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Work-Based Learning FAQ

General Questions

How does New York define work-based learning?

Work-based learning is authentic learning experiences that allow students to explore their career goals, abilities, and interests while applying their academic and technical knowledge and skills in a real-world context. These experiences are planned and supervised by instructional staff in collaboration with business, industry, or community partners.

How do I go about starting a work-based learning program?

A checklist has been developed by the Viva88Education Department which is designed to guide schools in many of the steps in developing a high-quality work-based learning program.

Do I need to have a work-based learning coordinator on staff?

An instructional staff member with a work-based learning extension is required to oversee New York’s registered work-based learning programs, or any experiences in which students are placed in sustained experiences outside of the school building, earn academic credit, or may meet the student learner exemption. Additional information and details of the extensions can be found in the Coordinator Certification section of this page. For unregistered experiences, while it is highly recommended that an individual with the work-based learning extension supervise those experiences, it is not required.

I am having trouble getting my student all of the work-based learning hours they need, is there any flexibility to use career awareness experiences such as guest speakers, career interest assessments, and industry tours as work-based learning?

If all hours cannot be met, then a school may, at their discretion allow for up to twenty hours of career awareness experiences to count as work-based learning. Full details on this flexibility as well as information on documenting such experiences can be found in our August 2022 memo.

What “counts” as work-based learning?

Any registered or unregistered experiences as defined in the work-based learning manual can count as work-based learning.

Where can I go to find additional information about work-based learning in New York?

The work-based learning manual is a reference which outlines New York’s policies and procedures for work-based learning.

Do employers have to provide accommodations to meet the needs of students with disabilities for work-based learning?

, a student with a disability shall be provided the special education specified on the student's IEP to be necessary to meet the student's unique needs. The work-based learning coordinator and special education teacher should work closely together to place students in settings that meet their needs and program goals.

Students should be provided information on disclosing their disability status to their employer. However, this is ultimately their own decision to disclose their disability and to request reasonable accommodations in a Memorandum of Agreement (MOA) that would permit the student to perform the essential tasks of the work-based learning placement. Additional information can be found on the . Please also see Question C15 of the CDOS Question and Answer Document.

If a student has health/nursing services as part of their individualized education program (IEP) or Section 504 Plan, do those same services need to be provided at a work-based learning placement taking place off site?

If a student is “in school” regardless of the location, the committee on special education (CSE) must determine if the IEP reflects all of the student’s special education needs including whether or not the student requires nursing services in every setting. The CSE determination as to whether a student needs school health services or school nurse services to receive a Free and Appropriate Public Education must be made on an individual basis. The types and amounts of services to be provided must be individually determined based on each student’s unique needs and documented within the student’s IEP, and the frequency and/or duration of services must be specific enough so that the extent to which health/nursing services will be provided is clear. For more information, please see Guidelines for Determining a Student with a Disability's Need for a One-to-One Nurse.

For questions regarding IEP implementation for students with disabilities at a work-based learning placement, please contact the Office of Special Education Policy Unit at speced@nysed.gov.

For assistance in meeting the health/nursing needs of students at school and school sponsored events, please contact the Office of Student Support Services at StudentSupportServices@nysed.gov.

Can performance events completed at CTSO competitions count as work-based learning hours?

A maximum of eight (8) work-based learning hours per high school career be allowable to count for purposes of the CDOS Commencement Credential using Option 1 or the 54-hour 5S3 program quality indicator for Perkins V. The following conditions shall apply:

  • This allowance is only applicable to New York’s six chartered CTSOs: DECA, FBLA, FCCLA, FFA, HOSA, and Skills USA.
  • The hours must be earned in grade 9 or above.
  • Hours may only be awarded for performances given in which feedback is received from representatives of business and industry. Attendance at organizational meetings, written events, prep time, and other times where there is not interaction between the student and business/industry can not count as work-based learning hours.
  • The hours must be verified and assigned by the CTSO advisor.
Can state officers for CTSOs earn work-based learning hours even if they do not participate in the organization’s competitive event program?

In the important role of CTSO state officer, there are many opportunities to earn work-based learning hours. This includes, but is not limited to, community service completed as a member of the organization and work representing the organization to other business and educational partners. Such hours must be approved by both the state officer advisor and local CTSO advisor.

