Keeping it Legal 1 Fair Labor Standards Act, Work Based Learning Guidelines and the ADA: Increasing...

Keeping it Legal

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Fair Labor Standards Act, Work Based Learning Guidelines and the ADA: Increasing Employment Opportunities for Youth

FLSA WBL Guidelines• The Departments of Labor and Education

joined this statement of principle with Policy Guidelines governing the participation of youth with disabilities in employment settings for career exploration, career assessment, and work-related training.

National Center for Secondary Education & Transition, Handbook for Implementing Comprehensive Work-Based Learning Program According to the Fair Labor

Standards Act, http://www.ncset.org/publications/essentialtools/flsa/NCSET_EssentialTools_FLSA.pdf

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FLSA WBL Guidelines

1. Youth with disabilities who engage in nonpaid career exploration, career assessment, and work-related training activities are not considered employees of the businesses in which they receive these services only if they can demonstrate compliance with all of the guidelines below. When schools and employers engaging in these WBL activities with youth with disabilities adhere to all of the following guidelines, they do not violate the provisions of the FLSA.

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FLSA WBL Guidelines2. Participants will be youth with physical and/or

mental disabilities for whom competitive employment at or above the minimum wage level is not immediately obtainable and who, because of their disability, will need intensive ongoing support to perform in a work setting.

3. Participation will be for career exploration, career assessment, or work-related training at a worksite placement under the general supervision of public school personnel.

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FLSA WBL Guidelines

4. Worksite placements will be clearly defined components of Individualized Education Programs (IEPs) developed and designed for the benefit of each student. The statement of needed transition services established for the exploration, assessment, training, or cooperative work experience components will be included in the student’s IEP.

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FLSA WBL Guidelines5. Information contained in a student’s IEP will not have to

be made available; however, documentation as to the student’s enrollment in the work-based learning program will be made available to the Departments of Labor and Education. The student and his or her parent(s) or guardian(s) must be fully informed of the IEP and the career exploration, career assessment, or work-related training components and have indicated voluntary participation with the understanding that participation in these components does not entitle the student participant to wages or other compensation for duties performed at the worksite placement.

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FLSA WBL Guidelines6. The activities of the student at the worksite do not result in

an immediate advantage to the business. The Department of Labor looks at the following factors to determine if this guideline is being met:

– There has been no displacement of employees, vacant positions have not been filled, employees have not been relieved of assigned duties, and the students are not performing services that, although not ordinarily performed by employees, clearly are of benefit to the business.

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FLSA WBL Guidelines

– The students are under continued and direct supervision by either representatives of the school or by employees of the business. The student receives ongoing instruction and close supervision at the worksite during the entire experience, resulting in any tasks the student performs being offset by the burden to the employer of providing ongoing training and supervision.

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FSLA WBL Guidelines

– Such placements are made according to the requirements of the student’s IEP and not to meet the labor needs of the business.

– The periods of time spent by the students at any one site or in any clearly distinguishable job classification are specifically limited by the IEP.

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FLSA WBL Guidelines

6. While the existence of an employment relationship will not be determined exclusively on the basis of number of hours, as a general rule, each component will not exceed the following limitation during any one school year:

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Career Exploration 5 Hours per Job Experience

Career Assessment 90 Hours per Job Experience

Work-Related Training 120 Hours per Job Experience

FLSA WBL Guidelines

7. Students are not automatically entitled to employment at the business at the conclusion of their IEP. However, once a student has become an employee, the student cannot be considered a trainee at that particular worksite placement unless in a clearly different occupation.

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Importance of Compliance with Guidelines

• Schools and participating businesses are responsible for ensuring that all seven of these guidelines are met. If any of these guidelines are not met, an employment relationship exists, and participating businesses can be held responsible for full compliance with the FLSA.

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Addressing Liability Concerns

• One barrier to establishing work based learning is the issue of liability for non-paid experiences.

• Provide Employer with basic Fact Sheet regarding Community Based Assessments – Include Purpose– Employer Expectations– Agency Responsibilities– Statement that the arrangement is “Not an

Employer/Employee Relationship” and employment is not a requested outcome


• Provide information to the employer regarding the Department of Labor Standards

In compliance with IRS Revenue Ruling 65-165 and with standard insurance practice, the Employer-Employee relationship actually exists between your agency and the client who is participating in a Community Based Assessment experience with the following understanding:


Department of Labor Standards (cont’d)• The services are for therapeutic or rehabilitative

purposes.• The ESO retains final control over the client and this

control is protective.• The client is a registered client of your ESO, and

receives token remuneration from your agency.• An ESO staff person will be available to client and

employer as needed.

