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Legal Aspects of Vocational Training

Deborah Ausburn


Deborah Ausburn

Litigator and Counselor at Law




  • February 8, 2018
    10:00 AM


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I appreciate the opportunity to talk to you guys and work with your schools I really love the Madison model I didn't grow up understanding it I'm not Adventist I'm actually. Presbyterian married an Anglican and so that that's my my personal background but once I got involved in Laurel broke to have eleven years ago I think it was when the Department of Labor came after the laurel broke program. That was when I started getting into the Madison school model and really understanding what you guys are trying to do. And and fell in love with all of that I think actually our public schools are are in a crisis for a number of reasons and one of the things that I'm passionate about thinking could help fix that would be more career technical education is that's what they call it in the public school setting. And the helping kids understand. How the real world works I I have learned this in my I spend my days as a lawyer I play with words I turned black into grey and then if you look at Grey long enough it becomes white. And it and I have discovered that in my free time I really enjoy I went through a woodworking phase and really enjoy doing a lot of the what you guys teach in career technical things and the reason it's a very good corrective for me because no matter how much I talk either the board that I could is the right link or it isn't and none of my lawyer skills will change the result and that's a very good and powerful lesson for our kids to lie. And the sooner they learn it the better. One of the from the trial that we had with with chloral book which which we were successful and one one of the stories that I remember and I've repeated until everybody who knows me is very sick of it but one of the alumni I was talking about is at the sanitarium they have their stand stand in with a group of kids around the toilet and the teacher who is a little German lady had put a chocolate chip cookie on the seat of the toilet and she said to them if you claim to this the way that you were supposed to clean this you would not be afraid to eat that cookie. And that lesson stuck with him and of course the story stuck with me. There is a lot of value in these programs so let me let me get an idea I know one day with a is working on on curriculum for this how many of you guys are in a program that already has vocational training you might call it work training we're going to suggest the way to talk about it OK So most everybody is is in one of those programs Well if you know the old saying that to somebody who has a hammer everything looks like a nail that is the U.S. Department of Labor they cover an employer employee relationships so everything they look at to them it looks like employees and it looks like work and it looks like work that should be covered by the Fair Labor Standards Act. And. The Fair Labor Standards Act covers it has a lot if people are classified as employees of your school then they have to you have to pay them minimum wage you have to pay them over time. And more importantly for what you guys are doing they cannot work during school hours so that would that would completely go any of your vocational programs and there are certain activities that are restricted to eighteen year olds so when I was going through the laurel broke trial Department of Labor kept coming in with pictures of kids using drills electric drills on school yes and we were teaching them how to use drills and I was able to convince the judge that we had a vocational program that looked an awful lot like the accepted vocational program of the public school just down the road. And as I kept saying and I still say fifteen sixteen year olds who do not learn how to use a table saw grow into eighteen year olds who cut their fingers off so just because someone is an adult doesn't mean they miraculously are learn the skills and that's why that's why we need to start teaching them at fifteen and sixteen. There is an exception for non employees and this is where we're trying to to fit in is to say to the department these are not employees these are students in an educational program now most of the. Work in this area has been. With interned and colleges there's not a lot out there about high school educational programs because frankly there are very few private schools that have vocational programs so most of the law and the cases in this area have been involved for example r.a.s resident advisors in colleges or interned. Who work for free at various. Private institutions. For a long time before January of this year the Department of Labor. Had a very restrictive standard they have it had a six part test and you had to meet every single one of those six parts and and it was it was a big strain really difficult to get through it well the Department of Labor kept losing in the courts and the courts tended to go with a primary economic benefit test which is in other words who's been a fitting the most. Is it the student or the school that's been a fitting from this arrangement and the court looked various factors. So in January just a month ago well in December the Department of Labor announced that they were going to go in with a different program I'm not sure how much of this you can see we'll go through this in depth but in January they and the Department of Labor announced what their standard would be they're going again the primary beneficiary test who benefits the most and they listed in there which you can find this on Department of Labor website they've listed