IRA Good Faith Effort Exception: What It Means and How to Document It
A Good Faith Effort (GFE) is a documented attempt to hire registered apprentices for your project. Under the Inflation Reduction Act (IRA), if you can’t meet the apprenticeship participation requirement because no apprentices are available, the GFE exception can protect you from penalties.
This article covers what GFE means, when it applies, how to document it properly, and includes a ready-to-use email template.
What Does Good Faith Effort Mean Under the IRA?
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.
Important note: GFE addresses the participation trigger (having at least one apprentice on crews that meet the 4+ worker threshold). It does not waive prevailing wage rules, and it does not let you count apprentice hours if the daily ratio rules weren’t met.
When Does the Good Faith Effort Exception Apply?
Use GFE when both are true:
Your crew size triggers the participation requirement (4 or more unique laborers/mechanics have ever worked on the project).
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 overall 15% apprentice labor-hour 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 directly 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. The IRS allows a 120-day grace period from the date of your original request. 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 (typically 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 does not help you request Good Faith Exceptions.
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 (Ready-to-Use)
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]
Frequently Asked Questions
If a program doesn’t respond, does that count?
Yes, document the attempt, timestamp, and any follow-ups. Keep proof of delivery.
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.
Can I send a GFE letter to Apprentix?
No. Send requests to RAP sponsors and your state agency.
What is a good faith effort in construction?
A specifically documented, timely attempt to request registered apprenticeship programs (RAPs) to supply apprentices for your project. If the request is not responded to within 5 days or cannot be fulfilled (assuming correct language was used), the requesting company qualifies for the Good Faith Exception with written proof.
How long is a good faith effort letter valid?
The exception is valid for 365 days (366 days in a leap year) from the date of the original request.
What is the difference between good faith effort and the apprenticeship participation requirement?
Good faith means you attempted to request apprentices in order to meet the apprenticeship participation requirement. The participation requirement states that once you have four or more unique individuals of any occupation performing labor on the project, you are required to have at least one registered apprentice.