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Pre-employment training and affordable childcare key to broadening the apprenticeship pipeline

  ·   By Melissa Johnson and Katie Spiker
Pre-employment training and affordable childcare key to broadening the apprenticeship pipeline

Policymakers seeking to increase the number of apprentices should focus their investments in pre-employment training like pre-apprenticeship programs and affordable child care, according to a new brief by the National Skills Coalition, Broadening the Apprenticeship Pipeline.  

Apprenticeships and other forms of work-based learning can help address the nation’s skills gap, but the U.S. falls far behind competitor nations in using work-based learning to train workers for in-demand, middle skill jobs. To address this underutilization and expand the pipeline of workers with access to work-based learning, U.S. policy should better support pre-apprenticeship programs and affordable child care that help women, parents, and other underrepresented people succeed.

For people who have historically had less access to apprenticeships, like women, pre-apprenticeship programs provide a valuable on-ramp that lays the foundation for success. Underrepresented workers without adequate industry experience often need the occupational skills training, exposure to job sites, and engagement with industry leaders that pre-employment programs provide before they reach the skill level necessary to enter work-based learning programs.

But, training alone may not be enough to ensure success. Significant child care costs can make participation in unpaid pre-apprenticeship programs nearly impossible for parents – nearly a third of the workforce. Pre-apprenticeship programs that provide both training and access to child care can open the door to an apprenticeship pathway for a broad range of workers. Once in an apprenticeship, child care continues to be an important support for ensuring participant success since starting wages are lower than those apprentices can expect to make once they’ve completed their program.

The Moore Community House Women in Construction (WinC) program illustrates the importance of child care to pre-employment and work-based learning participants. WinC is a pre-apprenticeship program in Biloxi, Mississippi, that trains women for apprenticeships and nontraditional career pathways in construction, skilled craft trades, and advanced manufacturing. In 2016, the program received a grant from the state — funded with federal dollars Mississippi receives through its Temporary Assistance for Needy Families (TANF) state grant — to offer child care to participants and graduates, and a separate grant from the U.S. Department of Labor’s Strengthening Working Families Initiative (SWFI) to support child care as a retention tool for participants after graduation. Since 2016, WinC enrollment has nearly tripled from nearly sixty women per year to about 180 women per year.

To build on the success of WinC and broaden the apprenticeship pipeline across the nation, this issue brief includes recommendations for both federal and state policymakers. Specifically, Congress and the states should:

  1. Maximize the use of TANF to support pre-employment and child care for work-based learning participants;
  2. Improve alignment between the workforce system and TANF and SNAP recipients; and
  3. Create new work-based learning support funds on both the federal and state levels.


Posted In: Work Based Learning, Work-Based Learning, Mississippi
Modernizing postsecondary data for 21st century students

Students, policymakers, institutions and others should have access to clear information on postsecondary education programs including their employment and wage outcomes. The Workforce Data Quality Campaign’s latest paper, Workforce success relies on transparent postsecondary data, reviews why existing data systems cannot provide key information on postsecondary programs and explains the changes needed to provide students and others with the information they need.  

When making decisions about which programs to invest in, students and policymakers should have information on program costs, completion rates, and employment and wage outcomes. The information should be comparable for programs across the nation and provided over a public, online dashboard that also displays other outcome information such as student retention, loan repayment, default rates, and rates of further education. The website should also include and be searchable by important student characteristics including student demographics and financial aid. The information should be based on student-level data but aggregated at the program level in ways that ensure the security and privacy of personally identifiable information.

Federal policies have stopped short, and even prevented, the provision of this important information. Congress has banned the creation of a data system based on postsecondary student-level data. The Department of Education provides the College Scorecard, but data for the Scorecard are limited to federally aided students. Also, the Scorecard does not show results for individual programs of study, only for institutions as a whole, even though evidence shows labor market outcomes for students vary more by program of study than by institution.

One recent proposal for reauthorizing the Higher Education Act, the “Promoting Real Opportunity, Success, and Prosperity through Education Reform” (PROSPER) Act, would authorize a dashboard with information on individual programs of study, but would still draw data only from federally-aided students, missing thirty percent of student data. The bipartisan College Transparency Act, on the other hand, would overturn the ban on student level data, and direct the Department of Education to create a student-level data network and post better information online about programs across the country.