Individuals with Disabilities Education Improvement Act (IDEA) 2004---Definition

The term “transition services” means a coordinated set of activities for a child with a disability that---

• (A) Is designed to be within a results-oriented process, that is focused on improving the academic and functional achievement of the child with a disability to facilitate the child’s movement from school to post-school activities, including post-secondary ed, vocational ed, integrated employment, continuing & adult ed, adult services, independent living, or community participation;

Individuals with Disabilities Education Improvement Act (IDEIA) 2004-Definition

(continued)

• (B) Is based on the individual child’s needs, taking into account the child’s strengths, preferences, and interests; and

• (C) Includes instruction, related services, community experiences, the development of employment and other post-school adult living objectives, and when appropriate, acquisition of daily living skills and functional vocational evaluation.

Fair Labor Standards Act (FLSA)Revised 3/2001

The Fair Labor Standards Act is designed to serve employers, educators, agency placement staff, labor organizations and all those involved in work-based learning initiatives by helping them to understand a variety of issues related to students in the workplace.

Work Based Learning Options(see Handout A)

Career Education & Work Standards

• Cooperative Education• Internships• Job Shadowing• Registered

Apprenticeships

Other Options:

• Diversified Occupations• Service Learning• Work Release• Work Study• Volunteering

Work Based Learning Options (continued)

For Students with Disabilities Only:• Work Experience• Community Based Vocational Training

CSPG No.61 Special Education –Cognitive, Behavior, and Physical/Health

Disabilities (CB-PHD) (see Handout B)

1. Grade Level – Scope of CertificateA person holding a valid certificate for CB-PHD is

qualified to provide all special education requirements in grades Nursery through 12.

Special ConsiderationsOther certification titles that are also applicable in

this area are: Mentally & Physically Handicapped, and Mentally Retarded.

CSPG No.61 Special Education –Cognitive, Behavior, and

Physical/Health Disabilities (CB-PHD)Under the provisions of CSPG #61, an educator

holding a Special Education Certificate may:• Conduct student activities including paid/unpaid

work-based learning opportunities in a community setting

• Involve the business enterprise in paid or unpaid settings

• Coordinate job training agreements• Place students in appropriate work or community

transition settings related to their career objective

Fair Labor Standards ActWork Experience---DefinitionEmployment opportunities for young people with disabilities are available through the school system, supported employment programs, private industry, and special government funded projects. Depending on the extent and type of disability, the student’s work experiences need to be designed with an appropriate level of support and supervision. Students who participate in a work experience program are paid at least minimum wage. Students must follow the requirements of the Fair Labor Standards Act and the Pennsylvania Wage and Hour Regulations.

Fair Labor Standards Act (continued)

Standards for 18 year-olds and older.

Once a student has reached 18 years of age, he or she is no longer subject to the Fair Labor Standards Act and there are no restrictions on employment.

Fair Labor Standards Act (continued) Standards for 16- and 17-year-old youths employed in non-farm jobs including Hours Limitations and Occupation Limitations.•Federal Law does not limit either the number of hours nor the time of day that youth 16 years of age or older may work.•Some state laws do restrict the hours that 16 & 17 year-olds may work.•Minors may perform all work except in 17 Hazardous Occupations (see Handout D).


Standards for 16- and 17-year-old youths employed in non-farm jobs including Exceptions to Occupational Limitations---Special Provisions.

Special Provisions for Student-Learners and Apprentices-The seven Hazardous Occupations identified with an asterisk permit the employment of apprentices and student-learners in vocational education programs under certain conditions.


