Hosting an Internship or Work-Based Learning Placement: An Employer's Guide to Try Before You Hire

The question we hear most often from employers who are genuinely open to inclusive hiring is not “why should we?” It is some version of is there a smaller first step? There is, there are several, and one of them can be run at no wage cost to you — which is the part almost nobody knows.

We have written about apprenticeships and on-the-job training from the job seeker's side. This is the employer's side, and it starts from a real and reasonable hesitation: a permanent hire is a permanent commitment, and if you have never employed someone with a disability before, you may not know what you do not know. A trial structure is a sensible answer to that, and it is also usually better for the candidate, who gets to find out whether the job suits them before either of you is locked in.

General Guidance, Not Legal or Tax Advice

This is a plain-English map of programs and structures — not advice for your business, and not a guarantee any program will approve any particular placement. Eligibility, funding, and program rules vary and change. Confirm current terms with each agency before you commit, and run wage-and-hour and tax questions past your own counsel and accountant. We are a placement service, not a law firm or a tax advisor.

The Structures, Defined Precisely

These terms get used interchangeably and they are not interchangeable. The differences decide who pays, who is on your payroll, and what you are agreeing to at the end.

Work Try-Out
A short paid trial run through New York's vocational rehabilitation agency, used as an assessment. The person goes on your payroll, and ACCES-VR reimburses the wages. No commitment to retain.
On-the-Job Training
Longer, and aimed at skills rather than assessment. Also your payroll, also reimbursed — but here the business agrees to retain the trainee at the end. That is the trade for the longer runway.
Internship
A fixed-term role, usually tied to a school or program. Paid internships at for-profit businesses are straightforward. Unpaid ones are a genuine legal question — see below before you consider one.
Registered Apprenticeship
A formal, structured program combining paid work with instruction, registered with the state. The most involved option and the least like a trial — it is a hiring pipeline, not a try-out.

If your actual question is “can we see how this goes without committing,” the honest answer is that the work try-out is the structure built for exactly that, and the rest are something else.

The Part Most Employers Don't Know About

New York's vocational rehabilitation agency, ACCES-VR, runs two wage-reimbursement programs for businesses. As currently published:

  • Work Try-Out. ACCES-VR can reimburse a business for 100% of an employee's wages for up to 480 hours. The agency's own language is that reimbursement occurs whether the employment outcome is successful or not — meaning you are reimbursed even if you do not keep the person. That is the single most important sentence in this article, and it is the one employers are most surprised by.
  • On-the-Job Training. 100% wage reimbursement for up to 26 weeks. If training needs to run longer, extensions are approved at a 50% rate. In exchange, the business agrees to retain the trainee on completion.

Read together, those two describe a fairly generous ladder. The try-out lets you find out. The training program funds the ramp-up once you have decided. And in both cases an agency partner is handling the recruiting, the screening, and the paperwork, which is the other cost employers tend to underestimate.

Check the Current Terms Before You Rely on Them

The governing policy document for both programs, ACCES-VR policy 1375.40, is stamped “Revised October 2018.” The figures above are what the agency currently publishes, and we have quoted them as such rather than as promises. Before you build a plan around a reimbursement rate or an hour cap, call the district office and confirm what applies today. Buffalo District Office: 508 Main Street, Buffalo, NY 14202, 1-888-652-7062 or (716) 848-8001.

What You Actually Take On

Reimbursed does not mean hands-off. For both programs, the obligations are real and worth knowing before you say yes:

  • The person goes on your payroll, covered by all benefits including Workers' Compensation and Social Security. You are the employer, not a host site.
  • You follow ordinary labor standards. This is a job, with the same rules any other job has.
  • You write progress reports. At minimum monthly, submitted to the ACCES-VR counselor, along with evidence that wages were paid. The reports are meant to be an honest assessment of how the person is doing, which means someone on your side needs to actually supervise and observe.

That last one is where placements succeed or quietly fail. A supervisor who has been told this is “a program thing” produces nothing useful; one who treats it as onboarding a new employee produces a real assessment and usually a real hire. Our manager's onboarding checklist applies here from day one.