This paper goes into greater depth explaining these issues -- how current policies fall short and the need for a federal student level data network with a public-facing website, a website that would provide students, education leaders, and policymakers with the information needed to make more informed decisions about postsecondary education.

Posted In: Workforce Data Quality Campaign, Data Sharing, State Longitudinal Data Systems, Employment & Wage Data
House Democrats introduce HEA legislation that would extend Pell grants to short-term programs and increase data transparency

On July 24, 2018, House Education and Workforce Committee Ranking Member, Bobby Scott (D-VA), along with several House Democrats, announced the roll-out of the Aim Higher Act (H.R. 6543)—a comprehensive bill that would reauthorize the Higher Education Act (HEA) for the first time since 2008 if signed into the law. According to the bill’s sponsors, H.R. 6543 consists of proposals contained in Aim Higher, the House Democratic legislative campaign launched in May 2017, as well as amendments offered by Committee Democrats during the December 2017 markup of the PROSPER Act (H.R. 4508)—a controversial HEA re-write introduced by House Republicans late last year.

Many of the provisions in the Aim Higher Act embody long-standing priorities of House Democrats—including access to free community college, increased Pell grant funding, strict oversight of proprietary institutions, and the expansion of support services for underserved students, including DACA recipients and foster and homeless youth. The bill has a number of provisions that contradict those contained in the PROSPER Act—demonstrating that House Republicans and Democrats have been unable to build consensus around modernizing higher education policy.

Bipartisan progress on HEA has also stalled in the Senate. Despite a series of promising hearings on higher education reform this year, Senate HELP Committee Chairman Lamar Alexander announced that his Committee will not produce legislation to reauthorize HEA this Congress. Nonetheless, the Aim Higher Act provides insight into the postsecondary priorities of House Democrats—which helps set the stage for HEA reauthorization debate in the 116th Congress.

Key elements of the Aim Higher Act include:

Extending federal financial aid to short-term programs – The Aim Higher Act contains language from the Pell Grant Preservation and Expansion Act—a comprehensive bill introduced by House and Senate Democrats this Congress; which aims to make a number of changes to the funding and accessibility of Pell grants.

This language would extend Pell grants to academic or job training courses that are at least 150 clock hours of instruction time over a period of at least 8 weeks; so long as the program is part of a career pathway, and results in an industry-recognized credential. Under current law, students are only eligible to receive Pell grants if they are enrolled in a program of study that requires 600 clock hours over a minimum of 15 weeks. This long-standing policy makes federal financial aid inaccessible to students who may be looking to upskill through high-quality, short-term programs—an issue that has been consistently raised by National Skills Coalition (NSC).

The PROSPER Act made similar changes to Pell grant eligibility—however, students would only have access to Pell grants if they were enrolled in a program that was at least 300 clock hours of instruction over a minimum of 10 weeks. Additionally, the PROSPER Act lacks important quality assurance provisions—missing opportunities to engage business and industry leaders in the oversight of short-term programs and set clear guidelines for institutions looking to offer these courses.

NSC has long advocated for students attending short-term programs of high quality to have access to Pell grant programs; a concept that Republicans and Democrats have now both supported in various pieces of legislation, including the bipartisan JOBS Act—introduced by Senators Kaine (D-VA) and Portman (R-OH) last year—the PROSPER ACT, and most recently the Aim Higher Act.

Improving postsecondary data transparency – Due to existing legal restrictions on the collection and dissemination of postsecondary data, students, parents and policymakers do not have a full picture of the quality of higher education programs. Currently, postsecondary institutions are required to report information to the Department of Education through multiple surveys rather than sharing consistent student level data; a practice that is both burdensome and ineffective. Additionally, the federal government only requires colleges to report data on students receiving Title IV financial aid—leaving the public without a clear picture of program outcomes.

The Aim Higher Act addresses this issue by overturning the 2008 student unit record ban and requiring the development of a secure system, housed by the Department of Education, that would evaluate program-level data. This language is similar to that of the College Transparency Act—a bipartisan, bicameral bill led by Senators Hatch (R-UT) and Warren (D-MA) and Representatives Polis (D-CO) and Mitchell (R-MI)—that aims to equip students with the data they need to make informed decisions about their futures. NSC supports the College Transparency Act and is encouraged by the inclusion of similar language in the Aim Higher Act.

