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Understanding On-The-Job Training &

Apprenticeship Approval
An Informational Guide for Employers and Sponsors

SECOND EDITION | EDUCATION SERVICE

VETERANS BENEFITS ADMINISTRATION | JUNE 2017


GI BILL® IS A REGISTERED TRADEMARK OF THE UNITED STATES DEPARTMENT OF VETERANS AFFAIRS (VA).
T H E A B S E N C E O F T H E R E G I S T R A T I O N S Y M B O L ® D O E S N O T C O N S T I T U T E A W A I V E R O F V A ’S T R A D E M A R K
RIGHTS IN THAT PHASE.
Table of Contents

Preface............................................................................................................... 1
Program Overview ............................................................................................. 1
Conditions Prior to Approval (VA) ...................................................................... 2
Approval of Programs (VA)................................................................................. 3
Registering Your Program (DOL) ........................................................................ 4
Registered Apprenticeship Sponsors .................................................................. 5
Employer Responsibility ..................................................................................... 6
Federal Statute References ................................................................................ 6

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Preface
This informational guide is written for employers and sponsors who are offering (or wish to
offer) On-the-Job or Apprenticeship training (OJT/APP) to Veterans and their beneficiaries.

The law provides that VA may pay educational assistance to Veterans and other eligible
individuals while they pursue approved training programs. Approval may be granted for
programs offered at educational institutions as well as formal on the job training provided by
employers (private or public).
The Director, Education Service, Veterans Benefits Administration, on behalf of the Secretary of
Veterans Affairs, has authority to approve programs offered by agencies of the Federal
Government. State Approving Agencies (SAA) have approval authority over non-federal
OJT/APP training programs within their respective states. Registered apprenticeship programs
are approved by the U.S. Department of Labor (DOL).
If after review, you have further questions about VA policies and procedures or about
completing VA forms, contact your SAA (non-federal approvals only) or your VA Education
Liaison Representative (ELR) (federal approvals only). You can locate your SAA and find your
ELR contact information.

For questions regarding registered apprenticeships, please see our contact list for your state
DOL representative.

You may also review additional information on eligibility for benefits and copies of pamphlets,
which provide detailed information on the GI Bill website and DOL’s registered apprenticeships
website.

Program Overview
Benefits for On-the-Job and apprenticeship training are available for Veterans under the various
VA educational assistance programs, including the Post-9/11 GI Bill. These programs allow
Veterans to learn a trade or skill through training on the job rather than by attending a formal
program of classroom based instruction yielding a degree or certificate. A Veteran generally
enters into a training contract for a specific period with an employer, and at the end of the
training period, the Veteran gains job certification or journeyman status.

Employers generally pay a reduced OJT/apprenticeship wage (which must be at least 50% of
journeyman wage). Unless the training establishment is operated by a Federal, State, or local
government, periodic wage increases must be granted and, by the last full month of training,
the wage must be at least 85% of the wage for a fully trained employee. Veterans in an
approved program can use their GI Bill benefit and receive tax-free benefits. First, the Post-9/11

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GI Bill pays a Monthly Housing Allowance (MHA) based on the Department of Defense’s Basic
Allowance for Housing (BAH) for an E-5 with dependents, which is paid in addition to wages.

Stipend = First six months of training 100% of applicable MHA

Second six months of training 80% of applicable MHA

Third six months of training 60% of applicable MHA

Fourth six months of training 40% of applicable MHA

Remaining pursuit of training 20% of applicable MHA

The stipend is reduced 20% every six months, until it equals 20% of the Monthly Housing
Allowance, as the Veteran’s wages regularly increase until the Veteran has attained journeyman
status and pay. Second, the Post-9/11 GI Bill also pays up to $83 per month for books and
supplies in a lump sum. See our rate table showing stipend payments for other GI Bill
programs.

Approved employers can use this benefit as a recruiting tool by using wages plus stipend to
attract Veteran candidates. This training is not available to active duty Servicemembers or their
spouses using a transferred benefit.

Conditions Prior to Approval (VA)


Prior to approval, the following conditions must be met:
 Availability of qualified journey workers to provide close supervision to trainees
throughout the training program.

 Ability to maintain records for each trainee. At a minimum, records should include
o Job assignments

o Promotions/demotions

o Layoffs/terminations

o Rates of pay

o Progress in training as outlined in the work processes

o Hours of training given monthly in each process, and

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o Overall progress evaluations made at least each 3 months

 Credit must be given for previous training and experience, and the length of the
program reduced proportionately.
o Trainees who are granted credit must be placed into the appropriate step of the
wage progression scale

 A copy of the approved training agreement must be provided to the trainee and VA.

 The wages paid to VA trainees will not be less than wages paid to trainees who are not
eligible for VA benefits.