several different factors no expectation of compensation everybody. We're going to go through each of these in depth but of just the no expectation of compensation training them a letter to an educational institution integrated into an educational program now for four private employers what the department labor looks at is are these show kids enrolled in a program where the school is looking at this and supervising in looking at the educate. Ational value and or are they getting credit for it. Credit. The next one connection to an academic calendar in other words does it go does that roughly match when your academic program is in session. The duration is limited to the training period now sometimes you end up. Laura BURKE For example one of the things we had to look at was once the the kids there had the opportunity to get their certified nursing assistant surgeon cation All right then once they had their C.N.A. if they were still assigned to the sanitarium it's hard to say that it's continued educational benefit from for them it starts looking more like you've got a trained C.N.A. for the program so that was that they had head of voided that trap but that is just that's a trap that's an example that you need to look at so if once the the kids have gotten your seal of approval that they have learned the skills and you're still sending them back there because you need someone there then they're replacing an employee and it causes difficulty. The last standard is the student does the disk placed paid employees now I know some of you probably are set up as religious orders and so you have staff members who are members of the religious order and are not paid in the same sense as others but it's the. Same thing adult employees you're you know if you're using kids because you run short on adults then the program is going to have difficulty. So let's look at each one of these in depth and those of you with programs or who are looking at. Tarting program please feel free to raise your hand and asked me about specific things yes. No it would it would be show I'll tell you what it's going to show up with most of you guys if there's a certification that you have and the kids get that certification saying they have learned everything now C.N.A. is unique and I know Laura brook with that sanitarium is a bit unique. But if for example you had certification in Microsoft's computer programming for example or anything that has an external certification or if you say I've given another example if you have kids who have gone through and they have gotten credit for all two or three whatever you offer. Courses for dietitian Let's say that they have gotten credit for a dietician one two three all right but then you start sending them back to work in the kitchen because you're short handed in the kitchen all right they're not being tracked for any program they've already gotten all of the credits that you that the school offers for the dietician program but you're still sending them back there OK So that that that's the and we are going to talk about each of these individual Lee but that that's what they're looking for are the kids learning something new Are they practicing something is it part of a curriculum or have they already gotten all the credits and you're just sending them because you need an experienced person in the kitchen. Practice Yes yes. Right you need to Bill and again we'll talk more about this you need to build that into your curriculum for that period of time if the practice needs to be built into before they get credit for it once they have credit for it you're going to have a hard time saying they're still learning something because your program has already said they know enough to get credit. That does that make sense if you are too if you've got a kid in rolled in our algebra you send them home with twenty algebra problems they do homework that's how they become proficient you don't just teach them the principles and then keep going. But when they have passed out and they're in geometry you don't give them out for problems anymore. So it needs to be the same principal in the vocational program the track you're making OK let's talk individually through the no pay job at the end of the course I always forget that one that one is really the easiest to. You know you guys may hire a lot but you don't hire somebody. You know hire one of the students at the end once they get their diet dietician or. Dietary one two and three training. So let's look at the easiest ones which is no expectation of a job at the end of the internship. And you understand there's no compensation the you're not paying them. Now everybody can understand that you can put that out one area that I've seen the schools get themselves in trouble with this is scholarships. And it's very it's a very good impulse to give kids Goller ships and use their work to help pay for the their tuition However if the scholarships are pegged only to the vocational program the Department of Labor says you're paying them for vocational work OK So if you have a scholarship it needs to be based on a combined G.P.A. of academic and location. All right. In order for it to be not for the departed labor to not say you're paying the kids it needs to be based and you can you can you can have vocational in there you can have academic in there you can have character training in there I know some of the schools like to give US citizenship grade or a character training grade or or similar to what used to be called a conduct grade until that. Hurt people's feelings so now public schools will do it any more. Well some of and but any of those things that you want to roll into determining how much of a scholarship they get you can do that as long as