The PROSPER Act also took steps to increase the transparency of postsecondary education data by mandating the creation of a college dashboard website. While this public-facing website would include valuable, institution-level information such as student to faculty ratio and the median earnings of students who obtained a certificate or degree both in the 5th and 10th years following their graduation, the student unit record ban would be kept in place—meaning no new data would be captured. While the dashboard acknowledges the importance of data transparency, it leaves students and their families without a complete picture of what to expect from various institutions.

Increasing support services for high-need students – National Skills Coalition has been a vocal advocate for support services for adult and other non-traditional students enrolled in higher education. The majority of postsecondary students today have at least one characteristic of a non-traditional student—which can include working full or part-time while attending school, parenting a dependent child, or entering college for the first time after spending years in the workforce.  These students often have different needs than first-time, full-time college students between the ages of 18-23 who are living on campus while attending classes.

To help aid non-traditional students, the Aim Higher Act establishes a $150 million grant program for states to establish or expand initiatives that help vulnerable populations, such as foster and homeless youth, successfully transition to college. Grantees would also be required to award funding to institutions looking to provide wrap around services to these students, such as housing, childcare, and transportation, once they enroll in college.

NSC supported a similar proposal introduced in the Senate this Congress, known as the Gateway to Careers Act. Led by Senator Hassan (D-NH) this measure would support career pathways for nontraditional students through dedicated federal grant funding. The grants, which would be administered by the U.S Department of Education in consultation with the U.S Department of Labor, would be awarded on a competitive basis to institutions that are working in partnership to serve students experiencing barriers to postsecondary access and completion. Career pathways, which combine access to career counseling, direct support services—such as childcare and transportation—and basic skills instruction, lead students to the skills and credentials they need to persist and succeed in today’s economy.

In addition to this new grant program, the Aim Higher Act increases funding for existing student support programs, including:

  • The Child Care Access Means Parents in School Program (CCAMPIS)
    • The Aim Higher Act would increase funding for CCAMPIS, a program that provides campus-based child care services to low-income parents, from $16 million per year to $67 million (a $51 million increase).
    • The PROSPER Act preserved CCAMPIS but did not provide additional funding for the program. 
    • The Federal TRIO Programs (TRIO)
      • TRIO programs are designed to provide services to individuals from disadvantaged backgrounds. TRIO includes eight different programs targeted to assist low-income individuals, first generation college students, and individuals with disabilities—so that they can progress through the academic pipeline from middle school to postbaccalaureate programs. The Aim Higher Act increases funding for TRIO programs by $110 million—which would bring total funding to $1.01 billion.
      • The PROSPER Act cut funding levels for TRIO by $50 million.
      • Federal Supplemental Educational Opportunity Grants (SEOG)
        • SEOG is a federal assistance grant reserved for college students with the greatest need—roughly 81% of students who receive SEOG come from families earning less than $30,000 per year.
        • The Aim Higher Act phases out the current SEOG allocation formula and replaces it with one that would base the amount of funding on the level of unmet need at an institution as well as the percentage of low-income students they enroll; rather than how long the institution has participated in the program. The Aim Higher Act also creates a pilot program that allows institutions to use up to 5% of their FSEOG funds to provide emergency grants to students.
        • Under the PROSPER Act, SEOG would have been eliminated.
        • Federal Work Study (FWS) program
          • The bill would also replace the current FWS grant allocation formula with the one proposed for SEOG—and would include a “bonus allocation” for institutions that have strong outcomes for serving and graduating Pell recipients. The Aim Higher Act would also double funding for FWS.
          • FWS also received an increase in funding under the PROSPER Act, although the current funding formula would stay in place. PROSPER also aimed to give students participating in FWS more flexibility to work in the private sector during their time in school.
          • Pell Grant Program
            • The Aim Higher Act extends financial aid access to those who have historically been unable to qualify for assistance, including undocumented students who are eligible for the Deferred Action for Childhood Arrival (DACA) and individuals who were previously or are currently incarcerated.
            • The bill would also increase the maximum Pell award by $500 each year and permanently index the grants for inflation. Additionally, students would be able to access Pell grants for fourteen semesters instead of the current twelve.

