Skip to main content

Good Faith Effort Exception Explained

Learn how the IRA Good Faith Effort works: who to contact, what to include, how long it lasts, and how Apprentix complements GFE.

Updated over 2 months ago

When you can’t meet the IRA apprenticeship participation requirement because no registered apprentices are available, you may rely on the Good Faith Effort (GFE) exception. This article explains what GFE is, when it applies, how to document it, and how Apprentix fits in.


What is “Good Faith Effort”?

A documented, timely attempt to engage registered apprenticeship programs (RAPs) to supply apprentices for your project. If programs decline, can’t supply, or don’t respond, your documented outreach can qualify you for the GFE exception.

Note: GFE addresses the participation trigger (having at least one apprentice on crews that meet the threshold). It does not waive prevailing wage rules, and it does not let you count apprentice hours if ratio rules weren’t met.


When does GFE apply?

Use GFE when both are true:

  1. Your crew size triggers the participation requirement (e.g., 4+ workers on covered work).

  2. You cannot obtain registered apprentices despite timely outreach to RAPs.

If apprentices later become available and you employ them, you must still follow daily ratio rules and work toward the apprentice labor-hours requirement for the project.


Who do I contact for GFE?

Reach out to registered apprenticeship programs serving your trade(s) and project location. This can include:

  • State or U.S. DOL-registered programs (union or non-union)

  • Local workforce/intermediary sponsors

  • Your state apprenticeship agency for a current list of RAPs

Apprentix is not a dispatch hall and does not receive or validate GFE letters. Send requests to RAPs and/or your state DOL/State Apprenticeship Agency as directed locally.


What should my GFE request include?

Send written requests (email preferred) that include:

  • Project name, site address/county/state

  • Trade(s)/occupation(s) needed and number of apprentices

  • Estimated start date and duration

  • Work description/scope & shift schedule

  • Your company contact (name, email, phone)

Keep copies of all outreach and responses.


How many programs should I contact?

Contact multiple RAPs reasonably able to serve your project (by trade and geography). Log each outreach and any follow-ups.


How long is a GFE request “good” for?

GFE documentation is time-bounded. Many reviewers treat requests as valid for a limited window (often ~120 days, sometimes longer per contract/owner guidance). Re-issue requests if your start date moves or the window lapses.


What documentation should I retain?

Create a simple GFE packet:

  • Copies of each request (emails/letters) with date/time sent

  • Delivery/read receipts or call logs

  • Responses (declines, “no capacity,” or no response evidence)

  • Current list of RAPs you contacted (source/date retrieved)

  • Internal memo tying the outreach to the project, trade(s), and start date

Retain for your standard recordkeeping period (e.g., 7 years).


What doesn’t qualify as GFE?

  • Contacting only one program when others exist

  • Requests sent too late (days before mobilization)

  • Missing project specifics (trade, location, timing)

  • No proof of delivery or follow-up

  • Relying on unregistered training pathways


How Apprentix fits in

  • Apprentix helps when you do employ apprentices: digital agreements, registrations (for Fractional Sponsor clients), hour tracking, ratio visibility (via certified payroll), and document storage.

  • GFE is for cases where apprentices aren’t available. Use GFE to protect eligibility until you can onboard apprentices. When you’re ready, Apprentix converts your employees into registered apprentices and helps you stay compliant going forward.


Copy-paste email template (use on your letterhead)

Subject: Request for Registered Apprentices – [Project], [Trade], [City, State]

Hello [Program Name/Contact],

[Company] is requesting registered apprentices for the following project:

  • Project: [Name], [Address/County/State]

  • Trade(s): [e.g., Construction Craft Laborer]

  • Needed: [# apprentices]

  • Estimated start: [Date] | Shifts: [e.g., Mon–Fri, 7a–3:30p]

  • Scope: [Brief description]

Please confirm availability or waitlist status. If unavailable, a written response is appreciated for our compliance file.

Contact: [Name, Title, Email, Phone]
Thank you,
[Signature]


FAQs

Q: If a program doesn’t respond, does that count?
Yes—document the attempt, timestamp, and any follow-ups. Keep proof of delivery.

Q: Does GFE let me ignore daily ratios or apprentice hour percentages?
No. GFE speaks to participation. When apprentices are employed, you must meet ratio rules daily and progress toward the project’s apprentice labor-hour target.

Q: Can I send a GFE letter to Apprentix?
No. Send requests to RAP sponsors and your state agency. See our IRA FAQs for more.

Did this answer your question?