Policy
Purpose: 

The University of Kansas sponsors a wide variety of educational opportunities and community outreach to support education, learning, service, and research.  The importance and benefits of internship experiences for KU students include:

  • heightened student engagement, retention, and success;
  • greater value to their higher education experiences;
  • enhanced opportunities for attainment of, and engagement in, initial and long-term employment; and
  • higher levels of success in their professional and personal lives.

These guidelines assist faculty, administrators, and participants in guiding and directing an unpaid internship experience sponsored by KU where a KU faculty or staff member directly supervises the activities.

Applies to: 

KU students serving unpaid internships sponsored by KU where a KU faculty or staff member directly supervises the activities.

Campus: 
Lawrence
Edwards
Parsons
Juniper Gardens
Yoder
Topeka
Policy Statement: 

According to the National Association of Colleges and Employers, “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.”

Guidelines to determine if an individual is an Intern or Employee

Human Resource Management (HRM), in consultation with appropriate administrative offices, and the Office of General Counsel has the authority to determine whether services provided to KU represent an intern, volunteer, or an employment relationship pursuant to applicable laws and regulations.

In general, an unpaid intern is one who:

  • Receives training that is similar to what would be given in an educational environment whether it is for academic credit or not.
  • Performs services primarily for the intern’s own benefit. 
  • Does not intentionally displace regular employees but works under their supervision. 
  • Produces no more than minimal business or operational value to the University. 
  • Understands that the intern is not entitled to wages, benefits or other compensation in connection with the internship.
  • Is not entitled to a position with the University at the conclusion of the internship. 

Restrictions to Internships

Any KU student may become an intern at the University with the following restrictions:

Individuals under the age of 14 may not serve as an intern. Individuals who are at least 14 years old but under the age of 18 must have parental consent.

Interns who do not hold U.S. Citizenship or permanent residency should consult International Student Services for any information related to visa status. An individual with a pending H-1B visa application to work at the University may not serve as an intern at any time.

Unit Responsibilities to Sponsor Interns

Units interested in providing internship opportunities are responsible for the following components for the intern experience:

Units must properly screen, train, engage and supervise the intern since interns may have access to sensitive data or other conditions.  Training includes all required safety and compliance training either based the tasks being performed or by University policy (e.g., FERPA, HIPAA, research requirements, compliance requirements, conflict of interest, sexual harassment, or other training appropriate to working with minors or vulnerable populations).

Unit is responsible for developing a written description of the internship prior to the commencement of the internship with clear expectations and/or program outcomes and noting such in a Learner, Research or Internship Agreement.

Units establish internships for a fixed duration of time not to exceed 13 months and not to exceed 15 hours weekly during the academic year or 25 hours weekly during the summer months unless HRM, in consultation with appropriate administrative offices, authorizes an extension or more hours weekly.  Internships should accommodate other established academic commitments to ensure progress toward degree completion and otherwise take into account the academic calendar. The prescribed time-period and must be set forth in the Learner, Research, or Internship Agreement. 

Interns may have access to University resources as necessary to the provisions of and as specified in the Learner, Research, or Internship Agreement. The unit is responsible for the prompt termination of access to University resources at the conclusion of an internship.

The appropriate administrative authority of sponsoring schools or units must approve and track interns as described herein. Schools and units will make information regarding their interns available to central administrative offices if requested.

An internship cannot circumvent the established processes that govern University hiring. Intern status cannot avoid or defer compliance with employment eligibility requirements of federal immigration laws, including allowing an individual to volunteer in situations without work authorization or if work authorization is pending.

Interns will be required to have a background check completed prior to the launch of the intern program if assignments involve access to:

  • minors,
  • populations deemed by KU to require enhanced supervision or protection,
  • and/or facilities or records requiring special clearance.

International students not residing in the U.S. for 30 days or students under 18 years of age are not required to complete a background check.

Interns cannot work in the same unit as a member of the intern/trainee’s immediate family or the same household without advance approval from HRM.

An immediate family member or someone of the same household cannot supervise the intern/trainee; nor can such a member make decisions about placement or the terms of the conditions or placement.

Unit staff, faculty or other designation officials must supervise interns. Interns may not supervise employees (including student hourly) or another intern or volunteer if not in a paid status.

Intern Responsibilities

An intern must complete and sign a Learner, Research, or Internship Agreement and other associated forms, agreeing to the terms and the scope of the internship.

Interns must conduct themselves consistent with standards of professional behavior common to all University and unit staff. 

All University interns must abide by all applicable University policies and internal/external regulations governing work actions, including, but not limited to, policies prohibiting discrimination and harassment and violence in the workplace, as well as policies regarding the use of technology and treatment of confidential information.

Interns do not have an employment relationship with the University on any grounds. The Fair Labor Standards Act, State of Kansas Wage and Hour Laws do not cover interns. Interns are not eligible for University sponsored benefits available to student employees.

Exclusions

Interns are prohibited from performing the following activities unless an exception is granted by HRM:

  • Performing service activities for which they are paid as employees,
  • Operating heavy equipment, including State vehicles,
  • Working with stored energy (steam, electricity, hydraulics)
  • Activity considered inappropriate for any employee
  • Has entered into a paid Contractual/Consultant Agreement with the University
  • Working with infectious or potentially infectious agents, including bodily fluids
  • Working in a DEA registered facility

Individuals must be 18 years of age to perform the following activities in an intern capacity unless specifically approved in advance by HRM:

  • Laboratory Work
  • Professional services, such as those performed by accountants, architects, engineers
  • Services involving any kind of travel
  • Services involving working with animals
  • Services working with or requiring access to confidential information
  • Services involving working with minors, patients, human subjects
  • Public speaker on behalf of the University
  • Museum gallery guide

Internship Discontinuance

The unit sponsoring the internship or HRM may decline and/or discontinue the internship at any time and without advance notice. Similarly, the intern may end service at any time.   

Exclusions or Special Circumstances: 

Interns do not include KU students performing services for student, campus, or community organizations registered with the Student Involvement and Leadership Center or human subject research participants as authorized by the Human Research Protection Program.

This policy does not apply to KU students required to serve internships with course credit as part of their academic program completion who are supervised by KU faculty and staff or employees its affiliated organizations.  

An unpaid intern should not be confused with a volunteer.  A volunteer is one who donates services for civic, charitable or humanitarian reasons or for personal purpose or pleasure and who derives no substantial or material benefit or advancement, other than altruistic satisfaction.

Consequences: 

Department heads of units utilizing interns are accountable and responsible for compliance with this University policy and may be subject to disciplinary action for the unit’s failure to comply.  Supervisors are obligated to assure that interns conduct themselves consistent with standards of professional behavior common to University expectations.

Contact: 

Department of Human Resource Management
103 Carruth-O’Leary Hall
1246 W. Campus Road
Lawrence, KS 66045
785-864-4946
hrdept@ku.edu

Center for Undergraduate Research
151 Strong Hall
1450 Jayhawk Blvd.
Lawrence, KS 66045
785-864-5733
cur@ku.edu

University Career Center
320 Anschutz Library
1301 Hoch Auditoria Dr.
Lawrence, KS 66045
785-864-3624
ucc@ku.edu

Approved by: 
Provost and Executive Vice Chancellor
Approved on: 
Tuesday, June 13, 2017
Effective on: 
Saturday, July 1, 2017
Review Cycle: 
Annual (As Needed)
Keywords: 
Intern, volunteer, student, unpaid, assist, train, student intern
Review, Approval & Change History: 

06/19/2017: New policy

Personnel: Affiliates/Volunteers Categories: 
Hiring
Workplace Rules & Guidelines

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