Methodology

Below, we describe our three-phase methodology for the report: (1) data compilation, (2) report card scoring, and (3) report card analysis. A more detailed description, including how the publicly available spreadsheet was built and a more detailed scoring methodology, can be found in Appendix II.

Subminimum wage data have been historically difficult to find and analyze, involving the compilation of a significant amount of data from multiple sources.

We gathered data from the DOL’s Wage and Hour Division,¹ which is made freely available to the public quarterly regarding the status of subminimum wage across the country. In addition, we used data from state participation in the Disability Innovation Fund,² Employment First Initiatives,³ Medicaid expansion,⁴ and ABLE programs.⁵ We also examined states’ websites to find policy efforts on the use of subminimum wages and evidence of benefits counseling. We were interested in whether (a) Work Incentives Planning and Assistance (WIPA) and (b) other benefits counseling programs are partly available or offered statewide.

Once the data were compiled, we scored each state for the report card on four categories: (1) policy engagement with subminimum wage, (2) use of subminimum wage in state from 2018 to 2023, (3) proactive employment policy and funding initiatives, and (4) support for individuals’ financial security. A rubric, found in Appendix III, was developed to track and score each category. Figure 1 provides detail on the category makeup and the rating breakdown.

After each category was scored, total state scores were calculated by computing the average score across the four categories, giving a final report card score for each state.

After we scored each state, we developed a set of new data sheets to display the data, review the category scores and final state scores, and send the preliminary data for peer review. Our findings are described below in detail.