the vocational program is only one factor and not the only factor OK. But otherwise this when you just make very clear and all of your parent pro information all of your. Documentation about your school that that that there's no. There's no compensation and make sure your scholarships are key to the entire or something more than vocational. OK the next one and that is that your curriculum needs to be to educational programs now in order to do this you need to look to a stablished curriculums and I know Ysaye is putting together an established curriculum. And a say isn't accrediting organization has some authority and some credibility. The other place to look is going to be state accreditation Now some of my clients have had actually gone to the state and said we want our vocational program certified according to state standards that's sort of the ultimate depending on what state you're in that can be very hard for religious school to do some of the less tolerant states are. You know our programs just look weird and they just don't understand them and it's just extremely difficult particularly if they're starting to put in all of these diversity requirements and all of these inclusion requirements and all of these we have to accept all sorts of people who don't follow our religious beliefs so that may not be practical but to the extent that your program can follow the state requirements so you can follow the education stuff and not worry about the inclusion diversity stuff the closer you are to put your state recognizes. The better off you're going to be the. These seven standards are not they're not absolute it's very flexible it's going to be weighing this and waiting that So what you need to do is get your program as much as possible without completely gutting it and losing the character of the Madison school yeah. Start with whatever the department is going to be part of education career usually career and technical education is that the division and then if it's not on the web I have found that if you call people and ask them they are are more than happy to send you information. And it I have had clients call and asked me to get it so that they don't end up on the state's radar so you may want to have somebody else do it but again just depends on the state see so just. You see. From your perspective the goal. Is that it's a whole industry or. It is defensible but the more that you can. Can't look at the states and I would say what they could could best do for it's figure out what is the most what's the highest standard among the states and see how close you can get to that so if if a home has a higher standard for electricians then Tennessee to. Try to get as close as you can to the Oklahoma standard. State Standards Now again if you don't want to go for accreditation this is where you stay as close to the states. And her to she can. Professional certifications there's the A.N.S.I. and a camera what a stance the American National Standards Institute and they. Sort of gather the standard of care and the standards for a lot of different technical organizations. If you're if you have a computer program Microsoft test certification again you don't have to get certification you just want to know what the standards are and how close are you tracking the kids skills and the teaching program. And then local vocational programs find out what the folks down the road from you are doing. How how closely does does your program match they are. One of the problems that you can run into with a residential school program is in order for the kids to practice carpentry there's not a lot of you can't put them on a bus and take them off somewhere on a regular basis so there's a lot of we need a bridge bill so let's have the carpentry class build the bridge we we need a. New roof put on the dining hall let's have some of the kids working alongside the contractors to the extent that OSHA regulations allow it those kind of things are fine as long as. Again you do you look at what the location of what the local vocational programs are doing now the local programs a lot of them for example some of the schools that I've worked with in. Public schools that I've worked with in various locations would have for example a green house and the key. Kids grow the plants and then they work with their marketing and their business students to sell them OK. And it's part of a integrated curriculum between the gardening and the marketing classes. That that's a great thing to do it's fine to sell the stuff and to make money off of it as long as it's part of a curriculum and something that the kids are learning what I was growing up there was a school that did body repair for cars and so anybody who got a fender bender would take their car down to the local school and sign it up. For the repair program that the school had their Yeah you got which paid for something it was good sometimes it was bad there there were folks in my hometown who made a living fixing what the school had messed up but yeah but that's goal was a good first place to start and so there was the end that program actually was very good. This is the other thing that I think if you put it together. It and you learn how to how to phrase it the kids who work in your kitchen for example if the food is not good adults may be nice and will eat it and be polite anyway their peers will not they will hear from their friends how terrible their food was and that's a really good lesson for fifteen sixteen seventeen year olds to learn but you need to learn how to phrase that same way if you have a greenhouse and suddenly your. Traffic drops off and people aren't coming to buy anymore it's because there's something wrong with the plants or some. So so this kind