Posting an On-Campus Internship

The CCD uses three Standards for vetting an internship experience submitted for credit:

• Standard 1:        The internship meets Department of Labor guidelines outlined for unpaid internships (CCD applies these to all internships regardless of compensation).
• Standard 2:        The internship meets policy set by the National Association of Colleges and Employers.
• Standard 3:        The internship satisfies CCD guidelines for training, supervision, and industry learning.

Full text for these Standards are below. These standards are advertised to employers in various ways, along with Manhattanville’s FERPA statement to employers supervising credit-bearing internships, also provided in this guide.

The CCD uses three primary criteria to evaluate an internship:

1. The student is the primary beneficiary of the internship, and daily operations and productivity of the company / organization may even be delayed to help the student learn.
2. The learning experience is equivalent to that which could take place in the classroom.
3. The student is acquiring industry-applicable skills that will benefit them after the internship ends.

Department of Labor - Internship Programs Under The Fair Labor Standards Act:

The Test for Unpaid Interns and Students provides general information to help determine whether interns and students working for “for-profit” employers are entitled to minimum wages and overtime pay under the Fair Labor Standards Act (FLSA).  The factors include:

1. The extent to which the intern and the employer clearly understand that there is no expectation of compensation. Any promise of compensation, express or implied, suggests that the intern is an employee—and vice versa.
2. The extent to which the internship provides training that would be similar to that which would be given in an educational environment, including the clinical and other hands-on training provided by educational institutions.
3. The extent to which the internship is tied to the intern’s formal education program by integrated coursework or the receipt of academic credit.
4. The extent to which the internship accommodates the intern’s academic commitments by corresponding to the academic calendar.
5.  The extent to which the internship’s duration is limited to the period in which the internship provides the intern with beneficial learning.
6. The extent to which the intern’s work complements, rather than displaces, the work of paid employees while providing significant educational benefits to the intern.
7. The extent to which the intern and the employer understand that the internship is conducted without entitlement to a paid job at the conclusion of the internship.

NACE Policy Statement:

To ensure that an experience—whether it is a traditional internship or one conducted remotely or virtually—is educational, and thus eligible to be considered a legitimate internship by the NACE definition, all the following criteria must be met:

1. The experience must be an extension of the classroom: a learning experience that provides for applying the knowledge gained in the classroom. It must not be simply to advance the operations of the employer or be the work that a regular employee would routinely perform.
2. The skills or knowledge learned must be transferable to other employment settings.
3. The experience has a defined beginning and end, and a job description with desired qualifications.
4. There are clearly defined learning objectives/goals related to the professional goals of the student’s academic coursework.
5. There is supervision by a professional with expertise and educational and/or professional background in the field of the experience.
6. There is routine feedback by the experienced supervisor.
7. There are resources, equipment, and facilities provided by the host employer that support learning objectives/goals.

CCD Standards:

In order to provide a robust learning experience and facilitate a strong relationship between intern and supervisor, the CCD requests that internship sites provide:

1. One primary supervisor to the intern, who is responsible for training, giving feedback, being available to answer questions, prioritizing tasks and responsibilities, and formally evaluating the intern for grading and/or professional coaching purposes.
2. A professional commercial office space (not a home office) or clearly defined virtual space for the intern to work in during internship hours, with no expectation that the intern will spend their own money outside typical travel expenses.
3. A formal training period (minimum one workday) and regular opportunities for in-person communication and feedback (once per week recommended).
4. Clearly defined working hours, with no expectation that the intern will complete work outside those hours.
5. Clearly defined responsibilities, tasks, and learning objectives that fall within the scope of the details outlined in this contract.
6. High-level exposure to one or more areas of the organization’s operations, wherever possible, and opportunities to contribute meaningful work that helps the student gain industry-applicable skills.

Manhattanville College FERPA Statement:

“By signing, the representative for this organization attests that student record privacy provided under the Family Educational Rights and Privacy Act (FERPA) for the student named in this agreement will be extended from Manhattanville College to include this business entity. Under FERPA, the named student’s personal data or educational record will NOT be released to third parties for any purpose without first obtaining the written permission of the student and Manhattanville College. This FERPA protection is in addition to any other federal, state or local policies that cover this workplace.”