Apprenticeship and OntheJob Training Basic Duties of Certifying

Apprenticeship and On-the-Job Training Basic Duties of Certifying Officials VETERANS BENEFITS ADMINISTRATION March 2015

Presenters Jorge L. Carrasquillo, KY ELR - Compliance Surveys Charles Humble, ATL ELR - Basic Duties of Certifying Officials / - Basic Forms Completion / Certification Issues Tracy Clay, KY SAA - SAA Approvals Tom Morrison, TN SAA - SAA Approvals VETERANS BENEFITS ADMINISTRATION 1

Certifying Officials Responsibilities 1. Act as the organization’s point of contact for the VA. 2. Provide general information regarding the certification process to the veteran trainee. 3. Maintain the veteran trainee’s file. VETERANS BENEFITS ADMINISTRATION 2

Certifying Officials Responsibilities 4. Verify hours submitted to VA. The Certifying Official must have access to official payroll records or other official records of hours worked by the trainee within each certification period. Note: The hours submitted must equal the number of hours the trainee was training in any of the approved work processes. Once the trainee satisfactorily completes a work process, or accumulates the total number of hours allowed for any work process, future hours performing that function should not be certified. VETERANS BENEFITS ADMINISTRATION 3

Certifying Officials Responsibilities 5. Complete and forward the initial Enrollment Certification (VA Form 22 -1999), and a copy of the signed training agreement to the VA’s Regional Processing Office. 6. Maintain a record of previous education and training of veterans and eligible persons, grant appropriate credit, shorten the course/program proportionately and notify the trainee of the results of the evaluation. A copy of the trainee’s notification should be retained in the trainee file. 7. Meet with a VA employee during a compliance or Liaison visit. VETERANS BENEFITS ADMINISTRATION 4

Sample of VA Form 22 -1999, VA Enrollment Certification. 5

Sample of VBA-6553 d Monthly Certification for OJT and Apprenticeship. 6

Certifying Officials Responsibilities 8. Forward appropriate documentation to the VA. This includes: * * * Copies of all Training Agreements Notification of trainee withdrawal from a program Changes in Certifying Officials, VAF 22 -8794 Changes in requirements for approved programs Name and/or address changes for the organization or the primary Certifying Official VETERANS BENEFITS ADMINISTRATION 7

Sample of VA Form 22 -8794, Designation of Certifying Official(s). 8

Sample of VA Form 22 -8794, Designation of Certifying Official(s). 9

Certifying Officials Responsibilities • As the Certifying Official, you are responsible for certifying the enrollment and changes in enrollment of eligible trainees to the VA. This section will briefly describe your responsibilities. • Your primary function is to let VA know if a trainee is enrolled in the program, showing the beginning and ending dates and reporting the number of clock hours per month the beneficiary works. Additionally, you are responsible for notifying VA of any changes in enrollment. an A Trainee • A trainee may be certified after they apply and are accepted by the employer into the training program. VETERANS BENEFITS ADMINISTRATION 10

Basic Duties of Certifying Officials • You can certify a trainee for VA benefits by filling out VA Form 22 -1999, Enrollment Certification Form and Application for Approval and Training Agreement for Apprenticeship/On-the-Job Training. Once completed, these forms must be mailed to the RPO of jurisdiction for processing. In addition, you should include any updated wage scales or other information pertinent to the program’s approval with the above forms. This will help to speed up the processing of the trainee’s application. VETERANS BENEFITS ADMINISTRATION 11

Basic Duties of Certifying Officials Cont’ Each trainee’s records should be verified monthly to determine that nothing has changed. Notify VA using VA Form 22 -1999 b, Notice of Change in Student Status, if the trainee does not make satisfactory progress in the program, has been laid off, changed jobs, etc. (except Chapter 31 trainees – where you need to notify their Vocational Rehabilitation Specialist). VETERANS BENEFITS ADMINISTRATION 12

