Why foreign workers could be the key to a controversial Trump jobs initiative.
The funding source that could put Project 2025's workforce plans at odds with the Trump's anti-immigration base.
The issue
If Project 2025’s plan for apprenticeship is something the Trump Labor Department wants, it probably needs to allow more foreign workers into the country.1
Wait, what?
Back in December, the Trump base found itself at odds over H-1B, the visa program that allows employers to bring high-skilled workers to the United States. If you weren’t paying attention to Twitter—generally a good idea—tech MAGA converts such as Elon Musk like H-1B, a key source of tech talent. They think it should be reformed to bring more deserving workers to the United States. MAGA originals like Steve Bannon felt like this embrace of H-1B diminished the core anti-immigration philosophy of MAGA.2
But H-1B isn’t just an immigration program. It’s a source of money that could be vital to carrying out Project 2025’s plans to bring back a purportedly more employer-friendly version of apprenticeship that struggled to find its feet in the first Trump Administration.
The U.S. Department of Labor plays a vetting role on worker visa applications, and applicants for H-1B must pay a fee for those applications. Congress has told DOL to spend H-1B application fees on training programs to make sure there are American workers to fill H-1B jobs so foreign labor can’t get them next time. Congress didn’t really restrict what type of workforce programs the money can fund.3
In any administration, this creates a weird tension. In a second Trump Administration, it puts two potential goals at odds—limiting legal immigration of foreign workers and changing how the federal government has defined apprenticeship for much of the past 100 years.
Explain yourself.
The federal government and state agency affiliates allow programs to “register” themselves under a 1937 law called the National Apprenticeship Act. These “Registered Apprenticeships” are often called a “model” of workforce development; from a legal perspective, it’s better to think of Registered Apprenticeship as a consumer protection device.
The idea being that if you—a worker looking for an apprenticeship—see a Registered Apprenticeship, you know the federal government has verified things like that the program pays apprentices at least the minimum wage, provides real training, and makes sure there are trained professionals who can keep untrained apprentices safe on the job site.
There is an another side of this as well: by marking certain apprenticeship programs as “not likely to rip you off and/or severely injure you,” the federal government has painted the word “SAFE” on that program so Congress can target money and resources in its direction.
Because Registered Apprenticeship has been around for a while, it’s very much the base concept of apprenticeship throughout federal law.4 In recent years, Congress has given DOL a year-to-year fund to expand apprenticeship. This money has only one significant string: it must be spent on Registered Apprenticeship.
Not everyone is a fan. Business interests and conservatives thinktanks argue Registered Apprenticeship has too many standards and DOL takes too long to register programs, preventing growth and scale. It probably doesn’t help that unions run more than half of the largest Registered Apprenticeship programs and registration by definition requires the government to scrutinize employers’ hiring and worksite practices.
In his first administration, President Trump appointed a task force5 that developed a plan for fixing federally supported apprenticeship: doing something else entirely.6
The task force proposed “Industry-Recognized Apprenticeship Programs” that meet DOL specifications, but approved by private sector organizations, not DOL. This proved controversial from the start, with unions viewing it as an endaround of Registered Apprenticeship to set up competing, lower-quality programs.
I don’t think I can fully capture in one newsletter the hyperdoom that besieged the first Trump Administration effort to figure out IRAPs—notably, it ended in a later-rescinded final rule that published the week of the pandemic shutdown in March 2020.7 But to summarize the flaws in the process very briefly based on publicly available materials: the Administration tried to will proof of concept of IRAPs into the world at the same time it was drawing up the rules of what IRAPs actually are.
At some point the Trump Administration directed money from the fund for Registered Apprenticeships toward contractors helping start IRAPs—and well before DOL publicly finalized the features of IRAPs, too. This was confirmed by a review by the accounting firm KPMG and DOL’s Office of Inspector General, the agency’s independent internal watchdog.8
The amount found spent on IRAPs—$1.1 million of $145 million—is not that much, comparatively. However, this type of unauthorized shuffling of appropriations money is one of the gravest political and legal no-nos in the federal government. Congress didn’t much care for it, and those suspicions still linger today over IRAPs.
So?
Project 2025 calls for bringing back IRAPs for much the same reasons as before: Registered Apprenticeship isn’t moving enough people due to bureaucratic overregulation.9 The initiative would face many of the same problems from the first administration—namely, IRAPs will need money to get started up, and congressional resources for apprenticeship go to Registered Apprenticeship.
I don’t see that as likely to change, and after the scandal in the first administration, the Hill—especially a closely divided House—could be even less likely to open coffers to IRAPs.
Which leaves one funding source available: those H-1B workforce funds.
Which need H-1B application fees.
Which could dwindle due to the anti-immigration efforts of the second Trump Administration.
Huh.
The week of many newsletters continues.
Thank you for your readership of JOBS THAT WORK, which you are getting plenty of this week thanks to my cleaning out Trump pieces delayed because I needed to write new Trump pieces. Next week will be a hair less Trump-y, constitutional crisis pending.
TOMORROW: No newsletter, but live-posting through Labor nominee Lori Chavez-DeRemer’s confirmation hearing on Bluesky.
THURSDAY: A newsletter summing up what we learned at the hearing and what it means for workforce in the years ahead.
FRIDAY: Federal, state, and other grants listings, updates on the funding freeze, and thoughts on whether it’s worth applying to federal grants listings.
NEXT TUESDAY: Skills-based hiring hasn’t taken off as expected. The problem? Hiring.
To get the disclaimer out of the way: I worked on several programs and initiatives described in this piece, including the various apprenticeship strategies of the first Trump Administration. I did not use any nongovernment information, client confidences, or otherwise privileged information in the construction of this piece, which relies on public sources of information.
Trump in December said he was a big fan of H-1B. Given the whim-based nature of the Trump governing enterprise, I wouldn’t put much long-term faith in that.
The money must go toward H-1B occupations—not that hard to meet—and it cannot go toward youth training programs.
The Workforce Innovation and Opportunity Act—the main $5.3 billion (1/8th of an emotional purchase of Twitter) pot of money for workforce development—defines apprenticeship as “Registered Apprenticeship,” albeit in a circuitous and frustrating way you can read here at 29 U.S.C. 3102(7)(B). Similarly, contractors on lucrative federal construction projects can pay a lower wage to registered apprentices than federal law requires for other construction workers.
Among the top apprenticeship experts on this task force? Trump friend John Ratzenberger, who played the mailman Cliff on Cheers and voices the talking piggy bank in the Toy Story series. He has personal interests in apprenticeship and workforce development… but he’s also Cliff from Cheers.
I am writing a later piece about Registered Apprenticeship and its future, but you may be asking why the Trump Administration doesn’t just change Registered Apprenticeship to lower its standards. It could happen, but I doubt it so long as MAGA thinks it can successfully court organized labor, which I wrote about yesterday.
Also worth noting: the final regulatory form of IRAPs ended up looking a lot like Registered Apprenticeship and added bureaucracy by requiring DOL first bless the private entities that would recognize IRAPs.
Less than a year later, the new Biden-Harris Administration suspended the IRAP initiative. The new administration finally rescinded the IRAP rule in 2022.
For now.
For what it’s worth, Agenda 47, technically Trump’s official presidential platform, is mum on the topic. It focuses on “internships,” only referencing apprenticeship to namecheck Trump’s reality TV show, The Apprentice.