Student-Learners (Career-Technical Ed.) will meet the exemption if the student is employed under a written agreement which provides that:

1. All hazardous work will be performed under the direct and close supervision of a qualified and experienced person

2. Safety instructions will be given by the school and re-enforced by the employer with on-the-job training

3. The job training follows a schedule which reflects organized and progressive skill development

4. The work is intermittent and for short periods of time

Fair Labor Standards Act (continued)Apprentices (An apprentice is a participant in an

apprenticeship program legally registered by the Department of Labor’s Bureau of Apprenticeship & Training or by an authorized State Agency):

1. The apprentice is employed in a craft recognized as an apprentice trade;

2. The work of the apprentice in the occupations declared particularly hazardous is incidental to his or her training;

3. Such work is intermittent and for short periods of time and is under close supervision of a journeyman as a necessary part of such apprentice training and;

4. The apprentice is registered by the Bureau of Apprenticeship and Training of the U.S. Department of Labor as employed in accordance with standards established by the Bureau, or is registered by a State agency as employed in accordance with the standards apprenticeship agency recognized by the Bureau of Apprenticeship and Training.

Fair Labor Standards ActExceptions (continued)

Standards for 14- and 15-year-old youths employed in non-farm jobs including Hours Limitations and Occupation Limitations.The hours that 14- and 15-year-olds may work are limited to:• outside school hours• no more than 3 hours on a school day• no more than 18 hours in a school week• no more than 8 hours on a non-school day• no more than 40 hours in non-school weeks• between 7AM and 7PM (between June 1 and Labor Day until 9PM)


The Work Experience and Career Exploration Program (WECEP) is a federal program under the Fair Labor Standards Act that permits individual states to apply to the federal government for approval to provide employment and career awareness opportunities for 14- and 15-year-old youths.


The Work Experience and Career Exploration Program (WECEP):•The following guidelines may permit 14- and 15-year-old students to participate in an employment arrangement: • up to 3 hours on a school day• up to 23 hours during a school week• any time during school hours


Standards applying to minors employed in farm jobs.

• Minors 16 years and older may be employed in any farm job at any time.

• Fourteen and 15 year old farm workers may be employed outside school hours in any occupation not declared hazardous.

• There are also special considerations for students under 14 years of age.


(see Handout C)

Community-Based Vocational Training (Non-paid)---Definition

CBVT is vocational training occurring on actual job sites within local business, industry and community service agencies. Training experiences include Vocational Exploration, Vocational Assessment, and Vocational Training that are non-paid and are limited to Fair Labor Standards Act requirements. An agreement outlining training objectives is required, as well as goals, objectives, and specially designed instruction in the student’s IEP.


The U.S. Department of Labor requires that an employment relationship does NOT exist for non- paid positions. The following criteria must be met to have students working in community job-sites without pay.


Where ALL of the following seven criteria are met, the U.S. Department of Labor will NOT assert an employment relationship for purposes of the FLSA. These seven criteria pertain to Community-Based Vocational Training.

Fair Labor Standards Act (continued)(See Handout E)

Seven Criteria: 1. Participants will be youth with physical and/or mental disabilities for whom competitive employment, at or above the minimum wage level, is not immediately obtainable and who, because of their disability, will need intensive on-going support to perform in a work setting.


Seven Criteria (continued): 2. Participation will be for vocational exploration, assessment, or training in a community-based placement worksite under the general supervision of public school personnel.


Seven Criteria (continued): 3. Community-based vocational training placements will be clearly defined components of individual education programs developed and designed for the benefit of each student. The transition services established for the exploration, assessment, training, or work-based learning components will be included in the student’s Individualized Education Program (IEP).


Seven Criteria (continued): 4. The student and the parent or guardian of each student must be fully informed of the IEP and the CBVT component and have indicated voluntary participation with the understanding that participation in such a component does not entitle the student participant to wages.


Seven Criteria (continued):

5. The activities of the students at the CBVT site do not result in an immediate advantage to the business. The Department of Labor will look at several factors:

• There has been no displacement of employees, vacant positions have not been filled, employees have not been relieved of assigned duties, and the students are not performing services that, although not ordinarily performed by employees, clearly benefit the business.


Seven Criteria (continued): 5. The activities…The Department of Labor will look

at several factors (continued):• The students are under continued and direct supervision by either

representatives of the school or by employees of the business.• Such placements are made according to the requirements of the

student’s IEP and not to meet the labor needs of the business.• The periods of time spent by the students at any one site or in any

clearly distinguishable job classification are specifically limited by the IEP.


