Senators continued a discussion on changing the Undergraduate Internship Policy. Senators heard an update from Liz Mullenix and a special report from Jason Ezell, Head, Learning and Engagement, Nate Floyd, Student Success Librarian for Foundational Learning and Laura Birkenhauer, Student Success Librarian for Campus Engagement on the Library retention programs. Senate was adjourned, but then reconvened to approve abbreviated minutes and with that vote, the resolution below was approved.

The November 6, 2023, minutes were approved, as were abbreviated minutes from November 20, 2023.

The following reports and minutes were received on the Consent Calendar:

1. Curricular Items_11.15.2023
2. Graduate Council Minutes_11.14.2023
3. LEC Meeting Minutes_10.31.2023

With the approval of the minutes from November 6, 2023, the following resolution was approved:

BE IT HEREBY RESOLVED that University Senate approves the proposed Management of Conflicts of Interest in Project with External Funding as it appears below:

Scope: Who is Covered by this Policy?

Employees, Students, 

Policy

General

Miami University requires investigators on proposals to all external agencies, public and private, to disclose to the University, via the Vice President for Research and Innovation, prior to submittal of the proposal, any significant financial interest (including those of spouse and dependent children) that would reasonably appear to be affected by the activities proposed for funding. Such a disclosure is facilitated within the proposal submission process. Financial conflicts of interest with externally funded projects are prohibited (or subject to University review/management) when there is a Significant Financial Interest as detailed within this policy.

Definition

“Investigator” means the project director or principal investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of research which may include, for example, collaborators or consultants. For the purpose of clarity, graduate student researchers and undergraduate student researchers may qualify as an Investigator if they satisfy the elements of this definition. 

“Senior Personnel” means any person (including a project director or principal investigator) who is identified by the University as senior or key personnel in a grant application, progress report, or other report submitted to the external funder. 

“Significant Financial Interests” has the meaning set forth below. 

Required Disclosures 

Investigators must disclose all significant financial interests. (1) A “Significant Financial Interest” is a financial interest consisting of one or more of the following held by the Investigator (or the Investigator’s spouse and dependent children) that reasonably appears to be related to the Investigator’s responsibilities at Miami:

(i) With regard to any publicly traded entity, a Significant Financial Interest exists if the monetary amounts received from the entity in the twelve months preceding the disclosure and the value of any equity interest in the entity as of the date of disclosure, together, exceeds $5,000.  Equity interest includes any stock, stock option, or other ownership interest;

(ii) With regard to any non-publicly traded entity, a Significant Financial Interest exists if the value of any monetary amounts received from the entity in the twelve months preceding the disclosure exceeds $5,000, or when the Investigator (or the Investigator’s spouse or dependent children) holds any equity interest (e.g., stock, stock option, or other ownership interest); or

(iii)  Receipt of income by the Investigator (or the Investigator’s spouse or dependent children) related to intellectual property rights and interests (e.g. patents, copyrights).  

(2) Investigators also must disclose the occurrence of any reimbursed or sponsored travel related to their responsibilities at Miami, only if the Investigator was not reimbursed or sponsored by Miami or any of the following: a U.S. federal, state, or local government agency, a U.S. Institution of higher education, a U.S. academic teaching hospital, a U.S. medical center, or a U.S. research institute that is affiliated with a U.S. Institution of higher education.  The details of this disclosure must include, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination, and the duration.  

(3) Investigators must disclose all foreign financial interests (which includes income from seminars, lectures, or teaching engagements, income from service on advisory committees or review panels, and reimbursed or sponsored travel) received from any foreign entity, including foreign Institutions of higher education or a foreign government (which includes local, provincial, or equivalent governments of another country) when such income is in excess of $5,000.  

(4) Investigators are required to update these financial disclosures:

Subrecipient Disclosures

The University is responsible for ensuring any subrecipient’s compliance and reporting identified financial conflicts of interests for subrecipient Investigators to the external funder.  Subrecipients of an externally funded award to Miami University must enter into a written agreement with the University to establish whether this Policy or the financial conflict of interest policy of the subrecipient’s institution will control for purposes of the subrecipient’s compliance with conflicts of interest regulations. 

