Protecting Employment For Individuals With Intellectual And Developmental Disabilities (Coalition White Paper)

Today’s commensurate wage work center programs for individuals with intellectual and developmental disabilities (I/DD) are provided in a safe, supportive, and positive educational and workplace setting, meeting strict licensing standards. Individuals receiving this service have cognitive or psychiatric/behavioral, as well as sometimes physical, disabilities that require extensive accommodations and supports, and often direct and continuous supervision by their professional workplace teams, for them to achieve their vocational and daily living goals in a safe and welcoming environment. Ultimately, commensurate wage work center programs are precisely what ensure that individuals with I/DD have a greater opportunity for employment with the accommodations and supports they need to thrive in the workplace.

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Coalition Outcome Updates

7/1/23 – Congressional Meetings:

In the first half of 2023, the Coalition continues its bipartisan, bicameral advocacy efforts, educating members of Congress and their offices about the importance of 14(c) and potential consequences of phasing out commensurate wage programs. So far this year, the Coalition has met with approximately 40 Congressional offices.

6/27/23 – Meeting with House Education & Workforce Committee Chair:

The Coalition meets with House Education & Workforce Committee Chair, Virginia Foxx, and brings her on a tour of a supported employment facility in her North Carolina district, where she meets constuents served by these programs.

6/6/23 – Press Conference:

The Coalition holds a Press Conference in Harrisburg, PA, facilitated by Coalition President, Colleen Stuart and supported by K&L Gates.

5/12/23 – Meeting with US Department of Labor, Wage & Hour Division:

The Coalition meets with representatives from the U.S. Department of Labor Wage and Hour Division to discuss the recent Government Accountability Office (GAO) Report and provide feedback regarding decreasing the amount of time to process 14(c) certificates. Much discussion ensues regarding the shift of the segments of the disabilty population served by 14(c) programs, from primarily blind or deaf individuals to over 80% people with intellectual and/or developmental disabilties.

4/17/23 – Meeting with the Government Accountability Office (GAO):

The Coalition meets with representatives from the GAO to discuss its February 2023 report on excessive processing time for 14(c) certificates, along with the information currently needed for an upcoming report to assess the impact on individuals with disabilities of phasing out 14(c) programs at the state level.

4/6/2023 – Guest Speaker:

The Coalition hosts Rep. Glenn Grothman to discuss his recent legislative proposals that would strengthen work opportunities for individuals with disabilities, including the Restoration of Employment Choice for Adults with Disabilities Act (H.R.1296) and Workplace Choice and Flexibility for Individuals with Disabilities Act (H.R.553).

2/24/2023 – Correspondence with the Government Accountability Office (GAO):

Following its 2022 meetings with the Coalition, the GAO issues a report entitled, “Subminimum Wage Program: DOL Could Do More to Ensure Timely Oversight” (GAO-23-105116). The Coalition corresponds with the GAO regarding the report and offers to serve as a resource on issues impacting 14(c).

1/6/23 – Educational effort targeting new Congress Members:

At the start of the 118th Congress, the Coalition sends letters to new members of Congress, introducing them to the Coalition and the 14(c) provision, inviting them to meetings, and asking them to refrain from co-sponsoring legislation phasing out commensurate wage programs.

11/15/22 – Meeting with Rehabilitation Services Adminstration (RSA) and US Department of Education:

The Coalition meets with Carol Dobak, Commissioner of the RSA, and Katherine Neas, Deputy Assistant Secretary in the Office of Special Education and Rehabilitative Services, at the United States Department of Education to discuss 14(c) and Section 511 obligations.

10/7/22 – Establish Dues Structure:

In order for the Coalition to continue its advocacy efforts, the membership has been asked to provide financial support by contributing dues as an individual/family membership or organizational membership starting in January of 2023. These dues provide a national coalition with a voice in Washington, the expertise of K&L Gates law firm, and the networking advantages of a group focused on the specific issues faced by the I/DD population who are unable to speak for themselves.