Other notable elements of the Aim Higher Act include:

Establishing a federal-state partnership to finance free community college – One of the hallmarks of the Aim Higher Act is the establishment of a federal-state partnership that would cover the cost of community college for students across the United States. States would be able to opt into a partnership with the federal government, through which they would receive federal funding, so long as they committed to providing all students with two years of community college free of cost—and continued to invest in education to reduce the financial burden on students and families.

The concept of free community college dates back to “America’s College Promise”—a plan announced by President Obama in 2015 that would tuition to community college students who maintain a grade-point average of 2.5 or better, and who graduate within two years. Although America’s College Promise was not supported at the federal level while President Obama was in office, a number of states have continued or adopted their own free tuition programs; including Tennessee, Oregon, Rhode Island and California.

Simplification of the federal student loan system – The Aim Higher Act would provide students with two repayment options for their student loans: a fixed repayment plan, or an income-based repayment plan. Borrowers who are more than 120 days delinquent will automatically be enrolled in an income-based repayment plan.

A step toward Competency Based Education (CBE) – The Aim Higher Act green lights a demonstration project that allows participating CBE programs to request flexibility from some regulatory requirements seen as barriers to implementation. In exchange, annual evaluations of CBE programs are required. An institution’s accrediting agency is also required to set standards specific to CBE.

As of today, the Aim Higher Act has not yet been scored by CBO. National Skills Coalition looks forward to continuing to work with Members of Congress on both sides of the aisle as move closer to enacting higher education legislation that works for today’s students.

Posted In: Adult Basic Education, Career and Technical Education, Federal Funding, Higher Education Access

New WIOA community engagement guide aims to bolster nonprofit input in planning process

  ·   By Amanda Bergson-Shilcock,
New WIOA community engagement guide aims to bolster nonprofit input in planning process

Note: A webinar about this new guide will be held on August 23, 2018. The webinar is being co-hosted by the International Rescue Committee, Grantmakers Concerned with Immigrants and Refugees, and Workforce Matters. Register here.

A newly released publication is encouraging community-based organizations in California to actively participate in their local Workforce Innovation and Opportunity Act (WIOA) planning process and otherwise engage with their local workforce boards.

California Nonprofits and the Public Workforce System: How CBOs Can Make Their Voices Heard in the WIOA Planning Process is a short, readable guide designed for nonprofit advocates. It is being released in anticipation of the upcoming deadline for the required modifications of WIOA plans, which occurs midway through the plans’ four-year timeframe.

The guide was authored by Erica Bouris of the nonprofit International Rescue Committee, which has offices in 26 US locations, including six in California. It was funded by the Grove Foundation and the Walter and Elise Haas Fund. Both foundations are part of the Immigrant Workforce Learning Community, a group co-convened by Grantmakers Concerned with Immigrants and Refugees and Workforce Matters.

Sections of the guide include:

  • What is WIOA planning and why does it matter?
  • Workforce system fundamentals: Understanding the local system and services
  • Who makes decisions about WIOA investments and services locally? 
  • How much funding is at stake?
  • Where do CBOs fit into this?
  • How could your CBO engage in the WIOA planning process?
  • What obligations do Workforce Development Boards have in the WIOA planning process and service delivery?

The publication also provides examples of how California nonprofits have engaged with their local public workforce system, including by informing strategy development for Opportunity Youth, having a seat on the local workforce board, becoming a contracted service provider, winning competitive grants through the state workforce board’s Workforce Accelerator Fund, and participating in the state’s trailblazing English Language Learner (ELL) Navigator program.

Finally, nonprofits are provided with practical suggestions for how to participate, including by making public comments at workforce board meetings, sharing reports and data, inviting workforce staff to witness programs in action, and applying for a seat on the workforce board.

The guide complements more formal guidance previously released by the California Workforce Development Board. That guidance requires local workforce boards to take specific steps to ensure that a diverse range of stakeholders have opportunities to participate in WIOA planning.

