Three Strategies for Advancing Workforce Education & Training

Introduction

For decades, the public education system offered one value proposition: do well here, get a college degree, and enjoy a meaningful career and a middle-class life—or don’t. Workforce education and training programs were deprioritized and viewed as the lower track toward, at best, a job with static prospects. Despite $1.86 trillion in total student loan debt—or approximately $40,000 per borrower—about half of college graduates go on to jobs that do not require a college degree (Hanson, 2026; Weismann, 2024). Considering these sobering statistics, today, the public increasingly sees workforce education as a path to a good-paying, stable career (Britebound, 2026). Almost two-thirds of Americans believe that workers who complete an apprenticeship are more employable than college graduates (Sweeney, 2018). The share of parents who believe career and technical education (CTE) is best suited for high-achieving students has nearly tripled from 13% to 35% since 2019 (Bay, 2026).

Enrollment in these programs has increased alongside improving perceptions. The number of apprentices in federal Registered Apprenticeship Programs (RAPs) increased from 395,764 in 2016 to 714,050 in 2026 (DOL, n.d.-a). Participation in CTE programs has also grown since 2019, despite expected enrollment declines during the COVID-19 pandemic (U.S. Department of Education, n.d.). During the 2023-2024 school year, 8,642,099 secondary and 3,325,414 postsecondary students participated in CTE. Furthermore, in 2019, about 85% of all high school students completed at least one CTE course before graduating (National Center for Education Statistics, 2024).

The question is whether policymakers can keep up with demand from both parents and employers. According to one source addressing labor market shortages in manufacturing, there is an “annual shortfall between skilled-trade openings and qualified graduates [of 1.7 million workers]” (Greiner & Matias, 2025). This skill gap forces employers to hire unqualified or underqualified workers. This issue extends to other industries as well. According to the U.S. Bureau of Labor Statistics, the number of annual openings in healthcare, education, and information technology will remain high over the next decade, primarily due to Baby Boomers retiring; meanwhile, there are not enough students in workforce education programs to fill projected openings in many occupations (U.S. Bureau of Labor Statistics, 2025a, 2025b, 2025c).

Federal statutes such as the Strengthening Career and Technical Education for the 21^st Century Act (“Perkins V”) (20 U.S.C. § 2301 et seq), the Workforce Innovation and Opportunity Act (WOIA) (29 U.S.C. § 3101 et seq), and the National Apprenticeship Act (29 U.S.C. § 50 et seq) provide governing frameworks and funding for workforce education and training. While these programs provide important support to states, policymakers must advance state-level policies to meet their unique labor market needs. States can and should serve as what Justice Brandeis called the “laboratories of democracy.” They can pilot new policy initiatives, discard those that don’t work for them, and look to adopt policies that have proven successful elsewhere.

There is not a one-size-fits-all approach to workforce education and training. However, there are a number of very promising approaches taking root in states across the country. The most promising approaches can be categorized into three distinct strategies:

1. Equip high school graduates with the skills they need to acquire stable employment where they grew up and where their family remains. Some states are taking significant steps to shift public schools away from an overriding emphasis on college preparation by providing students with more information about the local labor market and shifting instructional emphasis toward a focus on vocations.
2. Provide families with a clear understanding of the financial costs and benefits of pursuing workforce education. Some states are more effectively leveraging their education and workforce data to inform and empower families and young adults pursuing workforce education.
3. Build on federal apprenticeship program initiatives by directing tax credits and subsidies to businesses prepared to take a more active hand in training new employees. Some states are effectively supplementing federal Registered Apprenticeship Programs with employer incentives, strategic investments, and governance reforms to help employers train a more highly skilled workforce.

This toolkit identifies 14 policies from 12 states that are consistent with these strategies. What works in one state may not necessarily work in another. Regardless, every policy in this toolkit is worthy of examination by governors and state legislators across the country.

Strategy One: Equip high school graduates with the skills they need to acquire stable employment near their family’s home.

