Work-Based Learning Logistics: Transportation, Schedules and Liability for Minors

Three logistics problems stall most work-based learning (WBL): transportation, the master schedule, and insurance and child labor rules. Each has known solutions, and the rules are well defined, especially in Michigan. Topic 5 of 6 in the Career-Connected Education Research series from CareerConnectedSchools.org.

Not legal advice. This resource summarizes public statutes, rules and agency guidance so you can plan. Rules vary by state and change often. Confirm specifics with your district’s counsel, your insurer or risk pool, and the state agencies named below before you act.

How to read this resource

Each section marks which rules apply in any state and which are Michigan rules.

• Any state means federal law, or a practice that works anywhere.
• Michigan means a Michigan statute, rule or agency guidance. If you work in another state, look for the matching rule in your state; it may be stricter or looser.
• Confirm with the agency marks a point where sources conflict or are silent. The agency to ask is named, and the question is listed again under “Review status and sources.”
• Changing marks a rule or system that is new or in transition.

Summary

What is missing is comparative evidence. No study found compares transportation models or schedule models on student participation, outcomes or cost. The guidance below is descriptive and regulatory.

Transportation to the worksite

The barrier (any state)

In 2016-17, 98 percent of public school districts offered career and technical education (CTE), and 77 percent included on-the-job training, internships, clinical experiences or cooperative education (NCES). Those placements happen off campus, on schedules that fixed bus routes were not built for. Practitioners name transportation as a leading barrier, especially in rural districts and for students with disabilities (Illinois Center for Transition and Work survey of 364 transition staff, 2024).

Who usually transports today (any state)

• To a shared-time career center: the sending district usually runs the bus.
• To worksites and clinical sites: the student usually provides transportation. Michigan’s sample training agreement assigns transportation to the student.

When transportation is left to the student, students without a car or license are screened out. The options below widen access.

Options, from lower cost to higher cost (any state)

Regional coordination fits ISDs and other intermediate units well. A shared ride service across several districts spreads the cost of low-density runs. Vendor materials describe such arrangements; no independent evaluation was found.

Funding sources for WBL transportation

Federal (any state).

• Perkins V lets local recipients fund “a continuum of work-based learning opportunities” and, for special populations, costs of “fees, transportation, child care, or mobility challenges” (20 U.S.C. 2355(b)(5)(E) and (S)). The U.S. Department of Labor has administered Perkins V day to day since a May 2025 interagency agreement with the Department of Education, which keeps statutory authority. Changing. Last checked Oct. 3, 2026.
• McKinney-Vento subgrants may pay the excess cost of transportation for students experiencing homelessness (42 U.S.C. 11433(d)(5)). The pandemic-era ARP-HCY funds are no longer available for new spending; obligation ended Sept. 30, 2024. Ask your federal programs office about Title I homeless set-aside funds.

Other states (examples).

• Texas reimburses transportation “from a district campus to a location at which students are provided work-based learning” under the district’s CTE program, at miles traveled times the district’s official extracurricular travel per-mile rate, and lets districts buy transit passes with transportation allotment funds for students who qualify for regular transportation where that transportation is not workable (Tex. Educ. Code 48.151(f), (l)). This is the clearest WBL transportation provision found.
• Missouri state transportation aid covers transport to career education classes during the regular school day (5 CSR 30-261.040). WBL trips are not addressed.

Michigan.

• No Michigan provision that funds transportation to WBL sites was found. Section 61a(1) added-cost funding, MDE’s Added Cost Guide, R 340.15 and MDE’s WBL Companion Document do not mention transportation.
• Section 22l funds general transportation costs ($125 million in FY2025-26, Senate Fiscal Agency).
• Confirm with the agency (MDE Office of Career and Technical Education and Office of Financial Management): whether any School Aid section, including 22l, 61a(1), 61b or 61d, can pay for transportation to WBL or clinical sites. Last checked Oct. 3, 2026.

Liability for transportation

Any state. A district that chooses to transport students takes on a duty to do it safely. Governmental immunity rules decide how far that exposure reaches.

Michigan.

