Implementation toolkit
Clinical and Work-Based Learning Partnerships: Toolkit
These pages summarize rules to help you plan. They are not legal advice. Before you place students at a work site or change a program, check with your state agency, your district's counsel and your insurance carrier.
About this toolkit
Any pathway that puts students in a hospital, nursing home or job site needs a written agreement with that host, and the host’s own requirements often decide which students can go. This toolkit explains which agreement you need, what it should cover, what to collect from a host before the first placement, and how child labor rules apply, with nurse aide clinicals and electrical worksite placements as worked examples.
Use it alongside the pathway guides, which name the state rules for each pathway. Have your district’s attorney review any agreement before signing; the outlines here are a starting point, not legal advice.
Which agreement you need
Most programs need one agreement with each host and a separate signed plan for each student. The kind of placement decides which documents apply.
| Agreement | You need it when | Who signs | State requirements to know |
|---|---|---|---|
| Clinical affiliation agreement | Students do clinical hours in a nursing facility, hospital or other health setting | Your district or center (the legal entity holding program approval) and the facility | Required in writing for nurse aide programs in Arizona, Pennsylvania and Missouri; North Carolina’s DHSR approves each clinical site before use |
| Worksite training agreement and training plan | Students earn credit for a placement at a business, paid or unpaid | Student, parent, school coordinator, employer supervisor | Required for credit-bearing work-based learning in Michigan (R 340.15); Pennsylvania co-op requires a training agreement and plan |
| Student-learner agreement | A paid 16- or 17-year-old will do a task federal or state child labor law otherwise bars, such as using a circular saw or working on a roof | Employer and school coordinator or principal, naming the student | Federal rule 29 CFR 570.50(c); can be built into the training agreement |
| State hazardous-work approval | A placement involves work your state bars for minors | Depends on state | North Carolina: Supervised Practice agreement approved by NCDOL before the student starts (plan about 60 days). Virginia: work-training agreement copy filed with DOLI |
| College partnership agreement | A college delivers the course or the clinical program | District and college | Arizona requires an intergovernmental agreement for college courses at high schools (A.R.S. 15-1821.01) |
What a clinical affiliation agreement covers
Hospital and nursing home templates are usually written for colleges, so expect to negotiate the clauses that do not fit a public high school, especially insurance, indemnification and anything signed by a minor. The two public school agreements reviewed were the Clay County, Florida school board and HCA agreement (2023) and the Los Angeles Unified and Arcadia Care Center nurse aide agreement (2023).
| Clause | What it covers | What to watch for |
|---|---|---|
| Parties and scope | Who signs and which program the agreement covers | Sign as the entity that holds the nurse aide program approval. Check that the scope does not exclude students under 18. |
| Term and renewal | How long the agreement runs and how it renews | Match the term to your program’s state reapproval cycle and track the expiration date. |
| School responsibilities | Curriculum, approved RN instructor, rosters, student orientation, records | Confirm who keeps immunization, background and consent records and for how long. |
| Facility responsibilities | Access, orientation, a contact person, badges, final authority over resident care | Facility staff should not teach in place of your approved instructor. |
| Supervision and ratio | Instructor on site and the maximum number of students per instructor | The ratio must be at least as strict as your state’s rule. Students must never replace facility aides. |
| Student requirements | Immunizations, TB test, background check, drug screen, CPR, orientation, dress | Agree in writing who pays and who verifies. Ask the facility to accept your attestation instead of raw records. |
| Privacy | HIPAA training and confidentiality agreements | Students count as the facility’s HIPAA workforce. A parent should co-sign anything a minor signs. |
| Student status | Students are trainees, not employees | Keeps the placement out of child labor and wage rules. A student later hired by the facility is covered by them. |
| Insurance | Liability coverage each party carries | Often the sticking point. Ask your risk pool what it can provide before you sign. |
| Indemnification | Who pays if a claim arises | Many public bodies cannot agree to indemnify a private party. Limit it to the extent permitted by law, or strike it. |
| Governmental immunity | Preserves each public party’s legal protections | Add a clause saying nothing in the agreement waives immunity. |
| Removing a student | Facility can remove a student from the site; only the school dismisses from the program | Plan a make-up site or alternate assignment so a removal does not cost a required credit. |
| Injuries and exposures | First aid, bloodborne pathogen exposure response, incident reports | Students are usually not covered by facility workers’ compensation. OSHA’s bloodborne pathogens standard covers employees, not unpaid students (OSHA interpretations of Dec. 16, 1992 and Mar. 5, 1999). Your agreement should say who provides training, hepatitis B vaccination or declination, and follow-up after an exposure. Decide who pays for post-exposure testing and notify parents. |
| Termination | Notice period and what happens to enrolled students | Require that enrolled students can finish their clinical hours. Keep a second site. |
| Student records | Sharing education records with the facility | Parents sign FERPA consent until the student turns 18. Share only what the facility needs. |
| Governing law | Which state’s law applies | Public bodies usually must use their own state’s law and venue. |
State rules that change the agreement:
- Arizona: the Board of Nursing requires written clinical agency agreements that let the instructor assign patient care after consulting facility staff and include a termination clause that leaves time for enrolled students to finish (AZBN checklist).