 The beginning wage will be at least 50% of the wage for a fully trained employee,
periodic wage increases will be granted, and by the last full month of training the wage
will be at least 85% of the wage for a fully trained employee, unless your establishment
is operated by a Federal, State or local government.

 There is a reasonable certainty that the job for which the training is provided will be
available to the trainee after training has been completed.

Approval of Programs (VA)


The Director, Education Service, Veterans Benefits Administration, on behalf of the Secretary of
Veterans Affairs, has authority to approve programs offered by agencies of the Federal
Government, as well as programs related to interstate commerce carriers and railroads.

Under the provisions of 38 U.S.C. §3671, SAAs have approval authority over nonfederal
OJT/APP training programs within their respective states. Employers wishing to have their
OJT/APP program(s) approved must contact the SAA to begin the approval process. Employers
wishing to obtain approval in multiple States must contact the SAAs within those States.

Approval requirements for both federal and non-federal OJT/APP programs are the same.
When applying, the below information must be submitted to the VA ELR (federal) or SAA (non-
federal):

 Employer’s Application to Provide Job Training

 Training outline (schedule of major operations and tasks to be learned, including


number of hours required over the duration of the program).

 For apprenticeships – Meet criteria standards of apprenticeships published by


Department of Labor pursuant to 29 USC 50a.

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Read our FAQ to learn more information regarding OJT & apprenticeship programs and how to
apply.

Registering Your Program (DOL)


The U.S Department of Labor’s Office of Apprenticeship, works in conjunction with State
Apprenticeship Agencies to administer the program nationally. These agencies are responsible
for registering apprenticeship programs that meet federal and state standards; protecting the
safety and welfare of apprentices; issuing nationally recognized and portable Certificates of
Completion of Apprenticeship to apprentices; promoting the development of new programs
through marketing and technical assistance; assuring that all programs provide high quality
training; and assuring that all programs produce skilled and competent workers

Depending on your needs, there are multiple options for how you can register your program:

 National Guideline Standards (NGS) – NGS are generally appropriate for


organizations with multiple chapters of affiliates across the country. NGS are
useful when organizations seek to provide some level of consistency across their
affiliates, but wish to allow for some ability to customize programs at the local
level.

 National Program Standards (NPS) – NPS are generally appropriate for large
national employers that wish to implement the same apprenticeship program
across the country in multiple locations.

 State Apprenticeship Program Standards – Local programs are appropriate for


apprenticeship programs operating in one state or region.

The Department of Labor has released two tools to assist you with starting an apprenticeship
program:
 Quick Start Toolkit for Employers

 You can also register your program online using the Apprenticeship USA
Registration Tool

For more information on the registration process, please see our contact list for your state
representative.

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Registered Apprenticeship Sponsors
Industries today are constantly on the lookout for talent, and our nation’s Veterans are a
proven talent pool. The Departments of Veterans Affairs (VA) and Labor are working together
to make GI Bill® approval for registered apprenticeship programs a seamless process.

If your program is currently a registered apprenticeship program, it qualifies to be “deemed


approved” for the GI Bill®. To determine whether your program is eligible, it is best to first
contact your SAA for advice and guidance.

To ensure that eligible Veterans in your Registered Apprenticeship program can receive GI Bill
benefits, you will need to provide the following completed forms and information to your SAA:

 Employer’s Application to Provide Job Training - VA Form 22-8865


o Can be obtained from SAA representative

 Designation of Certifying Official(s) – VA Form 22-8794


o Can be obtained from SAA representative

 Registered Apprenticeship Program Standards

Your SAA can authorize your Registered Apprenticeship program as “Approved for the GI Bill®”
typically within 30 days. Then, VA can provide your eligible Veterans with the GI Bill educational
assistance benefits they have earned. Please inform your Veteran apprentices they should visit
the GI Bill website to complete their individual applications to receive benefits.

By taking this simple action, your organization is not only supporting your current eligible
Veteran apprentices, but also ensuring that future Veterans you hire in the Registered
Apprenticeship program can also receive their GI Bill benefits. We encourage you to inform
your Veteran apprentices about the GI Bill benefits available and advertise your program’s
eligibility in your Veteran apprentice recruitment efforts.

Upon approval, we encourage you to include in your apprenticeship job openings that the
positions are “Approved for the GI Bill®” in order to inform Veterans about their potential
eligibility for those benefits as an apprentice with your organization. Please also include the
following trademark disclaimer – ‘“GI Bill®” is a registered trademark of the U.S. Department of
Veterans Affairs (VA).’ More information about education benefits offered by VA is available at
the GI Bill website.

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Employer Responsibility
Apprenticeship programs provide jobs to apprentices, oversee training development, and
provide hands-on learning and technical instruction for apprentices.

As an employer/sponsor, you are the point of contact for Veterans enrolled in your program.
Providing them with general information regarding your program will be one of your primary
responsibilities. In addition, you will also be responsible for the following certification and
recordkeeping requirements:

 Maintaining the Veterans files Verifying hours submitted to VA. The Certifying
Official must have access to official payroll records or other official records that
reflect hours worked.