Sample of VA Form 22 -1999 b, Notice of Change in Student Status. 13

On the Job Training • The passing down of skills from one generation to the next has been going on since the beginning of civilization. This process has evolved over time into the formalized apprenticeship and on-the-job training (OJT) programs of the present day. • Today, apprenticeship and OJT are business-like systems designed to provide comprehensive training by exposing workers to the practical and theoretical aspects of a highly skilled occupation through structured training on the job and related theoretical instruction. • VA education benefits for college after service have been one of the greatest incentives to enlistment…and will continue to be. However, veterans can also use their benefits when they are employed in an apprenticeship or OJT program. VETERANS BENEFITS ADMINISTRATION 14

On the Job Training • These training programs are beneficial to both the employer and the veteran. Employers gain employees that generally have more life experience and discipline, and veterans can “earn while they learn” with wages from the job, and education benefits from their VA education entitlement. • While employed, veterans receive training and certifications that meet business and industry standards while the employer gains a highly productive and professional workforce. It is a partnership that is beneficial to all who are involved. • Apprenticeship plays an important role in developing skilled workers. The training model can be an effective system for addressing human resource issues and skill shortages that many businesses and industries face. VETERANS BENEFITS ADMINISTRATION 15

On the Job Training • Trainees are provided the opportunity to perform tasks required, receive related classroom instruction and mentoring, while advancing in their careers. • Experienced journeymen, who have the expertise and knowledge that individuals need to do their jobs effectively, teach, supervise and mentor apprentices. • On-the-job training programs develop proficiency skills unique to a particular job. Such programs involve a job that is learned in a practical way through a planned and systematic program of supervised training. VETERANS BENEFITS ADMINISTRATION 16

On the Job Training • There is a logical progression to the training allowing the trainee to move to the next higher classification based upon skills learned not just length of service. OJT programs are generally short, ranging in length from 6 to 24 months and may or may not include theoretical training. • Both on-the-job & apprenticeship training programs are available for Veterans using their VA education benefits, including the Post 9/11 GI Bill. • In this session you will learn about apprenticeship and OJT programs, their similarities and differences, and the players involved. • Note: This training is not available to active duty Servicemembers or spouses using a transferred benefit. VETERANS BENEFITS ADMINISTRATION 17

On the Job Training • Employers or unions generally pay a reduced OJT/apprenticeship wage (generally 40 -50% of journeyman wages). • Veterans in an approved program can use their GI Bill benefit and receive a tax free stipend. • The Post 9/11 GI Bill stipend is the equivalent of the Monthly Housing Allowance (MHA) of an E-5 with dependents, which is paid in addition to the entry-level wage. Payments are issued monthly after VA receives certification of hours worked from your employer or union. VETERANS BENEFITS ADMINISTRATION 18

On the Job Training • Minimum Period of Operation – the minimum amount of time that an educational institution (or branch or extension of such educational institution) must have been continuously operating and offering courses before a State approving agency may approve a course(s). Branches and extensions are subject to the minimum period of operation requirements as stated in 38 CFR 21. 4251 regardless of whether the branch or extension receives a separate or combined approval. OJT and apprenticeship programs are not subject to this requirement. • Point of contact (POC) – a designated educational institution employee at an extension or branch campus that does not have a school certifying official on location. The POC performs various functions similar to those of the certifying official but does not have the capability to certify enrollments through VA-Once. Stipend = First six months of training 100% of your applicable MHA Second six months of training 80% of your applicable MHA VETERANS BENEFITS ADMINISTRATION 19

On the Job Training The stipend is reduced 20% every six months thereafter as the Veteran’s wages regularly increase until the Veteran has attained journeyman status and pay. Stipend payments for other GI Bill programs are found at: http: //www. gibill. va. gov/resources/benefitsresources/ratetables. html VETERANS BENEFITS ADMINISTRATION 20

