Internship/Temporary Work (I/TW) Guidance

Revised: June 2026

Purpose

To review circumstances and considerations of an Internship/Temporary Work (I/TW) as a service for consumers.

Rationale

Many consumers can benefit from gaining work experience prior to securing permanent employment. This document provides staff with considerations and expectations when using this service to better support consumers and foster relationships with employers.

I/TW is defined as time-limited, paid work designed to provide in-depth knowledge of day-to-day job requirements in a real-world, competitive, integrated setting.

In some types of business, temporary work assignments are called internships; in other settings, the term "temporary work" may be used.

There is no expectation that the consumer will be hired permanently at the site, although they may be hired at the employer's discretion.

Providing Internship/Temporary Work as a Service

I/TW can be provided as a service when it is necessary and appropriate to support the consumer's employment goal. The I/TW site must be in an integrated setting consistent with the consumer’s interests and employment goal. Wages paid to the consumer must be at least commensurate with those paid to others performing the same or similar work.

The purposes of providing I/TW as a service will vary depending upon the individual needs of the consumer. I/TW services may not be provided for the purpose of maintenance (i.e., to meet the consumer's financial needs).

DVR staff are responsible for determining the purpose, goals, duration, and overall parameters of the I/TW based on the consumer's individualized needs. Each I/TW should include clearly defined, individualized goals that align with the identified purpose of the service. Goals should be specific and measurable when possible (e.g., increasing stamina to stand for four-hour shifts, demonstrating ability to follow multi-step directions, or improving workplace communication skills).

Based on identified consumer needs, DVR staff must define the purpose and specific goals of the I/TW in collaboration with the consumer and communicate them to the Service Provider.

Appropriate purposes of I/TW include:

• Determine a compatible vocational goal - Evaluate the consumer’s interests, strengths, work behaviors, productivity, and overall job suitability in a real work environment. *
• Determine needs for assistive technology or job accommodations – Identify supports or accommodations necessary for successful employment, including AT devices, services, or workplace adjustments.
• Build endurance for work (work hardening) - Improve physical, mental, or emotional capacity to sustain work-related tasks and schedules.
• Develop new skills - Learn new skills or refresh existing skills in a specific occupation or general employability.
• Establish current work references - Obtain a positive, current employment record to support a résumé and references.
• Try out a position to determine if it is a good fit – Explore a specific occupation, industry, or work environment to assess compatibility with the consumer's skills, interests, and employment goals. May include learning basic workplace behaviors and expectations.

*Note: If an I/TW is used as an assessment prior to development of an Individualized Plan for Employment (IPE), code it as an assessment. When used as an assessment after the IPE is written, include it in the IPE and code it as an I/TW. The specific purpose and parameters must be clearly documented.

Appropriate Use of I/TW

I/TWs should be used only when they directly support the consumer's employment goal and identified service needs.

An I/TW should not be used:

• For the purpose of maintenance (i.e., to meet the financial needs of a consumer).
• To allow an employer to "try out" a consumer to determine if they can perform the job.
• To replace or reduce hours of existing employees (including employees laid off, on strike, or labor disputes).
• To create ongoing or routine "slots" at a worksite for consumers.
• For group placements where multiple consumers perform similar work together without individualized placement.
• When the placement is based solely on the consumer's disability rather than individualized employment goals and interests.

Staff should consult with local management when there are questions about appropriate use.

Employer of Record (EOR)

In Wisconsin, DVR contracts with an Employer of Record (EOR) provider to administer payroll and provide required insurance coverage for consumers participating in an I/TW.

Work Permit Requirements

Consumers under age 16 are required to have a work permit before starting the I/TW.

• Work permits are valid for three years. If there is a break in service or employment, a new work permit must be obtained if the consumer is still under age 16 when they return to work.
• The cost of the work permit is reimbursable and should be added to the I/TW purchase order.
• If summer employment occurs at the same work site as the previous summer, a new work permit is still required to comply with labor laws.
• The work site must be listed as the employer on the work permit - not the Employer of Record (EOR) or DVR. Work permits that do not list the work site as the employer will be revoked. In such cases, the consumer will be required to reapply for a new work permit, and the I/TW start date may be delayed.
• The work permit must be kept on file at the work site.

