[AccessD] Filter text containing ampersand requires apostrophes?

When I needed to filter a datasheet subform on a certain field, I ran into a
case where the text filter had an ampersand
    Florida Power & Light Company

Access refused to find the record when I entered exactly that in the text
box that comes up when I choose the Equals... menu from the right-click,
until I put apostrophes around it.

I cannot understand why the Access interface requires apostrophe -- just
because there is an ampersand in the midst of the string.

I don't think users who are not programmers are going to know about that,
will they? More likely to conclude the field value is absent?