Action Recommended: WIOA Requirements and Career Counseling and Information and Referral Services Update
INARF continues to advocate for additional clarification concerning the requirements of the Indiana Bureau of Rehabilitative Services and employers under WIOA. INARF recommends that all employers send a list of the names and hire dates of individuals employed at sub-minimum wage to your local VR office as soon as possible to assure that BRS is made aware of all individuals employed at sub-minimum wage in Indiana and to ensure that these individuals receive the required Career Counseling and Information and Referral (CCIR) services within the required time frames.
We expect additional information and clarification concerning BRS' plan for providing CCIR services to be announced later this week. For your review and reference, below is information sent by Theresa Koleszar, Director, Bureau of Rehabilitation Services, to an INARF member who inquired on the status of WIOA required career counseling for those entering workshops after 7-22-16.
"Thank you for reaching out to us regarding the required Career Counseling and Information and Referral (CCIR) services for individuals employed at sub-minimum wage. VR staff in your area will be reaching out to you in the next week or so to coordinate a CCIR session at your facility. Before the end of January, our objective is to hold a session at each facility that has employees that began working at sub-minimum wage on or after July 22, 2016. If you are not contacted in the next week or so, please let me know and I will follow up directly with the local staff. A memo will be coming out next week with more information. Please let me know if you have additional questions at this time."
Additional information on the US Department of Labor Wage and Hour Division's guidance regarding WIOA Limitations on Payment of Subminimum Wages under FLSA Section 14(c) is available here.
We hope this information is helpful. If you need additional information, please contact the INARF office.