of real world experience is extremely good for kids as long as you understand how to market it how to explain how it's been a fitting the kids and not the school that all of this has to go back to what the kids are learning from this. And I actually have heard of there was one local school system here in Tennessee that the state told me about that they would go out and they would buy a house or land sometimes they were rehabbing house sometimes they were starting from scratch and then all the building trades students would go out and they would build a house that year and you know have have to learn from the from starting from the plans all the way through the framing through the plumbing through the electricity through getting it together and then they would sell it and the money would go back into the next year's project so. You don't have to if you look at the local vocational programs you don't have to avoid commercial type enterprises as long as you understand how the local folks are doing it and make sure that you're again staying as close to them as you came in. With with the residential schools have a little different set of challenges and of course Christian schools always have a little different view of some of the rules. The next to it integrated coursework and Educational Credit Now what this means is you need to have some classroom training because Department of Labor folks think school means classrooms. And actually if you look most of the local schools they they will have some level of classroom training most. It's safety most of them started out with a few days of classroom training about safety they emphasize safety all the way along but you know you kind of do the basics. Of this these are safety tests they may do a test on it but you don't have to have all classroom training but you need to have it when it's appropriate OK when you're starting with the basics. Next thing you have to do with these kids you have to have a program for a testing the skills that they have learned and giving them a grade. And sometimes now I know some states will have skills checklist that's what the kids are supposed to have learned at the end of the year it's not really a curriculum but that's how they test it. And vocational programs will do a check off list of the skill sets OK. You just have to have some way of measuring What skills did the kids learn in this carpentry class can't can they use the table saw safely can they put the. Nails in correctly you know what does the bird house look like kind of thing. So there has to be and I realize I don't put this down but it's assumed there has to be some documentation of it you know it doesn't have to be a pen and paper test but there needs to be something in the kids file that they learned this and they got this great. Then the next. Thing you have to track their progress. So one of the things that happens in smaller schools that has less manpower and I've I've I've seen this and I'll keep coming back to it because I've seen it be a problem and that is you you have kids who are let's just say you you put them they're doing dietician one and you put them in the program. And and they've they've learned it and then you put them in dietician to well. Come Thursday everybody's out and you don't have anybody to chop the vegetables let's not really but that's really part of the dietician one program not dietician too. But it's OK to do that for a day or two but you can't do it for a week because that child is losing educational time in what they're supposed to be learning OK The primary benefit of that situation is flowing to the school and not to the child again going back to if you put a kid in if they've gone from American lives to British will it and the teacher is out that day OK you have a substitute for a couple of days and everybody no substitutes don't really do anything except keep the kids quiet. And that's OK but she don't you don't cut him back to two weeks of reading Huckleberry Finn because that is not what British live involves OK so you have to follow that same principle of same guidelines with your vocation trying. Yeah. There. Is. A written test OK His question is is it is it OK to assess practical skills and not have written tests in vocational programs yes it is as long as the teacher has a checklist or some sort of documentation to say this is how I'm making the assessment the kid never has to put pen to paper if it's appropriate. Learning for them but but the person giving the grade and supervising needs to have some documentation of what Jane Smith learned and what she still needs to work on and what. Jerry Smith learned and what he still needs to work on OK. Think of it as. You know if you have tests in the academic program and you can use that and if the teacher decides to you know if they go on vacation at Christmas so they decide to get married and not come back then whoever picks up that class can go through the kids test and figure out what's going on OK OK tional program you don't need to test but the teacher from first semester needs to have some sort of documentation on this just for example on this list of fifteen skills this kid has learned ten of them they still need to practice the next five so there needs to be something that someone could pick up and go forward with. Yes. I want to. Right it could be a test for me like she said for safety if you don't. Tests can be appropriate they are just not required in vocational. Death Yes. Right exactly you have to track the proficiency and depending on what the skills are. All right the next one there we get. Is a successive curriculum and by this time mean you learn a first set of skills and then the second set of skills builds on top of us. So let's go