Seven Criteria (continued): 6. While the existence of an employment relationship will

not be determined exclusively on the basis of the number of hours, as a general rule, each component will not exceed the following limitation during any one school year:

• Vocational exploration-----5 hours per job experienced• Vocational assessment---90 hours per job experienced• Vocational training---------120 hours per job experienced


Seven Criteria (continued): 7. Students are not entitled to employment at

the business at the conclusion of their IEP. However, once a student has become an employee, the student cannot again be considered a trainee in that particular placement.

PA Wage and Hour Regulations(Child Labor Law)

Hours of Employment---Ages 16 & 17

During School Term:• Maximum of 28 hours per school week

(Monday through Friday) if enrolled in regular day school.

• Eight additional hours on Saturday and 8 additional hours on Sunday.

• Maximum daily hours cannot exceed 8 hours per day.


Hours of Employment---Ages 16 & 17During Summer Vacation:• Maximum 8 hours per day, 44 hours per weekNight Work During School Term:• Students may not work after midnight (Sunday

through Thursday) or before 6AM during the entire week. (Exception: Students may work the night preceding a school holiday occurring during the school year until 1AM the next morning.

• Students may work Friday/Saturday night until 1AM-Saturday/Sunday morning.



Night Work During Summer Vacation:No night work limit for students. No night

work limit at any time for minors legally excused from school attendance.



During School Term:• No more than 4 hours on a school day• No more than 18 hours in a school week, and only

at a time that does not interfere with school attendance.

• No more than 8 hours on a non-school day• Plus 8 additional hours on Saturday and/or

Sunday



During Summer Vacation:• Maximum 8 hours per day, 44 hours per

weekNight work:• Employment prohibited after 7PM and

before 7AM. (Exception: Summer vacation employment until 10PM).

Issues Concerning “Work Readiness”

• QUESTION: When is a student ready fornon-paid employment opportunities?

• ANSWER: It depends!

Issues Concerning “Work Readiness”

• Consider the following:a) IEP team decisionb) Based on a student’s needsc) Assessment resultsd) Post-school agency commitmente) Transportation issuesf) Practical considerations

Skills Employers Look For

Math, Reading, Writing, Speaking, Listening

Computer Literacy Reasoning, problem-solving, decision-

making Positive attitude Independence & Initiative Self-presentation

Community-Based Vocational Training (CBVT)

CBVT is vocational training occurring in community sites within schools, local businesses, industries, or community service agencies.

Student Documents Needed for CBVT

Documents needed by students for CBVT are dictated by the school district’s policy. The following are strongly recommended:

• PA non-driver identification card or• PA driver’s license (if applicable)• Social Security Card (required)• Proof of Health Insurance/Medical

Assistance Card• Medical/Emergency Procedures Card

Student Documents Needed for CBVT (continued)

• Bus pass/transit cards * • Act 34 and 151 Background Checks*• Tuberculin Skin Test TB test results *• Medical exam *• Selective Service card * • School entity/employer forms*

*if applicable


• Proof of school entity insurance• Video/photo release forms• Student schedule• Permission for Release of Information


• Fair Labor Standards Act (FSLA) requirements:

– IEP documentation of work-based learning goals– Written training agreement/plan (See CBVT

Agreement)– Ongoing evaluation (attendance records, progress

reports)(Handouts F & G)

Work Experience

• Work Experiences are paid activities in the community.

• Work Experience is governed by applicable Labor and Child Labor Regulations and requires documentation.

Student Documents Needed for Work Experience

– All documents listed for CBVT plus these forms:• (WH-14) Work permit• (W-4) Wage Tax Withholding• (I-9) Immigration and Naturalization• Permission for Release of Information

Student Documents Needed for Work Experience (continued)

• Fair Labor Standards Act (FSLA) requirements:– IEP documentation of goals– Written training agreement (See Work Experience

Agreement)– Written employer evaluation (See Handout G)

School Documents Needed for Work Experience (continued)

• Work Experience and Career Exploration Program (WECEP) Certificate---WECEP is secured by the Pennsylvania Department of Education (PDE). One certificate covers all LEAs in the Commonwealth.

The IEP and Work–Based Learning Activities

What parts of the IEP apply?• Transition Planning

– Desired Post-School Goals (Employment)

• Present Levels of Academic Achievement and Functional Performance

• Course(s) of Study; Activities; and Services• Goals/Benchmarks

There are five important federal laws that protect individuals with disabilities from discrimination in employment and the job application process:

Legislation Impacting Employment

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The Rehabilitation Act (Employment)

The Rehabilitation Act authorizes funding for various disability-related purposes and activities:

◊ Vocational Rehabilitation◊ Centers for Independent Living◊ Rehabilitation Research◊ 3 Sections that Prohibit Discrimination

• Federal agencies, includes those who receive federal contracts and/or financial aid.