About a third of Americans today have bachelor’s degrees, approximately the same share of Americans who had a high school degree in 1950 (Gauthier, 2026). The Greatest Generation did not need college degrees to have a fair shot at the American dream, and American middle and high schools gave students what they needed to enter the workforce and help make America the greatest economic powerhouse of the 20th century. While the expansion of higher education has undoubtedly benefited many, public education has increasingly become preparation for college rather than for a career. The notion that America must increase its share of college graduates to maintain economic competitiveness mistakes educational metrics for economic merit. Rather than insisting that students spend years in lecture halls to prepare them for a “globalized economy,” policymakers should look for ways to help high school students acquire solid employment where they grew up and where their family remains. Some states that are paving a path forward are doing so through the following measures.

Policy 1: Ensure that Middle School Career Exploration Courses Provide Meaningful Experiences and Labor Market Information

Middle school career exploration courses give students an opportunity to identify personal aptitudes and prospective career paths. Forty-two states require and dedicate funding toward such coursework (Britebound & Education Strategy Group, 2024, p. 3). But few states require middle schools to provide students with state labor market information or to emphasize career pathways that do not require a college degree. This may be due to a longstanding sentiment that “tracking” students—sorting them administratively into separate school rooms and, from there, careers—is un-American.

Rather than sort students, middle schools can empower students and parents to chart their own educational paths based on student aptitudes and career interests, and then school districts can respond to demand. For example, students who identify an interest in nursing through a middle school career exploration course may be more likely to enroll in health care CTE courses in high school, thereby preparing them for college and helping them build job-ready skills along the way. State policy should not only help students identify their aptitudes and career interests but also ensure that students understand relevant labor market information about potential careers, including median earnings and job demand at the state and national levels. Additionally, students should be exposed to the full range of education and training options available to them, including opportunities for apprenticeships, non-degree pathways, and short-term industry-aligned credentials.

State

Policy

Utah

Administrative Rule R277-916 (College and Career Awareness) requires 7th and 8th grade students to complete a “College and Career Awareness” course. State standards require students to: identify their interests, skills, and aptitudes; explore the connection between career choices and earnings; examine labor market information, including information on job demand and wages; evaluate multiple education and training pathways aligned to their career choice, including apprenticeships and industry certifications; and participate in work-based learning experiences (Utah State Board of Education, 2025).

Policy 2: Provide High School Students with Information on In-Demand Occupations and Median Wages, Annually

As students progress from middle school to high school, they should continue to receive information regarding in-demand occupations at the state and national levels on a consistent basis. Whereas a general course may suffice to help middle school students chart a path forward, high school students should be provided every year with the most up-to-date job market information. States have a duty to ensure that the students who graduate from their high schools do so with an accurate image of local economic conditions and knowledge of steps they could take to attain a variety of career goals.

State

Policy

Missouri

Mo. Rev. Stat. § 167.902 requires that all high school students receive annual information on in-demand occupations in the state. The law also directs the State Board of Education and the Department of Economic Development to provide information on: projected job growth, typical salaries, required skills and traits, licensure and credential requirements, education and training pathways to those occupations—including both college and apprenticeship options, as well as information on financial assistance for postsecondary education.

Policy 3: Provide Resources for Middle and High School Students to Pursue In-Demand Professional Training

Students thrive when families are empowered to direct their education. This principle should not be limited to school choice programs. Public and private school students can and should be provided with resources to opt into coursework outside of the traditional middle and high school curriculum and into training programs that yield industry-recognized credentials. Students can be given specialized accounts they can use for community college credits, providing them with the opportunity to complete an associate degree by the time they graduate. These accounts could also be applied toward state-approved workforce development programs, and schools should credit the acquisition of workforce skills towards graduation. Students may get more lasting economic value from an electrical apprenticeship program than from 12th-grade coursework, and states should provide students with the funding to chart their own course toward a career.

State	Policy
Idaho	Id. Code § 33.46 provides 7th-12th graders enrolled in public schools with up to $4,625, and students enrolled in accredited private schools with up to $2,500, to pay for dual credit coursework, workforce training, and approved industry-recognized certifications, including credentials for occupations ranging from plumber to dental assistant to medical patient care coordinator.

