Internships provide unique and valuable experiences for students both academically and in professional career preparation. The term internship encompasses many different program models for example; paid and unpaid, full time and part time, as a requirement of an academic curriculum or a course option, for academic credit or no credit, and of varying lengths. The broad use of this term to cover diverse circumstances makes it difficult to apply common and consistent standards, guidelines, and applicable policies. The criteria and oversight of these experiences vary widely among institutions of higher education and employers in the United States. Therefore, what constitutes an internship is determined in the final analysis by the student s educational institution and the employer. The purpose of this document is to set forth the definitions and guidelines of the Lee County Student Internship Program. What is the purpose of the Student Internship Program? Lee County Government s Student Internship Program offers a variety of internships for students ranging from high school through graduate school level. The program places talented students in departments throughout the County that are compatible with their field of study and areas of interest. This experience facilitates the transition from formal education to the work force. Interns can utilize the knowledge and skills acquired through their educational process and obtain valuable work experience and exposure to government functions. How does Lee County define Internship? Because the parties involved in the internship process students, academic institutions, and the employer, have differing objectives, it is important to have a definition of internship. In 2010, the National Association of Colleges and Employers (NACE) developed a framework to define the internship experience. To establish uniformity in the use and application of the term internship, we will use the following NACE recommended definition as a guideline: An internship is a form of experiential learning that integrates knowledge and theory learned in the classroom with practical application and skills development in a professional setting. Internships give students the opportunity to gain valuable applied experience and make connections in professional fields they are considering for career paths; and give employers the opportunity to guide and evaluate talent. To effectively implement this definition, it is necessary to develop criteria that we can use to identify workplace experiences that can legitimately be identified as internships. To ensure that an experience is educational, and thus eligible to be considered a legitimate internship, the NACE definition dictates that all the following criteria must be met: 1. The skills or knowledge learned must be transferable to other employment settings. 2. The experience has a defined beginning and end, and a job description with desired qualifications. 3. There are clearly defined learning objectives/goals related to the professional goals of the student s academic coursework. H:\Interns\Lee County Student Internship Program - 103017.docx Page 1 of 5
4. There is supervision by a professional with expertise and educational and/or professional background in the field of the experience. 5. There is routine feedback by the experienced supervisor. 6. There are resources, equipment, and facilities provided by the host employer that support learning objectives/goals. Should an internship be Paid or Unpaid? Both paid and non-paid (academic credit only) internships are available. While the FLSA doesn't define what an intern is, nor does it indicate any specific criteria for non-profit organizations, under federal law, organizations must pay workers unless the position fits six criteria: 1. The internship, even though it includes actual operation of the employer s facilities, is similar to training that would be given in a vocational school. 2. The internship experience is for the benefit of the student. 3. The intern does not displace regular employees, but works under the close observation of a regular employee. 4. The employer provides the training and derives no immediate advantage from the activities of the intern. Occasionally, the operations may actually be impeded. 5. The intern is not necessarily entitled to a job at the conclusion of the internship. 6. The employer and the intern understand that the intern is not entitled to wages for the time in the internship. The DOL states that all six factors must be met for someone to be deemed a trainee (unpaid intern for our purposes); however, the courts commonly find that the most important determinant is who primarily benefits from the arrangement. If the employer is the primary beneficiary, the individuals will be considered employees and must work under a paid internship. To ensure compliance, when offering unpaid internships, departments should structure the position in a way that the intern receives the full benefit of the experience. We also recommend establishing a written agreement between the Lee County and the intern outlining the terms of the unpaid internship. The document should contain a clear definition of the position, including verbiage that states that it is a learning experience. Unpaid internships that do not match all six of the DOL's criteria could also lead to legal problems involving workers' compensation, employee benefits, discrimination laws, federal and state taxes, and unemployment insurance coverage. If the Internship is Paid, what rate should be used? The Intern salary level will be determined by the highest level of education completed as well as the applicant s experience (work, volunteering, etc.) and the budget of the department for which the intern will work. The Intern salary range, regardless of High School or College status, is salary $20,863.00 to $41,325.00 When should a student be hired as a Temporary or On-Call employee in-lieu of an Internship? H:\Interns\Lee County Student Internship Program - 103017.docx Page 2 of 5
