GI Bill On-the-Job Training: A Guide for Minnesota Employers

Employer Guide · Updated September 2026 · 18 min read

When a veteran joins you in a role that takes months of structured training to learn, the GI Bill can pay the veteran a monthly benefit on top of the wage you pay. The training program has to be approved first, and in Minnesota that runs through the State Approving Agency at the Minnesota Department of Veterans Affairs (MDVA). Minnesota also has its own state GI Bill, which adds a benefit for the trainee and two state-paid job placement credits of up to $1,000 each for the employer. This guide covers approval, what the veteran receives, the state credits, and how all of it sits next to the Work Opportunity Tax Credit, which is still lapsed as of September 2026.

What GI Bill on-the-job training is, and who pays whom

On-the-job training (OJT) and apprenticeship let a veteran use GI Bill benefits while learning a trade or skill at work instead of in a classroom. The veteran usually signs a training agreement for a set period, you pay a wage that rises as skills grow, and at the end the veteran is fully trained for the job or reaches journeyworker status. VA's own examples include plumbing, electrical trades, law enforcement and firefighting, but what qualifies a job is the structure of the training, not the industry.

The money moves in two separate directions. You pay the wage. VA pays the veteran directly: a monthly payment for living expenses and, under the Post-9/11 GI Bill, a books and supplies stipend. Under the federal GI Bill, VA pays the veteran, not you. The only payments made to employers in this guide are Minnesota's state job placement credits, covered below. WOTC, covered at the end, is a tax credit rather than a payment.

VA lists who can use OJT benefits: veterans, reservists, family members using the Fry Scholarship or Survivors' and Dependents' Educational Assistance, and dependents using transferred Post-9/11 benefits. Two groups are excluded: service members still on active duty, and spouses of active-duty members who are using transferred benefits.

Which jobs can be approved

Federal law sets the test a State Approving Agency (SAA) applies before it approves on-the-job training other than apprenticeship (38 U.S.C. 3677). The agency has to find, after investigating, that the job is one where people move up because of skills learned through organized, supervised training on the job, not because of seniority or normal turnover. It also has to find that these criteria are met:

• The job customarily requires full-time training for at least six months and no more than two years.
• The training period is no longer than employers in your community normally need to make someone competent in that job.
• The training content is enough to qualify the veteran for the job at the end.
• Related instruction is provided for a trainee who needs it.
• You have adequate space, equipment, instructional material and instructors.
• You keep records that show each trainee's progress toward the job.
• The veteran is not already qualified for the job by training and experience. Training for a job someone can already do is not treated as bona fide.
• A signed training agreement, including the training program and wage scale the SAA approved, goes to the veteran, VA and the SAA.
• The program meets any other criteria the SAA sets.

Apprenticeship takes a separate track

Registered apprenticeship is approved differently. GI Bill benefits apply to apprenticeship programs that an SAA approves as meeting the apprenticeship standards published by the Secretary of Labor (38 U.S.C. 3687). In Minnesota, MDVA says apprenticeship programs must be registered with the Minnesota Department of Labor and Industry (DLI), and it points employers with OJT, or with a program that is not yet listed, to the State Approving Agency.

If your trade already runs a registered apprenticeship, start by confirming the program's registration with DLI. If the role you want to fill is a structured training job outside a registered apprenticeship, OJT approval through the SAA is the route this guide describes.

The wage commitments you sign

For OJT other than apprenticeship, your application must certify three things about pay and the job (38 U.S.C. 3677(b)):

• The starting wage is no less than you pay non-veterans in the same training position, and at least 50 percent of the wage for the fully trained job.
• Wages rise in regular steps so that, by the last full month of training, the trainee earns at least 85 percent of the fully trained wage. Federal, state and local government employers are exempt from this step-up requirement.
• There is reasonable certainty the job will be available to the veteran when training ends.

What the federal application asks you to agree to

The federal application, VA Form 22-8865 (Employer's Application to Provide Job Training), turns those rules into signed commitments. It asks for the job title and a short description, the program length, the hours in your standard work week, the beginning wage for trainees, the present journeyworker wage and the wage steps during training.

By signing, you also agree to provide close supervision by qualified journey workers, to give credit for previous training and experience and shorten the program to match, and to keep records for each trainee. Those records cover job assignments, promotions and demotions, layoffs and terminations, rates of pay, training hours given each month in each work process, and progress evaluations made at least every three months. You also agree to tell VA right away about any pay change that does not follow the training agreement.

This matters when you hire veterans with directly relevant military experience. The more of the job a veteran already knows, the shorter the approved program and the higher the starting step on your wage scale. A veteran who is already fully qualified for the job cannot be enrolled at all.

