Frequently Asked Questions - ETN of MN

Training

Q.  My unlicensed registered electricians are taking the Electrical Associations apprenticeship curriculum, aren’t they considered registered apprentices?
A.  No, in order for an apprentice to fall under the apprenticeship exemption for purposes of prevailing wage, they need to be registered with the Apprenticeship Program within DLI.  ETN of MN is a registered program with DLI.  A contractor first needs to be accepted by ETN of MN by submitting an application and being approved by the board.  Apprentices then need to go through a specific registration process.

Q. Do Companies who have Indentured Apprentices in the ETN of MN Program have to enroll their apprentices in the Apprentice Classes?
A. No, they can take classes from a different organization but would need to provide proof that they are in a different program getting their education. (144 hours per year).  Details on reporting this time would need to be determined with the ETN of MN staff prior to going this route.

Q. What is the waiver that the apprentice has to sign and why do they have to sign 2?
A. Apprentices need to sign a waiver allowing access to ETN of MN staff and their employers to view and submit their hours as required by the program.


Wage Scale

Q. If the company in ETN of MN is working on a prevailing wage job in a county that their office is not located in - should they pay the prevailing wage rate of the county that their office is located in or the prevailing wage rate of the county that the project is in? A. On state jobs, the company would follow ETN of MN standards.  Registered Apprentices, as long as supervised and paid according to the apprenticeship agreement, are exempt from prevailing wage provisions.  On federal jobs, the apprentice percentage must be paid on the base rate on the wage determination.

Q. How do you find the Prevailing Wage Rate to base an apprentice’s wage?
A. Use DLI’s online portal, select the county where your shop is based,  use the base rate for electricians listed in that document. http://workplace.doli.state.mn.us/prevwage/commercial.php

Q. When working on a non-prevailing wage/private jobs, the employer still has to pay the apprentice based off of the scale in the ETN of MN standards and the PW wage rate of the county that the company is located in?
A. Yes , when working on Private/non PW jobs, the company pays off of the county that they are located in – not necessarily the county where  the work is being performed. Registered Apprentice wages are documented in the apprenticeship agreement.

Q. If a company is a member of a union (such as CLA) and has a Collective Bargaining Agreement with them, would they follow the ETN of MN wage schedule or the wage schedule in their CBA?
A. If the CBA wage schedule is higher than ETN of MN wage schedule, the CBA wage schedule will be included in the apprenticeship standards.  The CBA wage rates must also be paid if the prevailing wage is lower.   If the prevailing wage is higher than the Journeyworker wage rate, the prevailing wage rate must be paid to journeyworkers working on the prevailing wage project.

Q. Who is responsible for Prevailing Wage increases in the county when they occur (the company or ETN of MN)?
A. Each company should be monitoring the PW scale in the counties that they do work within but ETN of MN will also try and inform the company if they notice these increases as well.

Q. When an increase happens in a county, do all apprentices move up on the pay scale or are some grandfathered in based on where they started in the program?
A. Pay increases must be given when the JW rate goes up – this does not need to be submitted to the DLI but it must be reflected on the time cards for the following month. 

Compliance with the Program

Q. How much does this all cost?  What are the fees associated with all parts of the program?
New Employer Fee - $1000 (One-Time)
New Apprentice Fee - $200 (One-Time)
Yearly Apprentice Admin Fee - $325 (Annually – December)
Fines: $50 / Per Apprentice/ Month they have a late time card
3 Consecutive Months Behind - Apprentice is put on probation
5 Consecutive Months behind - Apprentice is suspended and potentially terminated from ETN of MN
$100 Transfer Fee – Apprentice who transfers from one registered company to another

Q. Does an employer have to be a member of the Electrical Association to also be a part of ETN of MN?
A. Yes, it is a requirement of the program that you must be a member of MEA to be a part of the program.

Q. What is the Ratio of Journeyworkers to Apprentices in the ETN of MN Program?
A contractor is limited to a maximum of two apprentices for every journeyworker on the project site.

