How to Create a Good Faith Effort for PWA Apprenticeship Requirements

Understand when Good Faith Efforts are applicable and follow the steps to log them in Reunion for compliance protection.

Good Faith Effort for Apprenticeship Requirements

Federal clean energy projects and many state prevailing wage laws require that a certain percentage of total labor hours be performed by qualified apprentices.

However, there are situations where apprentices may not be available despite outreach to approved programs. In these cases, you can document a Good Faith Effort (GFE) to demonstrate that you made reasonable attempts to comply but were unable to secure apprentices.

When and How to Qualify for a Good Faith Effort

You may claim a Good Faith Effort (GFE) if:

• You contacted all relevant apprenticeship programs (local, state-approved, or DOL-registered) for the required work classification, but apprentices were unavailable, did not respond within 5 business days, or provided fewer than requested.

Before logging a GFE in Reunion, you must:

✅ Document the dates, programs contacted, and responses received.
✅ Make requests early enough for reasonable placement (e.g., 45 days before the work start date).
✅ Retain proof of outreach (emails, letters, call logs, or returned notices).

Documenting a GFE helps protect your project from penalties and keeps compliance records organized..

How to Create a Good Faith Effort

Follow these steps to create and save a Good Faith Effort request:

1. Navigate to your Reunion PWA Compliance platform
   https://app.reunioninfra.com/pwa/dashboard

   

2. Click “Apprenticeship Programs”

   

3. Click “Add Good Faith Effort”

   

4. Enter the Apprentice Program name

   

5. Select the Contractor requesting apprentices

   

6. Select the Contract & Project

   

7. Choose the Construction Type for the request

   

8. Select the Work Classification

   

9. Choose the dates apprentices were requested and the requested work start/end dates

   
   
   

10. Enter the number of apprentices and hours requested

11. Upload any supporting files as proof of outreach efforts

12. Add reasoning for the Good Faith Effort

13. Click “Save Changes”

To View all Good Faith Efforts created: Click “Good Faith Efforts” in the Apprenticeship Programs page

Good Faith Effort Exception Request Requirements (IRA / Treasury Guidance)

To qualify for the Good Faith Effort Exception under the Inflation Reduction Act (IRA), you must demonstrate that you requested apprentices in good faith from a registered apprenticeship program and either were denied or did not receive a timely response.

If you're subsequent GFE is not renewed, it disqualifies the original one.

Required Information in the Apprenticeship Request

According to IRS guidance (26 CFR 1.45-12), your written request should include:

1. Requester Information

   • Name, address, email, and phone number of the contractor, subcontractor, or developer making the request.

2. Project Information

   • Project name, location, and description of the work.

3. Apprenticeship Program Details

   • Name of the Registered Apprenticeship Program (RAP).

   • If available, include program ID, sponsor name, or registration number.

4. Requested Occupation(s)

   • Specific trades/occupations (e.g., electrician, laborer).

   • Indicate whether the request is for a new apprentice or an existing employee.

5. Number of Apprentices Requested

   • Specify how many apprentices are needed.

6. Work Dates and Duration

   • Expected start date and duration of the work requiring apprentices.

7. Statement of Intent

   • Affirm compliance with apprentice-to-journeyworker ratio requirements.

8. Willingness to Abide by Program Rules

   • Confirm adherence to the program’s standards and procedures.

9. Request for Confirmation

   • Ask for written confirmation of whether apprentices will be provided or if the program cannot accommodate the request.

We recommend reviewing our support article on how to properly Request Apprenticeship Programs

Documentation Required to Claim the Exception

If apprentices are not provided within 5 business days, retain:

• A copy of the written request (email or letter) with all required information.

• Proof of delivery (e.g., email timestamp, certified mail receipt).

• Any response (or lack thereof) from the apprenticeship program.

• A record of follow-up attempts, if applicable.