Arc Guide to Workforce Innovation and Opportunity Act (WIOA) for People Age 24 and Under

Background on the Workforce Innovation and Opportunity Act (WIOA)

WIOA is a 2014 federal law. WIOA is a law for job programs across the country. The law is to provide job seekers access to:

  • Employment
  • Education
  • Training
  • Support services


People with Disabilities

Some parts of WIOA impact people with disabilities. WIOA is to ensure people with disabilities have the support to look for work in the community. The goal is to make at least minimum wage and work with people without disabilities.


Pre-Employment Transition Services

Vocational Rehabilitation Services (VRS) works with schools to provide Pre- Employment Transition Services (Pre-ETS). This is for students age 14 through age 21 who have a disability. Your Individualized Education Plan (IEP) team determines your Pre-ETS needs.

Each school has a VRS counselor. Your teacher can connect you to them to start Pre-ETS activities. If you need these services, Pre-ETS will help you identify jobs that interest you. There are five required Pre-ETS activities:

  • Job exploration and counseling
  • Work-based learning experiences
  • Postsecondary education counseling
  • Workplace readiness training
  • Training in self-advocacy


Section 511: Limits on the Use of Subminimum Wage

In 2016, WIOA placed limits on the use of subminimum wage. Subminimum wages are less than the federal minimum wage. Many jobs at center-based programs pay subminimum wages. Some community-based group employment, such as work crews or enclaves, pay subminimum wages.

If you are under age 25, you can still choose a job that pays subminimum wage. Before starting a subminimum wage job you must:

  • Complete Pre-ETS while still eligible for special education services
  • Apply for VRS. If you refuse to apply for VRS, you will be ineligible for subminimum wage employment
    To qualify for a job that pays subminimum wage, you must be either:
    • Ineligible for VRS
    • Eligible but were not successful in a job in the community
  • Receive career counseling, information, and referral to other agencies that could help you get a community job if VRS has closed your file.
  • Starting in 2021, Pre-Vocational Services will be limited to 3 years. Participants must also receive employment service and/or a day support service.

If you are under age 25 and started working in a subminimum wage job before July 22, 2016, you:

  • Must meet with a career counselor.
    The counselor provides information and referral services twice in the first year. This is the informed choice process. After the 1st year, this meeting is once a year.
  • May refuse counseling and information and referral services.
    Then you cannot have a subminimum wage job.


What does this mean for me?

You must make an informed choice about the type of job you want.

An informed choice means you can explore and understand your:

  • Benefits
  • Options
  • Resources
  • Potential risks
  • Ways to get past barriers



Vocational Rehabilitation Services Information on WIOA, Section 511
Minnesota Department of Employment and Economic Development- Vocational Rehabilitation Services information on WIOA
Minnesota Department of Human Services information on WIOA


For further information or advocacy services, contact The Arc Minnesota at 833-450-1494 or visit www.arcminnesota.org.(Please note: This document is not legal advice. No information should replace the advice of an attorney.)

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