Q. Does an employer need to provide their indentured apprentices with benefits?
A. If the employer does not provide benefits for their employees, they would need to pay them based off of the total amount on the wage determination.   As long as one benefit is offered (doesn't matter how big, but it should be something of value for credibility's sake) the employer can pay based off of the basic wage rate.  On a federal job, DOL will enforce the employer’s benefit agreement.  If the employer does not have a benefit agreement, the apprentice must be paid based on the total wage rate in the wage determination.

Q. Does the employer need to list the benefits that they offer the apprentice when they are submitting them into the program?
A. Yes, Statute 178.044 indicates that the DLI needs to qualify whether it is a bonafide fringe benefit to ensure compliance with the formula for which your rate is based on if there are not any fringe benefits.

Q. When calculating the wage rate, do we use basic wage rate or total wage rate?
A.  As long as benefits are paid, the basic wage rate is used to determine the apprentice scale.  If benefits are not paid, the total wage rate is used to determine the apprentice scale.

Q. When do we need to submit time cards in to the ETN of MN staff?
A. By the 10th of the following month

Q. Will there be a fine for delinquent paperwork?
A. Yes, $50 / Per Apprentice/ Month they have a late time card

Q. Do the apprentices report Overtime on their time cards?
A. Overtime can be reported towards progression of hours.  Apprentices are capped at 2000 hours per year to align with registered unlicensed electrician progression.

Q. If the indentured apprentice works overtime, do those hours count towards their PW Scale payment, or just 40 hours per week max?
A.  Overtime must be paid and time at a half the apprentice’s regular rate of pay.

Q. How many hours of safety training will each apprentice need to get in the program?
A. 50 hours while in the program (used to be 50 per year)

Q. How can an apprentice earn safety hours?
A. Electrical Safety Talks, AWAIR Training, OSHA Training, etc.

Q. What is the policy for an apprentice who does not pass their JW exam and has already completed 4 years of classes in the program?
A. If the apprentice plans on taking their journeyworker exam by the first of the following year, it is acceptable for them to not be enrolled in Apprentice Classes.  The apprentice should attempt to take the test.  If they do not plan on taking their journeyworker exam by the first of the following year, they need to be terminated from the indentured apprentice program (follow appropriate indentured apprentice termination steps - including getting committee approval) or enroll in year 4 of the program again to continue receiving 144 hours of study time per year.  If the apprentice does not pass the test, retraining should take place until such time as the apprentice decides that electrical work is not for them or the employer decides to terminate.

Q. How soon after an apprentice has a change in status (terminated, passed JW, etc.) must the contractor notify ETN of MN?
A. As soon as possible, but no later than 30 days.  We have 45 days to report this information to the Department of Labor so we need to be made aware as soon as possible.

Q. Can someone put an apprentice in the program just for the summer or just for a PW job and then remove them once the project is complete?
A. No, once an apprentice is indentured, it is the expectation from the ETN of MN Board that the apprentice is supported by the contractor and completes the program.  This type of behavior will result in immediate action taken by the ETN of MN Board.

Q. Do I need to do anything to stay in compliance with the programs affirmative action plan?
A. Yes, all companies in the program need to take steps in the direction to hire women, minorities, people with disabilities, etc. Attending career fairs, sending letters to specific organizations, purposeful job posting etc. should be reported to ETN of MN so we can include it in the EEOC audit that is conducted by the MN DLI.

Q. Posting of wage rates – what do contractors and subcontractors performing work on a public project need to post for PW rates and hourly basic rates?  What if they have a CBA, do they still post this information?  
A.  Subcontractors must post the wage certification for the project in a location that is easily accessible to their employees.  Journeyworkers must be paid the CBA or PW rate which ever is higher.

Q. When doing PW work outside of their county – will they need to submit the hourly wage differently to us for that job?  And how would we track the wages that they are receiving for the different counties?
A.  State PW jobs allow for the apprentice to be paid according to the apprenticeship standards.  Federal PW jobs require the apprentice be paid a percentage of the wage noted on the Federal Wage Determination.

Q. Can an Electrical Lineman be in the ETN of MN Program?
A. No, ETN of MN Program can only accept Construction Electricians.