Competitive Integrated Employment
"Competitive integrated employment refers to jobs held by people with disabilities in workplaces where the majority of employees do not have disabilities; where they earn wages consistent with those earned by workers without disabilities performing the same or similar work; where they make at least minimum wage; and where they are paid directly by their employer rather than through a human service agency."
-Secretary Tom Perez, 2015, Ensuring Opportunity Extends to All
The Workforce Innovation and Opportunity Act (WIOA), signed into law by President Obama in 2014, makes significant improvements in federal law for Americans with disabilities by helping to ensure that all people have opportunities to acquire the skills and training needed to maximize their potential and enter competitive integrated employment.
WIOA further defines Competitive Integrated Work as work performed on a full or part-time basis (including self-employment) for which an individual is:
1. Compensated at not less than federal minimum wage requirements or state or local minimum wage law (whichever is higher) and not less than the customary rate paid by the employer for the same or similar work performed by other individuals without disabilities;
2. At a location where the employee interacts with other persons who do not have disabilities (not including supervisory personnel or individuals who are providing services to such employee) to the same extent that individuals who do not have disabilities and who are in comparable positions interact with other persons; and
3. Presented, as appropriate, with opportunities for advancement that are similar to those offered other employees who are not individuals with disabilities and who have similar positions.
For people with developmental or other significant disabilities, center-based employment, also called sheltered workshops, have long been used as a place to provide “prevocational” services for people deemed as either unemployable in competitive integrated employment, or as “needing training” to prepare them for eventual work in their communities. However, center-based employment has been shown to rarely result in competitive integrated employment, and most participants in center-based employment are paid substantially below minimum wage, as is currently allowed under Section 14(c) of the FLSA (PL 75-718).7 Currently, an estimated 228,600 people with I/DD and other significant disabilities are being paid subminimum wage under certificates issued by the U.S. Department of Labor (DOL) Wage and Hour Division. 1
Beyond “Place then Train”
Dale Deleo noted the evolution of human service employment models for people with disabilities in his article Moving Beyond Place Then Train (2014). When supported employment first challenged the practice of sheltered workhops over 25 years ago, it represented a shift in thinking, from Train and Place to its opposite -- Place, then Train. The traditional model of training people in congregated workshops with the hope that they would someday be ready for employment wasn’t working – too many people never actually got jobs, and people with disabilities were segregated from rather than integrated with other employees in the workplace.
This was replaced by the supported employment movement, Place then Train, in which job developers searched for any available job opening, placed job seekers in the job, and then used onsite job coaches to shadow and train for all expected tasks. “This approach is not only over-simplified, it causes poor quality work outcomes. While getting any job was an improvement over a life of segregated work, it still too often missed the mark for good wages, social inclusion, longevity, and personal satisfaction.”
The approach highlighted by Deleo in the above graphic– Plan, Match, Support – describes in part the one used by the Polus Center, as advocated by WIOA and the foundation of the Disabilities Employment Initiative: match an individual’s skills, interests, and work aspirations with critical job openings that lead to career pathways and opportunities. This happens through:
• Ongoing networking and employer engagement to identify critical talent needs and hard-to-fill positions, and establishing relationships with employers who welcome the potential of a qualified talent pool.
• Typical career planning processes and vocational assessments used by Career Centers and Human Resource professionals for all employees to help individuals identify their chosen career paths that align with critical local job opportunities.
• If needed, provide support for candidates to get credentials that will qualify them for those positions, through established relationships with existing career pathway programs at community colleges and industry recognized training programs.
• If necessary, address any additional barriers such as transportation or accommodation needs through cross-agency partnerships and alignment with critical services in the local area.
• Offer training and guidance to employers and co-workers to help them understand the value and approaches to diversifying their workplace.
“Match and Support takes the place of Placement and Training. Placement implies something we do to people, rather than assisting workers with disabilities to be hired successfully. Matching is a more facilitative approach.
Like a good headhunter or dating service, you want to bring together people and workplaces where there is a good fit, then help make the magic happen by negotiating a Job Match. This includes job analysis, customization of tasks, and helping arrange accommodations and other needs.
Once a job has been brokered, workplace Support and training strategies focuses on natural supports and building co-worker relationships to facilitate learning and assistance from within the work environment…..Place and Train too often turns into “Place and Pray,” which is no way to ensure high rates of job success.” - Moving Beyond Place Then Train, January 29, 2014, www.daledeleo.com.
1 From the Disabilities Employment Initiative website, htpps://dei.workforcegps.org and the U.S. Department of Labor’s Wage and Hour Division Presentation to the Committee, January 22, 2015. “The total number of individuals working on section 14(c) is not specifically tracked. The number provided is an estimate based on the number of workers with disabilities who were paid subminimum wages by the certificate holder during their most recently completed fiscal year, as reported during the certificate application process.”