Policy 4: Revamp CTE Classrooms and Increase the Number of Seats

Total enrollment in secondary CTE programs has grown tremendously over the last decade (U.S. Department of Education, n.d.). Yet student interest is, in many cases, outstripping school supply. For example, in the past five years, state funding for CTE in Pennsylvania increased by more than 50% (Pennsylvania Department of Education, 2026). But the number of students on waitlists for CTE programs rose 150.6% between FY 2019-20 and FY 2024-25, largely due to a lack of physical space (Legislative Budget and Finance Committee, 2026, p. 18). In addition to expanding the number and/or capacity of classrooms, there is a substantial need to upgrade or replace classroom equipment. Rapid changes in certain industries require CTE instructors to acquire modern, industry-standard equipment to keep instruction aligned with current workforce needs (Advance CTE, 2023). This requires more than simply increasing the annual budget for CTE programs. States should consider implementing and evaluating major, targeted capital infusions for CTE in select high schools, prioritizing programs that serve critical economic needs.

State

Policy

Ohio

Ohio appropriated funds for the Career-Technical Education Equipment Grant Program and the Career-Technical Construction Program through its operating budget for FY 2024-2025 (HB 33). The Career-Technical Education Equipment Grant Program was funded with $100 million for the purpose of establishing new or expanding existing CTE programs, with priority given to programs linked to careers on Ohio’s Top Jobs List (HB 33, Sec. 265.370). The Career-Technical Construction Program was funded with $200 million for the purpose of building or renovating new facilities to expand existing CTE programs or establish new ones (HB 33, Sec. 287.20). The Ohio Department of Education & Workforce (2026) reported that these investments created over 10,000 new seats in CTE programs. Funds were used at 116 schools to “expand or build new CTE facilities and purchase cutting-edge equipment.”

Policy 5: Recruit High-Quality CTE Instructors Through Compensation Incentives

Dedicating funding and more classroom space to CTE instruction will be of limited value unless schools can recruit highly qualified CTE instructors. These instructors should be both highly skilled within their field and personally compelling enough that students could aspire to be like them someday. In many states, teacher licensure systems keep competent CTE teachers out of the classroom. States can and should exempt experienced professionals who want to be CTE teachers from requirements for obtaining traditional licensure. Unfortunately, even when states reduce licensure barriers to entry, the step-and-lane compensation scales for teachers will still discourage high-quality professionals from transitioning from their field to the classroom. One solution is to honor their work by offering starting salaries that reflect their years of experience in the field, treating each year of work as the equivalent of a year in the classroom for compensation purposes. States could also provide direct bonuses for occupational certificates held by prospective CTE teachers. States could provide higher bonuses for occupational certificates in priority professions.

State

Policy

Idaho

Idaho Code § 33-1004B provides school districts with additional funding to compensate CTE instructors based on their certifications and years of experience. The state provides districts with $3,000 for CTE instructors who hold occupational specialist certificates. It also places new teachers entering the classroom from related careers higher on the state's career ladder by crediting between one and four years of career ladder experience based on prior occupational experience.

Policy 6: Provide Tax Credits to Employers Who Offer Work-Based Learning Opportunities to High School CTE Students in Critical Fields

Survey data suggest that high school CTE students credit work-based learning experiences with building career skills (80%) and helping them identify “what they wanted to do for a living” (70%) (Rice, 2025). Research also finds that paid work-based learning experiences for college students are associated with stronger employment and earnings outcomes than unpaid experiences (Torpey-Saboe et al., 2026). While there is broad support for expanding work-based learning opportunities for high school students, employer participation often falls short of student demand due to the time and costs required to train and supervise students (Johnson, 2022; Eddy, 2025). Because these barriers are often financial, targeted incentives for businesses could reduce costs and encourage greater participation.

States should incentivize local businesses to partner with high schools to provide CTE students with work-based learning experiences. States can prioritize critical local economic priorities by issuing tax credit certificates to businesses that employ high school students who are enrolled in an approved CTE program as part of a work-based learning experience. Businesses should apply to the relevant state agency, such as the department of education, describing how the structure of their work-based learning experience will benefit CTE students. While each state will need to determine whether a credit is refundable or nonrefundable, as well as the appropriate credit amount, the incentive should be large enough to lower employer costs associated with training and supervision, but not so large that it incentivizes businesses to subsidize unrelated employment.