• No duty to transport general education students. MDE states that Michigan districts are not required by law to transport regular education students. MCL 380.1321 sets obligations once a board chooses to transport. Special education transportation is required when the IEP includes it.
• District-owned vehicles. The motor vehicle exception to governmental immunity makes a district liable for injury and property damage caused by an employee’s negligent driving of a vehicle the district owns (MCL 691.1405). Immunity does not protect district vans driven to WBL sites.
• Small vehicles. A school bus is a vehicle seating 11 or more, including the driver (MCL 257.1807). MDE’s Pupil Transportation Advisory Committee (Feb. 7, 2019) says vehicles for 10 or fewer occupants are not school buses and are not regulated by the Pupil Transportation Act. It recommends that their drivers have a physical at least equal to a bus driver’s, fingerprinting and background checks, driver record checks, drug and alcohol testing, a defensive driving course every two years, and at least a chauffeur’s license.
• Private cars. A board may contract for transportation by private car (10 or fewer passengers including the driver) within the district when busing isolated students costs too much (R 340.281). The rule was written for home-to-school routes. Its use for WBL trips has not been tested.
• Staff and volunteer drivers in personal vehicles. One Michigan school risk pool (MAISL Trust, rev. April 2021) advises that the driver’s own auto liability policy is primary and the pool’s coverage is excess, and only within the scope of district duties. It recommends minimum limits of $250,000 per person and $500,000 per occurrence for bodily injury and $10,000 for property damage, plus a background check, insurance certificate, registration and maintenance records on file. Confirm with your risk pool, because your pool’s terms control.

Students driving as part of the job (any state). Federal rules bar 16-year-olds from driving on public roads as part of a job. A 17-year-old may drive only under all of these conditions (29 CFR 570.52(b)):

• vehicle of 6,000 pounds or less with seat belts, in daylight;
• valid license for the driving, a state-approved driver education course, and no moving violations at the time of hire;
• driving takes no more than one-third of the workday and 20 percent of the workweek;
• no more than two trips a day away from the workplace, within 30 miles;
• no towing, route deliveries or sales, transportation for hire, urgent time-sensitive deliveries, or more than three passengers.

Commuting to the worksite in the student’s own car is a separate matter that your district policy and parent permissions govern.

Fitting work-based learning into the master schedule

Schedule patterns (any state)

WBL needs blocks of protected time that a traditional six- or seven-period day rarely provides. These patterns are documented in practitioner sources. No study shows one improves outcomes over another.

The two lowest-cost moves for a comprehensive high school are a daily advisory block and a weekly early-release or community day. Deeper models build on them.

Shared-time centers (any state)

Half-day career center sessions cost students travel time and home-school periods. In one Michigan example, a 2 hour 15 minute center session took about 3.5 hours of the student’s day once bus time was included (Cedar Springs High School and Kent Career Tech Center). Build travel time into the schedule before you add WBL on top.

Michigan time rules for credit-bearing WBL

Work hour limits for minors

Any state. Federal law sets no hour limits for 16- and 17-year-olds outside hazardous work. For 14- and 15-year-olds, the federal Work Experience and Career Exploration Program (WECEP) allows up to 3 hours on a school day and 23 hours in a school week, including during school hours, under a program the state education agency gets approved by the U.S. Department of Labor for two school years (29 CFR 570.36).

Michigan. Under the Youth Employment Standards Act (YESA), 16- and 17-year-olds may work no more than 24 hours a week while school is in session, 10 hours a day and 6 days a week, and not between 10:30 p.m. and 6 a.m. (11:30 p.m. on Fridays, Saturdays and school breaks) (MCL 409.111). A student employed under a written school-employer agreement is outside YESA, including these limits (MCL 409.118). Federal law still applies.

Liability, workers’ compensation and child labor rules

Two layers apply to every placement. The federal layer sets child labor and wage rules. The state layer adds its own child labor rules, permits and insurance requirements. When both apply, the stricter rule controls (U.S. DOL Fact Sheet #43). A written training agreement ties the layers together for each student.

