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Career Counseling for Individuals in Subminimum Wage Employment

Section 511 of the federal Workforce Innovation and Opportunity Act (WIOA) places new requirements on Vocational Rehabilitation (VR) programs with regards to individuals with disabilities who are paid subminimum wage. This provision of the Act became effective on July 22, 2016 and requires Opportunities for Ohioans with Disabilities (OOD) to provide career counseling and information and referral services to individuals with disabilities who are employed at subminimum wage by an entity that holds a special wage certificate under Section 14 (c) of the Fair Labor Standards Act (FLSA).  WIOA also requires certificate holders to maintain documentation that individuals in subminimum wage employment have received career counseling, information and referral services from OOD every six months for the first year of employment and annually thereafter.  This documentation is provided by OOD.

OOD has dedicated staff to meet this requirement and ensure individuals with disabilities who are paid subminimum wage have access to career counseling, designed to promote opportunities for competitive integrated employment.  Topics covered include information on Employment First; places on the path to community employment; competitive integrative employment; supported employment services; work incentives and benefits; overview of OOD services, including application process; and explanation of individuals’ rights and informed choice. 

This document contains information regarding Employment First Taskforce Joint Guidance on Section 511. 

Learn more about Career Counseling Curriculum.

OOD Section 511 Summary Report

Further questions about career counseling for individuals in subminimum wage employment can be directed to Julie Hance at