State

Policy

Ohio

Ohio Revised Code 5747.057 provides a nonrefundable tax credit to businesses that provide paid work-based learning, internship, or cooperative education programs to high school CTE students aged 19 or younger. Businesses apply to the state’s Department of Education for a tax credit certificate. After receiving this certificate, businesses may claim a credit equal to the lesser of $5,000 or 15% of the wages paid to eligible CTE students.

Strategy Two: Provide families with a clear understanding of the financial costs and benefits of pursuing workforce education.

One thing federal policymakers have gotten right in recent years is the need for transparent data that connects education to economic outcomes. A ban on federally mandated and collected student records has meant that the Department of Education and Department of Labor are limited in their ability to provide granular information that can inform the educational decisions of high school students, or even adults who are seeking to upskill or reskill for a new occupation (20 U.S.C. § 1015(c)). States have access to vastly more data than the federal government. They can and should provide as much transparency to students and citizens as possible.

Policy 7: Maintain a Statewide Longitudinal Data System that Connects Education to Workforce Data, and Publicly Report Employment and Earnings Outcomes by Program

Systems that connect educational attainment to economic outcomes and track them over time, are known as “statewide longitudinal data systems” (SLDS) (von Zastrow & Perez, 2024). In many cases, SLDSs that connect education records to workforce data, often through unemployment insurance (UI) wage records, allow the state to report employment and earnings outcomes for specific programs (Jindal et al., 2015; Bloomquist, 2025). A high-quality SLDS can help parents and students identify programs with strong return on investment (ROI) and enable policymakers to make more strategic investments in education (Menees, 2026). Unfortunately, many states have an SLDS but do not make the data accessible to policymakers or the public, severely limiting its usefulness.

States should create data and reporting systems that connect student records to UI wage data and track student outcomes over time. These systems should protect student privacy while providing meaningful program-level outcome data for students, families, and policymakers. States should report employment and earnings data at the program level whenever possible. To further boost transparency and accountability, these data should be made publicly available online through user-friendly dashboards. In addition to committing to this level of outcome transparency, states should use these data to inform policy, including how to allocate funding to programs that meet local labor market demand and lead to high-wage employment opportunities.

State

Policy

Virginia

Virginia Code § 23.1-204.1 requires the Council of Higher Education for Virginia to publish certain employment and education outcomes at the program level for public and private nonprofit institutions of higher education that are eligible to participate in the Tuition Assistance Grant Program. Specifically, the statute requires the Council to publish employment rates for graduates eighteen months and five years after graduation at the program level. The Council must also report average salaries and, when possible, hours worked and occupation title or code. Additionally, the statute requires the Council to publish education outcomes such as average student debt, average credit attainment, completion rates, remediation rates, and other information the Council deems necessary. The Council publishes reports and interactive dashboards publicly on its website (State Council of Higher Education for Virginia, n.d.-a). Notably, employment and wage data are derived from the state’s UI wage data and linked to education records through the Virginia Longitudinal Data System (State Council of Higher Education for Virginia, n.d.-b).

Policy 8: Establish a Statewide “Credentials of Value” List Using Labor Market Demand and Earnings Criteria, and Link Workforce Program Approval and Funding to the List

A substantial share of postsecondary credentials and degrees offer little to no ROI. A series of analyses finds that over a quarter of associate and bachelor’s degree programs, roughly a third of certificate programs, and nearly half of master’s degree programs offer no ROI for students (Cooper, 2024; 2022; 2021). Students are, therefore, increasingly exploring short-term credential programs, yet these don’t necessarily provide benefit either; some evidence suggests that only 12% of such credentials are associated with positive wage gains (Schneider et al., 2025). Many states are addressing concerns about low- and negative-ROI credentials by identifying a list of high-value ones. These lists, generally referred to as “credentials of value” lists, are publicly available in forty-four states as of 2024 (Advance CTE, 2025).

