Proposed Labor Department rules won’t solve the nation’s apprenticeship awareness problem

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This January, the Department of Labor published a Notice of Proposed Rule Making (NPRM) that would make significant changes to the National Apprenticeship System. The stated purpose of the changes is to expand, modernize, and diversify apprenticeships while also ensuring that apprentices receive a high-quality education and a path to economic mobility. There are many improvements in the proposed regulations, yet they miss an important opportunity to clear up confusion about the terms “youth apprenticeship” and “pre-apprenticeship.”

Outside of a few narrow industries and occupations in the U.S., awareness of apprenticeships as a learning option is very low and plagued with misconceptions. This low utilization is particularly stark in comparison to many of our peer countries. Most Americans are unlikely to consider an apprenticeship without direct outreach.


Apprenticeships combine paid, real-world experience in a profession under the close supervision of a workplace mentor with related classroom education. They typically last one to six years and culminate in a journey worker certificate and/or degree.

Registered apprenticeships in the U.S. are apprenticeships that are approved by a federal or state apprenticeship agency to meet certain standards and wage progression requirements.

The National Apprenticeship System includes the stakeholders (employers, apprentices, intermediaries, joint labor-management organizations, education providers, and state and federal agencies) that support registered apprenticeship programs in the U.S.

Pre-apprenticeships, as defined in the NPRM, are structured education and work-based learning programs that are linked to a registered apprenticeship and prepare people with the foundational competencies and career exposure they need to qualify for a registered apprenticeship.

Youth apprenticeship has no standardized definition.

As part of the expansion of youth apprenticeships, grant-funded initiatives have created a surge of pilot programs in different places. As such, there has been a proliferation of approaches to youth apprenticeships and pre-apprenticeships, but little consistency in the purpose or specific characteristics of the various programs. Some programs are six months long with no postsecondary connection; others are three years long and end with a degree. Some programs are clearly about industry exploration; others prepare participants for specific occupations.

Moreover, it is virtually impossible for consumers to distinguish between youth apprenticeships, pre-apprenticeships, cooperative education, internships, and the myriad other forms of work-based learning. This extreme variation in approaches is confusing and overwhelming to prospective apprentices and employers.

Rather than offering unifying definitions of these commonly used terms, the new regulations propose both a pre-apprenticeship definition (above) and an entirely new and separate category of registered apprenticeship: the Career and Technical Education (CTE) apprenticeship. The CTE apprenticeship allows CTE courses and programs to be used as related instruction (CTE being the existing system of high school courses and postsecondary programs that teach career-specific and technical skills). It has fewer on-the-job training hours and more related instruction than a registered apprenticeship, but it does not lead to a journey worker’s certificate, so it is less advanced.

The proposal for “CTE apprenticeships” is largely driven by an administrative priority to increase alignment between K-12 education and the National Apprenticeship System. While this is a laudable goal, it is not necessary to create a separate type of registered apprenticeship program to achieve that. The use of the acronym “CTE” in the name also fails to put the customer at the center of the system—meaning that it is not designed so that end users can easily understand what it means and its value to them. Shared definitions should avoid technical language that most Americans don’t understand, and they should be recognizable to wide audiences.

The Department of Labor should clarify existing terms, not create new ones

Rather than creating new terms in the apprenticeship regulations, the Labor Department should focus on streamlining and codifying definitions for existing terms—starting with “youth apprenticeship” and “pre-apprenticeship”—and how each fits into a longer work-based learning pathway.

The proposed definition of “pre-apprenticeship” in the NPRM is a helpful step. The department could change the “CTE apprenticeship” to a “CTE pre-apprenticeship” and achieve the same educational alignment goals without having to lean too heavily on the technical name. In other words, it would be a specific type of pre-apprenticeship that helps CTE students have an easier on-ramp into registered apprenticeships. Returning citizens, people with disabilities, the long-term unemployed, out-of-school youth, and other groups would also benefit from a customer-centered path into registered apprenticeships. Fleshing out customer-centered pre-apprenticeship pathways would go a long way toward the NPRM’s stated aim of enhancing the equity and permeability of the National Apprenticeship System. On the other hand, adding a new “registered apprenticeship program” for each target population will result in more program silos, more confusion, and more fragmentation in the field.

For youth apprenticeship definitions, there are many existing definitions to build on and a wide variety of proven models from which to source evidence-based programs. For example, the Partnership to Advance Youth Apprenticeship (PAYA) published defining principles of high-quality youth apprenticeships in 2018. And the Department of Labor’s Advisory Committee on Apprenticeship proposed a recommended definition of youth apprenticeship in 2023.

Program quality is crucial and the goals of aligning apprenticeships with college credit and CTE are important. However, the introduction of a “CTE apprenticeship” does not advance the NPRM’s goal of expanding quality apprenticeship career pathways. It is a jargon-heavy term that will undermine effective outreach. Moreover, it creates more fragmentation in a field that needs streamlining.

The Department of Labor could go even further by laying the groundwork for a sophisticated branding and outreach initiative by situating pre-apprenticeships and youth apprenticeships within a broader work-based learning continuum that starts with light-touch career exposure and has the option to progress to a journey worker’s certificate and/or college degree. That is what Alabama and Colorado have done in their recent apprenticeship expansions, and they have found that clarity about definitions and how they relate to each other provide additional clarity for participants, educators, and employers—and in turn, create more productive conversations.

“Words matter,” said Josh Laney, director of the Alabama Office of Apprenticeship, at a recent Brookings event. “If I say apprenticeship and you say apprenticeship, we’ve got to be talking about the same thing, or we’re not communicating.”

Resources for submitting comments on the NPRM