Posted In: Immigration, Workforce Innovation and Opportunity Act

DOL releases guidance on “industry-recognized” apprenticeship programs

  ·   By Katie Spiker,
DOL releases guidance on “industry-recognized” apprenticeship programs

On July 27th, the Department of Labor (DOL) issued Training and Employment Notice (TEN) 03-18, Creating Industry-Recognized Apprenticeship Programs to Expand Opportunity in America, which outlines the process that will allow trade associations and other non-governmental entities to certify apprenticeship programs as meeting industry standards.

In July 2017, President Trump issued an  Executive Order to Expand Apprenticeship in America (EO), which called for the establishment of an alternative system of industry-recognized apprenticeships that would not require direct approval by a government entity. The proposed process is intended to make it easier for businesses to gain approval for new programs while also supporting the development of quality assurance standards in industries where apprenticeships are not well utilized.  

In the TEN, DOL provides insight in to the process by which a non-governmental entity, like a business association or non-profit intermediary, will be able to qualify as a certifier of industry-recognized apprenticeships and advises organizations interested in playing a certifier role to prepare to submit proposals to DOL. The guidance largely adheres to recommendations from the Task Force on Apprenticeship Expansion, established under the July 2017 EO and whose work culminated in a report to the President earlier this summer.

Distinctions between IRAP and Registered Apprenticeship

Under current law, the U.S. Department of Labor or a state agency registers apprenticeship programs, documenting that the structure of the program’s on-the-job learning, classroom instruction, mentoring and safety components meet certain standards such that successful completion of the program will earn workers a journey-level credential marking their expertise in a certain occupation. These programs are subject to regulations describing the types of occupations for which apprenticeship can be used, structure of training and expertise apprentices need to earn under 29 C.F.R 29 and to detailed rules to promote Equal Employment Opportunity (EEO) under 29 C.F.R. 30. Most apprenticeships in the U.S. are – and have been – in the construction industry, with occupations in manufacturing, utilities and transportation sectors also utilizing the training strategy. Occupations in industries like health care, retail, IT and financial services use registered apprenticeship with more frequency in recent years.

The state or federal government oversight required to register a program imbues upon its sponsors certain benefits – several states provide tax credits for registered programs, others support tuition costs and community colleges. Registered programs are automatically eligible to be added to a state’s Eligible Training Provider List (ETPL) under the Workforce Innovation and Opportunity Act (WIOA), which is intended to make it easier for training providers running apprenticeships to access federal workforce funds. Registered programs are also required to report less information on participants for which they use workforce funds, in part a recognition that an apprentice is, from the first day of a program and unlike other training programs, an employed worker. Congress has also appropriated nearly $250 million in recent years to DOL to support expansion of registered apprenticeship.

The guidance draws explicit and implicit distinctions between registered apprenticeship and industry-recognized:

  • Industry-recognized apprenticeship cannot be used in the construction industry or for military apprenticeships;
  • Industry-recognized apprenticeships will not be automatically eligible for the ETPL;
  • Industry-recognized apprenticeship program participants will not be considered apprentices under Davis-Bacon prevailing wage laws; and
  • The guidance includes a vague catch-all that these programs are ineligible for “other statutory benefits” which presumably includes access to Congressionally appropriated funds targeted to registered programs under 29 C.F.R. 29.

Requirements for Certifiers of Industry Recognized Apprenticeship Programs

Most of the guidance focused on the role and responsibility of an entity who certifies that the industry-recognized program meets industry needs. More detail is expected in draft regulations this Fall, however the guidance provides general insight into the direction in which DOL is likely to go in those regulations.

To qualify as a certifier, an organization or consortia will have to show:

  • Sufficient expertise in and engagement with a sector to serve as a qualified certifier. Future regulations will presumably offer a definition of what reaches the level of sufficient expertise, but DOL does recognize that there will likely be multiple certifiers within industry sectors.
  • Ability to provide public information on the programs certified, number of completers of a program, those participants pre- and post-program earnings, length of a program, and “post-apprenticeship employment rate.” The TEN cites to data collection required under WIOA and under rules applied to Registered Apprenticeship as models of necessary information certifiers should be prepared to release.
  • Quality of certified programs, defined as programs including a paid work component, structured on-the-job training, mentorship, training related instruction – with a focus on providing college credit for that instruction – the award of an industry recognized credentials, safe workplaces and “equal employment opportunity.”
  • Several procedural components of their capacity as a certifier such as well-established procedures for certifying programs and impartiality and independence from undue influence in doing so.