Subrecipient Institutions who rely on their financial conflict of interest policy must report identified financial conflicts of interests to Miami in sufficient time to allow Miami to report the conflict of interest to the funder to meet its reporting obligations. 

Subrecipient institutions that agree to comply with Miami’s policy must submit all Investigator disclosures of Significant Financial Interests to Miami in sufficient time to allow Miami to review, manage and report identified financial conflicts of interest to the funder.

Miami University is responsible for monitoring subrecipient’s compliance with financial conflict of interest regulations, management plans, and for reporting all identified financial conflicts of interest to the funder.

Exemptions From Disclosure

The term Significant Financial Interest does not include the following:

(i) Salary, royalties, or other remuneration paid by Miami to the Investigator, including intellectual property rights assigned to Miami and agreements to share in royalties related to such rights; 

(ii) Income from investment vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles; 

(iii) Income from seminars, lectures, or teaching engagements sponsored by a U.S. federal, state, or local government agency, a U.S. Institution of higher education, a U.S. academic teaching hospital, a U.S. medical center, or a U.S. research institute that is affiliated with a U.S. Institution of higher education; or 

(iv) Income from service on advisory committees or review panels for a U.S. federal, state, or local government agency, a U.S. Institution of higher education, a U.S. academic teaching hospital, a U.S. medical center, or a U.S. research institute that is affiliated with a U.S. Institution of higher education. 

Required Training

Each Investigator, including subrecipient Investigator(s), must complete training prior to engaging in funded research (and at least once every four years). Training is also required immediately under the following circumstances:

(i) Miami’s  financial conflict of interest policies change in a manner that affects Investigator requirements;

(ii) An Investigator is new to Miami; or 

(iii) Miami finds that an Investigator is not in compliance with this Policy.  

Identification of Actual or Potential Conflicts of Interest 

The Vice President for Research and Innovation or their designee will review each disclosure that is submitted in the Proposal Approval process. In consultation with the Office of General Counsel, the Vice President for Research and Innovation will make a determination of whether a Significant Financial Interest

(i) Could be affected by the funded research; 

(ii) Is in an entity whose financial interest could be affected by the research; or

(iii) Could directly and significantly affect the design, conduct, or reporting of the funded research.

Investigators may request review of this determination by the Office of General Counsel.

When an Investigator who is new to participating in the research project, failed to timely disclose, or  discloses a new Significant Financial Interest, the Vice President for Research and Innovation shall within sixty (60) days review the disclosures; determine whether a financial conflict of interest exists; and, if so, implement, on at least an interim basis, a management plan that shall specify the actions that have been, and will be, taken to manage such financial conflicts of interest.

Actions as necessary are to be undertaken to manage financial conflicts of interest, including any financial conflicts of a subrecipient Investigator, if applicable, and Investigator compliance is to be monitored with management plans until completion of the project.

Plan for Addressing Conflicts of Interest

When an actual or potential financial conflict of interest has been determined to exist, the Investigator and the department chair will propose a plan for addressing and managing any financial conflict of interest, detailing what conditions or restrictions, if any, should be imposed by Miami to manage, reduce, or eliminate the conflict of interest. Examples of conditions or restrictions that may be imposed to manage, reduce, or eliminate conflicts of interest include, but are not limited to:

1. public disclosure of Significant Financial Interests;
2. monitoring of project by independent reviewers;
3. modification of the project plan;
4. disqualification from participation in the portion of the funded project that would be affected by the Significant Financial Interests;
5. divestiture of Significant Financial Interests; or
6. severance of relationships that create actual or potential conflicts.

Such plans must be agreed to by the Investigator, department chair, dean, Vice President for Research and Innovation, and Provost prior to the beginning of the funded project.

Enforcement Policy

Violations of this Financial Disclosure Policy will be handled by the University in accord with the policy titled “Procedures for Disciplinary Action”, which provides for sanctions where appropriate.