- Pennsylvania: the agreement must state the instructor’s responsibility, the ratio, a nondiscrimination statement, that students perform only tasks they have been taught and shown competent in, and that students will not replace aides; both administrators sign (PDE Report of Change instructions).
- Missouri: a signed written agreement of cooperation is required for the 100 supervised on-the-job hours (19 CSR 30-84.010).
- Michigan: the long-term care background check law (MCL 333.20173a) names employees, contractors and people with clinical privileges, not students; your clinical site may still require a check by policy. Ask how it handles students under 18. ()
Host site requirements for students
Each facility sets its own student requirements, and they are often stricter than state rules. Collect them in writing before you schedule the course, because a requirement a 16-year-old cannot meet can block a whole cohort.
| Requirement | What facilities commonly ask for | What to settle for students under 18 |
|---|---|---|
| Minimum age | Varies by facility; some take only students 18 and older | Confirm the facility accepts 16- and 17-year-olds before you build the schedule |
| Hepatitis B | 3-dose series, series in progress, or a signed declination before patient contact | Childhood records usually satisfy this; agree who pays for any missing doses |
| MMR, varicella, Tdap | Vaccine records or titers | School immunization records usually satisfy this; ask the site to accept records instead of titers |
| Tuberculosis | Baseline screening with a blood test or two-step skin test | A two-step skin test needs extra weeks; CDC guidance does not call for routine annual retesting without exposure |
| Flu and COVID-19 | Seasonal flu vaccine or a masking policy for those who decline; COVID-19 policy varies by facility | Get the declination policy in writing so a student is not removed mid-rotation |
| Background check | Criminal history and registry checks; Arizona sites often ask for a fingerprint clearance card | Settle how a minor’s check is run and who sees results, since some systems have no process for minors |
| Drug screen | Pre-placement screen at some sites | Requires parent consent and a district policy for a positive result |
| CPR | American Heart Association BLS | Build BLS into the course |
| Privacy training | Site orientation and a signed confidentiality agreement | A parent co-signs for minors |
| Consent and release | Parent consent covering clinical risks and exposure response | Use one district consent packet; Utah’s statewide clinical consent form is a model |
| Health insurance | Proof of coverage at some sites | Ask whether your student accident policy is accepted instead |
| Uniform and ID | Scrubs, closed shoes, a badge identifying the student as a nurse aide student | Budget for it or use a program fee |
Placement platforms. Many health systems require students to upload these documents to a compliance platform before a rotation. ACEMAPP, run by the Michigan Health Council, offers schools shared onboarding modules, document storage and e-signatures and markets a high school track (ACEMAPP).