A Note on Project SEARCH

Employers sometimes ask about Project SEARCH by name, so it is worth describing accurately. It is a business-led model that began at Cincinnati Children's Hospital and now reports 800+ active sites worldwide with 72% of graduates achieving employment. The structure is an intensive academic year of career development and internship experience, hosted within a single business.

It is a serious commitment rather than a trial — a host business dedicates space and a year of programming, in partnership with a school district and a vocational agency. If that interests you, check the official Project SEARCH site locator for the nearest program rather than assuming there is one nearby; sites are not evenly distributed, and the closest one to Western New York may be a considerable distance away. For an employer looking for a smaller first step, the ACCES-VR programs above are the better starting point.

The Tax Credit Picture, Honestly

This section would have looked different a year ago, and getting it wrong is expensive, so here it is plainly.

WOTC Is in Hiatus — Do Not Budget 2026 Hires Around It

The federal Work Opportunity Tax Credit lapsed on December 31, 2025. The IRS states the credit applies to individuals who “begin work on or before December 31, 2025,” and New York State DOL says the program “has now gone into hiatus.”

For start dates on or after January 1, 2026, New York will accept applications, but state workforce agencies may not issue certifications for those requests until further notice from the federal Employment and Training Administration. In practical terms: no certification, no credit, for now.

Keep filing anyway. Form 8850 still has to be submitted within 28 days of a start date, and WOTC has lapsed and been retroactively restored several times in its history. Filing preserves your position if Congress reinstates it; not filing forfeits it. Just do not count the money yet. Note that some general state “hiring incentives” pages have not been updated to reflect the hiatus — the dedicated WOTC page is the one to trust.

New York has its own separate credits, and they are genuinely separate programs with different forms, different rules, and restrictions on claiming more than one for the same employee:

  • The Credit for Employment of Persons with Disabilities (Form IT-251 or CT-41).
  • The Workers with Disabilities Employment Tax Credit, or WETC, which applies to second-year wages.
  • The Workers with Disabilities Tax Credit program, or WDTC (Form IT-644 or CT-644).

Two cautions. First, these are commonly conflated with each other and with WOTC, and they are four different things — check which one you are actually claiming. Second, WETC is keyed to WOTC certification, which raises an obvious question about 2026 hires given the hiatus. We have not found an official source addressing that interaction, so we are flagging it as genuinely open rather than guessing at an answer. Take the specifics to your accountant, and see our fuller write-up of employer tax credits.

If You Are Considering an Unpaid Internship

Short version: talk to your employment counsel first.

At a for-profit business, whether an unpaid intern is legally an intern or an employee owed wages is decided under the U.S. Department of Labor's primary-beneficiary test, set out in Wage and Hour Division Fact Sheet #71. It weighs seven factors, no single one of which is determinative, and it turns on who is the primary beneficiary of the relationship. It is a fact-specific analysis and not something to eyeball.

Our practical view: given that ACCES-VR may reimburse 100% of wages for a work try-out, the case for an unpaid internship at a for-profit is weak anyway. A paid placement is cleaner legally, better for the person, and potentially costs you the same.

How to Start

The first step is smaller than it sounds. You do not need a program, a policy, or a budget line — you need one real role and a phone call.

  1. Pick an actual job. Not a made-up one. Placements built around invented busywork fail, because everyone can tell.
  2. Decide which question you are asking. “Can this person do this job?” points to a work try-out. “We want to hire, they need to learn the role” points to on-the-job training.
  3. Call a partner rather than the paperwork. An agency partner handles the recruiting, screening, coaching, and forms. That is the part that stops most employers, and it is the part you do not have to do.

If you are not sure what partnering looks like in practice, we wrote about what to expect when working with a placement service. And if you would rather just ask someone, that is what we are here for.

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Start With One Placement

We handle the recruiting, screening, coaching and paperwork, and we have been doing it in Western New York since 2001. Tell us about the role and we will tell you honestly whether we have someone for it.