back to two one that I know fairly well which is dietitian So you've got the kids generally what these programs to it's been a while since I've looked at it so correct me if I get any of the details wrong but generally dietician want you have kids who are learning how to chop vegetables your They're learning how to boil things that need to be boiled they're doing basic kind of stuff OK dietician too they start doing the garnishes they start doing a little more sauces they may seem to have a little you know more complex bread instead of the simple bread they start baking bread and then dietician three they start putting together their menus and start organizing and dietician three is where you generally see kids starting to supervise other kids make sure that the you know that the vegetables are getting chopped and that we have enough of them and and those kinds of things. So you. You want to look at a set of skills once the kids learn this then what is the second set of skills OK So woodworking you go from bird houses to coffee tables to draw wars in Cap Ex OK. Cabinets are basically boxes and diff but you learn how to do boxes and put them together in the cabinet. So rather than and the other area where I see sometimes there's problems is. It's spring the grass is looking really bad so it's time to put kids out from the gardening class out cutting grass OK cutting grass is important but is that all they're doing if they're in gardening one that may be OK if they're in gardening too then they're cutting the grass and they're doing the weeding because they're preparing it for the vegetable garden so they need to be at some point. Planting vegetables not just cutting grass does that is everybody following me what I'm talking about they're OK. Now. You need to track those of you who are in residential programs how many how many do we have who are in residential programs as opposed to OK So there's enough for all spend little time talking on this well eventually program you have chores that the kids have to do just as part of living there the dorms have to be cleaned up the this that and the other has to be fixed and then you've got the Sabbath duties OK which is things that have to be done. You know you still have to have the kitchen going. Minimally snap staff we still have to have it going and going during the Sabbath service. These are fine there's no problem with doing those and the Department of Labor has been brushed back enough times to where they're starting to recognize Look we've got these kids twenty four seven we have to do something constructive with them and character education is a big part of what we do and cleaning up after yourself is part of character education so this is not work this is education but it's not vocational education OK sweeping the dorms doesn't really teach them a career and technical skill so it's fine to do that but make sure that you're tracking it under the appropriate thing OK. Well. Yes yes you could do that you get to go back to Laura broke because they have the sanitarium they followed the same standards in the dorms so a lot of their training in the dorms was practice for. Health care facilities and the higher standards that you have there. The thing yes you could to design a curriculum that would encompass the stuff that you do in residential program but in order for it to pass muster as an educational program. Then again you have to you have to keep a list of things and then for example if one of the. Things on the list is changing the belt on the. Vacuum Cleaner OK you have to make sure that every child in the dorm changes the belt on the back plate not just when the vacuum cleaner is broken we fix it OK it has to be a very intentional training. And if if you teach them how to order supplies then everybody who's at whatever that level is has to have the opportunity to order supplies so when I hear you say is that resistance to our. Last. Areas if you put stuff dormant in there it's coming better to do the rounds right right right you don't have to residential chores as long as you are categorizing it correctly you don't have to follow all the educational requirements for stuff in the dorms just as long as you're very clear let's say for example that your school has a character grade OK Our citizenship grade or whatever make sure that the residential chores that the reports go into that bucket and not the vocational training bucket for example. OK. Yeah A So yeah he was first I think so it seems like because presidents or used them so yeah so many things that don't fall into either category of government labors or explain how do you differentiate normally persisted Britain because they've got to eat and go to live there and clean up after that even if you're not home you mean about a you can do dishes you'd probably hope. You know him so well plenty cleaning up in the kitchen can be part of the dietician one because good cooks clean up their kitchen. So so that's not a problem with that but we had it just looks. Quite the requirements for the issues with with the work because you know our philosophy imitation. Is the manual training yes. The skills that they learn specifically as it is the. Attitude they have towards We're right you know a lot of us here are probably schools right we we work on the day we weren't on the sanitarium we were. Going to be four hours a day I know you're innocent but there are the paperback three times I was a different generation Yeah yeah that was a small individual school so I'm not specifically I'm not going on we're going to crack. That's when I feel like there's a tension between we make it last few years we lose no you the last thing that we're trying to accomplish we're trying to treat the skills but