In addition to the non-degree and matriculated student categories, Central Washington University has authorization from the US Department of State to sponsor J-1 exchange visitors in the Student Intern category. However, this category has specific requirements for participants, hosts, and sponsors and must be used carefully.

At present, CWU must be simultaneously sponsor and host.

By regulation, the internship must be a formalized program to which the Student Intern specifically applies and is accepted. Faculty members working with colleagues at institutions abroad to host Student Interns should ensure a formal institutional agreement outlining program parameters and the responsibilities of all parties is in place.

Student Eligibility & Limitations

By regulation, Student Interns are subject to certain requirements and limitations.

• Prospective Student Interns must be “enrolled in and pursuing a degree at an accredited post-secondary academic institution outside the United States”.
• Prospective Student Interns must be “in good academic standing with the post-secondary academic institution outside the United States [in] which he or she is enrolled…and pursuing a degree”.
• The Student Intern must be “accepted into a student internship program at the post-secondary accredited academic institution listed on his or her Form DS-2019”.
• The proposed internship must “fulfill the educational objectives for his or her current degree program at his or her home institution”.
• The Student Intern must be “primarily in the United States to engage in a student internship program rather than to engage in employment or provide services to an employer”.
• The Student Intern must “return to the academic program and fulfill and obtain a degree from [his or her home] academic institution after completion of the student internship program”.
• The Student Intern must have “verifiable English language skills sufficient to function on a day-to-day basis in the internship environment”.
• The Student Intern must have “sufficient finances to support himself or herself and dependants [sic] for their entire stay in the United States, including housing and living expenses”.
• Student Interns may only participate in such a program for up to 12 months for each degree/major.

Program Requirements:

As stated previously, the internship must be a formalized program to which the Student Intern specifically applies and is accepted. Per federal regulation, the prescribed program must fit these requirements and limitations:

• Must consist of a minimum of 32 hours per week.
• All assigned tasks must be program-related.
• Participation may be paid or not.
  NB: CWU policies require one of these three compensation scenarios:
  • Academic credit
  • Wage/stipend
  • Recognized volunteer status with approved form filed through Human Resources

The latter two scenarios both require Labor & Industries (worker’s compensation) insurance to be paid by the sponsoring department or college. Faculty members should discuss the matter with their Chairs and Deans.

• Clerical work may account for no more than 20% of program tasks.
• Must expose the student to US “techniques, methodologies, and technology and [expand] upon the [student’s] existing knowledge and skills”. May not duplicate prior experience.
• May not place a student in any of these areas:
  • Unskilled or casual labor
  • Child care or elder care
  • Aviation
  • Clinical positions involving patient care or contact or the provision of therapy, medication or other clinical or medical care. This includes:
    • Sports or physical therapy
    • Psychological counseling
    • Nursing
    • Dentistry
    • Veterinary medicine
    • Social work
    • Speech therapy
    • Early childhood education
  • Any “position, occupation, or business that could bring the Exchange Visitor Program or the Department [of State] into notoriety or disrepute”
  • Cannot “serve to fill a labor need” or “displace full- or part-time or temporary or permanent American workers”
  • Must “[exist] solely to assist the student intern in achieving the objectives of his or her participation in a student internship program”
  • Must “meet all the requirements of the Fair Labor Standards Act…and the Migrant and Seasonal Agricultural Worker Protection Act”.

Program Evaluation Requirements:

By regulation, “a sponsor must develop procedures for evaluating all [S]tudent [I]nterns”, with the following requirements:

• At minimum, formal evaluation at the program’s endpoint is mandated for all programs.
• In programs more than six (6) months in duration, formal evaluation at both the program’s midpoint and its endpoint are mandated, at minimum.
• All mandated evaluations must be done prior to the program’s conclusion and the Student Intern’s departure.
• Both the Student Intern and the immediate supervisor must sign the evaluation forms.
• Evaluations must be retained for a minimum of three years following the program’s completion.

Form DS-7002 - Training/Internship Placement Plan (TIPP):

By regulation, as part of distinguishing between permitted “work-based learning” and prohibited “ordinary employment or unskilled labor”, a DS-7002 is required for all Student Interns. OISP cannot issue a DS-2019 for the Student Intern until we receive the completed and signed DS-7002.

The Student Intern’s immediate supervisor at CWU is primarily responsible for completing the document and obtaining the necessary signatures. This should not be left to the Student Intern or to his/her home institution advisor.

Among other things, the DS-7002 must:

• “State the specific goals and objectives of the student internship program (for each phase or component, if applicable)”;
• “Detail the knowledge, skills, or techniques to be imparted to the student intern (for each phase or component, if applicable)”; and
• “Describe the methods of performance evaluation and the frequency of supervision (for each phase or component, if applicable)”.