
Public Comment Letter Regarding National Apprenticeship System Enhancements
March 18, 2024
CHEPP, the Competency-Based Education Network (C-BEN), and the Community College System of New Hampshire (CCSNH) submitted the following public comment letter to the US Department of Labor’s Employment and Training Administration Request for Information (RFI) on National Apprenticeship System Enhancements. The letter opposes the proposed elimination of the Competency-Based approach to Apprenticeship on-the-job training requirements. The letter shares how this change will negatively impact ongoing growth of apprenticeships into more sectors, particularly in occupations not traditionally served by apprenticeships, including education. It also explains how prioritizing time instead of mastery of skills or content impedes the ability for training programs to act nimbly and limits the ability to rapidly update programs that must respond to changing workforce needs.