A retrospective review will be completed and documented within 120 days of Miami’s determination that either a financial conflict of interest exists or when a new or previously undisclosed Significant Financial Interest is disclosed to the University. The retrospective review shall determine whether any of the externally funded research that was conducted during the period of noncompliance with this Policy was biased in its design, conduct, or reporting. 

In instances whereby the  externally funded research project’s purpose is to evaluate the safety or effectiveness of a drug, medical device, or treatment, Miami shall require any Investigator involved that has a financial conflict of interest that was not timely reported to Miami to: disclose the financial conflict of interest in each public presentation of the results of the  research, and to request an addendum to previously published presentations.

Notification of Funding Agency

Annual (i.e., ongoing) and revised financial conflict of interest reports will be submitted to the funding agency  as specified below:

The funder will be notified promptly if bias is found with the design, conduct or reporting of funded research and a mitigation report will be submitted to explain what action(s) have been or will be taken to mitigate the effects of the bias. Reporting will include at a minimum the following elements:  entity name, name of the Investigator with the financial conflict of interest, nature of Significant Financial Interest, value of the Significant Financial Interest, and any additional information required by the funder/regulation.

The funder will be notified promptly if an Investigator fails to comply with this Policy; a financial conflict of interest management plan; or appears to have biased in the design, conduct, or reporting of the funded research. Corrective action will be taken for noncompliance with this policy or the management plan.

Records

In accord with federal regulations, Miami University will maintain records of all financial disclosures (whether or not a disclosure resulted in a determination of a financial conflict of interest)  and of all actions taken to resolve actual or potential conflicts of interest until at least three (3) years after the later of the termination or completion of the grant to which they relate, or until the resolution of any civil, government, or university action involving those records, or, where applicable, from other dates specified in 45 CFR 75.361.

 Records Request Upon request by a member of the public for information on the financial conflicts of interest of Senior Personnel in an externally funded project, the University shall provide a written response, within five days of receipt of the request, that contains the following information regarding financial conflicts of interests for Senior Personnel:

Subrecipients that agree to comply with Miami’s policy shall also be subject to this disclosure requirement. The University is only required to provide this information to the public when the following criteria are met: (1) a Significant Financial Interest was disclosed and is still held by the Senior Personnel; and (2) Miami has determined that the Significant Financial Interest is a financial conflict of interest. 

Inquiries regarding financial conflicts of interest of Senior Personnel in an externally funded research project should be directed to the Office of Research and Innovation (or in the event of a name change, its equivalent).

With the approval of the November 20, 2023 abbreviated minutes, the following resolution was approved:

BE IT HEREBY RESOLVED that University Senate approves the proposed new Internship Policy Proposal Revision as it appears below:

Policy Title: Internships

Proposer Names: 

Jennifer Benz, Assistant Vice President, Career Exploration & Student Success

Douglas Reichenberger, Regional Director, Career Services & Professional Development

Rationale:

The current policy on internships was developed in 2019, and it represented a major step forward in Miami University’s support of internships.  However, since its inception, several opportunities, issues and challenges have emerged that call for a revision to the existing policy.

Key revisions are:

1. Revised terminology, particularly the terms, “curricular,” “co-curricular” and “extracurricular,” which are confusing since they carry different connotations in the professional literature for experiential learning and student life;
2. Consideration of students who are undecided in terms of major or who may wish to pursue an internship not related to their major, or who cannot secure a faculty supervisor;
3. Clarification of the “zero credit” option for students who are pursuing internships in the summer (and thus do not need to pay)

Proposed Revisions to Internship Policy (Undergraduate) – Clean Version

Overview

Miami University supports and encourages internship opportunities for students. The purpose of this policy is to identify the different types and features of internships available to Miami students and to set forth the responsibilities of the student, the University, and the Internship Sponsor.

