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Other presidential directives — memorandums, administrative guidance letters and many others — can achieve the same results.
Instead, OCR has issued several guidance letters whose legal status is questionable.
In California, officials have issued guidance letters advising employers whether they are breaking the law, while Oregon regulators have unearthed numerous abuses.
Late last week, the DWP said fresh guidance letters – required under the law – were being sent to hundreds of thousands of jobseekers placed on the government's Work Programme, the Work Experience programme and a handful of smaller schemes.
However, department spokeswoman Jessica Smith pointed to guidance letters drafted by federal prosecutors in California, Illinois and Arizona which characterized dispensaries, in general, as drug traffickers.
OCR's 2010 Dear Colleague letter on bullying and harassment, Lhamon said, was based on previous guidance letters that did go through notice and comment periods.
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The key words to look for in a guidance letter are "terms that are mutually agreeable to both parties," and "subject to review from time to time".
The California agency's guidance letter involved Year Up, a program based in San Francisco that aims to develop basic job skills in information technology for 18-to-24-year-olds 18-to-24-year-olds 18-to-24-year-olds 18-to-24-year-olds 18-to-24-year-olds
A guidance letter sent Monday says it would be inappropriate for employers to send such warnings because of uncertainties about if and where the $110 billion in automatic cuts might occur.
Mr. Balter cited another guidance letter that said film studios should pay college students who do routine work like delivering messages, filing tapes and clipping newspaper articles, partly because the work was so similar to that of regular employees and could displace such employees.
In May, the Education Department issued a national guidance letter advising all schools and colleges that, under federal law, they "must allow transgender students access" to restrooms, locker rooms and dormitories that fit their "gender identity".
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