
Illinois is moving forward with a multi-year plan to phase out the use of 14(c) subminimum wages, a policy approach that diverges from the long-standing federal structure that allows pay below minimum wage under specific conditions. The change, framed publicly through the “Dignity in Pay” effort, comes with transition supports aimed at helping providers shift away from subminimum-wage labor models. Axios recently highlighted Illinois’ implementation arc and pointed to a Chicago-area example that already reflects the direction of travel.
Illinois’ “Dignity in Pay” timeline
The Illinois Council on Developmental Disabilities’ Dignity in Pay page describes the Dignity in Pay Act (HB 793) as a “5-year path” to end subminimum wages in Illinois. Under that timeline, the permission to pay below minimum wage ends starting December 31, 2029. The same implementation materials emphasize a transition program for 14(c) providers. As described, the program is designed to provide funding, training, and support to discontinue subminimum wage labor, signaling that the policy change is paired with operational assistance rather than an abrupt cutoff.
Medicaid and benefits elements tied to the shift
The Illinois Council on Developmental Disabilities also links the phaseout to Medicaid actions. Specifically, it cites a requirement for HFS and IDHS to file a Medicaid waiver amendment to increase small group supported employment rates. In addition, the Dignity in Pay page notes an increase in the Personal Needs Allowance for 11,000+ CILA residents. That allowance rises to $100 per month beginning January 1, 2025.
Federal 14(c) context and what changes in practice
At the federal level, 14(c) certificates authorize subminimum wages under the Fair Labor Standards Act through a certificate regime that includes application and compliance requirements. That framework also carries potential consequences, including revocation and back-pay liability. Illinois’ move reflects a broader tension in disability employment policy: how to protect opportunities while moving toward wage equity and community integration. Axios’ coverage underscored that tension by spotlighting HB Threads, a Chicago-area business connected to Easterseals. The example is presented as an integrated business environment that already pays above minimum wage and hires autistic workers.
Operational and workforce implications for IDD agencies
For agencies that operate employment or day program service lines, the transition away from subminimum wages can require program redesign. The shift often involves a pivot toward supported employment, building employer partnerships, expanding job coaching capacity, and coordinating transportation, which can strain organizations built around sheltered work or work center models.
The impacted groups extend beyond workers and employers. Affected populations include workers with disabilities in settings that have historically used 14(c), provider organizations operating sheltered work or work center models, supported employment providers, and individuals in residential programs such as CILA who are touched by connected benefits policy. Workforce implications include both increased wages for disabled workers and increased staffing needs for job development and community supports. Providers that can demonstrate integrated workforce success stories like the example Axios profiles may also see reputational and partnership advantages.

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