Competitive Integrated Employment: What It Means and How the System Is Built Around It

For decades, many people with intellectual and developmental disabilities were steered toward "sheltered workshops" — segregated settings where workers with disabilities performed repetitive tasks for wages below the federal minimum, often cents per hour. WIOA, enacted in 2014, set out to end that system and replace it with a single priority: competitive integrated employment.

Understanding what competitive integrated employment means — and how Pre-Employment Transition Services, supported employment, and VR services funnel toward it — is essential for any family planning a student's post-school employment pathway.

What Is Competitive Integrated Employment?

Competitive integrated employment (CIE) is defined by four criteria under WIOA:

1. At or above minimum wage — the person earns at least the prevailing federal, state, or local minimum wage, whichever is highest
2. Equal pay — the person earns wages comparable to non-disabled workers in the same role at the same employer
3. Located in the general labor market — the work takes place in a business that employs non-disabled workers, not a segregated disability-only setting
4. Full interaction — the person interacts with non-disabled people in the course of their job duties, not just in separate supervised environments

The emphasis on integration and equal pay is deliberate. CIE is the policy's explicit rejection of the subminimum wage model, which permitted employers holding Section 14(c) certificates under the Fair Labor Standards Act to pay workers with disabilities based on their productivity relative to non-disabled peers — often resulting in wages of $1–$3 per hour.

The Phase-Out of Subminimum Wages

WIOA Section 511 created significant restrictions on placing youth with disabilities in subminimum wage jobs without first exhausting Pre-ETS and VR services. A student under 24 cannot be placed in a 14(c) job without documentation that they have been offered and received Pre-ETS and VR services, explored and rejected CIE options, and received career counseling on the long-term consequences of subminimum wage employment.

States have gone further. As of 2024, the following states have enacted or completed full phase-outs of Section 14(c) subminimum wage certificates:

• New Hampshire (phased out 2015)
• Alaska (phased out 2018)
• Maryland (phased out 2020)
• Oregon, Washington, Hawaii, Colorado, California (phase-out enacted pre-2023)
• Delaware, Tennessee, South Carolina, Rhode Island (phase-out enacted)

The legislative trend is clearly toward elimination. Families planning long-term employment should build pathways toward CIE from the start rather than accepting subminimum wage placements as a permanent solution.

What Are Pre-Employment Transition Services (Pre-ETS)?

Pre-Employment Transition Services are the earliest formal employment preparation services available to students with disabilities, typically starting at age 14. WIOA requires state Vocational Rehabilitation agencies to spend 15% of their federal allocation specifically on Pre-ETS — a significant funding carve-out that did not exist before 2014.

The five required Pre-ETS activities are:

1. Job exploration counseling — learning about different careers, disability-related employment considerations, and labor market realities through career assessments, job shadowing, and informational interviews
2. Work-based learning experiences — actual work experience in real settings, including internships, paid work experiences, and mentorships
3. Counseling on post-secondary opportunities — information about community college programs, Comprehensive Transition Programs (CTPs), vocational certificates, and apprenticeships
4. Workplace readiness training — social skills, communication, punctuality, problem-solving, and other "soft skills" that employers consistently identify as entry-level gaps
5. Instruction in self-advocacy — teaching students to understand their disability, know their rights under the ADA, request accommodations, and communicate effectively with employers and service providers

Pre-ETS are available to students with disabilities who have IEPs or 504 plans — they do not require a full VR application or eligibility determination. A student can access Pre-ETS services while still in high school by simply being referred to the VR agency by the school's transition coordinator.

This is a critical distinction families often miss: Pre-ETS have a lower threshold for access than full VR services. Starting Pre-ETS at 14 or 15 builds work history and VR relationships years before graduation.

Pre-ETS vs. Full VR Services: What Changes at Application

Pre-ETS are available to potentially eligible students — meaning students who may be eligible for VR but have not yet applied or been determined eligible. Full VR services require a formal application, an eligibility determination, and the development of an Individualized Plan for Employment (IPE).

The IPE is the adult equivalent of the IEP's employment section. It documents the student's vocational goal, the specific services the VR agency will provide, and the responsibilities of the student and counselor. Services funded through a full VR plan can include:

• Job placement and job coaching
• Assistive technology for work
• Transportation support
• Post-secondary education tuition assistance (for programs that support the employment goal)
• Training programs, apprenticeships, and certifications
• Supported employment services for individuals requiring long-term job coaching

Students should apply for VR services by age 16 — not as an afterthought as graduation approaches. VR agencies have their own intake timelines and waitlists. In states where agencies are at full capacity, there may be waiting periods before an IPE can be developed.

Supported Employment: For Those Who Need Ongoing Support

Not everyone can transition directly to a standard job with standard supervision. Supported employment is the model designed for individuals who need ongoing assistance — typically a job coach — to perform competitive work.

Supported employment begins with an intensive period of on-site job coaching, with the coach gradually fading their presence as the worker builds competence and confidence. The goal is always to reduce coaching intensity over time — "natural supports" from co-workers and supervisors replace formal job coaching to the extent possible.

WIOA places heavy emphasis on supported employment as a bridge to CIE rather than as a permanent segregated solution. The funding model reflects this: VR agencies fund the initial intensive supported employment period, with the expectation that Medicaid HCBS waiver funding will cover ongoing support after the VR timeline concludes.

This handoff — from VR-funded intensive support to Medicaid-funded long-term support — requires advance planning, because Medicaid HCBS waiver waitlists in many states span a decade or more. The student's employment plan must account for what happens if the Medicaid waiver is not available when VR funding ends.

How Project SEARCH Fits In

Project SEARCH is a specific implementation of the supported employment model that operates during the final year of high school eligibility. Students rotate through three internship placements at a host business — typically a hospital or large employer — with on-site instruction and job coaching. Published outcomes show that 70–75% of Project SEARCH graduates obtain competitive integrated employment.

Project SEARCH is one of the most evidence-based pathways from school to CIE for students with significant disabilities. See the project search program post for details on how placement works.

For a complete sequence — from Pre-ETS at age 14 through VR services, supported employment, ABLE accounts, and long-term benefits planning — the United States Post-Secondary Transition Roadmap covers how each piece connects.

See more United States guides →