it's really our philosophy use them. Manually is is what helps your academic right does it work so even if it might be skewed they're going to be better off because they. Write write everything you're saying it is. Perfect and I understand I get what you're talking about that the manual labor has character building. Aspects that are completely outside the skill set the problem is we have more regulations now than we did before. If it is not valuable for education. Then it's going to have to be after school hours for example because there's this sense that during school hours you need to be doing education school stuff OK so that's why I'm saying you just have to track it separately and and unfortunately it's because of the regulations so in a thing that is sorely character based. Has to be either a minority during the school day or it has to be outside the school day OK that that's just kind of one of those issues I'm sorry but if they're under sixteen yeah if they're sixteen you can do whatever you want to because they quit school that's the. No they they assume that it follows whatever the local times are. No it is long as it's close to what the local schools are doing and it is this is not a part of education system are going to work and so they just they just follow what the local schools are doing now let me make sure that you understand it is OK to have character building as part of your vocational education All right that is not a problem it is OK to say that once the kid learns how to mop the floors they have to mop the floors. For another six days because that's practice again it's the same the same thing. As doing algebra problems practice and character building are fine to incorporate into your program as long as there is enough skills for it to me to the general. Requirement you know whatever the standards are want the Ysaye curriculum or your state curriculum then you just have to meet the minimum that they are learning skills because that's the only way that it has any educational value Yeah. OK. Oh yeah yeah. Again as long as you're reviewing previous material for. For a educational purpose like OK these kids have forgotten how to mop floors so we're going to have to go back and re learn how to mop floors and that that is not nobody involved in education department labor assumes that kids remember everything from year to year that's one of the reasons are doing a big push now to shorten the Summers is because kids learned lose so much of their learning between June and September. So. But. The question is are you going back because they don't know it and you're reteaching it to him or are you going back because the floor is dirty and it's got to be cleaned. You say Is it because the institution needs the floor cleaned or because the child needs to read learn how to play in the floors that that's the distinction if it is the first which is often the order because the liver is of interest to you because they're. The best place in the past you have this category and there it is residential sure. Well it is a lose what is now it's not a it's not a really a classification as much as yeah in a residential program the floors got to be cleaned and to see that benefit kids because they're living there. So well you know but if we had. Some. Sort of ridiculous because it goes. Right right right I you know greeted me it was. You know right. It comes back to who is most benefiting OK so in a nonresidential program yeah kids need to be in a clean classroom but it's still the it's still the institutions responsibility to get it clean whereas in a residential program you have more obligations to keep kids busy and to teach them character in rez guess what I'm saying is a residential program we have a lot more leeway for non educational type requirements OK in a resin a nonresidential program they are there for education and and you need to track the education in a residential program you have some more. Than they do in the closest city with the he was in and it is. Those troops the leaders of. The spread it where you get in a bind is if you say oh we're teaching kids all sorts of skills like we teach them how to mop floors Well OK then my next question is are you tracking what they're learning are you tracking the hours is it part of a curriculum if the answer is no then don't claim that as an educational benefit it's character building it's something else if you're claiming it as an as an educational part of this. Integrated coursework and Educational Credit then you have to track it like it's a. Regular C.T.E. or. Academic program so they're. Just a little different track. I'm sitting here thinking about all this and so far and where my mind is this is. One of. These. Schools which we have clear else along our understanding no spirit prophecy and Bible teaching is the gear. I don't know that we have clearly of dynomite the curriculum but if we worked it clearly has been a high character development as a curriculum I know personally that my character still in process. For a lot of me so Character development is a continuum wild thing and right I think that there may be an opportunity for us here if we could really put it like character development as a specific curriculum something that we do different than anybody else because it is a part of the Council. And it's been essentially. If we listen to what we read it may be the most important thing when we put it where it should be develop a curriculum in order. To assess and to some degree what's happening with the character then yes I binged to be an open window here but from your standpoint if you were to stand up for the judge with her to go with. What could be well first of all you don't have to have a curriculum OK you can