High-Risk Positions

The Employer of Record (EOR) cannot support certain occupations for an I/TW due to the level of workplace safety risks. Examples include driving positions; any paid time in a vehicle (including travel between job sites); construction; manual welding or grinding; and farm work, including the use of heavy machinery, power saws, woodchippers, ladder work, or rooftop access.

The EOR also cannot support I/TWs involving the use or cleaning of meat or food slicers, distributing medication, unsupervised personal care, or tattooing.

If any prohibited duties are present at the worksite, the I/TW Agreement must clearly indicate the restrictions that will apply. For example, if the I/TW is in a deli, the consumer may not use a meat or food slicer; if the job duties include oil change, tire rotation, detailing, or similar tasks, the consumer may not drive vehicles.

If a consumer wishes to complete an I/TW in an excluded occupation, consult with the Bureau of Consumer Services Director to determine whether another EOR can be used. If the consumer has this type of employment goal, consider use of an On-the-Job Training (OJT) so the site employer can review and assume responsibility for any associated safety risks.

Duration and Parameters for Internship/Temporary Work (I/TW)

The duration and the number of I/TWs must be based upon the consumer's individualized needs, the defined purpose of the service, and specific goals identified by DVR in collaboration with the consumer.

DVR staff are responsible for determining the authorized duration of the I/TW. Service Providers and work site businesses may provide input; however, the final determination should align with the identified purpose and goals of the service.

• The duration of an I/TW should be no longer than necessary to achieve the identified purpose and goals.
• I/TWs typically range from two (2) weeks to 45 calendar days.
• I/TWs exceeding 45 calendar days require supervisory approval and must be clearly justified based on the consumer's needs and goals.
• I/TWs must not exceed 90 calendar days without an approved exception.

When an I/TW ends, DVR and the consumer must review the outcomes of the experience and determine whether an additional I/TW is appropriate. When considering a subsequent I/TW:

• The new I/TW must have a distinct purpose and clearly defined goals, and
• Every effort should be made to secure a different position or worksite to promote skill development and broader exposure.

Repeat I/TWs should build on prior experiences and target new or expanded goals. Use of multiple I/TWs to assess the same skills or outcomes should be avoided unless clearly justified and documented.

If additional time beyond 90 calendar days is necessary, staff should consult with local management for review and approval and document justification of the request.

Hours Worked and Labor Standards

Labor standards apply to all I/TWs where an employee/employer relationship exists, as defined by the Fair Labor Standards Act (FLSA).

• Consumers can work up to 40 hours per week.
• Overtime is not permitted in an I/TW.
• Any time worked over 40 hours in one week is considered overtime. If overtime occurs, consult with the local supervisor or Director on how to proceed.

Providing Internship/Temporary Work in Conjunction with Other Services

I/TWs may be used in combination with other employment services as appropriate, such as Systematic Instruction (SI), Supported Employment (SE), and/or Job Development (JD). (See DVR Technical Specifications for descriptions of these services.)

Efforts to secure permanent employment should continue if the consumer is also seeking employment while participating in the I/TW. Participation in an I/TW should not delay other job development efforts.

If the consumer needs accommodations (which may include AT devices/services or personal attendant care services), these must be addressed during the I/TW. I/TWs may also help identify previously unknown accommodation needs prior to permanent employment. Depending on the purpose and length of the I/TW, AT may be rented, borrowed, or purchased.

Progress Reporting

I/TW services must be included in a consumer’s IPE, unless being used as an assessment prior to IPE development. Progress measures should be developed with the consumer based on the purpose and intended outcomes of the service and specific job duties.

Goals must be clearly documented and should guide service delivery and progress reporting throughout the I/TW.

Factors to consider include:

• Purpose and expected outcomes of the I/TW.
• Skills the consumer will gain or strengthen (e.g., stamina, soft skills).
• Employer expectations.
• Methods for gathering progress information (who will measure progress, how often, and what tools or reports will be used).
• How progress informs next steps in the IPE.

DVR staff should monitor the I/TW on an ongoing basis to ensure it supports advancement toward achievement of the IPE goal. Feedback from the site business and/or Service Provider may be used to refine future services, identify additional support needs, or adjust skill development goals as appropriate.