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On the Job Training • Employer Information. • Employers can participate in this program. Contact your State Approving Agency, which governs programs at the state level and helps determine which programs Veterans should enroll in to maximize their VA educational benefits. • Approved employers can use this benefit as a recruiting tool by using wages + stipend to attract Veteran candidates. VETERANS BENEFITS ADMINISTRATION 22

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On the Job Training State Approving Agencies (SAA) • The State Approving Agencies are responsible for approving OJT/apprenticeship programs in their respective states. Requirements generally entail submitting a training request form that specifically outlines the proposed program, wages, and standard workweek information, as well as the company contact name and phone number. Once all required documents are submitted, approval is generally completed in 1 -2 months. • For more information regarding OJT & apprenticeship programs, and how to apply see: http: //www. gibill. va. gov/resources/educationresources/programs/onth ejobapprenticeshiptraining. html • VETERANS BENEFITS ADMINISTRATION 24

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Vocational Rehabilitation & Employment (VR&E) OJT/Apprenticeship • In addition to the services of VA education benefits, VR&E also provides employers with other benefits through the Special Employer Incentive Program (SEI). • Employers hiring Veterans with a service-connected disability who are approved for VR&E services, may be entitled reimbursements up to 50% of the Veterans salary for six months to offset training costs. Additional information about the VR&E OJT program is located at: http: //www. vba. va. gov/bln/vre/empresources. htm VETERANS BENEFITS ADMINISTRATION 26

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Available Benefits Although the participation requirements are the same for all GI Bill© programs, the payment amount varies depending on the program. VETERANS BENEFITS ADMINISTRATION 28

Post-9/11 GI Bill recipients • The payment rates are as follows: You will receive 100 percent of your applicable MHA during the first six months of training in these increments: – 80 percent of your applicable MHA during the second six months of training – 60 percent of your applicable MHA during the third six months of training – 40 percent of your applicable MHA during the fourth six months of training – 20 percent of your applicable MHA during the remainder of the training • Post-9/11 GI Bill recipients will also receive up to $83 per month for books and supplies. VETERANS BENEFITS ADMINISTRATION 29

All other GI Bill programs For all other GI Bill© programs, the payment rates are as follows: • 75 percent of the full-time GI Bill© rate for the first six months of training • 55 percent of the full-time GI Bill© rate for the second six months of training • 35 percent of the full-time GI Bill© rate for the remainder of the training program VETERANS BENEFITS ADMINISTRATION 30

DEFINITIONS Apprentice. An individual who is employed full time to learn a skilled occupation through a structured, progressive, training program that combines hands on and theoretical instruction is an apprentice. 29 CFR 29. 5, Labor Standards for the Registration of Apprenticeship Programs, mandates that the apprentice be at least 16 years old, however, your state’s standards for mandatory education and child labor may supersede federal apprenticeship standards; consult with your colleagues. The term apprentice is used interchangeably with the term “trainee. ” Trainee may be used for one who is in an approved apprenticeship or OJT program. VETERANS BENEFITS ADMINISTRATION 31

DEFINITIONS Apprenticeship Agreement. This is the written and signed document that describes the terms and conditions of employment and the training program. The agreement is between the sponsor and an apprentice. With registered apprenticeship programs, this document is called an Indenture Agreement. VETERANS BENEFITS ADMINISTRATION 32

DEFINITIONS Apprenticeship Job Standards. The written document that describes the training program including the schedule of tasks to be learned, time in each task, related instruction, and wage schedule. If the standards are for a registered apprenticeship, the document will include such additional information as: minimum qualifications, selection process, probationary period, supervision and evaluation, safety requirements, and records maintained. The Department of Labor (DOL), Employment and Training Administration (ETA), Office of Apprenticeship (OA), or if a state has a State Apprenticeship Council (SAC) then the SAC, will register and approve standards for registered apprenticeships. Apprenticeship training standards are industry driven. VETERANS BENEFITS ADMINISTRATION 33

