Recent investigations by the U.S. Department of Labor鈥檚 Employee Benefits Security Administration (EBSA) have found that apprenticeship and training funds are being misused for graduation ceremonies and advertising. In order to help clear up confusion, the DOL has issued a field assistance bulletin that gives definitions and examples of allowed and non-allowed expenses, particularly in regards to graduation ceremonies and promotional activities.
Apprenticeship and training programs that are covered by ERISA 鈥 typically those that run a multiyear training program registered with the U.S. Department of Labor, Office of Apprenticeship or a recognized State Apprenticeship Agency 鈥 are subject to an EBSA audit and should be aware both of EBSA鈥檚 stepped-up auditing of such programs and which expenses are not allowed to be funded by the training funds.
According to , issued by EBSA on April 2, 2012, expenses that do not qualify as allowable training or administrative expenses include:
- Payments for meals, gifts, entertainment or other expenses associated with graduation ceremonies;
- Payments to market, advertise or promote the apprenticeship or training program.
- Modest compared to the plan鈥檚 assets;
- Approved in accordance with internal accounting and administrative controls; and
- Used for the cost of the ceremony.