by Tina Williamson
I’m exhausted. There’s no way I can keep up with this workload. I need to either hire another assistant or….hey…wait…I can hire a few unpaid interns to pick up the slack!”
Ever heard this before? If you have, your first response should have been to say, “It’s not as easy as it sounds.” The truth of the matter is, while we are tempted to “intern-out” our more mundane, time-sucking tasks, we may very well be violating the same laws that we have sworn to uphold and protect.
However, with the right preparation and planning, you can bring into your office one, or possibly more, energetic individuals who can assist you in the preparation, production, and finalization of your more pressing projects, while giving them the chance to gain real-world experience.
So, how do you structure an internship program in your company that is effective, legal, and provides an educational experience for future compliance professionals? I can’t answer all of the questions you may have but I can give you a few pointers on how to get started.
First step: you need to determine whether or not you want to pay your intern. For the sake of time and space, let’s say that you want to create an unpaid internship in your compliance program. Therefore, you need to ensure that your program remains in compliance with the Department of Labor.
Work.com1 states the following guidelines for unpaid internships. The six criteria developed by the Department of Labor that must be met in order for the positions to be an unpaid internship are:
1. The training, although it includes actual operation of the facilities of the employer, is similar to the training which would be received from a vocational school.
2. The training must be for the benefit of the intern.
3. The intern must not displace regular employees, but work under the close observation of a regular employee or supervisor.
4. The employer provides the training and derives no immediate advantage from the activities of the intern, and on occasion, the operations may actually be impeded by the training.
5. The intern is not necessarily entitled to a job at the end of the internship.
6. Both the intern and the employer understand that the intern is not entitled to wages. A student may be able to receive a stipend however.
All of these criteria must be met in determining if the intern is a paid employee or a learner/trainee.
So, you now know that the intern is not there merely to replace a worker for free, or to replace an employee that you’ve just laid off in the last round of budget cuts.
Point #4 is usually the hardest for employers to swallow, as we are all overloaded with enough work for three people. To actively seek out a mentor position that may actually slow us down, well, that’s not a big motivator. However, an intern can become an integral part of your team.
After you’ve reviewed the Department of Labor guidelines, you need to actively engage the business program’s education/career services director in your search for an intern so that you have a full understanding of what an internship in this particular program requires.
Questions to ask include:
- Who is the intern coordinator for the program?
- Does this program offer class credit for the internship?
- Is there a weekly hourly limit or minimum that the student must meet in order to get credit?
- Will I need to submit weekly reports regarding the intern’s work product?
- How often will I need to submit an evaluation of the intern?
- Will I need to submit a weekly schedule to the intern coordinator?
- What type of work experience does your program seek for its students?
- What are my options if the intern is not meeting the minimum requirements for my internship?
Once you’ve reviewed the program guidelines, it’s time to have a chat with your HR director. Most companies already have active internship programs. You may not even have to create your own intern handbook. And many companies require interns to go through the same background checks, training, and orientations that are required of
Next, you will need to take the evaluation forms that the college program requires, the HR department’s recommendations, and your own department needs, and create a handbook that clearly defines expected work hours, your code of ethics, attendance, training requirements, the company’s dress code, performance evaluations, and the consequences for failing to meet the internship requirements. This is one of the most important steps. If your company already has an internship handbook, you’re in luck. If
not, taking the time to create clear guidelines, review them with your interns, and have them sign an agreement to comply with these same guidelines is the best way to avoid confusion and major issues down the road.
Once you’ve covered these steps, you can then advertise with local colleges for possible interns. A quick post for the position may be as follows:
Wanted: Students who are interested in pursuing a career in the Corporate Compliance field. The ABC Corporate Compliance Department is seeking two Interns to join our team and gain valuable experience in one of the fastest growing fields in health care management. The positions will assist in research and development of policies and procedures that are in compliance with health laws and regulations, risk management, and best practices. Responsibilities include assisting with onsite facility inspections, departmental audits, conducting various research tasks, administrative duties, and other duties as assigned. Qualifications: currently enrolled as a college student, have strong attention to detail, a self-starter with strong initiative and good work ethic, have strong teamwork and organization skills, can type a minimum of 35 WPM and have working knowledge of MS Word, Excel, PowerPoint, and Windows. This is a non-paid position. To apply, please contact the Compliance Director at 601-555-5555, ext. 5555 or compliancedirector’semail.org no later than August 10, 2014.
Now it’s time to sit back and wait for the resumes to arrive.
Once the deadline has passed, it’s time to compile those resumes and get to interviewing. One last bit of advice: While I hold my interns to the same professional standards as my paid employees, I also realize that this may be the student’s first professional interview. I view the application process and the interview as part of the intern’s educational opportunity. I also conduct a mock professional interview with my interns in their final days with my company so that I can provide productive feedback on their resume and interview skills.
As you can see, creating an intern program in your corporate Compliance department may appear to be a bit daunting at first, but the rewards for you and the future compliance professionals who learn “at your feet” are limitless.
Tina Williamson, JD, RTT, is Director of Corporate Compliance from Mississippi Children’s Home Services. She can be reached at firstname.lastname@example.org.