DEFINITIONS Apprenticeable Occupations. Such occupations are trades recognized by the US DOL ETA OA, and throughout the industry. They require at least 2, 000 hours of on the job experience as well as 144 hours of related classroom/theoretical instruction each year. The OA allows instruction through independent study when classroom instruction is not available. You should review the list of the DOL’s “Officially Recognized Apprenticeship Occupations”. The most current list is also found at Appendix A. VETERANS BENEFITS ADMINISTRATION 34

DEFINITIONS Apprenticeship Committee. Larger apprenticeship programs likely have a committee, that is, a group of people, designated to act for the sponsor in administering the apprenticeship program and entering into apprenticeship agreements. The committee may include the employer’s representative, union collective bargaining agents, representatives from educational institutions providing required related instruction, etc. VETERANS BENEFITS ADMINISTRATION 35

DEFINITIONS Certificate of Completion. Employers must agree to award certificates of completion to trainees who complete the programs. More information is in section C below. Code of Federal Regulations (CFR). These are considered an official rule. In the Government, certain administrative agencies have a narrow authority to control conduct, within their areas of responsibility. The agencies use the Public Laws and United States Codes (USC) to establish the regulations. VETERANS BENEFITS ADMINISTRATION 36

DEFINITIONS Competency Based Apprenticeship. An apprenticeship program based upon the demonstration of successful mastery of skills, rather than a structured amount of time in each skill set. Compliance Survey. SAA and VA personnel routinely conduct surveys to training facilities. A compliance survey is the process of ensuring that training programs and the organizations offering them conform to all applicable provisions of the laws to prevent deficiencies and violations. If an organization or any of its programs are found to be deficient or in violation, you will need to work with the organization to ensure they are corrected, or withdraw approval. VETERANS BENEFITS ADMINISTRATION 37

DEFINITIONS Department of Labor (DOL). This US department promotes the welfare of job seekers by improving working conditions and advancing opportunities for employment. Employment and Training Administration (ETA). A division of the DOL, the ETA works with state and local workforce development organizations to provide quality job training and employment. VETERANS BENEFITS ADMINISTRATION 38

DEFINITIONS Joint Apprenticeship and Training Committees. JATCs or JACs are formalized apprenticeship committees that include an equal number of representatives of the employer and the employees represented by a bona fide collective bargaining agent. Joint committees enter into apprenticeship agreements and administer the apprenticeship program. They are generally representative of a particular trade that adopts the national standardized and registered training program for the occupation. Such committees ensure uniform, consistent training across the nation. VETERANS BENEFITS ADMINISTRATION 39

DEFINITIONS Journeyperson. A skilled worker who, through experience and training, meets the requirements to undertake the tasks necessary for employment in the occupations covered by the training program is called a journeyperson. Please note that in this manual this term is often shortened to “journey” with reference to the level of a fully trained person, and particularly the wage rate/level. VETERANS BENEFITS ADMINISTRATION 40

On the Job Training Non-registered apprenticeship. This is an apprenticeship program that is structured, systematic and progressive consisting of on-the-job training and related theoretical instruction that is not registered with the federal department of labor or state apprenticeship agency. The regulation does not distinguish between a registered or non-registered program. Either program must meet all regulatory approval criteria. Office of Apprenticeship (OA). This organization was formerly known as the Bureau of Apprenticeship and Training. The OA falls under the Department of Labor, Employment and Training Administration (DOL ETA). OA registers apprenticeship programs and apprentices in about 23 states and assists and oversees State Apprenticeship Councils (SACs). VETERANS BENEFITS ADMINISTRATION 41

