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Work-based learning experiences

Pre-ETS Notice

This part of the website has been updated to reflect the Notice of Interpretation in the Federal Register.

Work-Based Learning Experiences (WBLEs)

(WBLEs may include in-school or after school opportunities, or experience outside the traditional school setting (including internships), that is provided in an integrated environment to the maximum extent possible)
Work Based Learning1 is an educational approach or instructional methodology that uses the workplace or real work to provide students with the knowledge and skills that will help them connect school experiences to real-life work activities and future career opportunities. It is essential that direct employer or community involvement be a component of the WBL to ensure in-depth student engagement. These opportunities are meant to engage, motivate and augment the learning process. These WBL opportunities can be done in conjunction with private, for-profit, public or nonprofit businesses in your community and/or through web-based resources. In addition, work-based learning requires in-depth engagement of youth and an evaluation of acquired work relevant skills.

Work-based learning experiences, may include:

These WBL opportunities can be done in conjunction with private, for-profit, public or nonprofit businesses in your community and/or through web-based resources. In addition, work-based learning requires in-depth engagement of youth with oversight and evaluation of acquired work relevant skills by identified staff. The work based learning experience must be provided in an integrated setting in the community. Where paid WBL experiences are provided, the wages are to be paid at no less than minimum wage.


  • Job Shadowing: Job shadowing is a popular on-the-job learning, career development, and leadership development intervention. Essentially, job shadowing involves working with another employee who might have a different job in hand, might have something to teach, or can help the person shadowing him or her to learn new aspects related to the job, organization, certain behaviors or competencies2.
  • Career Mentorship: A mentor is one who teaches or provides guidance and advice to a less experienced and often younger person3.
  • Career Related Competitions: Career-related student competitions are work-based learning activities that require students to demonstrate mastery of career-related skills through presentations or competitions that are judged by professionals. Presentations demonstrate culminations of student effort over time, often involving teamwork. Career technical student organizations sponsor such competitions in the fields of agriculture, business, health, hospitality and industrial technology.
  • Informational Interviews: An informational interview is an informal conversation with someone working in a career area/job that interests you, who will give you information and advice. It is an effective research tool in addition to reading books, exploring the Internet and examining job descriptions. It is not a job interview, and the objective is not to find job openings4.
  • Volunteering: Volunteering is when a person donates his/her time or efforts for a cause or organization without being paid. It may be a one-time only or an on-going commitment. It should directly or indirectly benefit people outside the family or household or else benefit a cause, even though the person volunteering normally benefits as well. Most volunteer sites are non-profit organizations.
  • Workplace Tours/ Field Trips: A group excursion for the purpose of first-hand observation to specific work sites. Students learn about the business, meet employees, ask questions and observe work in progress5.
  • Internships (Paid Or UnPaid): An internship is a temporary position with an emphasis on on-the-job training rather than merely employment, and it can be paid or unpaid. An internship is an opportunity to develop specific job related skills before you are qualified for an actual job.
    The Department of Labor's website offers guidance and information on their "employment laws assistance for workers and small business - elaws section on volunteers. The following link provides helpful information on the Fair Labor Standards Act as it pertains to volunteers: Internships in the “for-profit” private sector will most often be viewed as employment, unless the test described below relating to trainees is met. Interns in the "for-profit" private sector who qualify as employees rather than trainees typically must be paid at least the minimum wage and overtime compensation for hours worked over forty in a workweek.

The following six criteria must be applied when making this determination6:

  1. The internship, even though it includes actual operation of the facilities of the employer, is similar to training which would be given in an educational environment;
  2. The internship experience is for the benefit of the intern;
  3. The intern does not displace regular employees, but works under close supervision of existing staff;
  4. The employer that provides the training derives no immediate advantage from the activities of the intern; and on occasion its operations may actually be impeded;
  5. The intern is not necessarily entitled to a job at the conclusion of the internship;
  6. The employer and the intern understand that the intern is not entitled to wages for the time spent in the internship.

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DOL's Time Limits on Internships and work exploration activities:

The Department of Labor has identified the following time limits specific to internships/
work experiences to ensure an employee relationship does not exist:

Career Exploration (limited to 5 hours/job) - a brief exposure to a variety of work settings and may include work site field trips or job shadowing to view the type of work being performed.
Career Assessment (limited to 90 hours/job) - an extended observation where the student undertakes work assignments for the purpose of assessing his/her interests, aptitudes, and support needs.
Work-Related Training (limited to 120 hours/job) - a period of work experience for the purpose of training job skills and job-related skills.

If all of the factors listed above are met, an employment relationship does not exist under the FLSA, and the Act’s minimum wage and overtime provisions do not apply to the intern. This exclusion from the definition of employment is necessarily quite narrow because the FLSA’s definition of "employ" is very broad.

The following link to the DOL website provides helpful information on the Fair Labor Standards Act as it pertains to the school to work designation which can be helfpul in determining whether or not a work based learning experience falls within this category:

eLaws - Fair Labor Standards Act Advisor : School-to-Work

The Wage and Hour Division (WHD)7 Exceptions for Volunteering/Unpaid Internships
WHD also recognizes an exception for individuals who volunteer their time, freely and without anticipation of compensation for religious, charitable, civic, or humanitarian purposes to non-profit organizations. Unpaid internships in the public sector and for non-profit charitable organizations, where the intern volunteers without expectation of compensation, are generally permissible. WHD is reviewing the need for additional guidance on internships in the public and nonprofit sectors.

Such permissible opportunities may include:

  • Practicum: a course of study devoted to practical training in the field, where supervision is provided. Usually applies to a specialized field of study.
  • Service learning: work-based learning activity that integrates meaningful community service with classroom instruction and reflection to enrich the learning experience, teach civic responsibility, and strengthen communities8.
  • Student Led Enterprises:  school based enterprises that produce goods or services   for sale or to be used by people other than the participating student(s).
  • Simulated Workplace Experience: Simulated workplace experiences are work-based learning activities that simulate work environments in any field. Examples include automotive or construction programs in which sustained industry involvement allows students to develop and apply their skills in the context of industry standards and expectations.
  • Work Experience ( Paid or Non-Paid): work experience offers students the opportunity to explore careers and understand the nature of work through first-hand exposure to the workplace. Students may or may not be paid.

    • Paid Work Experience can be general or vocational, focusing respectively on general workplace skills or career preparation activities within a specific industry or career area.
    • Non-Paid Work Experience is exploratory in nature and its intent is to expose an individual to a variety of occupations for the purpose of building basic workplace competence.

Section 511-Limits Use of Sub-Minimum Wage

Note: Section 511 of WIOA Title IV limits the use of sub-minimum wage. Individuals age 24 or younger may not begin work paying subminimum wage (less than Federal minimum wage) unless the following actions have been completed:

  • The individual received pre-employment transition services or transition services  under IDEA (and)
  • The individual applied for VR services and has been found ineligible for services (or)
  • The individual has been determined eligible for VR services but has not been successful /achieved Competitive Integrated Employment and client record of services closed.
  • The individual has been provided career counseling and information and referral to other resources designed to assist the person in attaining competitive integrated employment. For more complete detail on Section 511 of WIOA Title IV, see Laws, Regs, and Policy

For some specific resources for this required activity click here.

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