 Completing and forwarding the initial and monthly Enrollment Certifications (VA
Form 22-1999 and VA Form 22-6553d-1), and a copy of the signed training
agreement to the VA Regional Processing Office.

 Evaluating and maintaining a record of previous education and training of Veterans


and eligible persons, granting appropriate credit, shortening the course/program
proportionately and notifying the trainee of the results of the evaluation. A copy of
the trainee’s notification should be retained in the file.

 Forwarding appropriate documentation to VA. This includes:

o Copies of all Training Agreements

o Notification of trainee withdrawal from a program

o Changes in Certifying Officials

o Changes in requirements for approved programs

o Name and/or address changes for the organization or the primary Certifying
Official

Federal Statute References


Source: 38 U.S.C. § 3677: Approval of Training On the Job

(a) Any State approving agency may approve a program of training on the job (other
than a program of apprenticeship) only when it finds that the job which is the objective
of the training is one in which progression and appointment to the next higher
classification are based upon skills learned through organized and supervised training on

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the job and not on such factors as length of service and normal turnover, and that the
provisions of subsections (b) and (c) of this section are met.

(b)(1) The training establishment offering training which is desired to be approved for
the purposes of this chapter must submit to the appropriate State approving agency a
written application for approval which, in addition to furnishing such information as is
required by the State approving agency, contains a certification that—

(A) the wages to be paid the eligible veteran or person

(i) upon entrance into training, are not less than wages paid nonveterans in the same
training position and are at least 50 per centum of the wages paid for the job for which
the veteran or person is to be trained, and

(ii) such wages will be increased in regular periodic increments until, not later than the
last full month of the training period, they will be at least 85 per centum of the wages
paid for the job for which such eligible veteran or person is being trained; and
(B) there is reasonable certainty that the job for which the eligible veteran or person is
to be trained will be available to the veteran or person at the end of the training period.

(2) The requirement under paragraph (1)(A)(ii) shall not apply with respect to a training
establishment operated by the United States or by a State or local government.

(3) The requirement for certification under paragraph (1) shall not apply to training
described in section 3452(e)(2) of this title.

(c)As a condition for approving a program of training on the job (other than a program
of apprenticeship) the State approving agency must find upon investigation that the
following criteria are met:

(1)The training content of the course is adequate to qualify the eligible veteran or
person for appointment to the job for which the veteran or person is to be trained.

(2)The job customarily requires full-time training for a period of not less than six months
and not more than two years.

(3)The length of the training period is not longer than that customarily required by the
training establishments in the community to provide an eligible veteran or person with
the required skills, arrange for the acquiring of job knowledge, technical information,
and other facts which the eligible veteran or person will need to learn in order to
become competent on the job for which the veteran or person is being trained.

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(4)Provision is made for related instruction for the individual eligible veteran or person
who may need it.

(5)There is in the training establishment adequate space, equipment, instructional


material, and instructor personnel to provide satisfactory training on the job.

(6)Adequate records are kept to show the progress made by each eligible veteran or
person toward such veteran’s or person’s job objective.

(7)No course of training will be considered bona fide if given to an eligible veteran or
person who is already qualified by training and experience for the job.

(8)A signed copy of the training agreement for each eligible veteran or person, including
the training program and wage scale as approved by the State approving agency, is
provided to the veteran or person and to the Secretary and the State approving agency
by the employer.
(9)That the course meets such other criteria as may be established by the State
approving agency.

Source: 38 U.S.C. § 3687: Apprenticeship or Other On-Job Training

(a) An eligible veteran (as defined in section 3452(a)(1) of this title) or an eligible person
(as defined in section 3501(a) of this title) shall be paid a training assistance allowance
as prescribed by subsection (b) of this section while pursuing a full-time—

(1) program of apprenticeship approved by a State approving agency as meeting the


standards of apprenticeship published by the Secretary of Labor pursuant to section 2 of
the Act of August 16, 1937 (popularly known as the “National Apprenticeship Act”) (29
U.S.C. 50a), or

(2) program of other on-job training approved under provisions of section 3677 of this
title, subject to the conditions and limitations of chapters 34 and 35 of this title with
respect to educational assistance.

NOTE: Federal OJT/APP program approvals must adhere to the same


statute outlined above. However, per 38.U.S.C.S 3672, the Secretary has
responsibility for the approval of courses of education offered by any
agency of the Federal Government authorized under other laws to
supervise such education.

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Source: 38 U.S.C. § 3672: Approval of Courses

(b)(1) The Secretary shall be responsible for the approval of courses of education
offered by any agency of the Federal Government authorized under other laws to
supervise such education. The Secretary may approve any course in any other
educational institution in accordance with the provisions of this chapter and chapters 34
and 35 of this title.

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