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Americans with Disabilities Act (Employment)

The Americans with Disabilities Act (ADA) prohibits discrimination against people with disabilities and guarantees equal opportunities for individuals with disabilities in:

Employment

Transportation

Public accommodations

State and local government services, and

Telecommunications.

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What is a Person’s Rights under the Employment Provisions of the ADA?

The ADA makes it unlawful to discriminate in all employment practices such as: recruitment firing hiring training job assignments promotions

pay benefits lay off leave all other

employment related activities

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What Does the ADA Require an Employer to Do?

Employers covered by the ADA have to make sure that people with disabilities: have an equal opportunity to apply for jobs and to

work in jobs for which they are qualified; have an equal opportunity to be promoted once

they are working; have equal access to benefits and privileges of

employment that are offered to other employees, such as employer-provided health insurance or training; and

are not harassed because of their disability.

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ADA: Leveling the Playing Field (Employment)

Reasonable accommodations are intended to ensure that qualified individuals with disabilities have rights in employment equal—not superior—to those of individuals without disabilities. 6

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Under the ADA, employers must give people with disabilities special privileges, known as accommodations.

Roles & Responsibilities of an Employer

The purpose of the ADA is to level the playing field, NOT to provide special privileges or charity.

Ensure there is NO job discrimination.

Identify ESSENTIAL FUNCTIONS OF THE JOB.

It is NOT the responsibility of the employer to discuss the person’s disability. It is the person’s responsibility to request accommodations to meet the essential functions of the job.

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How Do You Know if a Person is Protected by the ADA? (Employment)

The first part of the definition makes clear that the ADA applies to persons who have impairments and that these must substantially limit major life activities.

An individual with epilepsy, paralysis, HIV infection, AIDS, a substantial hearing or visual impairment, mental retardation, or a specific learning disability is covered, but an individual with a minor, non-chronic condition of short duration, such as a sprain, broken limb, or the flu, generally would not be covered.

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The ADA Only Protects a Person Who is Qualified for the Job s/he Has or

Wants

The individual with a disability must meet job-related requirements (for example, education, training, or skills requirements).

S/he must be able to perform the job's essential functions (i.e., its fundamental duties) with or without a reasonable accommodation.

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What is a “Reasonable Accommodations” under the

Employment Provisions of the ADA?

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What is a “Reasonable Accommodations” under the Employment Provisions of the

ADA?

In general, an accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities.

Under the ADA, employers are required to provide "reasonable" accommodations for employees with disabilities. Therefore, you can request any accommodation that is considered "reasonable."

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Test of Reasonableness under the ADA

An employer is required to make a reasonable accommodation to the known disability of a

qualified applicant or employee if it would not impose an "undue hardship" on the operation of

the employer's business.

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When Does a Reasonable Accommodation Become An Undue Hardship?

Undue hardship is defined as an action requiring significant difficulty or expense when considered in light of factors such as an employer's size, financial resources, and the nature and structure of its operation. Undue hardship means that an accommodation would be unduly costly, extensive, substantial or disruptive, or would fundamentally alter the nature or operation of the business.

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An employer is not required to lower quality or production standards

to make an accommodation; nor is

an employer obligated to provide personal use

items such as glasses or hearing

Questions to Consider in Determining Employment

Accommodations

In seeking the answers to accommodation questions, it is essential to obtain input from the individual with the disability to achieve a

successful accommodation outcome. The following questions may be helpful during

the accommodation process:

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Questions to Consider1. What symptoms or limitations is the individual

experiencing?

2. How do the individual's symptoms or limitations affect job performance?

3. What specific job tasks are problematic as a result of these symptoms and limitations?

4. What accommodations are available to reduce or eliminate these problems?

5. Are appropriate resources being used to determine accommodations?

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Questions to Consider

6. Has the individual been consulted regarding possible accommodations?

7. Once accommodations are in place, would it be useful to meet with the individual to evaluate the effectiveness of the accommodations and determine whether additional accommodations are needed?

8. Do supervisory personnel and employees need disability awareness training or training on the Americans with Disabilities Act?

