How to Create a Good Faith Effort Exception for PWA Apprenticeship Requirements

Good Faith Effort Exception 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 Exception (GFEE) 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 Exception

You may claim a Good Faith Effort (GFEE) 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 GFEE 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 GFEE helps protect your project from penalties and keeps compliance records organized.

How to Create a Good Faith Effort Exception

Follow these steps to create and save a Good Faith Effort Exception 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 Exceptions 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 & Willingness to Abide by Program Rules

   • The following language should be directly included in the request: "the request for qualified apprentices is made with an intent to employ qualified apprentices in the occupation for which they are being trained and in accordance with the requirements and standards of the registered apprenticeship program and to employ qualified apprentices consistent with the expected number of hours and dates of employment specified in the request. "

8. 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.