Since the School-to-Work Opportunities Act was passed in 1994, there has been debate over whether sufficient numbers of employers can be recruited, in order to create a national school-to-work system with the substantial work-based learning component the legislation calls for. Recent research on the question has had mixed results. In order to obtain more information, a 3-year research project focused on the question. Field work was conducted at 12 school-to-work programs. The study found that many employers are being recruited successfully; in fact, the recruitment and retention of employer partners was not the primary barrier in the implementation of the programs studied. Rather, student recruitment and parent, teacher, and counselor buy-in were all found to be significant obstacles interrelated with the problem of employer participation. There appear to be trade-offs between employer participation, student demand, and program quality. In addition, employer motivations for participation are rarely pure but are mixed and can change over time. The study concluded that employer participation cannot be studied separately from other program features and concerns. (Contains 22 references) (Author/KC)