It is important to remember that Miami University awards academic credit for the learning outcomes gained through the experience, rather than for the experience itself. To receive academic credit the internship must be a legitimate learning experience benefitting the student with measurable learning outcomes and not just a work experience in a degree-related field. While the majority of internship sponsors will be organizations and businesses external to Miami, Miami University may sponsor internships and co-ops if the work experience advances measurable learning outcomes and the professional development of the student.

Students should complete the application for the appropriate type of internship in consultation with the faculty advisor and site supervisor.  For internships that are required as part of a degree program, the faculty should also develop a Memorandum of Understanding with the internship organization.

Although internships can be paid or unpaid, research shows that paid interns are more likely to gain meaningful employment upon graduation. Students may receive credit for both paid and unpaid internships. International students wishing to pursue internships in the United States should consult the guidelines for Curricular Practical Training and Miami’s International Student & Scholar Services.

Minimum Eligibility Qualifications

Students must:

1. Be in good academic standing with Miami University and have maintained at least a 2.00 cumulative grade point average prior to applying for and enrolling in an internship. Individual departments/colleges or programs may require a higher GPA; and
2. Have completed at least two full-time semesters with a minimum of 24 GPA hours earned at Miami (for continuing students); or completed at least 12 GPA hours earned at Miami (for transfer students); and
3. Understand that academic credits may only be awarded in the term during which the internship is conducted; they may not be awarded retroactively; and
4. Be currently enrolled at Miami University and have been enrolled for at least one full semester prior to beginning an internship

The department, program or internship sponsor may require a criminal record background check or a review of the student’s University disciplinary record and take that information into account when awarding internships.

General Expectations for Students:

Before and during an Internship, students must:

1. Complete the appropriate Internship Application which includes the Learning Plan. 
2. Communicate with their faculty advisor if there are concerns with the internship, including notifying the advisor if they are not able to participate in or complete the internship and reporting when they are in an uncomfortable work environment or experiencing discrimination or harassment as a protected class;
3. Abide by the Code of Student Conduct at all times.
4. Understand and follow the policies, procedures, rules and regulations of the Internship Sponsor.
5. Perform the internship duties for the hours and duration specified. Failure to maintain the internship hours may result in a loss or reduction of academic credit hours, a reduced or failing grade or administrative withdrawal from the internship.
6. Fulfill all of the academic assignments and reporting requirements of the Independent study or internship course. Failure to meet the goals of the Learning Plan may result in a loss or reduction of academic credit or a reduced or failing grade.
7. Complete the appropriate Human Subjects or Animal Research Training as required, if the internship involves research with human subjects (e.g., interviewing, collecting data) or animals.
8. Understand they are solely responsible for any financial obligations incurred by for their participation in the internship; this includes, but is not limited to, tuition and fees for credit hours, travel and housing arrangements, and the cost of background checks (if required).
9. Understand they are solely responsible for the payment of any medical care for injuries alleged to have resulted from their internship experiences.

Note: Students pursuing an internship may be considered for Title IV Aid if the internship is credit-based and a required part of the degree program.

General Expectations for Internship Sponsors

For credit-bearing internships, internship sponsor/employer should

1. Complete the appropriate portion of the Internship Application. 
2. Enter into the Learning Plan with the student and the University as articulated in the Internship Application
3. Submit to the faculty or staff mentor a final evaluation of the student by the deadline specified by the department.
4. Designate a full-time professional as the Internship Supervisor.
5. Provide pertinent policies and procedures to the student before they begin the internship.
6. Provide the agreed upon relevant education/training to the student. Maintain regular communication about the student’s work activities during the internship. Any conflicts should be quickly resolved by communication among the student, instructor, and employer
7. When the internship is unpaid, maintain the intern status of the student, to be distinguished from employment status.
8. Make individual arrangements, if agreed upon between the student and organization, for any stipend or other benefit of service deemed appropriate.
9. Notify the department of any decision to remove the student from the internship prior to the agreed upon time (including the situation when a student is offered and accepts an internship and the internship opportunity is withdrawn prior to the beginning of the internship period) and provide a written report to the department specifying the reasons for terminating the internship.
10. Ensure the student understands Title IX policy and where and to whom the student should report any concerns regarding the internship experience including but not limited to discrimination, sexual misconduct or harassment.
11.  Fully comply with all applicable state and federal laws including wage and hour laws. See, for example: https://www.dol.gov/whd/regs/compliance/whdfs71.pdf

