation, childcare, or career coaching are often essential for participants from underserved populations to successfully complete the program and transfer to an RA. 

This is a missed opportunity to inform state leaders and pre-apprenticeships practitioners about the central role their programs play in making the RA system more inclusive and how best to support participants from historically underserved communities to completion. 

To learn more about how pre-apprenticeships can advance equity, consider two alternative frameworks: Principles for a High-Quality Pre-Apprenticeship from CLASP and Framework for a High-Quality Pre-Apprenticeship Program from JFF. Like DOL’s prior guidance, these frameworks approach pre-apprenticeship as an equity strategy and identify specific design choices that allow underserved pre-apprentices to succeed in their programs. 

Pre-Apprenticeship Isn’t the Only Way Youth Fit into the RA System

TEN 05-26 provides helpful information about how youth—both in- and out-of-school—can participate in pre-apprenticeships and what federal funding streams can support them in doing so. But by virtue of the TEN’s focus on pre-apprenticeship, it says little about youth involvement in Registered Apprenticeship programs, which could leave an apprenticeship newcomer with the misconception that pre-apprenticeship is the only way young people can engage with the RA system.

Below we explain four ways youth fit into both pre-apprenticeship and Registered Apprenticeship. 

• A high school student does not need to complete a pre-apprenticeship before starting an RA. While a high-quality pre-apprenticeship can certainly be a helpful precursor to an RA, it isn’t required. RAs designed for youth include training and support to meet young people’s specific needs, like employability skills training. The TEN discusses this practice in the pre-apprenticeship context, but it’s also a good tool for RAs. 

• Learners do not need to wait until after high school graduation to begin an RA. Federal law allows for apprentices as young as 16 years old. In fact, many states have defined youth-serving models of RAP as RAPs that start while apprentices are in high school.  

• High school CTE isn’t limited to pre-apprenticeship and can serve as related instruction for RA. TEN 05-26 notes that high school CTE programs can serve as pre-apprenticeships if they connect to established RA programs, but that’s not the only role CTE plays in the apprenticeship system. Secondary CTE courses can also count towards related instruction for RA, and some states require them to do so for youth enrolled in an RA.

• Federal workforce and education programs, like WIOA and Perkins, can support youth in RA in addition to pre-apprenticeship. The TEN clarifies how federal funding streams, like the Workforce Innovation and Opportunity Act (WIOA) and the Strengthening Career and Technical Education for the 21st Century Act (Perkins V), can be used to support in-school and out-of-school youth participation in pre-apprenticeship. Those programs are also able to support youth participation in Registered Apprenticeship as well. 

Pre-apprenticeship can be a valuable on-ramp to apprenticeship, but it should not become a default prerequisite. When it comes to youth, our focus should be on creating effective pathways for young people into the apprenticeship system. Depending on the context and the needs of learners and employers, that might mean youth begin their apprenticeship journey with a high-quality pre-apprenticeship program, direct entry into a registered apprenticeship, or a state-defined youth apprenticeship model. In other words, the label a program carries matters far less than its commitment to quality and ability to connect students’ learning needs with the talent needs of employers. The terminology we use around youth and apprenticeship can sometimes create more confusion than clarity, but it shouldn’t stand in the way of building apprenticeship pathways that serve youth and industry alike.