Hi all,
I'm hoping to get some clarity (and possibly shared experiences) regarding the intersection of employment-based placements (EBPs) and labor laws.
We have several students completing their field practicum at their place of employment. However, one agency is requiring that employed students complete additional hours for field education beyond their full-time work hours. The agency indicates this requirement is based on U.S. Department of Labor guidance related to internships (Fact Sheet #71).
My understanding of the DOL guidance is that it focuses on whether the student/intern or the employer is the "primary beneficiary" of the experience, rather than requiring that practicum hours be entirely separate from paid employment.
I am not interpreting the guidance as requiring additional unpaid hours beyond a student's regular employment in order for the experience to qualify as a legitimate internship/field placement, but I want to make sure I'm not missing something.
Has anyone encountered a similar situation or received legal guidance on this issue that you would be willing to share?
Thank you in advance for any insight you can offer.
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Kim Crane Mallory
Director of Field Education
University of Tennessee at Knoxville
615-782-6157
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