A 50-state analysis finds that many states do not consistently incorporate critical labor market information and employer recommendations when assessing credentials: only 34 states incorporate employer recommendations, 24 incorporate job demand data, and 23 incorporate wage data (Advance CTE, 2025, p. 2).[1] Additionally, many states lack formal processes for approving credentials, phasing out credentials that no longer meet labor market criteria, and establishing accountability systems. States can create robust credentials of value lists that assess all programs—from short-term certifications to bachelor’s degree programs—and highlight those that both meet local labor market demand and provide a pathway to a career with strong, family-sustaining wages. This should become a standard feature of high school guidance counseling and should be discussed with parents to help families guide their children’s education path, as well as incorporated into college career counseling. State policymakers also can, and should, steer funding away from credentials that do not make the list toward those that do.

State

Policy

Florida

Fla. Stat. § 445.004 directs the Credentials Review Committee to identify nondegree and degree credentials of value to be included in the state’s Master Credentials List. The statute requires that the committee be comprised of representatives from education, commerce, workforce development boards, the Governor’s Office, industry associations, and businesses. The committee is tasked with developing a Framework of Quality and reviewing credentials on the list biennially against that framework. Credentials are evaluated using criteria that include labor market demand and occupational wage thresholds tied to associated occupations (Florida Credentials Review Committee, 2025). The Framework of Quality also includes credential sequencing criteria for industry-recognized, stackable credentials that lead to occupations meeting the framework’s wage thresholds. Credentials that no longer meet the established criteria are removed from the Master Credentials List and could be phased out. The list must be made publicly available.

Policy 9: Protect Students and Future Workers from Low Value College Degrees by Eliminating Programs that Fail an Earnings Test

The Trump Administration and Congress have taken steps to identify low-value degrees with poor earnings outcomes and to steer students away from taking on student loan debt to pursue these degrees. Known as the “Do No Harm” standard: if a bachelor’s degree program or postsecondary credential fails to provide students with a greater return than what they would have received from a high school diploma alone, the program could be cut off from federal financial aid (Cooper, 2025). Graduate or professional programs fail to meet this standard if the median earnings for degree completers are less than the median earnings for workers with only a baccalaureate degree. The federal government has set a satisfactory floor, but states can and should go further in stewarding their tax dollars and protecting students from pursuing programs of dubious economic worth.

States should create their own low-earnings metric based on the earnings of program graduates compared to the earnings of workers with lower levels of educational attainment and review them on an annual basis. Programs failing to meet earnings thresholds should be flagged for potential elimination. It is important that states take a nuanced approach to removing low-earning programs that lead to high-demand occupations which serve the public interest.

State

Policy

Indiana

Indiana SB 199 (2026), enacted as Public Law 120, adopts the definition of a “low earning outcome program” from the Working Family Tax Cut Act, and requires programs at all public postsecondary institutions to pass this earnings threshold. Programs that fail these earnings tests may be eliminated or consolidated with other programs. The statute allows the institution to seek approval to continue offering a program that fails this metric from the Commission for Higher Education. If the approval is denied, the institution must eliminate the degree program and any costs associated with it.

Strategy Three: Build on federal apprenticeship program initiatives by directing tax credits and subsidies to businesses prepared to take a more active hand in training new employees.

The Trump Administration has shown an admirable commitment to expanding apprenticeships and workforce education. For example, President Trump has announced a national goal of reaching one million active apprenticeships. The Working Families Tax Cuts Act expanded the Pell Grant program to cover short-term workforce education, including eligible programs that provide related technical instruction for RAPs. While better federal policy was surely necessary, it is hardly sufficient to foster the kind of progress that our economy demands. States are far better positioned to understand the needs of their local and regional economies, and the most successful states will supplement federal policy reforms with tailored initiatives of their own.

Policy 10: Waive Tuition and Registration Fees for Eligible Youth and Pre-Apprentices and Reimburse Community Colleges

The U.S. Department of Labor (DOL) regulates RAPs, “earn-while-you-learn” programs that combine on-the-job training with classroom instruction (DOL, 2025). Apprentices who complete a RAP earn a nationally recognized certificate of completion. Apprenticeships can start as early as high school through pre- and youth apprenticeship programs that allow students to explore their options while providing a pathway into a RAP (DOL, 2022a; 2022b). Today, over 60% of pre-apprentices continue into a RAP, but there is room to grow that percentage and the overall number (DOL, 2022a). One promising approach is to waive tuition fees for related technical instruction at community colleges with the college receiving a reimbursement for the waived amount. Five years after North Carolina enacted this policy in 2016, the state saw an 83% increase in the number of apprentices (Harrington & Hwang, 2021). More states should follow suit.