just say character development is part of what we teach it's important to was here. Cleaning the floor every Thursday teaches the character skills OK And here's how we observe it at this is why I keep going back to some schools give a citizenship grade or a character grade or whatever and it's done by the dorm folks that's fine this is this is not part of our we aren't claiming that this is a is a. Technical career technical education it is part of our character so if you want to have a curriculum. In the best way. To. Be able to. There's a part of her go to her heart. That will be her fixed higher. And. Just her and I well then then what you would well what you would do is the same way that you list skills as. Let's just say carpentry you would say at the end of the child will have learned how to safely use a table saw how to safely hammer nails how to safely so you got safety issues and then you got skills issues you can put into character development you know this program will teach kids patience you know whatever else we are it will Yeah I think it. Will be well yeah that's what this does it will it will teach the teacher is how to have patience. And so guess if you can if you know you can put the character development in because this is what makes the Madison school and the S.T.A. schools different from the public schools our public schools. Kind of making a effort at character development you know they have the word of the week and all this other nonsense. But so but you guys can put it front and center by putting it at the top of the curriculum. Want to. Write. Write write write write write write write. Write write and then you're. OK with. That. Right. Right right and you can you can do that let me make clear if you put character development in your curriculum you don't have to track that because it is it's difficult to track and because the day really doesn't care about that they care about if your. Or vocational credits that you're awarding are valid they want to know are the kids learning skills OK so that when they come in and say Is East ace curriculum real or is it made up they're going to say what kills What skills do they expect the kids to learn and that's how they compare apples to apples. Every Christian school I know has a and you know part of their mission statement is is spiritual growth to to serve the kingdom of God to raise kids to be. Good servants of God there's no way to measure that in the state knows there's no my way to measure that so you don't have to. Track that as part of the vocational grade it's it's good for you to put it in there because it shows where your priorities are but you don't have to track everything you just have to track the things that the state expects you to track. In this is religious and yes that character is our work in that gives us what's. Right as long as everything you say shows that it is a priority as long as it's not an after the fact thing and my whole point in all of this is whatever you do you have to be intentional from the beginning you cannot come up with this as an after the fact justification because if it's not in your material from the beginning then it doesn't look real. Yeah yeah. Oh oh. Into another. Bright and. Bright even or. Were. Ripe and I will say I want to know as I were raising our granddaughter now long story but she's fifteen and she was turning her nose up at career technical training. You know everybody's got to go to college until she found out what underwater welders make. Underwater welders they make really good money you know. Learn welding and learn how to scuba dive and there are jobs out there. Just a little bit worried about the school hours. I haven't been. In in the teaching but as a student I went from the deep to three school system to a study system. Started at seven which was with me worked in the afternoon do we have flexibility to have programs yes yes you can't you can you can have your educational program any time of the day you want OK. If it if it starts looking like it's not education then you get into all of these restrictions but as long as it's an education program you can do whatever it is you have it whatever you want it can be it can be from seven to twelve and one to six or just whatever whatever works for you the thing is it has to look like an educational program and it has to have the hallmarks of an educational program and that. Got ten more minutes to let me see how many of these I can run through they in order for it to have the hallmarks of an educational program these a thing it has it has to have a path. To the about I said Sabbath services and Sabbath duty by the way OK please quit talking about work programs. They are NOT work programs they are vocational classes or vocational education or career C.T.E. or. They're just not work. And just. To get rid of that go through every piece of paper you have everything that goes out and make sure they have academic classes and vocational classes. And character trait if you want to track character training separately you can but again I think the overarching. To go back to one thing you were saying Steve about the the academics are part of your character training then you need to put character training in as the academics what will kids learn from the south class so if we're going to start putting character goals in vocational programs it needs to be in the academic goals to. Or it could be just kids will learn to use their spiritual gifts I mean it can be any number of things it just just need to make sure it's intentional. Just remember it's education it's a different kind of education. Connection to the academic calendar duration limited to the training period I think we've talked about that one of the things