On the Job Training Non-registered apprenticeship. This is an apprenticeship program that is structured, systematic and progressive consisting of onthe-job training and related theoretical instruction that is not registered with the federal department of labor or state apprenticeship agency. The regulation does not distinguish between a registered or nonregistered program. Either program must meet all regulatory approval criteria. Office of Apprenticeship (OA). This organization was formerly known as the Bureau of Apprenticeship and Training. The OA falls under the Department of Labor, Employment and Training Administration (DOL ETA). OA registers apprenticeship programs and apprentices in about 23 states and assists and oversees State Apprenticeship Councils (SACs). VETERANS BENEFITS ADMINISTRATION 42

On the Job Training Occupational Information Network (O*NET). This automated system provides the nation’s primary source of occupational information through a database containing standardized, occupation-specific descriptors – the knowledge, skills and abilities related to the performance of a particular occupation. O*NET Online is an interactive application for exploring and searching occupations. O*NET replaces the Dictionary of Occupational Titles (DOT). Probationary Period. This is a set period of time during which the apprenticeship agreement can be terminated by either the apprentice or the employer. Probationary periods are part of apprenticeship programs, and may also be part of OJT programs, especially government training programs. VETERANS BENEFITS ADMINISTRATION 43

On the Job Training Related Instruction. Also called supplemental instruction, this is an organized form of theoretical and technical instruction related to a particular trade. Such training often takes place outside normal working hours. It may be provided by a Junior or Community College, or by the organization sponsoring the program at the facility. It may also be provided through distance education. Although the VA regulation does not specifically make related training part of their regulatory requirement, it is part of 29 USC 50 a and 29 CFR 29. 5, which CFR 38 21. 4261 states is a criteria for approval of an apprenticeship program. Registered Apprenticeship. A formalized training program accepted and recorded by the OA or registered and/or approved by a recognized state apprenticeship agency/council (SAC). Such programs conform to the federal requirements of a structured and systematic training plan designed to meet industry standards. The goal of such a program is to produce skilled workers who are trained in all aspects of an occupation. VETERANS BENEFITS ADMINISTRATION 44

On the Job Training SAA-Employer Agreement. This is part of the application. It may be in the form of “Conditions” in the application or a separate agreement. It requires that the employer, by signature, agrees to criteria that: ensures accurate and timely reporting, reporting of all changes, maintenance of adequate records to show progress toward a job objective, and allows for the SAA and VA to have access to the facility for review records of VA beneficiaries. Individual SAAs may add any additional state requirements. State Apprenticeship Agency or Council (SAC). This is an organization that has been approved by the DOL, ETA, and OA as the appropriate organization to register local apprenticeship programs and agreements for federal purposes. About 25 states have their own organization, the SAC, which registers apprenticeship programs and apprentices for their state. SACs are a properly constituted state entity that is empowered by the Governor or other similar official, as it is a state’s right to determine who will register apprenticeship training in their state. The OA assists the state councils. VETERANS BENEFITS ADMINISTRATION 45

On the Job Training Standard Occupational Classification (SOC). SOC is a classification system used by the federal statistical agencies to classify workers into occupational categories for the purpose of collecting, calculating or disseminating data. SOC serves as the framework for information being gathered through the O*NET, which as replaced the DOT. Sponsor. A person or organization, generally an employer, operating an apprenticeship or OJT program is known as a sponsor. The sponsor provides the name under which the program is registered or approved. Trainee. This is a term used to describe the person who is receiving training and may be used interchangeably with the term “apprenticeship”. Such training may be through a registered or non-registered apprenticeship or OJT program. VETERANS BENEFITS ADMINISTRATION 46

On the Job Training Time Based Apprenticeship. A program of apprenticeship that is determined based upon a specific period of time. Training Plan. A training plan includes a description of the work processes and time elements for each component or task. United States Codes (USC). These are a compilation and codification of the general and permanent federal laws of the United States. The Office of Law Revision Counsel prepares and publishes the Codes according to subject matter. Title 38 USC is the most commonly used by SAAs and reflect the laws upon which the CFRs are authorized. VETERANS BENEFITS ADMINISTRATION 47

Questions ? VETERANS BENEFITS ADMINISTRATION 48