Nurse aide clinical site rules by state
| State | Clinical site rule |
|---|---|
| Michigan | 16 clinical hours in a long-term care setting, in person with a permitted trainer on site; no written agreement or ratio set by rule (LARA overview), so set a ratio in your agreement |
| Virginia | At least 40 hours of direct client care, no more than 10 students per instructor; sites with certain federal penalties in the past two years cannot be used; sites 50 miles or more away need Board approval (18VAC90-26) |
| North Carolina | DHSR approves each clinical site before use through a site approval request; direct RN supervision at no more than 10 students per instructor (DHSR) |
| Arizona | Written agreement required; at least 20 hours of direct resident care in a licensed long-term care facility; no more than 10 students per instructor |
| Pennsylvania | Agreement terms set by PDE (see above); changing a site requires a Report of Change; students need a State Police criminal history report before training |
| Missouri | Signed agreement of cooperation for the 100 on-the-job hours; no more than 15 students per instructor; trainees may not be on the state Employee Disqualification List |
| Hawaii | 70 hours of supervised practical training; facility-based programs cannot be certified after certain federal penalties; the rule does not mention written agreements, and most high school programs run through certified partners |
Electrical worksite placements and child labor law
A 16- or 17-year-old can work on an electrical job site in all seven states, but some tasks are barred everywhere, some need a student-learner agreement, and North Carolina and Pennsylvania bar electrical work itself unless an exemption applies. When federal and state rules differ, the stricter one controls.
Paid or unpaid. An unpaid placement is lawful when it is mainly for the student’s learning: it is tied to coursework or credit, closely supervised, time-limited, and does not displace paid workers (DOL Fact Sheet 71). A student doing billable work alongside a crew for weeks should be paid. Michigan caps unpaid placements at 45 hours per training experience (R 340.15). Treat the federal hazardous-occupation limits as the safety floor for every placement, paid or not.
Working with Minors in CTE Pathways covers the child labor rules for all eight pathways in all seven states: the federal hazardous occupations orders, state hour, permit and hazardous-work rules, each state’s exemption route, and a student-learner addendum you can attach to the training agreement below.
The student-learner agreement. For a paid student to do a task covered by federal Hazardous Occupations Orders 5, 8, 10, 12, 14, 16 or 17, the employer and the school coordinator or principal sign a written agreement naming the student that says (29 CFR 570.50(c)):
- The hazardous work is incidental to the training.
- It is intermittent and brief, under direct and close supervision of a qualified, experienced person.
- The school provides safety instruction, and the employer ties it to on-the-job training.
- There is a schedule of organized, progressive work processes.
The exemption never covers driving or riding outside a vehicle (HO 2), lifts and other power hoists (HO 7), or demolition (HO 15).
| Task on an electrical job site | Federal rule for 16 and 17 | Stricter state rules |
|---|---|---|
| Scissor lift, boom lift, bucket truck or forklift | Prohibited; no exemption | Same in all seven states |
| Demolition or demolition cleanup | Prohibited; no exemption | Same in all seven states |
| Driving a company vehicle or riding outside the cab | Prohibited, except limited daylight driving at 17 under strict conditions | Same in all seven states |
| Work on or about a roof, including rooftop equipment | Student-learner agreement only | Pennsylvania bars roofing except for apprentices and student-learners (34 Pa. Code 11.63); North Carolina bars work with a fall risk of 10 feet or more |
| Trenching deeper than 4 feet | Student-learner agreement only | Arizona’s list bars most excavation, with a CTE student exemption |
| Circular, reciprocating or band saws, abrasive cut-off discs | Student-learner agreement only | Arizona’s list bars power saws, with a CTE student exemption |
| Pulling wire, mounting boxes, terminating devices on de-energized circuits | No federal order | North Carolina bars any electrician or helper work under 18 unless the student is a registered apprentice, a student-learner, or under an NCDOL-approved Supervised Practice agreement. Pennsylvania bars electrical work except for apprentices, student-learners and graduates of an approved program |
| Welding or torch cutting | No federal order | North Carolina and Pennsylvania bar it, with exemptions |
No child labor rule reviewed addresses energized work directly. Keep live work, lockout and tagout, and arc-flash exposure off limits to students as a program policy.