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Tools to Determine Employment Accommodations

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Requesting an Employment Accommodation requires Disability Disclosure

In order to request an accommodation, a person must disclosure his/her disability. This requires self-advocacy skills.

To Disclose or Not to Disclose …

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Why to Disclose:

• Obtain information on career plans• Disability-specific employment services• Employment requirements• Job requirements

– With or without accommodations– Supports available

• Mentoring and peer support

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What and When to Disclose

• When a person makes a disclosure about his disability, what is most important and helpful is to provide information about:

– How his disability affects his capacity to learn and perform effectively, and

– The environment, supports, and services he’ll need in order to access, participate in, and excel in his job.

• The individual must decide what and how much of this sensitive information is necessary to reveal in order to obtain the needed accommodations.

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What to Disclose:• Here is some information a person with a disability may choose to

present to his employer, supervisor, work mentor, or co-workers:– General information about his disability;– Why he’s chosen to disclose his disability, including its impact on his job

performance; – The types of job accommodations that have worked for him in the past (in

school, previous jobs and in training situations);– The types of job accommodations he anticipates needing in the

workplace; and – How his disability and other life experiences can positively affect his work

performance.

• Most importantly, keep the disclosure conversation focused on the person’s abilities, not his disability.

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To Whom to Disclose InformationA job seeker with a disability might disclose

information to the following individuals:– Career counselors– Disability-specific adult employment services

personnel– One-Stop Career Center personnel– Prospective employers or human resources

personnel– Workplace mentors

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Disclosure Rights of An Individual:

• Have information about his disability treated confidentially and respectfully.

• Seek information about hiring practices from any organization.

• Choose to disclose his disability at any time during the employment process.

• Receive appropriate accommodations in an interview so he may demonstrate his skills and abilities.

• Be considered for a position based on his skill and merit.

• Have respectful questioning about his disability for the purpose of reasonable accommodation.

• Be self-determined and proactive. 86

Disclosure Responsibilities of An Individual:

• Disclose her need for accommodation(s) If she desires any work-related adjustments.

• Search for jobs that address her skills and abilities.• Inform the manager or interview panel about her need for

appropriate interview accommodations in a timely manner.

• Identify appropriate and reasonable accommodations for an interview.

• Negotiate reasonable accommodation(s) with an employer at the point of job offer and beyond.

• Be truthful, self-determined, and proactive.

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Requesting an Employment Accommodation

The ADA does not include specific guidelines or forms for requesting reasonable accommodation. When may accommodations be requested:

The process for formally requesting the accommodation may be determined by the employer. Some employers have developed in-house forms. Otherwise, individuals with disabilities can use any method that is effective; the ADA does not require specific language or format.

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Sample Employment Accommodation Request Letter

Content to consider in body of letter: Identify yourself as a person with a disability

State that you are requesting accommodations under the ADA (or the Rehabilitation Act of 1973 if you are a federal employee)

Identify your specific problematic job tasks

Identify your accommodation ideas

Request your employer's accommodation ideas

Refer to attached medical documentation if appropriate*

Ask that your employer respond to your request in a reasonable amount of time

Source: Job Accommodation Network

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What Accommodations can be Requested?

Here are some examples of reasonable accommodations from the EEOC:

making existing facilities accessible job restructuring part-time or modified work schedules acquiring or modifying equipment changing tests, training materials, or policies providing qualified readers or interpreters reassignment to a vacant position medical leave work from home

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Examples of what are NOT Accommodations

Removing or eliminating an essential function from a job.

Lowering production standards.

Providing personal use items such as a prosthetic limb, a wheelchair, eyeglasses, hearing aids, or similar devices if they are also needed off the job.

Note: While employers are not required to eliminate an essential function, lower a production standard, or provide personal use items, they can do so if they wish.

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Resources to Assist with Employment:

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Accommodations:

Job Accommodations Network: www.jan.wvu.edu

The Family Center on Technology and Disability - www.fctd.info Employment, Career Interest and Occupational Information:

National Collaborative on Workforce and Disability: http://www.ncwd-youth.info

Career One Stop: http://www.careeronestop.org

PA Career Zone: www.pacareerzone.org

Keeping it Legal 1 Fair Labor Standards Act, Work Based Learning Guidelines and the ADA: Increasing...

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