Submit your comments on 14(c) sub-minimum wage to Dept of Labor by Friday!

The U.S. Department of Labor is collecting input on Section 14© of the Fair Labor Standards Act, which allows people with disabilities to be paid less than minimum wage. Currently, we are seeing that the comments are weighted heavily toward keeping sub-minimum wage facilities in place. This is an important time to highlight the significant progress Wisconsin and other states have seen through implementation of WIOA and HCBS.

You can submit comments by going to this website and establishing a user ID and password:

Survival has submitted its comments, which include data from Wisconsin showing that HCBS and WIOA implementation are improving outcomes. You can both read and use ideas/wording from our comments here:

Some talking points that you can feel free to use and that come from The Arc of the United States include:

Public policy and funds should focus on the supports people need to  find and keep community jobs based on their preferences, interests, and strengths, work alongside people without disabilities, receive comparable wages, and be free from workplace discrimination. Rather than continuing to focus on subminimum wage, public funding and policy should focus on strengthening:  Opportunities for post-secondary education, including college and vocational training, to gain knowledge and skills to allow people to get better jobs; ongoing planning to promote job advancement and career development; fair and reasonable wages and benefits; opportunities for self-employment and business ownership; the ability to explore new directions over time and, at the appropriate time, retire; and opportunities to work and increase earnings and assets without losing eligibility for needed public benefits.

Evidence-based Supports

  • Public funding for employment supports and services should use strategies that have a track record of improving employment outcomes:
  • assessing skills and interests,
  • working with employers,
  • matching jobs to skill sets and employer needs,
  • providing individualized and ongoing job supports,
  • designing reasonable job accommodations,
  • integrating people into the workforce,
  • building social skills necessary in the workplace, and
  • securing needed support services,  such as transportation.
  • People with I/DD must have training and information on how to access supports needed to find and keep jobs.

 Importance of School-to-Work Transition

  • Transition planning should start early.
  • Transition activities should foster individualized exploration of and experiences with community-based employment options that enable youth to make informed choices.
  • Transition activities should include career assessments to identify students’ interests and preferences, exposure to post-secondary education and career opportunities, training to develop job-seeking and workplace skills, and participation in multiple on-the-job activities and experiences in paid and unpaid settings.
  • Transition activities should not be limited to unpaid internships at pre-set community worksites.
  • Students should leave high school with opportunities to pursue post-secondary education and/or with an appropriate job or an action plan for finding one.

Training of Staff and People with I/DD

  • Staff of employment and school-to-work transition programs must receive training in best practices to help people find and keep jobs.
  • Along with ensuring appropriate on-the-job training, people with I/DD should receive guidance, if needed, in acquiring the social skills necessary in the workplace.
  • People with I/DD must have training, including, if desired, driver’s education, to allow them to travel in the community so they can get to jobs and enhance their independence.

Please encourage all your members to individually register and submit a comment. It does not have to be long or include multiple points.