State steps for worksite placements
| State | Work permit for 16 and 17 | What to file or follow |
|---|---|---|
| Michigan | Yes, through LEO’s online Youth Employment Permit Portal since October 2, 2026 | Written school-employer agreement on file at the worksite (LEO); 24 hours a week cap during the school year |
| Virginia | Not required | File a copy of any work-training agreement for hazardous tasks with DOLI (Va. Code 40.1) |
| North Carolina | Youth employment certificate for all under 18 | Supervised Practice agreement approved by NCDOL before start for barred tasks (submit about 60 days ahead) (G.S. 95-25.5) |
| Arizona | Not required | State list exempts CTE students and registered apprentices; federal orders still apply (A.R.S. 23-235) |
| Pennsylvania | Yes, from the school district issuing officer | Training agreement and plan for co-op; 28 hours a school week cap (PDE co-op guidelines) |
| Missouri | Not required at 16 and over | Federal rules govern; no state template found |
| Hawaii | Certificate of Age through DLIR online | Student-learner and apprentice exemptions sit inside HAR §§ 12-25-43, -46, -47, -49, -51, -53 and -54. Section 12-25-48 (bakery machines) has no exemption, so employed minors may not run power-driven mixers, including countertop mixers. Section 12-25-56 (logging and sawmill) has no student-learner exemption. Hawaii’s rule requires a DOE-approved cooperative vocational program, brief supervised work and school safety instruction. It does not require a separate state agreement, but the federal written student-learner agreement is still needed |
Insurance, liability and workers’ compensation
A paid student is the host’s employee and is covered by the host’s workers’ compensation like any other employee. For unpaid students, Hawaii is the only one of the seven states with a statute; elsewhere, confirm coverage in writing with your insurer or risk pool before the first placement.
| State | Paid placement | Unpaid placement |
|---|---|---|
| Hawaii | The State is the employer for workers’ compensation | The State is the employer for workers’ compensation (HRS 302A-430) |
| Michigan | Host employer | MDE sources conflict: the rule and 2023-24 manual list host workers’ compensation as required, while a 2022 FAQ says it is not; confirm with MDE |
| Arizona | Host employer | No statute; ADE’s guide suggests the school’s coverage follows the student; confirm with counsel |
| Pennsylvania | Host employer must provide workers’ compensation; never classify a student as a contractor | No rule found |
| Virginia, North Carolina, Missouri | Host employer | No statute or state guidance found |
For every placement:
- Get the host’s certificate of liability insurance and workers’ compensation carrier and policy number, and record them on the training agreement.
- Ask your district’s insurer whether your student accident policy covers clinical and worksite injuries, including bloodborne exposures.
- For clinical agreements, ask your risk pool whether you can name the facility as an additional insured before agreeing to it.
Templates
Copy these into your district’s formats and have counsel review agreements before signing. The clinical affiliation agreement outline is the clause table earlier in this toolkit.
Worksite training agreement outline
Built from the Michigan, Pennsylvania, Virginia and Arizona state guides and the federal student-learner rule.
- Parties and contacts: student, parent or guardian, school coordinator, host employer and named workplace supervisor, with emergency contacts.
- Placement terms: paid or unpaid, job title, dates, weekly hours, wage if paid, credit earned, program name and code.
- Permit: work permit or certificate number where your state requires one.
- Training plan: attached and made part of the agreement.
- Hazardous tasks: only if planned, the four student-learner statements and the student’s name, plus any state filing (North Carolina, Virginia).
- Employer duties: qualified supervision, a safe workplace, tasks tied to the plan, evaluations, compliance with child labor and wage law, prompt notice of injuries.
- School duties: certified coordinator, safety instruction before placement, related classroom instruction, site visits on a set schedule, credit.
- Student and parent duties: attendance, safety rules and protective equipment, hour logs, transportation.
- Insurance: host workers’ compensation carrier and policy number, liability carrier, and who covers unpaid students.
- Termination: the school may end a placement immediately for a safety concern; no promise of employment.
- Nondiscrimination and harassment statement.
- Signatures: student, parent, coordinator, principal or designee, employer supervisor. Keep a copy at the worksite.
Training plan outline
- Student career goal and program title with code.
- 6 to 12 competencies to be learned, tied to program standards, with approximate time for each.
- Related classroom instruction for each competency.
- Safety training required before and during the placement, including limits on any hazardous task.
- Evaluation method and dates, with supervisor sign-off.
