WIA TITLE I-B PROGRAM MANAGEMENT POLICIES AND PROCEDURES
Memorandum #04-06

To:   All WIA Title I-B Youth Program Subrecipients

Subject:   Youth Work Experiences

Effective Date:  April 1, 2005

A.    POLICY

  1.   Definition and Purpose

The Workforce Investment Act (WIA) allows for the provision of work experience activities for an eligible participant in need of world of work experience to achieve the goals of her/hisIndividual Service Strategy. The term "work experience" means any planned, structured work-based learning experience that takes place in a workplace for a limited period of time.

Work experiences may be full or part-time and must be in compliance with OSHA/WISHA laws and regulations regarding the employment of minors. Work experiences may be in the public sector, the private non-profit sector, or the private for profit sector.

There are a range of allowable work experiences including worksite tours, job shadows, unpaid work experiences and paid work experiences. The type(s) of work experience in which a given participant is engaged should be developmentally appropriate given her/his age, career awareness, and related experiences.

Work experiences are to be designed to promote the development of good work habits and basic work skills for youth who have never worked, have very limited exposure to the world of work, or who have been out of the labor force for an extended period of time.

Participation in a work experience activity shall be for a reasonable length of time, based on the needs of the participant as documented in her/his Individual Service Strategy.

Work experiences shall be accompanied, either concurrently or sequentially, by other services designed to increase the basic education and/or occupational skills of the participant, as documented in the Individual Service Strategy.

  2.   Minimum Requirements

•  Participation in an approved educational program shall be a prerequisite to participation in a paid work experience for any youth under the age of 18 who is a school dropout.

•  Paid experiences may be provided only in instances where the youth is making satisfactory academic progress, as defined by the school.

•  The youth must have identified a career pathway of interest to participate in a paid work experience.

•  Summer work experiences must be combined with educational and appropriate occupational activities.

  3.   Compensation

In conformance with the Fair Labor Standards Act, a participant shall be enrolled in a paid work experience when s/he is performing work which contributes to the productivity of the agency or business hosting the work experience. In such instances, the participant shall be paid an hourly wage at the same rates as similarly situated employees or trainees, but not less than the higher of the minimum wage prescribed under federal and state minimum wage laws.

Participants enrolled in one of the following classroom training activities, combined with a paid work experience, may receive the hourly work experience wages for such participation, provided the scheduled paid work experience time is more than 50% of the combined activities.

  4.   Work Experience Agreement

All work experiences must be documented on a given participant's Individual Service Strategy and in case notes. Additionally, a WorkSource Snohomish County Work Experience Agreement shall, provided in Attachment A, must be completed prior to the start of the work experience for any paid work experience and for any unpaid work experience of greater than eight hours in duration.

A single Work Experience Agreement may be written for group training with a single training site provided the working conditions, job description, training plan, wage rates, and term of the Agreement are the same for all participants covered by the Agreement.

  5.    Work Experience Placement Checklist

The WDC considers participant safety on the worksite to be of paramount importance. Therefore, a WorkSource Snohomish County Work Experience Placement Checklist, provided in Attachment B, must be completed for every work experience to document the site's compliance with all relevant OSHA/WISHA requirements prior to the start of the work experience.

  6.    Supervisor and Participant Handbooks

In every instance where a Work Experience Agreement is developed, the host site supervisor must be given a Supervisor Handbook and the participant must be given a Participant Handbook , to be developed by the subrecipient and approved by the WDC , that describes fair labor laws, minor work laws, the WDC 's complaint and grievance process, the process for documenting time and attendance and receiving payment, if applicable, and other relevant information.

  7.   Additional Subrecipient Responsibilities

It is the responsibility of the subrecipient to review and approve all Work Experience Agreements within established policies; to maintain a system of obligating and reobligating funds for paid work experiences; to maintain a time and attendance and wage payment system; to maintain a system for providing work experience participants with benefits which shall, at a minimum, include FICA and workers' compensation; to track all work experience wages and benefits expenditures by participant; and maintain documentation of eligibility for participation in a work experience. The Work Experience Agreement and associated documents, including time and attendance records, wage and benefit payment information, and all progress reports for a given participant are to be maintained in the participant file and subrecipient's fiscal system.

B.    PROCEDURES

The WorkSource Snohomish County Work Experience Agreement and Work Experience Placement Checklist are to be used to establish work experience assignments as described above. The Agreement format may be revised by the subrecipient with prior approval by the Snohomish County Workforce Development Council. A draft Supervisor Handbook and Participant Handbook are to be provided to the WDC for approval prior to dissemination to work experience host sites and participants.