Unpaid Research Internship Policy
The following information pertains to USU Policy 589: Unpaid Research Interns.
Why USU Instituted Policy 589
- USU Policy 535: Volunteer Policy (Issued September 2019) restricted a common practice of involving unpaid students in research for training purposes.
- Unpaid students working in research settings need to be covered by Worker’s Compensation and University insurance
- Potential Federal Fair Labor Standards Act violations when unpaid students work alongside paid/credited students
- USU is missing essential data on student participation in the research enterprise
Key Points of Policy 589
- To support the University’s commitment to engaging students in its research efforts and ensure the safety and fairness of those experiences, this policy formalizes the authorization to work with, train, and supervise Unpaid Research Interns.
- While a Research Intern does not receive wages or academic credit for their involvement and does not provide this involvement as part of a requirement for a degree or a course, Internships under this Policy must be for the primary benefit of the Research Intern. This benefit must come in the form of hands-on or other training in an educational environment.
A Focus on Training
"Under the supervision of a Supervising University Employee, Research Interns may conduct research and perform research-related tasks, including laboratory and field work, where such experience is consistent with ongoing training under appropriate supervision and where such experience is for the primary benefit of the Research Intern."
How It Works
- Student and mentor agree to work together
- Mentoring compact
- Initial training
- ServiceNow request completed by mentor
- Includes MC
- Required trainings indicated
- Student approves request
- Reviews list of required trainings
- DH approves request
- Student, mentor, and DH notified when the agreement expires
Benefits of the Policy and Process
|Clarifies expectations and helps build self-awareness
|Clarifies expectations and facilitates communication
|Facilitates understanding of student engagement
|Builds robust data on UR engagement
|Promotes safe and responsible research activity
|Ensures that students understand safety protocols & expectations
|Prevents incidents and allows DH a view onto varying safety practices
|Supports compliance with USU Policy 337: Safety and reduces risk
|Most activities covered by Worker’s Compensation and university insurance
|Ability to include students who are not paid in research training outside the classroom
|Supports more inclusive and accessible research experiences for students
|Affirms USU’s commitment to UR without violating Policy 535: Volunteers
|Protects student from labor abuses
|Helps mentor document mentorship for promotion and tenure or CV
|Enables units to better articulate their investments in UR through documentation
|Ensures USU’s compliance with the FFLSA, which has implications for Federal funding eligibility
- USU Policy 589
- Basic Mentoring Compact Template
- Aligning expectations (from the University of Wisconsin Institute for Clinical and Translational Research)
- Office of Research provisional list of trainings
- Federal Fair Labor Standards Act Internship fact sheet
- USU Human Resources
How do I register an Unpaid Research Intern?
- The process takes place through ServiceNow. In the Service Catalog, select Departmental Forms > Office of Research > Unpaid Research Internships
Who is responsible for initiating the ServiceNow request?
- The mentor, or in Policy language, “Supervising University Employee” who must be a USU employee.
- After the request has been submitted, the student will receive an e-mail prompt via their USU e-mail to approve the request. Mentors should alert students to this process, as most students have minimal experience with ServiceNow.
- Students must be logged into the university network or VPN on their device in order to approve the ServiceNow request.
- The student will also receive an e-mail detailing the required trainings. At present, there is no way within ServiceNow to link to the various training-management platforms USU employs (e.g. ILS), so the responsibility will rest with the mentor to ensure that the student follows up.
Why did USU institute Policy 589, Unpaid Research Interns?
- USU Policy 535: Volunteer Policy (Issued September 2019) restricted a common practice of involving unpaid students in research for training purpose.
- Unpaid students working in research settings need to be covered by Worker’s Compensation and University insurance.
- Potential Federal Fair Labor Standards Act violations when unpaid students work alongside paid/credited students.
- USU is missing essential data on student participation in the research enterprise
What is an “Unpaid Research Intern”?
- This is defined in Policy 589.2.1: “While a Research Intern does not receive wages or academic credit for their involvement and does not provide this involvement as part of a requirement for a degree or a course, Internships under this Policy must be for the primary benefit of the Research Intern. This benefit must come in the form of hands-on or other training in an educational environment.”
- ANY student who is participating in research activities (other than as a research subject) and who is not receiving some form of compensation, such as academic credit, Honors points, or pay, is an Unpaid Research Intern
Is the ServiceNow “Unpaid Research Internships” form required? Why?
- Yes, it is required
- The requirement allows the university and units to keep accurate and up-to-date records of student training activities, providing more robust data and stronger evidence of compliance with local, state, and Federal guidelines and regulations
Does this policy apply to graduate students as well as undergraduates?
Does this policy apply to high school students who are working with me?
- Yes, but high-school students participating in research at USU MUST have a USU A# (e.g. through Concurrent Enrollment) and if under 18 are subject to USU Policy 534: Protection of Minors
Does this policy apply to non-USU individuals over 18 who are working in my lab or on a creative project with me?
