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Comment #12 — Please provide further guidance on including all California (CA) apprenticeships on the local Eligible Training Provider List (ETPL). There are some apprenticeship programs that are not available locally (example: apprenticeship programs in Imperial County do not have a presence in Southern California), and does not seem to make sense to list locally as we are unable to provide the Individual Training Account (ITA) for training due to the distance restrictions. Resolution — Per TEGL 13-16, Change 1, "All Registered Apprenticeship Program (RAPS) on a statewide ETP list must also be located on all local ETP lists in the state." In addition, TEGL 8-19 states that "Local Boards may add additional requirements for providers, except for RAPS, which result in providers that are on the state ETP list that may not be eligible for inclusion on the local ETP list." Comment #13—Can Local Boards require local program requirements to apprenticeship programs related to payments (W-9s, Invoice Agreements) and other WIOA assurances (WIOA section 188), list of employers partners, or is that assumed by the state? Resolution —Apprenticeship programs cannot have additional eligibility requirements added to them, per TEGL 8-19. If an apprenticeship program is approved by DOL or DIR DAS and want to be added to the ETPL, they must be added to the state and local ETPL. They cannot be removed from the ETPL until they request to be removed or they lose apprenticeship approval/designation from DOL or DIR DAS. Comment #14—Are registered apprenticeship programs required to provide a paid employment component and if they are not providing employment, how is that monitored? If they do not provide employment, isn't that just a regular training program? Resolution —Yes, per the Factsheet located on the DOL A renticeship website, apprenticeships are required to provide a paid employment component. The approval of apprenticeship programs is managed by the DOL and/or DIR DAS. Comment #15 —Are we allowed to require apprenticeship to meet our contracting/insurance requirements to be on the local list? Resolution — No. Per TEGL 8-19, no additional eligibility requirements can be added to apprenticeship programs. Comment #16 —There are approved apprenticeship programs in occupations that are not in our local priority sector or in -demand occupations. Our local policy is to not put such programs on our local ETPL. It would be inconsistent to allow such a program to be listed as an apprenticeship when we do not list it as a private postsecondary training program. Resolution — Per TEGL 13-16, Change 1, "Given that RAPS are a link to demonstrated hiring needs and WIOA provides automatic training provider eligibility to RAPS, ETA has determined that RAPS qualify as occupations in -demand in the local labor market." In addition, TEGL 8-19, Attachment 1, page 3 states: "RAPS are automatically eligible to be included on the ETP list and are exempt from state and local ETP eligibility requirements." Page 4 of 25