Getting approved in Minnesota, step by step

MDVA's State Approving Agency approves OJT programs in Minnesota, and its guidance for employers who want approval is to contact the SAA directly at [email protected]. Based on the federal rules and forms, expect these steps:

• Check whether your program is already approved. Search for your organization in VA's GI Bill Comparison Tool, which covers schools and employers with programs approved for VA education benefits and can filter for on-the-job training and apprenticeships. VA tells trainees to use the same tool to confirm that an employer's program is approved.
• For a registered apprenticeship, confirm the program's registration with DLI.
• For OJT, contact the SAA and prepare what the application asks for: the job title and description, the program length, the standard work week, and the wage progression from the starting wage to the journeyworker wage.
• Complete VA Form 22-8865, or the version of the application the SAA asks you to use. The SAA must investigate before it approves, so plan for questions about your training setup.
• For each veteran you enroll, sign a training agreement (VA Form 22-8864) and give copies to the veteran, VA and the SAA.
• Name a certifying official. Under the Post-9/11 GI Bill, VA pays the veteran each month only after the employer submits that month's training hours, so the reporting has to be reliable.
• Keep the records the application requires, and evaluate each trainee's progress at least every three months.

What the veteran receives under the Post-9/11 GI Bill

Under the Post-9/11 GI Bill, the monthly payment is based on the Department of Defense Basic Allowance for Housing (BAH) for an E-5 with dependents, using the ZIP code where the training takes place. For payments from August 1, 2026 to July 31, 2027, VA uses the 2026 BAH rates.

Two adjustments apply. The payment is multiplied by the veteran's Post-9/11 eligibility tier, which runs from 50 percent to 100 percent depending on length of active-duty service. VA also reduces it for any month in which the veteran works fewer than 120 hours or does not work the full month. The entitlement charged to the veteran's GI Bill falls along with the payment, so a later month of training uses less entitlement than an early one. Post-9/11 trainees can also receive up to $83 a month for books and supplies, prorated by tier, up to $1,000 a year.

The payment then steps down every six months of training:

• Months 1 to 6: 100 percent of the full BAH rate
• Months 7 to 12: 80 percent
• Months 13 to 18: 60 percent
• Months 19 to 24: 40 percent
• After two years: 20 percent

Under the Montgomery GI Bill, and what it means in dollars

Under the Montgomery GI Bill Active Duty (Chapter 30), the monthly OJT payment is a fixed share of the veteran's full-time monthly rate: 75 percent for the first six months, 55 percent for the second six months and 35 percent after that (38 U.S.C. 3032(c)). A month with fewer than 120 hours of training is paid in proportion to the hours worked. Montgomery rates reset every October 1, so check VA's current table.

Under either program, the payment comes on top of the wage you pay. Under the Post-9/11 GI Bill it is set by where the job is, not where the veteran lives. Look up the E-5 with dependents rate for your worksite ZIP code with the Defense Travel Management Office BAH lookup to see the starting figure.

The Minnesota GI Bill training benefit

Minnesota runs its own GI Bill program under Minn. Stat. 197.791, administered by MDVA and separate from the federal GI Bill. Subdivision 6 creates an apprenticeship and on-the-job training benefit. An eligible employer is one operating an apprenticeship or OJT program approved by the commissioner of veterans affairs, and MDVA's instruction for becoming an approved training site is to contact the State Approving Agency. At a minimum, a qualifying program must be with an eligible employer, be documented and reported, reasonably be expected to lead to an entry-level position, and be for a position that requires at least six months of training to become fully trained.

Eligible trainees include veterans who are serving or have served honorably in any branch; members of the Minnesota National Guard or any other active or reserve component who are not veterans, with at least five years of cumulative honorable service, some of it on or after September 11, 2001; and certain surviving spouses and children of people who died as a result of military service, and spouses and children of people with a total and permanent service-connected disability, if they are eligible for federal Chapter 33 or Chapter 35 education benefits. MDVA also requires the trainee to be a Minnesota resident.

The trainee applies through MDVA's online Minnesota GI Bill application and uploads a W-9, a DD-214, a direct deposit form and a training verification. The training verification is MDVA's form for the employer to complete. It asks for your organization, the position title, the length of the program, the training start and estimated end dates, whether it is OJT or apprenticeship, and a point of contact or certifying official. Ask MDVA's Minnesota GI Bill team ([email protected]) how the employer placement credits are claimed for your trainee.

Minnesota's amounts, including two employer credits of up to $1,000

Two limits come first. The placement credits attach to a person receiving the state OJT or apprenticeship assistance, so the veteran has to apply for and receive that benefit for the credits to exist. And every Minnesota GI Bill payment comes from one state appropriation that the statute caps at $6,000,000 a fiscal year. Within those limits, the statute sets these maximums for each eligible person:

• Up to $3,000 per fiscal year for on-the-job training, and separately up to $3,000 per fiscal year for apprenticeship expenses. As of September 2026, MDVA's Minnesota GI Bill page lists a lower trainee maximum of $2,000 per fiscal year, payable after every six months of training.
• A job placement credit of up to $1,000, payable to the employer upon hiring and completion of six consecutive months of employment.
• A second job placement credit of up to $1,000, payable to the employer once the person has worked for you for at least 12 consecutive months as a full-time employee.
• No more than $5,000 in total under this benefit paid to or on behalf of one person in a fiscal year. If the person also receives other Minnesota GI Bill benefits, the statute caps the combined lifetime total at $15,000, and MDVA's page describes $15,000 as the program's maximum benefit.