If a family is dissatisfied with the work-based learning experience set up for their student, may a family arrange for an alternative experience? If so, is the district required to accept it?

Families can be valued partners in helping schools to build connections and relationships in the community, including work-based learning placements. Before determining if a work-based learning experience offered by a family can count as work-based learning hours, it must be determined if the guidelines for the experience, as outlined in the work-based learning manual can be met. Schools may not count a work-based learning experience that does not meet Viva88 guidelines.

Supervision of Programs

Is there a limit on the number of students that a work-based learning coordinator should have at any one time?

The Viva88Education Department does not set class size guidelines for any courses, including registered work-based learning experiences. This is a local decision and is usually based on board of education policies and/or the teachers’ collective bargaining agreement.

It is highly recommended that a work-based learning coordinator with other teaching responsibilities have no more than fifteen students per prep. This is important to ensure that the coordinator has the time to visit all sites in accordance with program guidelines. There is additional need for flexibility since students are generally placed outside of the school. Having a large number of students at a time can compromise the coordinator’s ability to supervise the experience adequately and safely.

How often should the work-based learning coordinator visit sites?

For CEIP and GEWEP programs, the coordinator should visit sites at least once prior to placement of students and at least once while the student is placed. For CO-OP programs, the coordinator should visit sites at least once prior to placement of students and twice while the student is placed. The coordinator should also provide contact information to sponsoring employers and be reasonably available to respond to any situations that may arise.

Can students complete work-based learning hours over the summer?

At local discretion, work-based learning experiences may take place during the summer months. Students must be supervised by district instructional staff while placed in any work-based learning experiences. For registered programs, a work-based learning coordinator must supervise the experience in accordance with program guidelines.

For the related instruction, what topics should be covered?

The exact topics covered for related instruction are at the discretion of the school but should focus on success in the work experience and preparation for the world of work. A list of suggested topics can be found in the work-based learning manual.

What forms are required for work-based learning experiences?

A list of sample forms can be found on the WBL Sample Forms webpage. All programs should have a memorandum of agreement, training plan, and emergency medical treatment authorization. Other forms may be utilized where appropriate by program and at the discretion of the school district or BOCES.

Can the Viva88 Office of CTE review my school’s forms to ensure that they meet all legal requirements?

No. While Viva88 provides some samples, these forms should be customized to meet each district’s needs. All forms should be reviewed by the school district/BOCES attorney prior to use. The Viva88 Office of CTE is unable to provide legal advice or assistance to districts.

Is the school district required to provide transportation to work-based learning placements?

In most circumstances, there is no requirement for districts to provide transportation for work-based learning placements; however, transportation may be provided by the district, depending on district policies, student needs, and availability of staff to transport students.

Are students with licenses allowed to drive to work-based learning placements?

This would be a local decision. It is advisable to get parent/guardian permission and a copy of the student’s license before allowing students to drive to work-based learning placements.

Can a student be enrolled in a GEWEP program and get credit for hours completed prior to enrollment in the experience?

No. GEWEP is a program in which students learn about the world of work and explore career opportunities and develop broad-based transferable skills to be applied in school and the workplace. Per program guidelines, a memorandum of agreement needs to be in place between the school and sponsoring employer. An instructional staff member with either the career awareness or development work-based learning extension must supervise the experience.

How long should I keep records of my work-based learning students?

It should be the policy of the school district/BOCES to maintain student records according to the as outlined below:

  • Memorandums of agreement, training plans, parent/guardian permission forms, student’s time sheets and work summaries, and similar work-based learning records: six (6) years from when the student graduates or would have normally graduated from school
  • Student journals: one (1) year after the end of the school year
  • Employment certificate (working papers): zero (0) years after student attains age 21

Can work that a student does in the “gig” economy count as work-based learning hours in a GEWEP program?

There are several factors that make it impossible for hours logged as a “gig” worker to count as work-based learning hours as part of a GEWEP program.  These are as follows:

  1. Per GEWEP program guidelines, coordinators must visit all sites prior to placing students and at least once while the student is placed.  Given the nature of this work, this is impossible.