State

Policy

North Carolina

NC Gen Stat § 115D-5 originally authorized community colleges to waive tuition and registration fees for students in approved pre-apprenticeship or registered apprenticeship programs if they began participation in the program while enrolled in a North Carolina high school. According to current guidance, students who enroll in a qualifying registered apprenticeship within 120 days of high school graduation can continue to receive the tuition waiver (North Carolina Community College System, 2024). Community colleges submit requests to ApprenticeshipNC for disbursement of funds to cover related instruction expenses, including tuition and fees (North Carolina Community College System, 2026).

Policy 11: Create New Grant Opportunities for Employers to Establish or Expand Registered Apprenticeship Programs in Critical Fields

Prior research finds that RAPs present employers with high upfront and ongoing costs, from recruiting apprentices, compensating mentors, developing curriculum, and delivering instruction (Goger, 2026; GAO, 2025). Recent DOL guidance has cut red tape and provided increased flexibility in program design for employers, but these changes don’t address the underlying financial disincentives or provide employers with the technical assistance they may need to develop and sponsor a RAP (DOL-ETA, 2026a, 2026b).

More states are offering employers tax credits to expand RAPs, but these incentives are generally tied to employing more apprentices rather than defraying the upfront costs of developing and registering new programs (DOL, n.d.-c). States should do more to encourage employers to create new RAPs or expand existing ones by providing targeted financial incentives combined with technical assistance. States can support businesses by creating competitive grant programs for employers that launch new RAPs or commit to expanding existing ones. Additionally, state agencies overseeing these grants should provide technical assistance to ensure that funds lead to new or expanded apprenticeship opportunities. Lastly, states should set clear reporting requirements tied to the number of new programs created and apprentices served.

State

Policy

Colorado

CO Rev Stat § 8-15.7-302 created competitive “Scale-up Grants” administered by the Colorado Department of Labor and Employment. The goal of these grants is to increase the number of active apprentices and geographic distribution of programs, “especially in high-priority, high-demand industries.” Applicants must explain how grant funds will be used to create a new RAP or expand an existing one, with the statute outlining specific performance expectations. An announcement for the first application cycle states that grants would be awarded in $50,000 increments and, if awarded, grantees would also receive technical assistance from the department (Colorado Department of Labor and Employment, n.d.).

Policy 12: Provide Enhanced Tax Credits to Businesses That Employ Apprentices Who Are Enrolled in CTE or WIOA Programs

More than a third of states offer annual tax credits to employers who hire apprentices, with most states offering incentives between $1,000 and $5,000 per apprentice (DOL, n.d.-c). These tax credits offset the costs of hiring and retaining apprentices in Registered Apprenticeships. However, these tax credits often fail to align employer incentives with other workforce education and training initiatives that serve state workforce priorities, such as Perkins V and WIOA programs. States should bolster support for youth already involved in CTE and workforce training programs by providing additional bonuses to businesses hiring apprentices who are also enrolled in CTE programs or WIOA-funded training. These students may require additional supervision and mentoring, increasing employers' training costs. As such, employers should receive larger incentives for hiring them.

State

Policy

Kansas

KS Stat § 74-50,231 established a tax credit for employers who hire apprentices in RAPs. Employers are eligible to receive up to $2,500 per apprentice, up to 20 apprentices per year, and may claim the credit for the same apprentice for up to four years. Beginning in tax years after December 31, 2025, the credit increases to $2,750 per apprentice. The law also provides an additional $500 credit for each apprentice under age 18 who is employed for at least 90 days and participating in a CTE or workforce training program funded by Perkins or WIOA. Each employer may claim up to 10 of these additional credits per year.

Policy 13: Condition State Procurement Contracts on Supporting Registered Apprentices

There is tremendous need to recruit and train new talent in industries related to manufacturing, homebuilding, and critical infrastructure. The problem becomes more dire each year as Baby Boomers retire from these industries. According to the U.S. Department of Education, there could be as many as 2.1 million unfilled positions in the skilled trades by 2030. The labor shortage is expected to have up to $1 trillion in economic losses annually by 2030 (Moore, 2026).

