II. State Work-Study Program Employers Guidelines

  1. Employer Eligibility Requirements
  2. Placement/Supervision
  3. Record Keeping and Reconciliation

A. Employer Eligibility Requirements

  1. The employer must be a business, industry, nonprofit organization, or governmental agency located in Pennsylvania.
  2. The employer must develop tasks that will provide actual high tech training experience or use the student's classroom knowledge/skills in a project identified as one which assists in the economic, social, or cultural development of the community.
  3. The employer must ensure that employment/work conditions comply with all federal, state and local laws.
  4. The employer must accept responsibility for 100 percent of student earnings where PHEAA approval has not been received prior to the start of employment.
  5. The employer may not hire students from a postsecondary institution which owns the company/organization or with which the company/organization has an indirect or direct relationship or affiliation without PHEAA approval.
  6. Placement of a State Work-Study student may not displace employees in the normal work force (including those on lay-off or on strike) or impair or interfere with existing contracts. The program's intent is to create additional training opportunities for postsecondary students.
  7. State Work-Study jobs may not involve any political activity.
  8. Projects, assignments, activities, etc., involving lobbying are prohibited and cannot be assigned to State Work-Study students. (Note: Businesses involved in lobbying may not be approved.)
  9. The work may not involve constructing, operating, or maintaining any part of a building used for religious worship or sectarian instruction. In addition, the work assignment must be in the public interest.
  10. Work is in the public interest if the work performed contributes to the general welfare of the community, rather than work performed for a particular interest or group.

    Work is not in the public interest if it primarily benefits the members of an organization that has membership limits, such as a credit union, a fraternal or religious order, or a cooperative.

    For example, a student may be employed by an organization such as a private nonprofit civic club if the student's work is for the club's community drive to aid handicapped children. If the student's work is confined to the internal interests of the club, such as a campaign for membership, the work would benefit a particular group and would not be in the public interest. As another example, a tutor at a parochial school may not use religious material to tutor children.
  11. The employer must ensure that no student will be denied work or subjected to different treatment on the grounds of race, color, national origin, or sex. The employer must also be in compliance with the provisions of the Civil Rights Act of 1964.

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B. Placement/Supervision

  1. Eligible SWSP students will be placed with companies as available. The completion of the Participation Agreement does not guarantee that a student will be placed with your company.
  2. A job description for each SWSP position must be developed in order to ensure that the student will be placed in a career-related high tech or community service position.
  3. A full-time, paid employee must be assigned to interview potential SWSP students. If the employer wishes to hire the student through the SWSP, the employer must complete the Employer Data Section of the SWSP Student Application/Placement Form (1.13 MB PDF). If the student does not have this form, contact PHEAA Work-Study staff for a copy. The Application/Placement Form must be received by PHEAA on or before the filing date listed on the form.

    (Note: Employers should not permit any student to begin work without having received a copy of the SWSP Placement Approval Document; if an ineligible student is permitted to work, the employer may be responsible for full payment of all wages.)
  4. A full-time, paid employee must be assigned to supervise SWSP students during the performance of all assignments, tasks, and projects, and ensure that the experience is consistent with the purpose of the program.
  5. The supervisor must hold an orientation session with each student to ensure that the student understands:
    1. the hourly rate of pay (which cannot be less than the prevailing minimum wage);
    2. the dates of temporary employment;
    3. the scheduled work hours (not to exceed 40 hours per week in the summer or holiday break and 20 hours a week during the academic year) the student is expected to work and during which a full-time paid employee will be available;
    4. employer expectations relating to the job description;
    5. the dates on which the student will be paid;
    6. safety rules; and
    7. if appropriate, professional guidelines for relating and/or interacting with clients during the supervised, assigned work period and contacting, relating, and/or interacting with clients outside of supervised, assigned work hours.
  6. At no time may a student be left alone on the premises in charge of company property or sent on assignment without the presence of a paid, full-time employee of the organization.
  7. The employer must immediately contact PHEAA if any of the following apply:
    1. the supervisor has a concern about a student's performance;
    2. the supervisor is requesting reassignment or dismissal of a student.

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C. Record Keeping and Reconciliation

  1. The employer must establish payroll procedures, add the student to the payroll, and pay 100 percent of actual wages as well as all required associated payroll costs, including Workers' Compensation.
  2. Reporting Payroll Earnings
    1. The employer must submit payroll data to PHEAA for all weeks that students work. It is important that earnings be reported accurately and in a timely manner so that disbursement can be processed promptly. When submitting payroll data, the following items are required:
      1. Program on which the student is working.
      2. Student's name.
      3. Student's social security number.
      4. Payroll beginning and ending date.
      5. Student's gross earnings for payroll period.
      6. Employer name.
      7. Employer code (including suffix, if applicable).
      8. Employer department code and name (if applicable).
      9. Employer telephone number.
      10. Employer contact person.
    2. Employers may report the payroll data to PHEAA by using any one of the following formats:
      1. Complete and submit the PHEAA Work-Study Earnings Report (72.5 KB PDF).
      2. Complete and submit a spreadsheet.
      3. Data enter the student's earnings online via the Internet.
  3. Disbursements
    1. Employers will receive reimbursement via Electronic Funds Transfer (EFT). All employers are required to complete an ACH Authorization Form (26 KB PDF) upon program enrollment.
    2. Disbursements will be scheduled to occur every two months as follows:

      January 15    July 15
      March 15       September 15
      May 15          November 15
    3. A disbursement roster will accompany each disbursement. Employers must certify and return any previous roster before a subsequent roster and disbursement can be produced.
    4. Employers are subject to a PHEAA audit and are required to maintain a copy of time cards that include the following information for review during the audit. Records must be maintained for a minimum of five years:
      1. Student's name.
      2. Work dates.
      3. Hours the student actually worked.
      4. Payroll records verifying that the student was paid for the hours worked.

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