Paid or unpaid: the primary beneficiary test (any state)

For a for-profit employer, an unpaid student is lawfully unpaid only if the student, not the employer, is the primary beneficiary. The U.S. Department of Labor (Fact Sheet #71, January 2018) lists seven factors:

1. Both sides understand there is no expectation of pay.
2. The training resembles what an educational setting would give.
3. The placement is tied to the student’s formal education through integrated coursework or credit.
4. It fits the academic calendar.
5. It lasts only as long as it gives beneficial learning.
6. The student’s work complements, rather than displaces, paid staff.
7. Both sides understand there is no promise of a paid job at the end.

If the student is really an employee, minimum wage and overtime apply. Public agencies and nonprofits have more room for unpaid volunteers.

Federal hazardous occupation orders apply only when there is an employment relationship. Treat them as the safety floor for every placement anyway, because a placement that fails the test above is employment.

Federal hazardous occupation orders (any state)

• 16 is the basic minimum age for nonagricultural work. 18 is the minimum for the 17 nonagricultural hazardous occupation orders (HOs).
• The 11 agricultural hazardous orders apply only to youth under 16.
• No federal HO bars electrical work as such. Limits on electrical and construction tasks come from state law and from task-based HOs, such as HO 7 (power-driven hoisting, including forklifts, aerial lifts and patient lifts), HO 16 (roofing) and HO 17 (trenching and excavation).

The student-learner exemption (any state)

A 16- or 17-year-old in a recognized vocational program may do some otherwise prohibited tasks under 29 CFR 570.50(c).

It covers only these HOs: 5 (power-driven woodworking machines), 8 (metal forming, punching and shearing machines), 10 (meat processing machines), 12 (balers and compactors), 14 (certain power saws and shears), 16 (roofing) and 17 (excavation).

It never covers: HO 2 (driving and outside helper), HO 7 (power-driven hoisting, including patient lifts) or HO 15 (demolition).

Requirements. The student is employed under a written agreement, signed by the employer and the school coordinator or principal, with copies kept by both, stating that:

• the hazardous work is incidental to the training;
• it is intermittent and for short periods, under direct and close supervision of a qualified, experienced person;
• the school gives safety instruction, correlated by the employer with on-the-job training; and
• there is a schedule of organized and progressive work processes.

The exemption opens specific tasks. It does not open an entire industry, and state law may still bar the task (see Michigan below).

Patient lifts. HO 7 covers powered patient lifts and has no student-learner exemption. Under Field Assistance Bulletin 2011-3, the Wage and Hour Division will not enforce HO 7 against a 16- or 17-year-old who has completed 75 hours of nurse aide training and assists an adult with a lift, as the junior member of a two-person team led by someone 18 or older, with no independent patient contact, is not injured while operating or helping with the lift, and works for an employer that has given written notice using the bulletin’s Attachment A.

Subminimum wage. An employer may apply for a federal certificate to pay a student-learner at least 75 percent of the federal minimum wage (29 CFR 520.500 to 520.508). State minimum wage law may not allow it. Confirm with the agency (Michigan LEO Wage and Hour Division) whether Michigan permits the federal student-learner rate; Michigan’s own rate for minors is 85 percent of the state minimum. Last checked Oct. 3, 2026.

Federal penalties (any state)

Effective January 16, 2026, unchanged from 2025, the U.S. Department of Labor may assess up to $16,035 per child labor violation, up to $72,876 when a violation causes a minor’s serious injury or death, and up to $145,752 when that violation is repeated or willful.

Michigan child labor rules

• State hazardous bars for all minors. R 408.6208 bars all minors under 18 from a list of hazardous work, including construction work, roofing, excavation, demolition, power-driven woodworking machines, power saws, metal-forming machines and power hoists such as forklifts and cranes.
• The school-employer agreement route. YESA “does not apply” to a student 14 or older employed under a written agreement between the employer and the school district, public school academy or nonpublic school, as long as the employment does not violate federal law and a signed copy is on file at the worksite before the student starts (MCL 409.118; R 408.6206(a)). The state bars then fall away, but the federal HOs still apply. Only the student-learner exemption can open a federally hazardous task.
• No deviations for hazardous work. Since 2024 PA 196, LEO may not grant a deviation that allows hazardous work (MCL 409.120).
• Hazardous task timing. MDE’s 2022 WBL FAQ reads “intermittent” as under one hour at a time and “short periods” as under 20 percent of the shift, citing the U.S. Department of Labor. Use these as working guides.