States should use every available policy lever to support proven training methods with high retention rates for completers, such as RAPs. One such method is state procurement. When states spend taxpayer dollars on construction, infrastructure, or manufacturing, to name a few, they should ensure that public contracts help train the next generation of American workers. For example, Maryland’s procurement laws require contractors and certain subcontractors who are awarded procurement contracts to support registered apprenticeships. More states should adopt similar policies.

State

Policy

Maryland

MD State Finance and Procurement Code § 17-603 requires contractors who are awarded a procurement contract to support apprenticeships in one of three ways. Before commencing work, contractors must verify that they are either: participating in a RAP; donating to the State Apprenticeship Training Fund; or making payments to a RAP or an organization that has a RAP. Work cannot commence until contractors provide written verification that they meet one of those conditions.

Policy 14: Ensure State Apprenticeship Agencies, Not State Advisory Councils, Approve New Registered Apprenticeship Programs

Sponsors seeking to establish a RAP either apply directly to the DOL Office of Apprenticeship (OA) or, in states or territories with federally recognized State Apprenticeship Agencies (SAAs), to the SAA for registration. States may establish an SAA that is recognized by OA as the state's Registration Agency pursuant to 29 C.F.R. Part 29. Currently, the OA recognizes 32 SAAs in states and territories to serve as registration agencies (DOL-ETA, 2026c). States with SAAs must also establish a State Advisory Council (SAC) that “may be either regulatory or advisory in nature” (p. 3). Importantly, as recent DOL guidance reiterates, federal regulation requires that only the SAA serve as the Registration Agency, explicitly noting “that a SAC ‘is ineligible for recognition as the State's Registration Agency’” (p. 3).

States that delegate the SAA's authority to approve new RAPs to SACs have, on average, registered far fewer programs than compliant SAA states or states that use the OA as the Registration Agency (Gardiner & Nayak, 2024). Fewer new RAP approvals mean fewer apprentices to fill critical labor gaps. Currently, through law or regulation, SAAs in six states have given their SAC some or all of the authority to approve and/or register RAPs in conflict with federal regulation: Kansas (Kansas Stat. Ann. § 44-662(f), Nevada (NV Rev. Stat. § 610.144), Ohio (Ohio Rev. Code § 4139), Oregon (ORS 660.120), Pennsylvania (34 Pa. Code § 83), and Washington (RCW Chap. 49.04.010). As DOL guidance from this year warns, these states run the risk of having their SAA recognition revoked by OA and, therefore, no longer being able to register new RAPs. States should ensure that the respective roles for their SAA and SAC are clearly defined in statute.

State

Policy

Tennessee

Tennessee statutes clearly define the roles of both the SAA and SAC, assigning responsibilities to each allowed under 29 C.F.R. Part 29. Together, Tenn. Code Ann. § 50-11-103 and Tenn. Code Ann. § 50-11-104 established the state’s Office of Apprenticeship and granted it the authority to approve and register programs. Tenn. Code Ann. § 50-11-105 created the Tennessee Apprenticeship Council as “an advisory council composed of individuals representing employer and employee organizations.”

Conclusion

The idea that 21st century jobs would require students to spend ever more years in formal postsecondary education is belied by economic data. More parents and students are realizing that the ticket to an economically fruitful life isn’t a bachelor’s or a master’s degree, per se, but rather the ability to perform an in-demand job effectively. States that effectively offer and promote workforce education and training programs will see greater economic growth, and those that remain stuck in the old paradigm risk stagnation. The Trump Administration has taken substantial steps at the federal level to promote workforce education, but federal policy can only do so much. Ultimately, it will be up to state policymakers to take serious steps to foster more effective workforce education. Any state looking to do so would be wise to examine the strategies and policies covered in this toolkit.

[1] Advance CTE’s 50-state review primarily examined nondegree credentials (i.e., certificates, industry-recognized credentials, apprenticeship certificates, and occupational licenses), which are aligned to specific occupations. Some states, such as Florida, also include associate and bachelor’s degree programs that are linked to specific occupations (e.g., nursing and computer programming).