Internship Supervisor Handbook

The National Association of Colleges and Employers (NACE) has developed a formal definition of what constitutes a legitimate internship. 

By taking on a Loyola University New Orleans student intern, you (the internship site supervisor) are agreeing that the internship experience meets the criteria as defined by NACE and presented below. 

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 National Association of Colleges and Employers (NACE) definition, all of 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 designed learning objectives/goals related to the professional goals of the student’s academic coursework. 

5. There is side-by-side direct supervision by a professional with expertise and a professional background in the field of 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. 

If these criteria are followed, it is the opinion of NACE that the experience can be considered a legitimate internship. To learn more, visit http://www.naceweb.org/about/membership/internship

The Career Development Center strongly encourages all organizations to pay their interns to ensure compliance with Department of Labor regulations. Even if a student is working through a school program for which he or she is receiving college credit, the student still has the right, under the Fair Labor Standards Act (FLSA), to be paid unless the experience meets all of the criteria in Fact Sheet 71. 

By taking on a Loyola University New Orleans student intern, you (the internship site supervisor) are agreeing that the internship experience is in compliance with all guidelines established by the Department of Labor and Fact Sheet 71.

Fact Sheet 71 states:

The FLSA requires “for-profit” employers to pay employees for their work. Interns and students, however, may not be “employees” under the FLSA—in which case the FLSA does not require compensation for their work.

The Test for Unpaid Interns and Students

Courts have used the “primary beneficiary test” to determine whether an intern or student is, in fact, an employee under the FLSA. In short, this test allows courts to examine the “economic reality” of the intern-employer relationship to determine which party is the “primary beneficiary” of the relationship. Courts have identified the following seven factors as part of the test:

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.

Courts have described the “primary beneficiary test” as a flexible test, and no single factor is determinative. Accordingly, whether an intern or student is an employee under the FLSA necessarily depends on the unique circumstances of each case.

If analysis of these circumstances reveals that an intern or student is actually an employee, then he or she is entitled to both minimum wage and overtime pay under the FLSA. On the other hand, if the analysis confirms that the intern or student is not an employee, then he or she is not entitled to either minimum wage or overtime pay under the FLSA.

For more information about Fact Sheet 71 and the test for unpaid internships, please visit https://www.dol.gov/whd/regs/compliance/whdfs71.htm

In an effort to provide students with a safe and comfortable educational environment in their internship, we require internship site supervisors to review and acknowledge the following standards and policies that apply to our internship program and participants. If you become aware of a student who is being sexually harassed or otherwise discriminated against, you should call the Title IX Coordinator (listed below) immediately. 

Loyola University New Orleans Policy on Prohibition of Discrimination and Harassment, Including Sexual Harassment and Abuse is located at http://titleix.loyno.edu/. We expect intern site supervisors to comply with this policy. Discrimination, harassment, and retaliation are prohibited. If you have any questions about your responsibilities or these issues, feel free to contact Jill Boatright at boatrigh@loyno.edu

Non-Discrimination 

Loyola University New Orleans prohibits discrimination on the basis of gender, sexual orientation, gender identity or expression, age, race, color, religion, national origin, veterans’ status, genetic information, or disability, as prescribed by law and as further described below. In addition, discrimination against members or potential members of the United States Uniformed Services, as proscribed by the Uniformed Services Employment and Reemployment Rights Act (USERRA), is also prohibited. Likewise, an employer is prohibited from discriminating or harassing a student intern or employee on the basis of the above-identified classifications. For more information regarding Loyola’s Discrimination & Harassment Policy, please visit the Human Resources Manual

Sexual & Other Unlawful Harassment 

Loyola University New Orleans adheres to Title VII of the Civil Rights Act of 1964 and Title IX of the Education Amendments of 1972. The College’s unlawful harassment policy applies to our internship program to protect the rights of interns and provide an environment that is free from sexual/gender harassment. Sexual harassment also includes conduct that is directed at an employee or student because of his or her sexual orientation or gender identity or expression. 

The following conduct is prohibited: unwelcome sexual advances, requests for sexual favors, and other verbal or physical contact of a sexual nature when: 

1. Submission to such conduct is made either implicitly or explicitly a term or condition of an individual’s employment, academic status, or participation. 

2. Submission to or rejection of such conduct by an individual is used as the basis for employment or academic decisions or decisions concerning educational or other educational benefits affecting such individual; or 

3. Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working or learning environment. 

A single incident of sexual assault may be sufficiently severe or pervasive to interfere unreasonably with one’s educational environment and therefore create a hostile environment. 

Sexually-related conduct creates a hostile environment if it is sufficiently severe or pervasive to interfere unreasonably with academic, other educational, or employment performance or participation in a College activity or living environment. 

Sexual/gender harassment includes in-person acts and/or behavior via computer, telephone or other electronic medium, including text messages, emails, social media and other forms of electronic communication. 