Service Provider Role in Internship/Temporary Work

Prior to contacting potential employers, DVR staff, the consumer, and others involved (e.g., Service Providers, guardians/legal decision-makers, family members, and/or other agency representatives, as appropriate), should identify and discuss:

• Preferred hours, wages, job duties, employment settings, and geographical area.
• Barriers to participation (e.g., transportation needs and plan).
• Any anticipated accommodations or supports needed to participate successfully.

Service Providers are responsible for developing and managing the I/TW on behalf of the consumer and DVR. This includes:

• Contacting employers directly to develop the I/TW and ensuring it is individualized based on the consumer's skills, interests, and the identified purpose of the I/TW.
• Working with DVR staff, the consumer, and the worksite business to confirm that the duration, scope, and expected outcomes of the I/TW align with the identified purpose and goals.
• Once a site is developed, discussing the proposal with DVR and the consumer for approval.
• Ensuring all required paperwork is submitted to the EOR at least one week (seven calendar days) prior to the consumer's anticipated start date.
• Maintaining regular contact with the consumer, DVR staff, worksite business, and EOR throughout the I/TW to monitor progress, address barriers, and ensure compliance with hours, site rules, and agreements.
• Verifying wages in conjunction with the consumer and the worksite business, as needed. Monitoring the consumer's work hours to ensure that neither the consumer nor the site business exceed the authorized hours. Hours worked beyond the authorized amount are not allowed.
• Contacting DVR and/or the EOR for technical assistance or intervention when needed, when requested by the site business or consumer, or when there are proposed changes to the established work hours and dates on the I/TW Agreement.

The I/TW duration and scope are determined by DVR based on the identified purpose and goals, with input from the consumer, Service Provider, and site employer as appropriate.

All I/TW opportunities must be reviewed and approved by DVR prior to finalizing arrangements with a site employer.

I/TWs exceeding 45 calendar days require WDA supervisory approval. I/TWs exceeding 90 calendar days timeframe require a WDA Director-approved exception.

If a consumer or DVR staff develops the I/TW, a Service Provider should be utilized to facilitate the EOR paperwork. If the consumer does not want a Service Provider involved, DVR staff should consult with the local WDA Director/Supervisor on how to proceed.

Payment of Internship/Temporary Work

I/TWs must occur in a community-based, competitive, and integrated workplace where the consumer is paid at or above minimum wage and no less than the prevailing wage and level of benefits paid by the site employer for the same or similar work.

Payment of wages is provided through the EOR and is a separate service to the consumer.

The EOR provider must be paid the set-up fee for each individual position established for a consumer.

Special Considerations

I/TW sites must be developed with the individual consumer in mind. The same site may be used more than once if it continues to meet the consumer's individualized needs and supports new or expanded goals. If DVR staff have concerns about repeatedly used sites and/or sites that rarely hire consumers, staff should discuss this with the Service Provider and local management before authorization.

I/TWs are typically used for existing paid positions with job descriptions. A volunteer position may be used as an I/TW only with consultation and approval from local management.

Some non-profit entities or smaller/newer businesses may create customized positions without formal job descriptions. DVR staff should consult with supervisors when considering these situations to ensure the placement aligns with the consumer's employment goals and I/TW purpose.

I/TWs may also be supported at publicly funded organizations such as state, county, or municipal operations. Please also see the State Limited-Term Employment (LTE) guide for further information about when a State LTE may be more appropriate.

When planning I/TWs, staff should consider the consumer's prior experiences, expected outcomes, and opportunities for skill development. Repeat I/TWs should build on prior experiences and provide distinct learning opportunities, rather than duplicating previous I/TWs, unless clearly justified and documented.

Impact of Internship/Temporary Work on Social Security Benefits

Earned income from an I/TW may affect Social Security benefits, including Trial Work Periods or Extended Periods of Eligibility for SSDI beneficiaries working above the Substantial Gainful Activity (SGA) level.

DVR staff should discuss potential impacts on benefits during IPE planning and refer consumers to the Social Security Administration or for Work Incentives Benefits Services, as appropriate.

Impact of Internship/Temporary Work on Child Support and Other Benefits

Wages earned during an I/TW may result in wage garnishment for child support or may affect other public benefits. These impacts should be reviewed on a case-by-case basis.