Host intake checklist
- Business license, and for electrical hosts the contractor license and the licensed supervisor who will be on site
- Certificate of liability insurance and workers’ compensation policy
- Registration in your state’s youth employment system where required, such as Michigan’s permit portal
- Worksite safety review completed
- Task review against federal and state child labor rules, with no lifts, demolition or driving
- Named supervisor with time for direct and close supervision
- Agreement to sign the training agreement, build the training plan and complete evaluations
- Site safety orientation and protective equipment the host will provide
- Coordinator site visits agreed
- Incident reporting procedure to the school
- For clinical sites: minimum student age, immunization, TB, background check, drug screen, CPR and privacy training requirements in writing
Clinical consent packet contents
- Parent consent to clinical participation, describing the setting and risks.
- Authorization for the background check and any drug screen, with how results are handled.
- Consent to share immunization and health records with the facility (FERPA).
- Exposure response and medical care acknowledgment, with who pays.
- The facility’s confidentiality agreement, co-signed by a parent.
- Photo and identification release if the facility issues badges.
Quick reference by pathway
One row per pathway. Each pathway guide has the full state-by-state detail; rows are added as new guides are completed.
| Pathway | Where students learn off campus | Agreement and filings | Federal task limits for 16- and 17-year-olds | Pathway guide |
|---|---|---|---|---|
| Nurse aide | Clinical sites, usually long-term care, under an RN | Written clinical agreement in most states; regulator approval of each site in North Carolina | Patient lifts count as hoists (HO 7): aides under 18 may assist an adult-led team but never operate a lift | Nurse aide guide |
| Electrical | Contractor job sites, as unpaid placements, paid co-op or youth apprenticeship | Placement agreement with task limits in every state. North Carolina: NCDOL Supervised Practice agreement approved before work starts (plan about 60 days). Pennsylvania: apprentice or student-learner status and a work permit. | No lifts (HO 7) or driving (HO 2). Roofs (HO 16), trenches over 4 feet (HO 17) and power saws (HO 14) only under a student-learner or apprentice agreement. | Electrical guide |
| EMT | Emergency departments and ambulances, under the program’s clinical agreements | Written clinical affiliation agreements with hospitals and EMS agencies (required in Michigan and Missouri); each site sets its own minimum age | Students ride but never drive (HO 2); Pennsylvania bars minors from operating an ambulance | EMT guide |
| Welding | Fabrication shops, contractors, union and employer training programs | North Carolina: NCDOL Supervised Practice agreement approved before work starts (plan about 60 days). Pennsylvania: apprentice or student-learner status and a work permit. Michigan: no welding under 16. | Press brakes and shears (HO 8) and power saws and cutting discs (HO 14) only under a student-learner or apprentice agreement; no forklifts or cranes (HO 7) | Welding guide |
| Construction / carpentry | Builders, contractors, union and contractor training programs; a student-built house | Placement agreements with task limits; North Carolina Supervised Practice agreement approved before work starts (plan about 60 days); Pennsylvania work permit and student-learner status; for a house, a written ownership, permit and contractor-of-record agreement | Woodworking machines (HO 5), saws (HO 14), roofing (HO 16) and trenches (HO 17) only under an agreement; never lifts or forklifts (HO 7) or demolition (HO 15). Michigan and Virginia add broad state bars. | Construction and carpentry guide |
| HVAC/R | Residential and commercial HVAC contractors; union and contractor training programs | Placement agreements with task limits; North Carolina Supervised Practice agreement approved before work starts (plan about 60 days); Pennsylvania work permit and student-learner status | Roof work (HO 16) only under a student-learner or apprentice agreement, and barred by several states; no lifts (HO 7) or driving service vans (HO 2) | HVAC guide |
| Cybersecurity / networking | IT departments, managed service providers, government cyber internships, competitions | Internship agreements with defined tasks, system access limits, confidentiality terms and device arrangements; background checks are common | No federal hazardous occupations orders apply; state hour limits and work permits still do | Cybersecurity and networking guide |