Examples of sexual harassment may include the following: 

• Unwelcome sexual advances or requests for sexual favors based upon gender, sexual orientation, gender identity or gender expression;  
• Unwanted physical contact, including touching, pinching, or brushing the body;  
• Verbal harassment, such as sexual innuendos, suggestive comments, jokes of a sexual nature, sexual propositions or threats, epithets, slurs, or negative stereotyping;
• Non-verbal conduct, such as display of sexually suggestive objects or pictures, leering, whistling, obscene gestures, written or graphic material that defames or shows hostility or aversion toward an individual or group because of gender, sexual orientation, gender identity, or gender expression;  
• Repeated, unwelcome requests for social engagements;  Questions about sexual behavior or preference; and  
• Acts of physical aggression, intimidation, hostility, or threats  
• Stalking;  
• Sexual assault;  
• Relationship/Dating Violence; and  
• Domestic Violence

Safe Environment 

If the internship is located in an area that is unsafe and/or has recently has been the subject of criminal activity, please notify the Career Development Center immediately so that arrangements can be made to provide safe transportation and/or other safety measures to help protect the student intern. Thank you for serving as an Internship Site for our students and for helping Loyola University New Orleans maintain a safe and enriching learning environment for all.

By taking on a Loyola University New Orleans student intern, you (the internship site supervisor) are agreeing to provide the Loyola University New Orleans student intern with a safe work environment and comply with Title IX, Loyola’s Discrimination & Harassment Policy, and Title VII of the Civil Rights Act of 1964 and Title IX of the Education Amendments of 1972. You (the internship site supervisor) are also agreeing that if you are made aware of any instance of Discrimination or Harassment involving the Loyola University New Orleans student intern you will contact Jill Boatright, Director, Career Development Center, boatrigh@loyno.edu, 504-865-3860 immediately

As an internship supervisor you will lead, motivate, delegate, communicate, train and evaluate. The student will look to the supervisor as a mentor who assists in the transition from classroom to work environment. Since the internship is an extension of the learning process, the supervisor should provide opportunities to bridge the academic with the work environment by:

• assigning daily tasks, monitoring and evaluating the work  
• creating goals with deadlines  
• giving the intern support when needed to succeed 

The supervisor should be aware of the intern’s daily tasks. Watch for signs of the intern being bored or confused. It’s easy to be shy with new people who all know each other. Observe whether the intern is working on a project that needs another person’s input. 

Meet regularly to provide feedback concerning his/her performance. During the meetings, you may coach, counsel, and reinforce positive attitudes and performance. Encourage the intern to develop teamwork and communication skills. 

Some internships lend themselves to producing a portfolio of work accomplished during the experience. The portfolio created by the intern, and maintained electronically. This could help fulfill the intern’s academic requirements and provide a sense of accomplishment. In addition, it will give the supervisor a basis to discuss his/her professional growth. 

Keep the intern busy and directed towards his/her learning outcomes. Students rarely complain of being overworked, but they do complain if they are not challenged. Encourage professionalism by assisting the intern in developing interpersonal skills, decision-making abilities and managing office politics. Demonstrate how this work relates to the overall efforts of the department or agency.

Think about the ways your company has benefited from the program:

• How well is the internship meeting your program’s needs?  
• How well is the internship meeting the needs of your intern(s)?  
• Are there other projects or departments where an intern could add value?  
• There is an investment of time by staff members in any internship. Was the time invested worthwhile to your organization?

Criteria to consider when evaluating an intern are:  

• Progress towards or accomplishment of learning objectives as stated in the learning agreement 
• Skill development or job knowledge gained over the course of the internship  
• Overall contribution to the mission of the organization  
• Dependability, punctuality, attendance  
• Relations with others, overall attitude  
• Potential in the field

Final Review 

The final evaluation of the intern’s work should encompass both hard and soft skills learned. The hard skills pertain to the technical proficiencies and abilities required for the position related to the student’s area of study. Soft skills include communication, self-management, leadership, decision making, etc. It is important for students to know that success on the job is related to both of these skill sets. Note in the evaluation how the intern grew and developed as well as areas for improvement.

Please note it is best practice to formally conduct an exit interview to formalize the conclusion of the student’s internship experience

The Internship Agency and Supervisor agrees to:

1. Adhere to all local, state, and federal guidelines and mandates pertaining to COVID-19 safe operations
2. Provide and maintain a clean and safe environment for all Loyola students
3. Promote healthy hygiene behavior with regular and frequent access to hand washing and hand sanitizer
4. Institute and practice social distancing measures
5. Implement flexible policies and practices for Loyola students to accommodate absences related to COVID-19 illness or exposure
6. Immediately notify the Loyola University New Orleans Career Development Center and its’ students of any exposure to COVID-19