Approving internships

Unpaid internships posted by non-profit and for-profit employers

Unpaid internships can only be posted to BroncoJOBS by nonprofit and government organizations. If a for-profit organization posts an unpaid internship, look them up online to confirm that they are not a government or nonprofit organization. 

If you cannot determine their non-profit status, send the following message to the employer through BroncoJOBS and WExchange. Please make sure to send the message through WExchange, too, because still about half of our employers do not receive notification of messages sent through Handshake:

Western Michigan University only posts unpaid internships for non-profit employers.  If you would like to have a non-paid internship posted in BroncoJOBS, please share your nonprofit designation.  If a reply is not received within five business days, your posting will be denied.  For more information about posting unpaid internships, please visit: http://www.dol.gov/whd/regs/compliance/whdfs71.htm

If you confirm that they are a for-profit organization, send the following message through Handshake as well as WExchange:

Dear (Name),

I have noticed that you have posted unpaid internships in BroncoJOBS at Western Michigan University.  Since they are unpaid, we will need to remove them from BroncoJOBS.  According to the Fair Labor Standards Act (http://www.dol.gov/whd/regs/compliance/whdfs71.htm) and the guidelines of the National Association of Colleges and Employers (NACE), we cannot post unpaid internships for "for-profit" private sector employers. 

The positions you have posted sound like great opportunities for students who are eager to apply their skills.  However, the positions cannot be posted in our system as unpaid opportunities because they do not pass the Fair Labor Standards Act (FSLA) test.  Having carefully analyzed the positions in the context of the FLSA, we will need to remove them from our system. 

Although the students gain valuable skills while working with you, their positions do not qualify as unpaid internships to be posted in our system because, according to the U.S. Department of Labor, if "the interns are engaged in the operations of the employer or are performing productive work (for example, filing, performing other clerical work, or assisting customers), then the fact that they may be receiving some benefits in the form of a new skill or improved work habits will not exclude them from the FLSA’s minimum wage and overtime requirements because the employer benefits from the interns’ work." (...)  "If the employer is providing job shadowing opportunities that allow an intern to learn certain functions under the close and constant supervision of regular employees, but the intern performs no or minimal work, the activity is more likely to be viewed as a bona fide education experience.  On the other hand, if the intern receives the same level of supervision as the employer’s regular workforce, this would suggest an employment relationship, rather than training." (U.S. Department of Labor, http://www.dol.gov/whd/regs/compliance/whdfs71.htm).

Since the positions you have posted on BroncoJOBS do not appear to align with the FLSA, we are unable to have them in our system

I hope you understand that as a career services office, we must follow the guidelines put forward by the Fair Labor Standards Act and our professional association (NACE). 

If you are looking for capable individuals to help as volunteers, you might want to share the opportunities at http://volunteerkalamazoo.org/

Please feel free to contact me if you have questions or would like to discuss the issue further.

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Add the message above to the "Comments" box, and set the posting status to "Decline"