- Technically, yes, but even these individuals need to have an A# in order to be covered by Policy 589
- Consult Policy 535: Volunteer Services to determine whether non-USU individuals are more appropriately classed as “volunteers” with the attendant restrictions that allow them to be covered by Worker’s Comp
Are Undergraduate Research Fellows (or recipients of other, similar Fellowships) who are doing unpaid, uncredited work URIs?
- Undergraduate Research Fellows receive a scholarship that is not (and cannot legally be) attached to any work expectations, and therefore, they are not compensated for work they do through the URF program. If a URF is working with a mentor on a project and neither receiving pay nor academic credit, a URI agreement is needed.
Are students working on an URCO, GRCO, or similar internal student research grant URIs?
- Because students who have received funding specific to a research project already have a formal, signed agreement with their mentor and the administering unit for the grant, they are in effect receiving a form of academic recognition for their work, and do not need to create an additional agreement through the ServiceNow form.
- However, if you have concerns about whether the student is covered by Worker’s Comp, you may want to create a URI agreement in order to ensure that they are.
One of my students wants to do a research project for a local social-service not-for-profit group, and I am serving as their advisor on the project. Do we need a URI agreement?
- When a student participates in or initiates an extramural research project, they clearly must work with the external organization’s own policies and procedures.
- If the organization requires an academic advisor, supervisor, or mentor, then it is understood that the advisor/supervisor/mentor bears some responsibility for the student. In that case, the answer is probably yes, this would be an appropriate time to initiate a URI agreement.
- If part of your role is to serve as PI on a Human Subjects Research protocol for the student’s project, then the answer is definitely yes, you need a URI agreement
- If instead this is simply an informal consulting role that you may play occasionally, and the student is not representing the university or any of its units in the project, then the answer is likely that you do not need a URI agreement
- Students doing community-based work of this sort are strongly encouraged to contact the Community Engaged Learning center for guidance
I have several students who want to accompany me on a field expedition this summer. I can’t afford to pay them, but I can accommodate them and provide them with opportunities to conduct research and mentor other students. Do I need to have a URI agreement with them?
- Previously, the legal status of these students would have been out of compliance with USU Policy 535, and they would not have had any indemnification or Worker’s Comp eligibility. Under Policy 589 and a URI agreement, they are usually qualified.
A graduate student in my lab has a 50% appointment as a research assistant but is working in the lab closer to 60 hours a week. I rely on this student’s labor for the advancement of my own research. Do I need a URI agreement?
- The student is only being paid for 20 hours a week. The remaining hours they are in the lab should be, per the policy, “for the primary benefit of the Research Intern,” and focus on their training, rather than on their contributions to the mentor’s research productivity.
- However, this is something of a gray area, because the remaining hours may be in service of the student’s fulfillment of degree requirements, such as research that will become part of their thesis.
- The best way to determine whether this situation qualifies as an Unpaid Research Internship is to draw up a mentoring compact so that both the student and the mentor understand the distribution of time and effort and the student is clear on how they are being compensated, financially and academically, for their time.
What is a mentoring compact and why is it required for the URI agreement in ServiceNow?
- A mentoring compact is a written, non-binding, agreement discussed and signed by mentor and student that outlines the terms of the unpaid research internship (or any other mentoring relationship). It is widely considered a best practice in research mentoring and helps minimize instances of miscommunication that may lead to safety violations, interpersonal conflict, and even legal grievances.
- A basic template for the compact is available through ServiceNow, and a variety of models can be found at the website of the University of Wisconsin’s Institute for Clinical and Translational Research, the group leading the national conversation on mentoring compacts.
- The mentoring compact requirement ensures that prior to the submission of a URI request, the mentor and student will have reached a good mutual understanding of the duration, expectations, and projected outcomes of the internship.
What is the department head’s role in the implementation of Policy 589?
- The DH will be prompted to sign off on the URI request after the student has approved it. This helps DHs to have a clearer picture of how students are participating in research in their unit.
- As per Policy 589.3.1 “Responsible Units must oversee the safe and fair implementation of Research Intern experiences.” Department Heads establish clear expectations for research mentoring in their units, and ensure that mentors consistently complete Research Intern Participation agreements.
What is the Office of Research’s role in implementing Policy 589?
- The Office of Research provides the framework and tools (such as the ServiceNow agreement) to support mentors, unit heads, and colleges in compliance.
- OR will also keep track of data and provide (on request) reports to mentors and unit heads, and compile a library of mentoring compacts that can be consulted
- OR maintains and updates the “trainings” list and works with IT services to increase functionality, for example with the goal of connecting the indicated trainings in ServiceNow to other systems such as ILS, CITI so that prompts to complete trainings come directly to the student from those systems.
What are the student’s responsibilities?
- The Unpaid Research Intern is responsible for working with the mentor to draft and sign the mentoring compact, and for completing the necessary trainings specified in that form and by the ServiceNow agreement
- The mentoring compact is intended as a living, evolving document, and the URI and mentor should return to it as the evolving nature of their arrangement demands, for example if availability changes or if new trainings become pertinent.