| Programming / computer science | Software employers, district IT, nonprofits as project clients, youth apprenticeship | Mentor and client-project agreements; registered apprenticeship (Software Developer occupation) where available | No federal hazardous occupations orders apply; state hour limits and work permits still do | Programming and computer science guide |
| Automotive service | Repair shops and dealerships, as co-op placements | Placement agreement with task limits. Michigan: a Secretary of State mechanic trainee permit or certification for co-op students who repair customer vehicles. Hawaii: paid helpers work under a licensed mechanic. | Vehicle lifts are allowed at 16, but engine hoists, winches and tow-truck hoists are HO 7 with no exemption. Move cars only on shop property (HO 2); leave public-road road tests out of the agreement. | Automotive service guide |
| Medical and dental assisting | Medical offices, clinics and dental practices, under clinical agreements | Clinical agreement with HIPAA and bloodborne pathogens terms, who verifies live-patient skill counts, and whether students take X-rays. North Carolina: Dental Board approval for student dental assisting functions. | Dental X-rays need a passed state exam first in Virginia, Pennsylvania, Arizona and North Carolina; paid minors who take X-rays fall under HO 6, with no exemption. Phlebotomy needs a site that lets minors do 30 live venipunctures and 10 capillary sticks. | Medical and dental assisting guide |
| Cosmetology | Board-licensed schools and salons; salon internships in Pennsylvania | Hours count only in a board-licensed school or partner school, except Virginia’s VDOE-approved programs. Register students with the board before day one. | No federal hazardous occupations orders apply. Virginia lets 16- and 17-year-olds work in salons as apprentices, in work-training programs or with a license. Arizona bars paying students in a school salon. | Cosmetology guide |
| Agriculture | Farms through SAE placements; agribusinesses such as feed mills, equipment dealers and vet clinics | Signed SAE or student-learner agreement for paid farm placements; Missouri requires three supervision visits a year. Keep tractor and machine certificates in the employer’s file. | Farm hazardous orders stop at 16; off-farm agribusiness follows the nonfarm orders to 18, including forklifts (HO 7). Paid pesticide handlers and applicators must be 18 in nearly every state. Parent-owned farms are exempt. | Agriculture guide |
| Early childhood education | Licensed child care centers and preschools; in Michigan, family and group homes for ages 14 and 15 | Decide whether the student is staff, volunteer or student, which sets the background check. Paid staff need a fingerprint check before starting (all three clearances in Pennsylvania). A school lab preschool usually needs a child care license. | Students count in ratio at 16 at the earliest, usually under direct supervision. North Carolina requires a credentialed supervisor 21 or older; Missouri bars junior aides from infant and toddler ratios. | Early childhood education guide |
| Culinary arts and hospitality | Restaurants, hotels and the school’s own restaurant or café | Student-learner agreement for slicer use; Michigan school-employer agreement on file at the worksite. A public-facing school restaurant needs a health department permit and plan review. | Slicers (HO 10) only under a student-learner agreement; floor mixers (HO 11) never. Paying students in a school restaurant makes them employees. Alcohol service starts at 17 in Michigan and 18 in most other states. | Culinary arts and hospitality guide |
| Machining and mechatronics | Machine shops and manufacturers, as co-op placements or registered and youth apprenticeship | Student-learner agreement or registered apprenticeship (from 16), with the task list written by machine type. Michigan: school-employer agreement on file before work starts. Hawaii: a DOE-approved co-op program. | CNC mills and lathes are machine tools, not HO 8. Presses, press brakes and shears (HO 8) and cutoff saws (HO 14) only under an agreement; no cranes, forklifts or lifts (HO 7). Pennsylvania also bars grinders except for student-learners. | Machining and mechatronics guide |
| Engineering and drafting | Engineering and design employers and prototyping shops, as internships | Internship agreement with defined tasks; no occupational license or second-agency approval applies | No federal hazardous occupations orders apply to engineering and CAD work; HO 8 or HO 5 applies only if a placement puts a student on shop equipment. State hour limits and work permits still apply. | Engineering and drafting guide |
