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GPSS Senate Meeting 2/11/15

by Social Work Student Union
Are practicum programs in compliance with
Federal labor standards?

 Introduction to SWSU
UW School of Social Work Practicum Program
Department of Labor Standards for Unpaid
Internships
Student Survey and SSW 2014 survey
How GPSS can support this fight!

What Well Cover

Dimitri Groce
1st Year MSW
Jooree Ahn
2nd Year MSW, 1st Year MPH
Sean Johnson
MSW/MPH concurrent student, 3rd Year

Who are we?

1) Legality of unrecognized practicum labor

2) Exploitation of practicum students and displacement
of paid workers
3) Safety and protection of students
4) Student burden in practicum participation

Major Concerns

 Student role at practicum site

Cost of practicum credits
Workplace protections
Student grievance process

Practicum Program:
What You Should Know

 CSWE Mandates 900 hours of practicum

UW SSW Mandated Hours of Practicum
MSW: 1,040 (26 credits)
BASW: 480 (12 credits)
Advanced Standing: 1,200
Impacts approximately 500 students
Resident Total Cost: $15,361
Pay $14.77/ practicum hour
Non-Resident Total Cost: $25,706
Pay $24.72/practicum hour
Does not include:
lost wages and benefits
child care
transportation
other costs: books, professional clothing,
agency materials and requirements, etc.

Student Burden

Discrimination
Student reports: dismissal based on mental health status,
reporting legal action against intimate partner violence,
taking sick days

Sexual Harassment
Unclear what legal and institutional protections are in place

Injury
Students assume all risks for injury at their practicum site
Must sign liability waiver

Lack of Protection

 Dealt with according to internal, academic protocol

Viewed as interpersonal issues where the goals is:
to reach a mutually satisfactory resolution of a dispute

Legal recourse unclear and is not explicitly explained

before beginning practicum

Grievance Process

DEPARTMENT OF LABOR STANDARDS

Internship Programs Under the Fair Labor
Standards Act

For an unpaid internship to be exempt from minimum wage and overtime

laws, all 6 of the following criteria must be met:

1) The internship, even though it includes actual operation of the facilities of the
employer, is similar to training which would be given in an educational
environment;
2) The internship experience is for the benefit of the intern;
3) The intern does not displace regular employees, but works under close
supervision of existing staff;
4) The employer that provides the training derives no immediate advantage
from the activities of the intern; and on occasion its operations may actually
be impeded;
5) The intern is not necessarily entitled to a job at the conclusion of the internship;
6) The employer and the intern understand that the intern is not entitled to wages for
the time spent in the internship.

On paper
1) The internship, even though it includes actual operation of the
facilities of the employer, is similar to training which would be
given in an educational environment.
Clarifying language from the DOL:
structured around a classroom or academic experience as opposed to
the employers actual operations

Student experiences
Learning happens at the practicum site, not in a classroom.
Learning is centered on the employers actual operations.

SSW Student Survey Summary Report on Field Education Experience and the U.S. Department
of Labor Criteria Spring, 2014

On paper
2)

The internship experience is for the benefit of the intern;

4)

The employer that provides the training derives no immediate

advantage from the activities of the intern; and on occasion its
operations may actually be impeded;

As stated in the UW Practicum Affiliation Agreement

The training site shall maintain the right to bill and receive payment
for services performed at the training site (p.4, item 27).

SSW Student Survey Summary Report on Field Education Experience and the U.S.
Department of Labor Criteria Spring, 2014

Student experiences
Many students feel that practicum sites and the UW receive the
most benefit.
Health coverage reimbursement and client payment
Awarded grants and other funding sources developed by
students
Research, publications and creation of agency documents and
manuals
Strategic partnerships with UW built and strengthened by
practicum student labor

On paper
3)

The intern does not displace regular employees, but works

under close supervision of existing staff;
Clarifying language from the DOL:
If an employer uses interns as substitutes for regular workers or to
augment its existing workforce during specific time periods, these interns
should be paid at least the minimum wage and overtime compensation for
hours worked over forty in a workweek. If the employer would have hired
additional employees or required existing staff to work additional hours
had the interns not performed the work, then the interns will be viewed as
employees and entitled compensation under the FLSA

SSW Student Survey Summary Report on Field Education Experience and the U.S.
Department of Labor Criteria Spring, 2014

Student experiences

Students have displaced employees.

Students do the work of paid employees.
Students do whatever work the agency needs.
Students have little sense of agency in choosing their
placements.

On paper
6)

The employer and the intern understand that the intern is not
entitled to wages for the time spent in the internship.

Student experiences
Practicum sites voluntarily paying students hourly wages.
Practicum sites unclear about legal liability and labor laws.
Practicum sites recognize that students are performing work that
would be paid otherwise.

Support from GPSS on a Resolution to:

1. Urge the UW to conduct an independent audit on the practicum
program that specifically assesses the programs adherence to the
Department of Labors standards and incorporates student input
2. Urge the UW SSW to procure sustainable practicum positions that are
compensated and therefore protected under Federal Labor Laws that
ensure student safety.
3. Opportunity for UW SSW to set a precedent against unpaid practicums

Supporters
Sponsors
Solidarity