Unpaid Internship and Volunteer Policy

• All those who have supervising authority or employment authorization at GW 

GW recognizes that unpaid internships and volunteer opportunities can serve as a vital part of the individual’s learning process. Such opportunities help further an individual’s training, education, or career learning by providing planned and supervised activities within a practical setting. Volunteers may also play a role in supporting university activities for civic, charitable, and humanitarian purposes that advance the university’s mission of excellence in the creation, dissemination, and application of knowledge. GW offers many volunteer opportunities to support the university and its community. 

Unpaid Internships

The “Primary Beneficiary Test” should be used to determine if an individual is appropriately categorized as an unpaid intern and not an employee within the meaning of FLSA. Under the test, the following seven factors should be considered to evaluate whether the intern or the university benefits more from the relationship. This is considered a flexible test with no single factor being determinative. The circumstances of each opportunity must be determined on a case-by-case basis. To the extent that the intern benefits more than the university, it is likely that the intern would not be classified as an employee of the university.  

1. The intern and the university clearly understand that there is no expectation of compensation.  
2. The internship, even though it may include actual operational tasks, is similar to training which would be given in an educational environment. 
3. The internship is tied to the intern’s formal education program by integrated coursework or the receipt of academic credit. 
4. The internship accommodates the intern’s academic commitments in alignment with the academic calendar. 
5. The internship’s duration is limited to the period in which the internship provides the intern with beneficial learning. 
6. The intern’s work complements, rather than displaces, the work of paid employees while providing significant educational benefits to the intern. 
7. The intern and the university understand that the internship is conducted without entitlement to a paid job at the conclusion of the internship. 

Sponsoring managers must consult with Human Resource Management and Development (HRMD) to determine if the internship opportunity is appropriately classified, via the request process outlined below. 

Volunteers

The U.S. Department of Labor provides guidance, summarized below, for determining whether work is legitimate volunteer service (for which no pay or work authorization is required) or whether it is employment (for which pay and work authorization is required): 

1. The services are intended to be voluntary and to be offered freely; rendered without compensation, or the expectation of compensation, and typically on a part-time basis.
2. The services must constitute a bona fide effort of the individual to volunteer for a civic, charitable, humanitarian, or other non-profit organization service purpose.
3. Volunteers must not be utilized in ways that displace or replace regular employees in the performance of their normal duties.
4. The fact that the individual is an employee elsewhere in the university does not mean they cannot volunteer in a capacity that differs from their employment, but the employee cannot volunteer to do activities that are already expected as part of or related to their current job. 

Sponsoring managers must consult with HRMD to determine if the internship opportunity is appropriately classified, via the request process outlined below. 

Eligibility for Unpaid Internships or Volunteer Opportunity 

In addition to properly identifying an opportunity as an unpaid internship or volunteer position, the following criteria are also required for an individual to be eligible for an unpaid internship or volunteer opportunity: 

• 18+ years old or parental written consent for a minor. In the case of a minor serving in an unpaid internship or volunteer opportunity, the sponsoring manager must ensure compliance with the Protection of Minors Policy. 
• The assignment should be short-term, and not to exceed 12 months. 
• Successful completion of a background screening.

Sponsoring Manager Responsibilities

Should a unit identify an opportunity for an intern or volunteer, the sponsoring manager must: 

• Properly identify, review, and evaluate volunteer or unpaid intern assignment.
• Complete a Request for Unpaid Internship or Volunteer Opportunity form and submit it to HRMD for review and approval.
• After receipt of HRMD’s approval of the request, ensure completion and submission of the Unpaid Internship or Volunteer Opportunity Agreement form to HRMD.
• Sponsor the individual as an affiliate of the university to obtain a GW UserID and/or GWorld Card.
• Ensure that the individual signs any additional department-specific agreements if provided access to sensitive information
• Properly place, train, supervise, and conclude a volunteer or unpaid intern assignment.
• Plan meaningful opportunities to meet experience expectations.
• Complete any future verification needs and documentation for the individual.

Prohibited Activities

Unpaid interns and volunteers are prohibited from performing the following activities:

• Operating heavy equipment including but not limited to a university vehicle.
• Working with infectious or potentially infectious agents or hazardous materials or in environments that may cause an increased risk for physical harm.
• Entering into any contract or agreement on behalf of the university.
• Representing themselves as a university employee.
• Violating any rule, regulation, policy, procedure, or instructions provided by the university.

Additional Considerations

• Individuals participating in unpaid internships and volunteer opportunities are required to comply with university policies, as well as any policies and regulations which are related to the university activity the individual is involved with.
• Foreign nationals may serve as volunteers or unpaid interns for the university if in accordance with all legal and visa restrictions. Sponsoring managers must ensure, prior to the beginning of the volunteer or internship experience, that the volunteer or intern complies with all visa requirements, in partnership with the International Services Office.
• Volunteers or unpaid interns who wish to seek reasonable accommodations for a disability should contact Equal Employment Opportunity and Access (EEOA).