Expectations for Miami Internship Supervisors

For credit-bearing internships, Miami supervisors should: 

1. Ensure that the appropriate Internship Application has been completed, including the Learning Plan and all portions by the employer and student.
2. Complete a fully executed Memorandum of Understanding with the University to provide internships required for the degree program or major.
3. Maintain regular communication about the student’s work activities during the internship. Any conflicts should be quickly resolved by communication among the student, instructor, and sponsor.
4. Assign appropriate credits for the internship experience.
5. Ensure that the student understands where and to whom the student should report any concerns regarding the internship experience, including but not limited to discrimination, sexual misconduct or harassment.

 Expectations for Career Services

1. Maintain Internship Application (currently Handshake), the software that collects student requests for internship/co-op credit and enables the workflow to gather internship approvals from Internship Sponsors and Internship Supervisors.
2. Assist students in internship/co-op position searches without guaranteeing placements.  Career Services will cultivate relationships with new and existing employers in line with student interests and academic program offerings.
3. Document communications with the student and the employer regarding internship expectations and activities. 
4. During the internship experience, serve as a resource to students, internship sponsor and internship supervisor.  Assist in the completion and collection of evaluations and help resolve any conflicts among the student, sponsor, and instructor.
5. Ensure that the student understands where and to whom the student should report any concerns regarding the internship experience, including but not limited to discrimination, sexual misconduct or harassment.

Types of Internships

Internships involve a partnership between students, Miami University, and employers that formally integrates students’ academic study with work or community service experiences and that:

• Are of a specified and definite duration and are posted for a recognized academic term or part of a term and follow all academic calendar deadlines;
• Evaluate (when completing credit-bearing internships) each participating student’s performance in the internship position, both from the perspective of Miami University and the student’s internship sponsor/employer;
• May provide participating students with academic credit upon successful completion of the internship, and may provide students with compensation in the form of wages or salaries.

Internships at Miami can come in three different forms:

1. Optional, Noncredit Internships are internships that are initiated by the student, are not required for the degree and do not receive academic credit. Students do not enroll in any Miami internship-related course.
2. Optional, For Credit Internships are not required for the student’s academic degree or major, but because they relate to the student’s program of study, these internships qualify for undergraduate academic credit. These internships may count for the degree requirements, if the academic program requirements include that opportunity.
3. Required, Program-Related Internships are a requirement for the student’s declared degree or major and carry academic credit.