that and I'm sorry calling it Sabbath service and I know it's different but anyway summer work a lot of the residential programs have kids come in before school starts or has them stay late or again you've got to assess why that is are you tracking that for an educational curriculum. Or is it because you need extra pair of hands. Yes Yeah as long as there's a benefit to the kids I mean that if you want to do agriculture you have to be there during the summer that's and that's just the you know the real world is the real world. But. Yes because then it becomes work if they're earning money it becomes work and you're under the Fair Labor Standards Act So you have to pay minimum wage have to pay overtime and you're you're limited with hours and and what people. Say yeah that same it the regular jobs. They don't have the school hour restriction but they do have the what under eighteen can do kids under eighteen cannot used use any tools that use power but no power tools and actually could and they can't participate in anything that you sell because that becomes an industry there's a lot of rules if you're going pay them during the summer if you're in a hole and that would take another hour to explain everything but it's a completely different ballgame than what we're talking about here. What. We. Are very. Mean and. That's problematic because then you need to be paying them for that on agriculture stuff and indeed be paying a minimum wage. But. Going back to the recreational training OK. But I gan if it's if it's successive are they they come into work and they're there doing things and then they go to their vocational training is the success of training are they just repeating the things that they've already learned it's OK if they've not gotten credit for what they've learned and now they're going through a more traditional curriculum and getting credit for it. That's fine they don't really look at that as long as the vocational piece tracks the vocational requirements. Yes but what you're describing is not an education program a straight work program straight work program it minimum wage their employees and they're entitled to minimum wage if you're going to have an education program then you have to have the you have to track and you have to have a success curriculum in those kinds of things. Or. A higher sense of vigor. Or not I have not seen that with with international students I've not seen the department labor worry more about that then not international students. The only thing is you may have to do some remedial English with them or even sell classes but that's an academic issue and not a not a vocational issue so you you can hold them and track their progress the say so actually it's a little easier with the occasional than it is with English to track their skills. Residential chores again you can do those any time. And the character training I think we've all we've already discussed. The last one doesn't just place the paid employees. So you have to keep the areas fully staffed with adult employees that void the pay because I understand some of you have members of the religious order assigned tasks according to the curriculum not we need two students in the kitchen today or it's time to mow the lawn so we're going pole students out and have them mow the lawn you need to put the kids in a curriculum and follow it as much as you can. You you can do it nine weeks by nine weeks it's possible to do it week by week with it is extremely difficult it's really difficult to do that from educationally sound basis so you just need to again go with one of the kids learning what do they need to learn and if you have an opportunity for them to learn something today that they couldn't learn last month that's fine as long as it's an educational thing and not just a we need this chore done and we need some hands to do it. And that's it here's my contact information feel free to. Call me. Cell is really the best place to get hold of me I'd say that yes it was. Just. One on services. Like. Three. She was asking about students volunteering. I'd have to look at that it's again it's problematic if you're if they're doing it and they're getting some sort you need to come up with some sort of credit or some sort of something that they they earned for their volunteering. In is is not going to be the same you just have to make it very clear in your paper work this is this is an internship you call it internship not because training your your this this would be how you would do is I'm thinking it through it's an internship it's not because training it's a completely different and you're not getting paid you're doing this for the skill and in exchange for the skills and whatever recommendation we give you at the end of. The time that would be just a straight unpaid internship as long as again if they were to quit tomorrow you could still handle things without them. Because that gets back to the deployment displacing other workers. So you just have to you don't have to track it with an internship you do have to be able to defend it that it benefited them more than it benefited us. For. Any other questions. The world gets more complicated it's not as easy to do the Madison schools as it was when the Madison school started but it is still possible and it's still worth doing so if I can help any of you do it let me know that's my that's where you find me are David want always know where to make. This media was brought to you by audiotapes a website dedicated to spreading God's word through free sermon audio and much more if you would like to know more about audio or if you would like to listen to more sermon leave a Visit W W W dot audio dot org.


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