Real Work = Real Pay ( APSE.org.) Two Opinions on DOL's 14 (c)
1. Spending my day analyzing comments from DOL's 14(c) online dialogue. Wanted to share one particularly poignant comment from a parent:
"My daughter has Down syndrome and her work is and will be valuable and important. As her mother, it's only natural for me to look at how little value our society places on people with intellectual disabilities and to simply accept crumbs and lull myself into thinking that I'm doing something good for my child and others like her, but I refuse to let my fears confine and limit her and her peers' lives and worth.
It is time to completely get rid of an antiquated legal remnant the purpose of which has long ago expired and that has evolved into a
permission to exploit and refuse to invest in our most vulnerable citizens. We know from extensive experience and studies that no one 'needs' to be paid a pittance for their work, not for the quality of their work nor for the availability of work. It is a sham to act as if the current debate is between work at a subminimum wage or no work at all. That's a false dichotomy and only serves to carry on the current disservice and stoke our fears.
People with disabilities deserve more from us."
2. I posted this a few minutes ago on all 3 of the boards (I couldn't decide which one it best fit so better all, right?):
"On behalf of the Maine Chapter of APSE, we write to share that the use of 14C certificates (subminimum wage) has no place in the array of employment services or supports available to people with disabilities. It is a practice that is no longer viable as we’ve learned how to customize employment and enhance our use of technology as support in the workplace. Everyone can work and the payment of wages must be comparable to all other workers.
As of May 1, 2019 Maine can proudly say that there are no subminimum wage certificates in use in Maine—all people with disabilities are paid at or above the minimum wage, which in Maine is now $11.00 per hour. Like the closures of institutions remove a state’s option to warehouse people, the elimination of the use of subminimum wage removes the option to discriminate and exploit people with disabilities in the workplace.
We believe our years-long commitment to Employment First, workforce development, interagency collaboration, employer engagement and competitive, integrated employment have contributed to this success and many others. Maine APSE looks forward to further collaboration with stakeholders and all interested parties to continue our state’s and nation’s progression toward equal work and equal pay in an inclusive workforce – to advance employment equity for people with disabilities."
Once 14(c) is eliminated and Employment First is fully implimented Kansas Rehabilitation Services (KRS) will see a significant increase in referrals. KRS must be ready to provide capable oversight of employment services and mandate competent (certified) individual providers. There is currently some discussion of a fee differential for certified employment services providers but this not enough. ALL individual service providers should eventually be certified and under-performing providers should be assisted or lose their public funding. Employers evaluate the performance of their employees and KRS must evaluate the performance of their providers. And the Employment First Oversight Commission must evaluate the performance of KRS.
-by Joe Scarlett, MS, CRC/CESP (RET.), APSE Public Policy Liaison