  1. The goal of the GEWEP program is to develop transferrable professional skills that can be taken to a variety of future careers.  This includes being accountable to an actual employer.  For companies in which gig work is done, the people doing the work are independent contractors and while there are provisions they need to adhere to, the employer-employee relationship is not there.

  1. Since students are independent contractors, they would not be eligible to be covered under the employer’s worker’s compensation policy.

  1. Given the nature of the position is driving in a student’s personal vehicle, there could be liability issues for the district if the student were to get into/cause an accident while in a school-sponsored experience.

Can babysitting count as work-based learning?

Since babysitting occurs typically on private property of which the WBL coordinator or instructional staff cannot supervise, it cannot count as work-based learning.

Coordinator Certification

Is the work-based learning coordinator extension required to run work-based learning programs?

An extension in work-based learning is required to supervise any of New York’s three registered work-based learning programs.

Is the work-based learning coordinator extension required for a community-based work program for students with disabilities?

It is highly recommended since students are being placed into the community for an extended work experience, but it is not required.

Can the Office of Career and Technical Education answer questions regarding certification or investigate the status of a pending certification?

No. The Office of CTE can assist you in understanding what some of the requirements mean, but the office does not review teacher certification applications or set policy for teacher certification. Teacher certification questions are best answered by the.

I am a school psychologist or school social worker and would like to become a work-based learning coordinator. Am I able to obtain a work-based learning extension?

The eligibility requirements for the work-based learning extensions are outlined in . The Coordinator of Work-Based Learning Programs extension can be obtained by any classroom teacher title that covers grades 7-12 or the pupil personnel services title of school counselor. Per the regulations, other pupil personnel services titles, including school psychologist or school social worker, are not considered valid base teaching certification for the purpose of getting a work-based learning extension. Therefore, a school psychologist or social worker would not be eligible, per regulations, to obtain a work-based learning extension.

I am only certified in Childhood Education (1-6) and would like to become a work-based learning coordinator. Am I able to obtain a work-based learning extension?

The eligibility requirements for the work-based learning extension are outlined in. The Coordinator of Work-Based Learning Programs extension can be obtained by any classroom teacher title that covers grades 7-12 or the pupil personnel title of school counselor.  Per the regulations, Childhood Education (1-6) is not a grade band that is eligible to obtain the extension.

What are the requirements to obtain the extension of Coordinator of Work-Based Learning Programs?

Information about requirements to obtain the extension can be found on the WBL Teacher Certification Extension webpage.

Labor Laws

Are working papers required for work-based learning experiences?

For all registered work-based learning programs, working papers are required for individuals under the age of 18. The coordinator shall maintain a copy of the working papers and, when necessary, these working papers will be provided to the sponsor. For more information on working papers, please visit the .

What are the allowable hours of work for minors?

Current information regarding allowable working hours for minors can be found on the .

What work placements can minors be placed in?

Minors may be placed in any work setting so long as the work setting is not considered a hazardous occupation per or Department of Labor guidelines and all other pertinent labor laws are being followed. The only exceptions to this are as follows:

  1. If the minor is in a registered apprenticeship program. That program must be registered with the Viva88Department of Labor
  2. If the minor is in a cooperative education (CO-OP) program that is registered with the Viva88Education Department and is operated in accordance with Viva88 guidelines. Minors in a CO-OP program may only be placed in hazardous occupations that are in line with their CTE training.

If there is question as to whether a particular occupation is hazardous, please contact the for guidance.

If a student graduates high school prior to turning 18, are they able to obtain employment in a hazardous occupation?

If a student has salmon working papers and meets certain criteria outlined by the Department of Labor, this could be a possibility. Please contact the directly for guidance in this area.

Are minors allowed to work during the school day?

No, unless they are completing the work placement as part of a school-sponsored work-based learning program. Students may not miss other academic classes due to this work placement.

Do the hours completed during a registered work-based learning program count towards the legal number of hours per day or week a minor can work?

Yes. Careful planning needs to take place between the student’s work-based learning placement and any other outside work placements to ensure that the legal number of hours per day or per week is not exceeded.