An internship is a legitimate learning experience that emphasizes exposing students to the career field and providing valuable mentorship opportunities; not simply an operational work experience that just happens to be conducted by a student. The experience must be an extension of the classroom and it is important to ensure that the interns receive the primary benefit from the experience. The intention of the internship must not be simply to advance the operations of the employer, or be the work that a regular employee would routinely perform. Common examples of when a student should instead be hired as a supplemental employee (On-Call or Temporary) include: The employer uses the student as a substitute for regular workers or as a supplement to its current workforce. If not for the student, the employer would have hired additional employees or asked its existing staff to work additional hours. The student is engaged in the employer s routine operations and/or the employer is dependent upon the student s work. Who funds the Student Internship Program? Since all funds for both high school and college intern pay come from the hiring department s budget, the number of paid internships available may vary depending upon fiscal constraints and departmental needs. Non-paid internships can usually be arranged with proper notice. When can I offer an Internship? While most internships are usually conducted during the summer months, internships can be made available year-round and tailored to fit the student s schedule. How many hours per week may an Intern work? Each department will determine the number of hours their Interns will work based on their department budget and the criteria set forth by both the student and their associated educational institution. How long should the Internship last? A student intern may be employed for a period of two calendar years as long as they demonstrate Active Student status throughout the two year period. Upon completion of two calendar years or when Active Student status has ended, the department must either terminate the Internship or move the individual to another approved position (On-call, Temporary, or a regular Part-time or Full-time position). Who is eligible to apply for an Internship? Any student who has completed the 10 th grade in high school and is currently enrolled in school (High School or College) is eligible for the Student Intern Program. In order to be considered for employment, students applying for internships MUST submit all of the following: A completed Student Intern Application with an attached resume (application attached). 3 letters of recommendation (from teachers, coaches, clergy, guidance counselors, employers, etc.). H:\Interns\Lee County Student Internship Program - 103017.docx Page 3 of 5
o If a college student is referred to Lee County directly from their academic institution, the requirement for 3 letters of recommendation may be waived. A current school transcript showing Active Student status and any past transcripts (if a college degree was earned). A letter submitted by the intern as to what they expect to learn and achieve as a result of their internship. Note: Active Student status must be maintained for the duration of their Internship. Other than the student s grade level, are there any differences between High School and College Internships? Yes. In simple terms, the focus of the High School Internship should be exposure to general business practices in county government within the students field of interest. The focus of the College Internship should be exposure to more specific career opportunities in county government within the students area of study. How do I hire an Intern? There are three ways: 1) An interested department creates a requisition for an Internship through our NEOGOV system to allow for job posting and on-line application processing. 2) A department identifies a prospective Intern through their own methods. Simply complete an Intern Request Form (attached) and submit to Human Resources. 3) A student completes and submits an unsolicited Intern Application to Human Resources. Our office contacts the department we have identified as a potential match to determine if they have an interest in creating an Internship opportunity. If so, the department will complete an Intern Request Form as outlined in Step 2 above. Whether through a formal job posting or the completion of an Intern Request Form, interns hired by a department must be presented with a specific scope of work and performance objectives. As required for regular positions, all intern positions need to be approved by Senior Management just as regular positions do. These approvals must be provided to Human Resources prior to processing the position. Furthermore, once a department is ready to hire an intern, an Intern Intent to Hire package needs to be submitted to Human Resources. What are my responsibilities to the program after I hire an Intern? Departments are responsible for ensuring their Interns are actively enrolled in school throughout their internship. Also, though the students are ultimately responsible for ensuring they receive academic credit from their academic institutions, at the conclusion of the internship, supervisors should assist in providing any documentation needed for the student to receive the credit they desire. After review with the student, supervisors should also complete and submit an Intern Evaluation Form to Human Resources. Does Lee County have a specific policy regarding interns? Yes. Policy 309 - Supplemental Workforce states: H:\Interns\Lee County Student Internship Program - 103017.docx Page 4 of 5
A student intern is hired by the County with the intention of providing opportunities that will equip students with practical, real-world work experience to help them transition into a future professional career. The program is designed to attract, develop and retain our interns in local government. An intern may work either regularly scheduled hours, or unscheduled irregular hours throughout the course of their internship. An intern may remain employed for no longer than two (2) calendar years, providing they demonstrate active student status throughout the course of their employment. It is our hope that this document will help departments reach a clear understanding of the expectations associated with Lee County s Student Internship Program. Not only serving as a FAQ, our objective is to provide departments with a functional resource to assist in the process of how an Internship should be defined at Lee County. Furthermore, once a determination is made to proceed with an Internship, it is our goal that this document serves as a reference tool to help departments determine if the internship should be paid or unpaid. If you have any questions, please feel free to call the Human Resources Department at 239-533-2245 or email us at HR_Staffing@leegov.com. H:\Interns\Lee County Student Internship Program - 103017.docx Page 5 of 5