Michigan youth work permits

Changing. Last checked Oct. 3, 2026.

Since October 2, 2026, Michigan youth work permits are issued by the Department of Labor and Economic Opportunity (LEO) through the online Youth Employment Permit Portal (YEPP), under 2024 PA 196 (MCL 409.104 as amended).

The law still allows a permit to be suspended for poor attendance that lowers school performance, for up to 30 days with notice and a chance to correct, before it is revoked (MCL 409.107). Your school’s role in that process now runs through YEPP.

Open question for WBL. MCL 409.118 says YESA does not apply to a student employed under a school-employer agreement, and MDE’s 2022 WBL FAQ says those students do not need permits. Both predate YEPP. LEO’s YEPP materials do not mention WBL or cooperative education, and no MDE or LEO memo to schools on this point was found. Confirm with the agency (LEO Wage and Hour Division): whether students placed under a 409.118 agreement need a YEPP permit, and whether their host employers must register in YEPP. Until LEO answers, keep the signed agreement on file at the worksite and ask the host whether it has registered.

Michigan insurance requirements

• How to verify workers’ compensation. Use the state’s Current Workers’ Compensation Insurance Coverage Lookup (wcinsurancecoveragelookup.apps.lara.state.mi.us). The Workers’ Disability Compensation Agency now sits in LEO, though the lookup keeps a LARA web address. An employer with a Notice of Exclusion from the Agency, documented by the district, is excepted.
• Unpaid placements: conflicting guidance. MDE’s Companion Document and its 2022 FAQ say workers’ compensation is not required for unpaid placements. R 340.15 requires the training agreement to verify that the employer has workers’ disability compensation and general liability insurance, with no paid or unpaid split, and the 2023-24 WBL Manual insurance chart lists workers’ compensation for unpaid placements. Confirm with the agency (MDE Office of Career and Technical Education) which requirement governs. Last checked Oct. 3, 2026.
• Whether a host’s policy covers an unpaid student at all. Michigan’s workers’ compensation act covers a person in the service of another “under any contract of hire,” and treats minors the same as adult employees (MCL 418.161(1)(l)). The Michigan Supreme Court has held that a contract of hire needs real, wage-like pay (Hoste v. Shanty Creek Management, 1999). An unpaid student may fall outside the host’s coverage. Confirm with the agency (Workers’ Disability Compensation Agency) and your risk pool how an unpaid student injured at a host site is covered, and whether your district’s own coverage applies.

Why workers’ compensation matters to the employer (Michigan)

• For a covered employee, workers’ compensation benefits are the employee’s exclusive remedy against the employer, except for an intentional tort (MCL 418.131(1)).
• An employee of an employer that is required to carry coverage and does not may sue the employer in court, and the exclusive-remedy protection does not apply. Failing to insure is a misdemeanor (MCL 418.641).
• A private employer must carry coverage if it regularly employs 3 or more people at one time, or 1 person for 35 or more hours a week for 13 weeks or more (MCL 418.115).
• A minor injured while illegally employed receives double compensation (MCL 418.161(1)(l)). A placement that breaks a child labor rule raises the employer’s exposure.

MDE’s “Work-Based Learning: Myth vs. Fact” sheet tells employers that proof of valid liability and workers’ compensation insurance is a placement requirement, and that company policy may be the only barrier to hosting qualified CTE students. Questions about how hiring a minor affects premiums belong with the employer’s carrier.

The Michigan training agreement

MDE publishes a sample CTE training agreement (2021), sample training plan and workplace safety checklist through its WBL Tool Kit.

Steps for a district starting or expanding WBL

These steps apply in any state; Michigan specifics are in parentheses.

1. Decide which placements are paid and which are unpaid, using the seven-factor test.
2. Screen every planned task against the federal HOs and your state’s list (Michigan R 408.6208).
3. Use the school-employer agreement route for each placement (Michigan MCL 409.118), and add student-learner language only for exempt HO tasks.
4. Collect the host’s general liability certificate and workers’ compensation carrier and policy number, and check coverage in the state lookup (Michigan Coverage Lookup).
5. Get written answers from your risk pool on unpaid students, district vehicles and staff personal vehicles.
6. Ask the host whether it has registered for youth employment permits (Michigan YEPP), pending LEO’s answer on WBL students.
7. Choose a transportation option and record who transports in the training agreement.
8. Set the schedule pattern and confirm it fits your state’s WBL time limits (Michigan R 340.15).