8/18/22 – Guest Speaker:

Devon Westhill, president and general counsel of the Center for Employment Opportunities (CEO), a civil rights advocacy organization, visits with the Coalition and discusses, among other recommendations, the importance of having data to promote advocacy efforts. Mr. Westhill was formerly the civil rights official for the US Department of Agriculture and also worked in the US Department of Labor.

8/18/22 – Coalition Meeting with Wage & Hour Division (WHD) of the US Department of Labor:

K&L Gates coordinates a discussion with Coalition Board members and leaders of the WHD), including Acting Administrator Jessica Looman, to provide feedback regarding WHD’s recent WIOA/Section 511 guidance and to request WHD’s help in ensuring that state Vocational Rehabilitation agencies timely and correctly fulfill their responsibilities under WIOA/Section 511.

6/22 – Meeting with the House Education & Labor Committee:

Coalition Board Members meet with Phoebe Ball, Disability Counsel for the House Education and Labor Committee. The visit includes a productive conversation regarding future directions for 14(c) programs.

6/2022 – Guest Speaker:

US Equal Employment Opportunity Commission (EEOC) Commissioner, Keith Sonderling, was invited to speak to the Coalition.

5/17/22 – Meeting with the US Government Accountability Office (GAO):

K&L Gates coordinates a discussion with GAO and Coalition Board Members to discuss the current GAO 14(c) Study.

4/28/22 – Strategy Work:

The Coalition continues to advocate for the 14(c) commensurate wage program and to have a seat at the table at the Federal level, as decisions are made about the future of the program. The Coalition also begins developing strategies and consensus around other critical issues including Workforce Innovation & Opportunity Act (WIOA), Competitive Integrated Employment (CIE), the Ability One program, and other issues of importance to Coalition members.

4/18/2022 – Meeting with the Office of Disability Employment Policy (ODEP):

K&L Gates facilitates a meeting with the Coalition Board of Directors and ODEP, Wage & Hour (Department of Labor) to discuss the value and future of 14(c) programs.

3/23/2022 – Adoption of “The Coalition for the Preservation of Employment Choice” name:

Coalition members and Board of Directors recognized the call for a name change to more clearly represent the goals of the Coalition.

3/2022 – Connections to other Advocy Groups & Agencies:

Across the country, a series of connections linking Coalition members is becomes increasingly apparent as members discuss issues related to 14(c) and comparing the vocational services provided in various states.

3/2022 – Congressional Meetings:

Coalition members meet and discuss the 14(c) program with over 100 congress members and/or their staff during the 2021-22 legislative session, facilitated and coordinated through K&L Gates Congressional Outreach.

3/1/2022 – Coalition Membership:

The Coalition grows to include representatives from 22 States and more than 80 individuals. The group continued meeting every Thursday until 2023, when they switched to meeting on alternate Thursdays (twice a month).

2/6/2022 – Educational Focus:

The Coalition begins meeting with and educating congressional committee members, federal agency leaders, and policy makers, focusing on educating them on the value of 14c programs.

2/1/2022 – Coalition Position Paper:

The Coalition develops a White Paper to educate congressional members and their staff on their position, which values employment choice to meet the needs of a full array of abilities and preferences, including the 14c program. The K&L Gates law firm provides support, guidance, and leadership.

6/2021 – Organizational Development:

A Board of Directors, including agency providers and family members of people with I/DD (Intellectual and/or Developmental Disabilities), is formed. K&L Gates law firm is hired to coordinate and facilitate congressional outreach and meetings with Federal policy makers.

5/4/2021 – Incorporation of the “Coalition for the Preservation of 14c, Inc.”:

The nonprofit group forms with the purpose of developing a coalition of organizations that believe in the value of giving individuals with significant disabilities a full range of employment choices. *The name of the nonprofit was officially changed in July of 2023.