| Firefighting | Fire departments, through cadet, explorer or junior member programs | Fire department membership is usually required (Virginia, Michigan, Pennsylvania, Missouri). Pennsylvania: live-fire training at 17 needs the Act 155 parent and chief permission form. | No wildland firefighting for paid 16- and 17-year-olds (HO 4, no exemption). Interior live fire only in training, with a state-credentialed instructor on site; North Carolina bars structure fire suppression for 16- and 17-year-olds. | Firefighting guide |
| Law, public safety and corrections | Police and sheriff agencies, 911 centers and Explorer posts, for observation and ride-alongs | The agency’s ride-along consent form plus a written work-based learning agreement. Explorer ride-alongs under 18 need two trained adults 21 or older. | Each agency sets its own ride-along limits; no state statute does. Students are escorted visitors with no CJIS terminal or screen access. Handguns only with prior written parental consent (18 U.S.C. 922(x)). | Law, public safety and corrections guide |
| Business management and marketing | Retail stores and offices, as co-op placements | Co-op training agreement; Pennsylvania co-ops need a certified coordinator. Check the store’s own age policy for register alcohol sales. | Balers and compactors (HO 12) only under a student-learner agreement; no delivery driving at 16 (HO 2). Register alcohol sales need age 18 in Michigan, Missouri and Hawaii. | Business management and marketing guide |
| Entrepreneurship | Mostly on campus in a school store or school-based enterprise, with business mentors and volunteer coaches | Run a school store as a district activity under board policy and district tax registration. A student-owned business is a family matter, and minors’ contracts are voidable. North Carolina WE11: at least 120 hours on the job. | Unpaid school-based enterprise work is learning, not employment; paid students become district employees under hour limits and hazardous occupations orders. Food sold to students must meet Smart Snacks. | Entrepreneurship guide |
Review status and sources
State rules were checked against agency pages, administrative code and statute on October 2, 2026. On October 3, 2026, the Hawaii student-learner sections were read in full and the OSHA bloodborne pathogens and Michigan background check notes were added. Items still under review:
- Michigan: whether students placed under a school-employer agreement still need a permit through LEO’s new portal, and whether host employers must register there.
- Michigan: whether host workers’ compensation is required for unpaid placements (MDE sources conflict), and whether a host’s policy covers an unpaid student at all, since Michigan’s law covers people working under a contract of hire.
- Virginia and Michigan: whether the nurse aide program application asks for written clinical site agreements, since the rules do not require them.
- North Carolina: the current Supervised Practice agreement form from NCDOL, and the contents of DHSR’s clinical site approval request.
- Arizona, North Carolina, Pennsylvania, Virginia, Missouri: who covers unpaid students for workers’ compensation.
- Every state: whether your district may sign an indemnification clause under state law.
- Every state: how background checks are run for students under 18.
- Michigan’s youth permit portal launched October 2, 2026; check LEO guidance for work-based learning.
- Hawaii HB 1068 (2026) proposed extending state workers’ compensation coverage to new graduates in work-based learning.
- Facility COVID-19 and flu policies change by season.
Sources
- Federal: 29 CFR 570.50 · 29 CFR 570 Subpart E · DOL Fact Sheet 71 · DOL Youth Employment FAQ · 42 CFR 483.151 · CDC TB screening for health care personnel
- OSHA bloodborne pathogens interpretations: Dec. 16, 1992 and Mar. 5, 1999 (checked Oct. 3, 2026) · MCL 333.20173a (checked Oct. 3, 2026)
- Agreements reviewed: Clay County and HCA (2023) · LAUSD and Arcadia Care Center (2023) · Truckee Meadows Community College template · NYSED nurse aide affiliation requirements · Intermountain Health under-18 packet · Utah clinical consent forms
- State nurse aide rules: LARA overview · 18VAC90-26 · NC DHSR orientation · AZBN checklist · PDE Report of Change · 19 CSR 30-84.010 · HAR 17-1444
- State work-based learning: Michigan R 340.15 · MDE WBL Manual · LEO permit portal · Va. Code 40.1 Ch. 5 · G.S. 95-25.5 · 13 NCAC 12 .0406 · A.R.S. 23-231 · ADE WBL Guide · PDE co-op guidelines · Missouri child labor summary · HAR 12-25 · HRS 302A-430
Checklist for this toolkit
Tick what your team has done or decided, then download it. Your ticks also count toward your plan if you start one.
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