IBM today submitted comments to the U.S. Department of Labor Notice of Proposed Rulemaking (NPRM) entitled “National Apprenticeship System Enhancements.” As an experienced apprenticeship program sponsor, IBM is grateful for the opportunity to provide input on this NPRM to modernize and scale this extremely valuable and viable workforce development model.

 

We appreciate the Department’s efforts to improve the National Apprenticeship System and agree with the overarching goals to strengthen, expand, and modernize Registered Apprenticeship Programs. However, IBM is concerned that the myriad of new, and often complex, requirements being added to a system that is already difficult for employers to navigate does not advance the Department’s stated goals and could lead to fewer career opportunities for Americans without college degrees and the communities the Department aims to support. This is especially important at a time when employers and employees are increasingly interested in and concerned about the impact of artificial intelligence (AI) on work and job roles across industries.

 

Unless the NPRM is significantly modified to prioritize workers, it could have a chilling effect on employer engagement in apprenticeship programs and the availability of quality career pathways for more Americans. Indeed, given the anticipated impact of the new, proposed requirements, IBM will need to reconsider whether the Registered Apprenticeship Program can remain a viable talent strategy and pipeline for the company. Because we believe registered apprenticeships are an important, effective vehicle to provide good job opportunities and attract talent, we offer the attached comments and recommendations to modify the proposed rule and rebalance the regulatory framework to ensure more Americans can access high-quality, flexible pathways to secure well-paying jobs and career trajectories.

 

Read the full letter below or download it here.

 

 

 

 

 

 

 

 

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