Notice: Stakeholder engagement session on the implementation of apprenticeship and internship procurement requirements


The Maryland Department of Labor (MD Labor) and the Department of General Services (DGS) invite interested stakeholders to participate in an online engagement session regarding the establishment of new regulatory requirements under the Maryland Procurement Reform Act of 2025 on January 12, 2026, from 1:00 p.m. to 2:30 p.m. 


This engagement will help ensure that State procurement dollars support the development of a strong skilled workforce across Maryland.


We are seeking technical expertise and practical feedback from contractors, labor organizations, workforce advocates, and other members of the public to ensure these regulations are effective, scalable, and commercially viable. 


Session Details 


If you need a reasonable accommodation to participate, please contact anupa.geevarghese@maryland.gov by Wednesday, January 7, 2026. 


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Key discussion areas 


At the online engagement session, we will specifically seek input on the following regulatory pillars. Sample questions for consideration include, but are not limited to, the following: 


1.  Defining "covered procurements" (scope and thresholds) 

  • Contract duration: Should the requirements apply only to contracts with a minimum base term (e.g., 6 months, 1 year, or some other base term) rather than applying to all covered contracts regardless of length? 
  • Industry exceptions: Are there specific industries where apprenticeship or internship models are especially challenging or not yet feasible? 
  • Thresholds: While the Act specifies a $1,000,000 contract threshold for internship requirements, what threshold total dollar value, if any, should be established for apprenticeship requirements? 


2.  Program implementation standards


  • Direct vs. indirect utilization: To what extent should an intern or apprentice be required to work directly on the specific State contract versus the contractor’s general operations? 
  • Existing programs: How should the regulations credit contractors who already sponsor or participate in registered apprenticeship programs? 
  • Internship metrics: What standards should define an “eligible internship program,” such as regarding minimum hours, compensation, mentorship ratios, or educational alignment? 


3.  Enforcement and compliance 


  • Penalty structure: The Act directs penalties for non-compliance to be paid into the State Apprenticeship Training Fund. Should these penalties be calculated per violation, per missing labor hour, as a percentage of the contract value, or using some other metric? 
  • Waiver processes: What criteria should the State consider when establishing a waiver process? 


Background 


Subtitle 8 of the Procurement Reform Act of 2025 (Maryland Code Annotated, State Finance and Procurement Article (SFP) §§ 14-801 through 14-805) establishes requirements for certain State procurement contracts to support workforce development through paid internships and registered apprenticeships. Collectively, these requirements are intended to support contractors in building a sustainable talent pipeline while providing Marylanders with paid opportunities to gain valuable skills and work experience. The law applies to “covered procurements,” which will be defined in the new regulations. The statute provides that for covered procurements valued at $1 million or more, contractors must participate in an eligible paid internship program. The statute further provides that for covered procurements, contractors must utilize a registered apprenticeship program approved by the Maryland Department of Labor. Contractors will be required, before award, to submit written verification detailing the number of interns or apprentices to be used, the work they will perform, and the duration of the programs. 


The statute assigns the Secretary of the Maryland Department of Labor the responsibility for overseeing compliance and directs MD Labor to establish criteria, including penalties and reporting procedures, to ensure contractors meet their commitments. Contractors that fail to use interns or apprentices as promised may be subject to civil penalties, interest, attorney’s fees, and court costs. Alleged violations will be reported to MD Labor and referred to the Office of the Attorney General for potential enforcement. Collectively, these requirements are designed to support the state’s workforce pipeline and ensure that state spending creates high-quality training opportunities.


Please note that these requirements do not apply to public work contracts subject to SFP §17-202–meaning these requirements do not apply to most construction contracts valued $250,000 or more. Those public works contracts remain subject to existing apprenticeship utilization statutes. 


The statute further directs the Chief Procurement Officer, in consultation with the Secretary of Labor and, for contracts subject to Title 3.5 of SFP, the Secretary of Information Technology, to adopt regulations establishing the definition of “covered procurement.” The statute also provides that the Chief Procurement Officer may adopt regulations to improve the recruitment or skills of employees of vendors or other regulations necessary to carry out Subtitle 8 of the Procurement Reform Act, including waiver processes.