The U.S. Department of Labor (DOL) issued new guidance establishing a five-component framework for effective pre-apprenticeship programs.
“For the merit shop electrical contracting industry, the new framework is significant because it outlines the federal government’s vision for the relationship between pre-apprenticeship and Registered Apprenticeship,” IEC’s federal lobbyist Ben Brubeck, Principal and CEO of Government Affairs Solutions, said. “Rather than viewing pre-apprenticeship simply as introductory training, DOL wants pre-apprenticeship programs to prepare participants and provide a defined pathway into Registered Apprenticeship as the Trump administration continues to shape policy and government funding in support of the administration’s goal of creating 1 million apprentices as part of its broader talent strategy supporting reindustrialization and other needs of the U.S. economy.”
Issued September 8 by DOL’s Employment and Training Administration, Training and Employment Notice (TEN) 05-26, Framework for Effective Pre-Apprenticeships, provides a framework for states, workforce boards, education providers, employers, and apprenticeship sponsors developing pre-apprenticeship programs and clarifies how pre-apprenticeships can operate across federally funded workforce and education programs. It rescinds and replaces DOL’s 2024 guidance TEN 23-23, Quality Pre-Apprenticeship Programs.
DOL on Pre-Apprenticeship
DOL describes pre-apprenticeship as an “effective on-ramp” to Registered Apprenticeship that prepares career seekers with the “foundational, technical, and employability skills needed to enter and succeed in a Registered Apprenticeship and beyond.”
The new DOL guidance calls for “clearly defined pathways into Registered Apprenticeship career opportunities” and encourages partnerships among pre-apprenticeship programs, Registered Apprenticeship sponsors, and employers. DOL also emphasizes that existing workforce and education programs can serve as pre-apprenticeships by partnering with Registered Apprenticeship sponsors and creating pathways into apprenticeship.
A workforce training program may provide valuable occupational skills without necessarily providing the structured pathway DOL envisions for pre-apprenticeship. The goal is to prepare participants for an actual apprenticeship opportunity and help them succeed once they enter.
DOL identifies five core components of an effective pre-apprenticeship program.
1. A Pathway into Registered Apprenticeship
Pre-apprenticeship should establish a clear pathway into Registered Apprenticeship through partnerships with apprenticeship sponsors and employers.
For sponsors, this creates an opportunity to help shape the workforce pipeline before individuals enter apprenticeship and to establish clear expectations for the transition from pre-apprenticeship into apprenticeship.
2. Industry-Driven Training
Training should be aligned with the skills, competencies and expectations of the relevant Registered Apprenticeship and occupation.
For the electrical industry, this could include foundational technical skills, safety, employability skills, and career exploration that prepare participants for the requirements of an electrical apprenticeship. Employers and apprenticeship sponsors should have a meaningful role in shaping the curriculum.
3. Hands-On Learning and Career Exposure
Effective pre-apprenticeships should provide opportunities for participants to gain hands-on experience and understand the occupation and workplace.
For electrical contractors, that could include exposure to construction sites, laboratories, equipment, tools, and safety practices. This gives prospective apprentices an opportunity to develop foundational skills while determining whether the occupation is a good fit.
4. Workforce and Education Partnerships
DOL encourages partnerships among employers, Registered Apprenticeship sponsors, workforce organizations, and education providers.
These partnerships can help programs leverage existing resources and provide participants with services such as career counseling, mentoring, transportation, childcare, tools, and other support. Potential funding sources include the Workforce Innovation and Opportunity Act (WIOA), Perkins V, Workforce Pell, and other federal, state, and local programs.
WIOA is particularly relevant because it provides a pathway for pre-apprenticeship to become part of the broader public workforce system. DOL’s framework explains how pre-apprenticeship can be incorporated into workforce programs and supported through WIOA-funded services, creating an opportunity for workforce boards and other WIOA partners to connect participants with training, supportive services, and pathways into Registered Apprenticeship.
For employers and apprenticeship sponsors, this can help shift pre-apprenticeship from a stand-alone recruitment effort to a coordinated workforce pipeline supported by employers, workforce boards, education providers, and other partners.
5. Outcomes and Continuous Improvement
Programs should track enrollment, completion, credentials, and, importantly, whether participants actually enter Registered Apprenticeship.
DOL points to the existing Registered Apprenticeship data system as one way to improve this measurement. Apprentices are asked on ETA Form 671 whether they previously completed a pre-apprenticeship program, allowing that information to be captured in the Registered Apprenticeship Partners Information Database System (RAPIDS).
This shifts the focus from simply counting pre-apprenticeship graduates to measuring whether programs are actually producing apprentices and, ultimately, skilled workers.
Workforce Pell Provides Another Potential Connection
TEN 05-26 also addresses the relationship between pre-apprenticeship and Workforce Pell. DOL explains that an eligible pre-apprenticeship may potentially qualify for Workforce Pell if it satisfies the applicable requirements. For programs that do not independently qualify, DOL identifies potential approaches involving a partnership with a Title IV-eligible institution or integration of the pre-apprenticeship into the related instruction component of a Registered Apprenticeship. Workforce Pell eligibility is not automatic simply because a program is designated as a pre-apprenticeship.
What This Means for IEC Members
For electrical contractors, apprenticeship sponsors, and pre-apprenticeship providers, TEN 05-26 provides a practical framework for evaluating existing and proposed pre-apprenticeship programs.
The key questions are:
- Does the program provide a clear pathway into Registered Apprenticeship?
- Are employers and apprenticeship sponsors involved in developing the training?
- Is the curriculum aligned with the apprenticeship and occupation?
- Does the program provide meaningful hands-on or work-based learning?
- Can workforce-system resources such as WIOA help support training or participant needs?
- Does the program measure how many participants actually enter Registered Apprenticeship?
“As the electrical construction industry faces continued demand for an estimated 80,000 electricians a year for the next ten years, the DOL’s new framework may provide the spark needed to transform pre-apprenticeship programs into structured talent pipelines connecting prospective workers with employers and Registered Apprenticeship opportunities,” Brubeck said. “This policy shift has the potential to benefit IEC’s apprenticeship programs, pre-apprenticeship programs, stakeholder relationships, and member contractors if executed properly.”