Review status and sources

Status: Revised and verified October 3, 2026, from a July 2026 research draft. Federal and Michigan items were checked against primary sources. Vendor and practitioner examples are labeled as such and were not independently verified. The full claim-by-claim log is kept with S4IS research files.

Open agency questions

Sources

Federal

• U.S. DOL WHD, Fact Sheet #43, Child Labor Provisions for Nonagricultural Occupations
• U.S. DOL WHD, Fact Sheet #71, Internship Programs Under the FLSA (Jan. 2018)
• U.S. DOL WHD, Field Assistance Bulletin 2011-3 (powered patient lifts)
• U.S. DOL WHD, Youth Employment FAQ
• U.S. DOL WHD, Civil Money Penalty Inflation Adjustments
• U.S. DOL, Child Labor Bulletin 101
• 29 CFR 570.50 (student-learner exemption)
• 29 CFR 570.52 (HO 2, driving)
• 29 CFR 570.36 (WECEP)
• 29 CFR 570.71 (agricultural hazardous occupations under 16)
• 20 U.S.C. 2355 (Perkins V local uses of funds)
• 42 U.S.C. 11433 (McKinney-Vento subgrant uses)
• U.S. DOL news release on the DOL and ED workforce partnership (Sept. 8, 2025)
• NCES Fast Facts, Career and technical education
• SchoolHouse Connection, ARP-HCY wind-down

Michigan

• LEO, Youth Employment Permit Portal
• LEO news release, New Youth Employment Permit Portal (Oct. 1, 2026)
• LEO, Youth Employment Standards Act page
• LEO, Minimum Wage and Overtime FAQ
• Youth Employment Standards Act, 1978 PA 90 (MCL 409.101 et seq.)
• Mich. Admin. Code R 408.6206 and R 408.6208
• Mich. Admin. Code R 340.15 (work-based learning experiences)
• Mich. Admin. Code R 340.281 (private car transportation)
• MDE, Work-Based Learning Companion Document to Pupil Accounting Manual Section 5-P
• MDE, Work-Based Learning Manual, 2023-2024 Edition
• MDE, Work-Based Learning FAQ (rev. Jan. 7, 2022)
• MDE, WBL Tool Kit, Managing Your Risk
• MDE OCTE, Work-Based Learning: Myth vs. Fact
• MDE, Pupil Transportation FAQ
• MDE Pupil Transportation Advisory Committee, Vehicles with Ten or Fewer Occupants (Feb. 7, 2019)
• MCL 257.1807 (school bus definition)
• MCL 691.1405 (motor vehicle exception to governmental immunity)
• MCL 418.161 (employee defined)
• MCL 418.131 (exclusive remedy)
• MCL 418.641 (uninsured employers)
• MCL 418.115 (private employers covered)
• Hoste v. Shanty Creek Management, Inc. (Mich. 1999)
• Current Workers’ Compensation Insurance Coverage Lookup
• MCL 388.1661a (Section 61a, CTE added cost)
• Senate Fiscal Agency, FY2025-26 School Aid Budget summary
• MAISL Trust, School Employees/Volunteers Using Personal Vehicles to Transport (rev. April 2021), posted by Bloomfield Hills Schools
• Cedar Springs High School, Kent Career Tech Center schedule

Other states

• Tex. Educ. Code 48.151 (transportation allotment)
• 5 CSR 30-261.040 (Missouri transportation aid)

Practitioner and descriptive sources

• Illinois Center for Transition and Work, Transportation Solutions (Aug. 2024)
• Learning Policy Institute, Redesigning High School sample schedules (2024)
• Getting Smart, Innovative High School Schedules (2023)
• Aurora Institute, Rethinking the Master Schedule in Competency-Based Schools
• Education Week and HopSkipDrive webinar, The Road to Opportunity (vendor-sponsored)