Though­ unpaid internships have long been a staple of a Georgetown education, they may not always be legal.

Last April, the Economic Policy Institute issued a report titled, “Not So Equal Protection — Reforming the Regulation of Student Internships,” which questions the legality of unpaid internships and called for greater federal regulation.

“This paper contends that the current system of regulations governing internships must be reformed, both for the immediate protection of students’ rights and also to maintain a strong and vibrant labor market that compensates all workers fairly,” the report says.

The report argues that a lack of clear regulations makes student interns vulnerable to workplace discrimination and incentivizes replacing paid employees with unpaid interns. It also stated that unpaid internships are unfair to students who cannot afford to spend a summer or semester working for no pay.

Whether or not they are aware of the issues cited in the report, many Georgetown students continue to hold unpaid internships. According to a survey of the Class of 2010 conducted by the Career Education Center, 83 percent of students reported having had at least one internship while at Georgetown.

Patricia Kehoe (SFS ’12) has held two unpaid internships during her time on the Hilltop. Currently she works a part time job in addition to her internship to make up for the fact that she is not being paid.

“In the case of an unpaid internship the student needs to be sure that it’s something they enjoy doing, and it’s something that will further their career, otherwise it’s not worth it,” Kehoe said.

Not all students, however, have the option of making that tradeoff, especially if the internship hours run long. Professor Thomas Cooke, who teaches the one-credit Internship in Business course, believes that it is wrong not to pay a student for doing legitimate work.

“The system is clearly prejudiced against students without resources to cover room and board,” Cooke said. “If there’s [an employee] down the hall doing the same work and getting paid, then that’s fundamentally unfair to the student working without compensation.”

According to Kehoe, legitimate work is exactly what unpaid interns are doing.

“I’ve heard of students who have had to take work home with them and skip classes. There’s a lot of pressure to do the work of a paid employee even though you’re an unpaid intern,” she said.

Ross Eisenbrey, vice president of the Economic Policy Institute, said that unpaid internships also set a bad precedent.

“They’re making it all right for employers not to pay people for their work,” he said.

According to Eisenbrey, unpaid internships require federal regulation because students are often afraid to speak out, even if their position is being abused. He talked to several student interns in D.C. who felt they needed to accept their position as unpaid interns.

“If the internship is ongoing and the intern blows the whistle, they could be fired,” he said.

“They were more interested in having at this point the employer on their resume and having a good recommendation than being paid for their time. [Whistleblowing] is something that scares most people because they’re afraid that they’ll be blacklisted. Student interns are reluctant to assert their rights.”

According to Eisenbrey, this trend has implications even beyond the student demographic.

“For society as a whole, we’re getting to a bad place,” he said.

The release of the report coincided with the announcement of more stringent regulations on what qualifies as a legal unpaid internship. In January 2010, the Department of Labor released six criteria for unpaid internships at for-profit companies. Among these are the requirement of on-the-job training, and the requirement that the employer “derives no immediate advantage” from the work of the intern.

According to Robin Richards, chairman and Chief Executive Officer of, the Department of Labor’s regulations are impractical.

“To me, an employer deriving no immediate benefit from the activity of the intern is unrealistic,” he said. “I don’t think anyone I’ve ever spoken to wouldn’t agree that the current Department of Labor criteria do require a little bit of altering.”

Nina Ravi (SFS ’12), who currently holds an unpaid internship at Emily’s List, agreed.

“I’m kind of skeptical about [the Department of Labor’s] definition,” she said. “The point of an intern is to do the very basic work that the boss could be paid to do but it would be a waste of time for them to do. I don’t necessarily see that as a bad thing because it’s essentially job training for the future, and you’re definitely getting something out of it even if it’s not monetary compensation.”

Richards said that government regulation of unpaid internships would do more harm than good.

“Let’s not kill what has always been one of America’s great institutions. Experiential learning has been a special piece of capitalism. It’s critical that we don’t stifle this with government intervention,” he said.

Cooke agreed.

“The less government intrusion the better,” he said. “The government steps in and at the end of the day there are fewer internships.”

Instead, Cooke feels that students are best qualified to make decisions about the value of their unpaid internships.

“The question is: internships at what price? And I think that’s a decision the student has to make,” he said.

Georgetown offers services to help students make that decision. Internships are not posted on the Career Center’s Hoya Career Connection until a Career Center staff member has reviewed the internship and spoken with the employer, according to Career Center Director Mike Schaub. Additionally, the one-credit courses offered for internships in business, government and journalism help to give structure and faculty oversight to an unpaid internship.

Cooke expressed high confidence in Georgetown’s internship advising system.

“We have top-notch faculty advisers that have that depth of knowledge for students,” he said.

Cooke also requires students in his Internship in Business class to write a report about their experience at the end of the semester.

Ultimately, many students and faculty feel that internships are an invaluable part of the Georgetown experience.

“An internship is often the most important, educational and practical experience a student will get in college,” Cooke said.

Kehoe agreed that her internship prepared her for her future career.

“The opportunities I’ve gotten at my internships have been more than enough to make up for not being paid,” she said.

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