WOTC in September 2026, and how the programs stack

The Work Opportunity Tax Credit (WOTC) is a federal income tax credit for hiring people in certain target groups, including several groups of veterans. When it is in force, the credit is 40 percent of first-year wages up to a cap that depends on the category: from $2,400 for a veteran unemployed at least four weeks, or in a family receiving SNAP benefits, up to $9,600 for a veteran with a service-connected disability who was unemployed at least six months. The worker must put in at least 120 hours, and the full 40 percent rate needs 400 hours.

Status as of September 2026: WOTC has lapsed. The law excludes wages paid to anyone who begins work after December 31, 2025, and Congress has not renewed it. The IRS WOTC page, last reviewed July 20, 2026, still gives authorization only through December 31, 2025, and the Congressional Research Service reported in May 2026 that the authority lapsed on January 1, 2026. Minnesota's WOTC program, through CareerForce, describes a program hiatus: applications for start dates on or after January 1, 2026 are accepted and held until reauthorization, and employers are asked to keep filing on time.

WOTC has lapsed before and been extended retroactively, for 2014 hires by legislation passed in December 2014 and for 2015 hires by legislation passed in December 2015. Nothing guarantees the same outcome this time. The steps that protect your position are the same either way: complete IRS Form 8850 with the candidate on or before the day you make the job offer, then submit it to the state workforce agency within 28 days of the start date.

GI Bill OJT, the Minnesota placement credits and WOTC are separate programs with separate eligibility, so one hire can qualify for all three, some, or none. A veteran in an approved OJT program is not automatically in a WOTC target group. WOTC turns on unemployment, SNAP or disability status at hire, which the state workforce agency certifies.

One WOTC rule touches training money directly. The Internal Revenue Code says wages do not count toward WOTC for any period in which the employer receives federally funded payments for the on-the-job training of that worker (26 U.S.C. 51(c)(2)). Under the federal GI Bill, VA pays the veteran rather than the employer, and the Minnesota placement credits are paid to the employer from the state general fund. Have your tax adviser confirm how each payment is treated on your return before you count on the credit.

One hire, month by month

Here is how the pieces line up for a veteran hired full time into an approved 18-month OJT program in Minnesota, using the Post-9/11 GI Bill at the 100 percent tier and approved for the state OJT benefit. Dollar amounts depend on your ZIP code and the veteran's eligibility, so the percentages are what to plan around.

• Before the start date: SAA approval in place and a training agreement signed. If the veteran may be in a WOTC target group, complete Form 8850 with them on or before the day you make the job offer, then submit it to the state workforce agency within 28 days of the start date.
• Months 1 to 6: VA pays the veteran 100 percent of the E-5 with dependents BAH rate for your worksite ZIP code, reduced in any month under 120 hours. You report training hours every month.
• After six consecutive months of employment: the first Minnesota placement credit, up to $1,000, becomes payable to you. MDVA's page says the trainee's state benefit is also payable after every six months of training. VA's payment drops to 80 percent for months 7 to 12.
• After 12 consecutive months as a full-time employee: the second Minnesota placement credit, up to $1,000, becomes payable. VA pays 60 percent for months 13 to 18.
• End of month 18: training ends. By the last full month of training, the wage must have reached at least 85 percent of the fully trained wage.

Sources

Every figure above is drawn from these sources. Figures and rules change, so check the current source before you act.

• VA: On-the-job training and apprenticeships
• VA: Post-9/11 GI Bill (Chapter 33) rates, effective August 1, 2026
• VA: Montgomery GI Bill Active Duty (Chapter 30) rates
• 38 U.S.C. 3677: Approval of training on the job
• 38 U.S.C. 3687: Apprenticeship or other on-job training
• 38 U.S.C. 3032: Montgomery GI Bill payment for on-job training
• VA Form 22-8865: Employer's Application to Provide Job Training
• VA Form 22-8864: Training Agreement for Apprenticeship and Other On-the-Job Training Programs
• VA: GI Bill Comparison Tool
• Defense Travel Management Office: BAH rate lookup
• Minn. Stat. 197.791: Minnesota GI Bill program
• 2026 Minn. Laws ch. 49 (amends Minn. Stat. 197.791, subd. 8)
• MDVA: Minnesota GI Bill
• MDVA: State Approving Agency
• MDVA: OJT and Apprenticeship
• MDVA: Minnesota GI Bill OJT/Apprenticeship Training Verification (employer form)
• Minnesota Department of Labor and Industry: GI Bill benefits and apprenticeship
• IRS: Work Opportunity Tax Credit
• IRS: About Form 8850
• 26 U.S.C. 51: Work opportunity credit, amount of credit
• Congressional Research Service: The Work Opportunity Tax Credit (R43729, updated May 13, 2026)
• CareerForce Minnesota: Work Opportunity Tax Credit