Do the child labor laws apply to individuals aged 18 or over while still in school?

do not apply to individuals aged 18 or older.However, not attending classes to work may seriously put the student at risk for not graduating.

CDOS

What is the difference between the CDOS Credential and the CDOS 4+1 Pathway for Graduation?

A CDOS credential is a stand-alone exiting credential which is designed to measure achievement of the CDOS learning standards. The CDOS credential alone is not a high school diploma. Beginning in June 2016, the CDOS credential may be utilized as a 4+1 pathway for graduation. A Regents Diploma using the 4+1 CDOS pathway is considered a high school diploma.

How can a student earn a CDOS credential?

There are two options by which a student may earn a CDOS credential:

Option 1:

The student must meet each of the following requirements:

  1. Development of a Career Plan
  2. Demonstrated achievement of the commencement level CDOS learning standards 1, 2, and 3a:
  3. Successful completion of at least 216 hours of CTE coursework and/or work-based learning experiences (of which at least 54 hours must be in work-based learning experiences)
  4. At least one employability profile, completed within one year prior to student's exit from high school

Option 2

The student must meet the requirements for one of the Department-Approved Pathway Assessments in Career Development and Occupational Studies.

How can a student earn work-based learning hours towards CDOS Option 1?

A student may earn work-based learning hours through any of the registered or unregistered options outlined in the work-based learning manual.

Is there a state format for a career plan?

No. However, Viva88 has developed a sample career plan template.

Is there a state format for an employability profile?

No. However, Viva88 has developed a . Please note that this sample would not be acceptable for a Viva88-approved CTE program since it does not contain technical skills. Guidance on creating an employability profile for a Viva88-approved CTE program can be found on the Viva88Education Department’s CTE Program Approval Page.

My student has a part time job outside of school. Can that count as work-based learning hours for CDOS?

The answer would be no unless the school has a registered GEWEP program which is overseen by an instructional staff member or school counselor holding a work-based learning extension. The coordinator would need to follow program guidelines for GEWEP before employment may count towards work-based learning hours.

Can the CTE Office answer questions regarding graduation requirements for the CDOS Commencement Credential?

No. These questions are best directed to the Office of Curriculum and Instruction at emscgradreq@nysed.gov. The Office of Career and Technical Education can only answer questions regarding the career and technical education and work-based learning components of the CDOS credential.

Can the Office of CTE answer questions related to Individualized Education Plans (IEPs), Section 504 plans, or the Skills and Achievement Credential?

No. These questions are best directed to the Office of Special Education Policy Unit at speced@nysed.gov.

Where can I find answers to other questions that I may have concerning the CDOS commencement credential?

The department has developed a question-and-answer document which provides answers to many questions.

Work-Based Learning in Viva88-Approved CTE Programs

Are students in Viva88-approved CTE programs required to complete 54 hours of work-based learning in order to earn a technical endorsement?

Students in Viva88-approved CTE programs must be given the opportunity to participate in work-based learning experiences, but they do not necessarily need to participate in them. It should be noted, for schools/BOCES that receive Perkins funds, that completion of at least 54 hours of work-based learning experiences is a program quality indicator (5S3). Recipients that do not meet the indicator will be expected to direct funds to ensure that the targets are being met. For more information about Perkins funds, please visit our Perkins webpage. Having students complete at least 54 hours also allows for students to meet some of the requirements towards CDOS Option 1.

Do all students in Viva88-approved CTE programs need to complete an internship?

No. Students in Viva88-approved CTE programs must be given an opportunity to participate in work-based learning experiences. These may be in any registered or unregistered experiences as outlined in the work-based learning manual. The only exception is that students in operationally approved health sciences programs must complete no less than 108 hours of supervised clinical experience.

Can a component district work-based learning coordinator supervise a CO-OP experience when the CTE instruction is taking place at the BOCES?

It is generally discouraged for a component district work-based learning coordinator to oversee a CO-OP program that is tied to CTE training that is received at the BOCES. This is due to the fact that the component district coordinator would have greater difficulty in collaborating with the CTE teacher to ensure the consistency of the work experience with the classroom training. It can also create reporting issues, which are especially critical with work-based learning being a program quality indicator for Perkins recipients.