The default rule
Ratio and supervision responsibility stay within each employer. If your company has a registered W-2 apprentice, that apprentice needs to be supervised by your own company's journeyworker to satisfy the daily 1:1 ratio requirement. A journeyworker who works for a different company — a subcontractor, a client, a general contractor, another trade partner on the job site — cannot supervise your apprentice by default, even if they're standing right next to each other on the same project.
This is true regardless of occupation match. Even if the third-party journeyworker is registered in the exact same occupation as your apprentice, the ratio doesn't transfer between companies without approval.
The exception: a Letter of Authorization
A journeyworker employed by a different company can supervise your apprentice — but only with a Letter of Authorization (LOA) issued by Apprentix as your program sponsor. This is the same kind of approval used for cross-occupation supervision (see: Resolving an Occupation Mismatch Between an Apprentice and a Journeyworker) — here, the thing being authorized is cross-company supervision instead of (or in addition to) cross-occupation supervision.
One thing this does not change: the apprentice must remain your own company's W-2 employee. An LOA authorizes a different company's journeyworker to provide supervision — it does not transfer the apprentice's employment, and it cannot be used to have a third party's registered apprentice count as your own.
⚠️ An Apprentix LOA covers DOL registration — not IRA tax credit compliance
A Letter of Authorization from Apprentix confirms this arrangement is acceptable from the Department of Labor and apprenticeship-registration side, since Apprentix is your program sponsor for that purpose.
That is not the same thing as confirming the arrangement is acceptable to the Treasury Department for IRA tax credit purposes. These are two separate regulatory bodies, and DOL sign-off does not guarantee Treasury/IRA sign-off.
Because of this, an Admin needs both of the following before relying on a cross-company supervision arrangement on an IRA project:
A Letter of Authorization from Apprentix, as your program sponsor (the DOL side)
Confirmation from whoever oversees IRA compliance on that specific project — your company's IRA Compliance Firm, or the client's IRA Compliance Officer — that the arrangement is also acceptable for IRA tax credit purposes
Apprentix's authorization is necessary, but on its own it is not sufficient for IRA purposes — always confirm with your IRA compliance contact as well.
When you'd need this
Some common situations where this comes up:
Your apprentice is working alongside a subcontractor's crew, and the only journeyworker on-site in that trade works for the subcontractor, not you.
You're a subcontractor, and the general contractor's journeyworker is the one actually supervising day-to-day work.
A client or another trade partner has journeyworkers on-site who are the practical choice for supervision, even though your apprentice is your own W-2 employee.
If you're in a situation like this and haven't requested an LOA — and separately confirmed it with your IRA compliance contact — don't assume it's fine because "someone qualified is supervising." Without both, those hours may not satisfy your ratio requirement or count for IRA purposes.
How to request one
To request a Letter of Authorization for cross-company supervision, submit a request to Apprentix with:
The apprentice's name and occupation
The name of the company employing the supervising journeyworker
The journeyworker's occupation
A description of the specific work/duties involved
Apprentix reviews the request and, if approved, issues a Letter of Authorization. A copy is kept in your IRA Compliance Package alongside your other registration documents, so it's available if a client or auditor asks for it.
Remember: this covers the DOL side only. Separately confirm with your IRA Compliance Firm or the client's IRA Compliance Officer that the arrangement also works for IRA tax credit purposes on that project.
FAQ
Q: Does this affect the third-party company's own ratio or apprentice program?
No — the LOA authorizes their journeyworker to supervise your apprentice. It doesn't affect their own apprenticeship program, registrations, or ratio obligations in any way.
Q: Can I request this after the fact, once I realize the wrong company's journeyworker has been supervising my apprentice?
Submit the request as soon as you realize it — but don't assume approval will be retroactive. Request this before the arrangement starts wherever possible.
Q: Does this combine with an occupation-mismatch request if both apply — different company and different occupation?
Yes — include both the company and occupation details in a single request so Apprentix can review the full picture at once.
Q: If Apprentix approves the LOA, does that mean the hours are automatically good for IRA purposes too?
No. Apprentix's approval covers the DOL/registration side only. Always separately confirm with your IRA Compliance Firm or the client's IRA Compliance Officer before relying on it for IRA tax credit purposes.