Editor’s Note: The following is a comment submitted on behalf of LIFTT to the Wage and Labor Division, United States Department of Labor, encouraging the adoption of a proposed rule designed to severely curtail, if not end the employment of persons with disabilities at a subminimum wage (<$7.25/hr) under Section 14(c) of the Fair Labor Standards Act.
January 16, 2025
To the U.S. Department of Labor, Wage and Hour Division:
Subject: Ending Subminimum Wages: Upholding Dignity and Equity
Living Independently for Today & Tomorrow (LIFTT) strongly supports the Department of Labor’s proposed action to eliminate the use of 14(c) certificates. The payment of subminimum wages to individuals with disabilities is an outdated and discriminatory practice that must end. Here are ten reasons why subminimum wages should be prohibited:
- Violation of Human Rights: Paying individuals with disabilities less than minimum wage undermines their fundamental human rights to fair and equal treatment.
- Erosion of Dignity: Subminimum wages devalue the skills, contributions, and inherent dignity of people with disabilities, reducing them to second-class status in the workforce.
- Equal Opportunity and Access: Subminimum wages directly conflict with the principles of equal opportunity and access enshrined in the Americans with Disabilities Act (ADA).
- Outdated and Discriminatory: The 14(c) program is rooted in an antiquated view of disability and fails to reflect modern values of inclusion and equity.
- Perpetuation of Poverty: Subminimum wages trap individuals with disabilities in cycles of poverty, preventing them from achieving financial independence and security.
- Barriers to Inclusive Employment: Allowing subminimum wages discourages employers from adopting inclusive hiring practices and providing accommodations to workers with disabilities.
- Lack of Incentives for Skill Development: Subminimum wages disincentivize investment in training and skill-building programs that could empower individuals with disabilities to achieve competitive employment.
- Undermines Labor Protections: Subminimum wages weaken the broader framework of labor laws designed to ensure fairness and equity for all workers.
- Negative Social Impacts: The practice reinforces stereotypes and stigma surrounding disability, perpetuating social exclusion rather than fostering inclusion.
- Proven Alternatives Exist: Numerous states and organizations have successfully transitioned away from subminimum wages through supported employment programs, demonstrating that individuals with disabilities can thrive in competitive, integrated workplaces.
At LIFTT, inclusion means valuing every person equally, and fair wages are a cornerstone of dignity and independence. We encourage everyone to join us in supporting the Department of Labor’s effort to prohibit subminimum wages by submitting a public comment before January 17, 2025.
Together, we can build a future where real work earns real wages for everyone.
Sincerely,
Carlos A. Ramalho, Executive Director
LIFTT – Living Independently for Today & Tomorrow
About Living Independently for Today & Tomorrow (LIFTT): LIFTT is a Montana 501(c)3 corporation organized as a Center for Independent Living (CIL). With team members based in Billings and Glendive, LIFTT provides people with disabilities with programs and services that help empower them to break down the physical, bureaucratic, and cultural barriers that prevent them from being fully independent participants in their lives and communities throughout 18 counties in southeastern and south-central Montana: Big Horn, Carbon, Carter, Custer, Dawson, Fallon, Garfield, Golden Valley, McCone, Musselshell, Powder River, Prairie, Richland, Rosebud, Stillwater, Treasure, Wibaux, and Yellowstone. For more information, please visit LIFTT.org or download our mobile app for your Apple or Android Device.
You can donate to LIFTT by clicking here.