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On November 19, 2018, the Center on Education and Skills at ¹ú²úÊÓƵ (CESNA) submitted these to the U.S. Department of Labor (DOL), Employment and Training Administration (ETA) on its proposed information collection request (ICR), , which was published in the Federal Register on September 20, 2018. This submission includes recommendations and clarifying questions for DOL to assist it in refining the criteria by which it will assess the qualifications of entities that wish to accredit industry-recognized apprenticeship programs (IRAPs).