Many CMCI students are required to complete 3 internship credits in order to graduate. While we encourage all employers to pay interns, we realize this is not always possible. However, we do require all employers to follow the same guidelines required by the University of Colorado Boulder’s Career Services Office and the federal government. Employers are required to sign a contract agreeing to abide by these policies, when they post internships on our online system. Students are able to receive both pay and academic credit simultaneously.
CU Boulder encourages its students to participate in a wide variety of internship opportunities throughout the year. We define an internship as a hands-on, career related experience that supplements classroom academic experience to enhance the student’s education. Interns should participate in activities that mirror the professional activities of their supervisors rather than performing clerical or tasks that would otherwise be performed by assistants. Internships must include orientation, training, ongoing supervision, and evaluation. Further clarification is below, and please also refer to the University of Colorado Boulder’s Employer Policies.
Internships can be paid or unpaid. If you are going to pay your intern, you must pay them at least minimum wage for the hours they work.
If you want to host an unpaid intern, please be aware of the following federal guidelines and recent court rulings surrounding unpaid internships: Under the federal Fair Labor Standards Act, internships at for-profit companies can be unpaid if the internship is “for the benefit of the intern” and “similar to training which would be given in an educational environment.” View the new Department of Labor guidelines.
The U.S. Department of Labor (DOL) has developed seven criteria for identifying learner/trainee who may be unpaid:
- 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.
- 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.
- The extent to which the internship is tied to the intern’s formal education program by integrated coursework or the receipt of academic credit.
- The extent to which the internship accommodates the intern’s academic commitments by corresponding to the academic calendar.
- The extent to which the internship’s duration is limited to the period in which the internship provides the intern with beneficial learning.
- 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.
- 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.
All seven requirements must be satisfied in order for an intern to be deemed a non-employee trainee. Further clarification on student internship duties is provided by NACE.
The Drug Free Schools and Communities Act 1989 (DFSCA) provides, “as a condition of receiving funds or any form of financial assistance under any Federal program, an institution of Higher Education must certify that it has adopted and implemented a program to prevent the unlawful possession, use, or distribution of illicit drugs or alcohol by students and employees.” Further, under the DFSCA, institutions of Higher Education must employ “standards of conduct that clearly prohibit, at a minimum, the unlawful possession, use, or distribution of illicit drugs and alcohol by students and employees on its property or as part of its activities.”
Dispensaries (i.e. retail shops), cultivators or manufacturers of THC infused edibles are examples of businesses that directly work with marijuana, a federally illicit drug. However, many businesses fall into a gray area including ancillary (e.g. a grow-light manufacturer) businesses, real estate leasing businesses, consumption device and consulting businesses among others.
In order to ensure compliance with federal law, Career Services will not promote internship or work opportunities at companies that may possess or come into contact with marijuana products. Additionally, Career Services will not host internships for credit where a student may come into contact with marijuana products (including work with a company’s clients, attendance at marijuana conventions, etc.).
Thank you for advertising your internships to CMCI students and for hosting interns! The experience they gain is invaluable.