Specific Expectations for Different Types of Internships

1. Optional, Noncredit Internships
   1. Are initiated by the student, are not required for the degree and do not receive academic credit. In this situation, students do not enroll in any internship courses.
   2. May be pursued during academic terms in which students are enrolled in other classes or during breaks between periods of enrollment.
   3. Need not be related to the student’s program of study. No faculty supervision or written Learning Plan is required for an Optional, Noncredit Internship.
   4. Do not involve an agreement between Miami University and the Internship Sponsor.
   5. May be listed on the student’s resume, but do not appear on the student’s academic transcript.
2. Optional, For Credit Internships
   1. Are not required for the student’s academic degree or major. However, because these internships relate to the student’s program of study (e.g., major, minor, certificate program), they qualify for undergraduate academic credit. Note: The internship must meet a degree requirement to qualify for federal financial aid.
   2. May not exceed six (6) credit hours per semester/ term, nor more than ten (10) credit hours per academic year, and must follow the required minimum time commitments:
      1. 0 credits = less than 37.5 work hours
      2. 1 credit = 37.5 total work hours
      3. 2 credits = 75 total work hours
      4. 3 credits = 112.5 total work hours
      5. 4 credits = 150 total work hours
      6. 5 credits = 187.5 total work hours
      7. 6 credits = 225 total work hours
   3. Must involve an internship course (typically numbered 340, type N) in which the student is enrolled and which is supervised by an assigned faculty supervisor or a qualified career services staff member.  This course appears on the transcript and may be offered as credit/no credit or for a letter grade.  It adheres to the normal registration schedule and course-add deadline for the semester or term in which the internship is taken. Note: Students may elect to take a zero-credit internship course.  A zero-credit internship may be a cost-effective option for students particularly during the summer or winter term.  In consultation with the faculty supervisor, students may also take an independent study course (X77 with the I designation) for one or more credits during the semester following the internship experience to reflect on the learning gained during the internship experience.
   4. Complete assessments, which are strongly encouraged.
   5. May not be substituted for degree requirements.
3. Required, Program-Related Internships
   1. Are a requirement for the student’s declared degree program or major.
   2. Must be for academic credit. Academic credit may not exceed 15 credit hours per semester or summer term.
   3. May not exceed 3 credits during the winter term and are often preceded or followed by a full-semester.
   4. Abide by the following minimum time commitments:
      1. 0 credits = less than 37.5 work hours
      2. 1 credit = 37.5 total work hours
      3. 2 credits = 75 total work hours
      4. 3 credits = 112.5 total work hours
      5. 4 credits = 150 total work hours
      6. 5 credits = 187.5 total work hours
      7. 6 credits = 225 total work hours
      8. 7 credits = 262.5 total work hours
      9. 8 credits = 300 total work hours
      10. 9 credits= 337.5 total work hours
      11. 10 credits = 375 total work hours
      12. 11 credits = 412.5 total work hours
      13. 12 credits = 450 total work hours
      14. 13 credits = 487.5 total work hours
      15. 14 credits = 525 total work hours
      16. 15 credits = 562.5 total work hours
          1. Have assigned faculty supervision that includes ongoing communication and guidance by the responsible faculty member.
          2. Have concurrent integrated coursework that appears on the student’s transcript and may or may not be offered as credit/no credit or for a letter grade.
          3. Have a completed Internship Application which includes a written Learning Plan.
          4. Involve appropriate education by Miami University to better ensure that the student is prepared for the internship experience. This may include clinical and other hands-on training provided by Miami University.
          5. Have a fully executed Memorandum of Understanding between the internship organization and Miami University.
          6. Ensure that the required internship experience is related to the program of study by regular interaction with the student.
          7. Require the student to report on a regular basis throughout the internship.
          8. Complete on-site assessments for all Required, Program-Related Internships. If personal visits are not feasible, the instructor should regularly converse with the intern electronically including skype, phone, Internet and/or e-mail.
          9.   Obtain the Internship Sponsor’s site supervisor’s completed Internship Evaluation.
4. Internships Outside of the United States
   1. Require students taking an internship for academic credit outside of the United States to register in the Miami University Independent Travel Program system at least 30 days prior to departure.
   2. Strongly encourage students engaging in noncredit internships to register in the Miami University Independent Travel system.
   3. Require enrollment in Miami University’s international travel supplemental health and safety insurance plan and in the S. Department of State Smart Traveler Enrollment Program (STEP). Students will also be expected to provide documentation regarding housing, transportation, and emergency contact information.
   4. Require faculty supervisors to consult with Global Initiatives prior to approving an internship in a country listed on the S. Department of State Travel Advisory List.
   5. Understand and abide by visa requirements and labor laws relevant to engaging in an internship in the host country.

Effective Date: January 2024

Responsible Parties:

Center for Career Exploration & Student Success (Oxford Campus)

Career Services & Professional Development (Regionals)

University Registrar

Academic Departments

Office of Provost

Implementation:

Application and guidelines will be put on the Center for Career Exploration & Student Success website by January 1, 2024.

Related References and Resources:

Center for Career Exploration & Student Success (Oxford Campus)

Career Services & Professional Development (Regional Campuses)