NSC supports a focus on paid, high quality work-based learning programs and the collection and dissemination of data on outcomes for participants in these programs and many components in the TEN are consistent with NSC recommendations.

Upcoming regulations, expected this Fall, offer DOL an opportunity to expand on this guidance in a few important ways:

Enable a local focus: While portability is an important component of industry-recognized credentials, NSC encourages DOL to focus on the role local industry partnerships can play in certifying programs that meet local workforce need, particularly through the inclusion in the process of small and medium-sized businesses. The bipartisan PARTNERS Act would support industry partnerships between representatives from the workforce and education systems, multiple businesses and community organizations to expand access to work-based learning. NSC encourages DOL to emphasize the importance of engagement with both national companies and local businesses in establishing the context for “industry-recognized.”

Require disseminated, disaggregated data: NSC supports the alignment of data measures with WIOA performance metrics and the requirement that certifiers release the data on participation and retention for apprentices after completion of their program. We also encourage DOL to require certifiers to collect and make publicly available disaggregated data on these metrics.

Ensure meaningful equal employment opportunity in industry-recognized apprenticeship: DOL defines a certifier’s role in ensuring EEO as requiring sponsors to engage in outreach and recruitment strategies to “diverse” populations, adhering to existing EEO laws, and designating a person with responsibility for monitoring these efforts. These are all important components to ensuring equity in apprenticeship but are far from sufficient. Given task force recommendations that regulations governing EEO in registered programs do not apply to industry-recognized and the absence of explicit application to programs in the TEN, industry-recognized programs will likely not be required to meet the standards required by 29 C.F.R. 30. The rules in this section were recently updated to require more targeted analysis of potential workers in an apprenticeship program, with a focus on how programs are creating equal opportunity for women, people of color and people with disabilities. Integrated and intentional EEO requirements from the formation of the new industry-recognized apprenticeship system could help prevent the inequities that currently plague registered apprenticeship, where only seven percent of apprentices are women and where people of color earn significantly lower wages and complete programs and significantly lower rates than white men.

In addition to meaningful EEO requirements, NSC encourages DOL to require certifiers to ensure that apprentices have access to and success in apprenticeship programs by working with sponsors to provide workers access to supports like child care, transportation and pre-apprenticeship training. The bipartisan BUILDS Act would provide support for services like these that help a diverse set of workers succeed in apprenticeship.

Establish quality control mechanisms for certifiers: Upcoming regulations also offer DOL the opportunity to provide a detailed mechanism for enforcing certifier requirements. NSC encourages DOL to include enforcement and monitoring mechanisms that enable accurate and continuous evaluation of certifier efficacy in meeting the needs of both businesses and workers in upcoming draft regulations, expected this fall.

Next steps on Industry-Recognized Apprenticeships

Interested entities can submit to be qualified as a certifier “shortly”, which is likely to be after the release of draft regulations providing more insight on the rules governing industry recognized apprenticeships. DOL is currently accepting comments and statements of interest in becoming a certifier at apprenticeship@dol.gov.

While DOL does not describe funding availability in the TEN for certifiers, earlier this month the agency announced a call for applications for $150 million in funds to support the expansion of industry recognized system. Partnerships between educational institutions and business associations or consortia of businesses are eligible for that funding, for which applicants will help businesses set up and run industry-recognized apprenticeship programs. Applications are due October 16th, 2018. DOL also released almost $1 million in funding available to community-based organizations to provide technical assistance to help expand women’s access to apprenticeship and non-traditional occupations through the latest iteration of the Women in Apprenticeship and Nontraditional Occupations (WANTO) grants. WANTO applications are due August 16th, 2018.

NSC will continue to work with our partners across the country and Apprenticeship Forward national partners to provide DOL and Congress with recommendations to implement high-quality apprenticeship programs that meet business demand and worker need.

Posted In: Work Based Learning