JUNE 2025
TABLE OF CONTENTS
TABLE OF CONTENTS
TABLE OF CONTENTS
TABLE OF CONTENTS
TABLE OF CONTENTS
Summer Interns -
Employer Compliance Checklist
Summer interns can be a great asset, but they also come with important compliance considerations, especially as more states extend benefits and protections to temporary workers. Here are a few reminders to help keep your program on track:
Wage & Hour Rules
Interns must be paid at least minimum wage unless they qualify under the Department of Labor’s strict “primary beneficiary” test for unpaid internships. When in doubt, treat them as hourly employees.
​Paid Sick Leave Eligibility
In states with Paid Sick Leave laws, like Colorado, California, New York, and Washington, interns are often entitled to accrue and use PSL, even if they are seasonal, part-time, or only with your organization for a few months.
Workers’ Comp Coverage
Most states require that interns be covered under the employer’s workers’ compensation insurance, regardless of whether they are paid or unpaid. This is a common compliance blind spot for summer programs.
Anti-Discrimination Protections
Interns, especially unpaid ones, are still protected under most workplace policies and applicable laws. Ensure they receive appropriate onboarding, policy acknowledgments, and access to reporting channels.
Tax Withholding and Form I-9
All interns must complete Form I-9 to verify employment eligibility. Paid interns should also complete a W-4, and applicable tax withholdings must be processed. Misclassifying interns as independent contractors can result in penalties and back pay liability.
Youth Labor Law Considerations
All interns must complete Form I-9 to verify employment eligibility. Paid interns should also complete a W-4, and applicable tax withholdings must be processed. Misclassifying interns as independent contractors can result in penalties and back pay liability.
Confidentiality and NDAs
If interns will access proprietary systems, client data, or internal processes, consider having them sign a non-disclosure or confidentiality agreement during onboarding. These should be reviewed for state-specific compliance, especially in Colorado.
Colorado Compliance Note: Under C.R.S. § 24-34-402.5, employers may not restrict interns from engaging in lawful off-duty activities, such as volunteering for a political campaign, unless the restriction is tied to a legitimate business need or avoids a conflict of interest.
Colorado also limits the use of NDAs to silence reports of unlawful workplace conduct. Agreements should not prevent interns from reporting or discussing harassment, discrimination, or safety concerns.
Orientation and Exit Feedback
Provide a structured onboarding experience that includes policies, workplace expectations, and a point of contact for support. At the end of the internship, consider conducting an exit interview or survey to collect feedback and improve future programs.
Intern-to-Hire Transitions
If there’s a chance your intern may transition to a regular role, make sure you clearly document their original internship start and end dates. When hiring them into a new position, treat it as a standard onboarding process, including benefit eligibility evaluations, background checks, and any required compliance forms.
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Even short-term roles deserve thoughtful planning, proper documentation, and compliance oversight. With the right structure in place, your intern program can stay legally sound and leave a positive, lasting impression on future talent.
QUESTION:
I have an employee who asked if they could be allowed to take a day off every other week, stating it was for religious reasons. We work in a warehouse that is currently very understaffed, and the days he asked to take off are busy days where we need all hands on deck. Am I required to accommodate his request?
Must Employers Grant Religious Leave on Peak Work Days?
Answer:
It depends.
Under Title VII of the Civil Rights Act of 1964, employers are prohibited from discriminating based on religion. This includes a duty to reasonably accommodate an employee’s sincerely held religious beliefs or practices, unless doing so would cause an undue hardship for the organization. An employer refusing to accommodate an employee’s sincerely held religious belief does qualify as discrimination under this law, unless it would impose ‘undue hardship’ on the company.
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Defining "Undue Hardship"
It's difficult to determine what is and is not considered an ‘undue hardship’. On July 23rd, 2023, the Supreme Court ruled that undue hardship ‘is shown when a burden is substantial in the overall context of an employer’s business’. Unfortunately, this ruling does not come with a true definition for what a substantial burden is, needing to be determined on a case-by-case basis.
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Prior to the ruling, the law was historically understood to mean an employer did not have to provide a religious accommodation if it would impose more than a "de minimis" burden on the employer; which basically meant that the employer had to prove that the accommodation is more than a trivial task to implement. With the Supreme Court ruling, it means that employers cannot deny an accommodation just because it is inconvenient to the business or results in some additional costs.
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The Interactive Process
Regardless, an employer can only determine undue hardship by going through the interactive process; which involves a discussion with the employee about the nature of the accommodation, determining if the accommodation prevents the employee from doing essential job functions, etc.
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For guidance on how to conduct this process, we recommend reading the article The Interactive Process.
While it focuses on the ADA interactive process, the underlying principles are virtually the same.
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iSolved Enhanced Security Options for Login
iSolved has begun a new rollout of login features to enhance the security process when logging in to the employee portal including updates to the password setup and reset process, an easier step-by-step setup process for Authenticator Apps, and a new Passkey login feature.
Password Entry Enhancements:
Password Strength Indicator:
Users do still have the option to use their password to login and now have a visual guide available to help create stronger, more secure passwords during setup or reset.
For users who choose to continue to use their password to login, the Multi-factor Authentication (MFA) options are still available to verify the user’s identity by email or phone.
Authenticator Setup:
For those users who would prefer to use an Authenticator App, iSolved has a redesigned, step-by-step form to make it easier to set up TOTP (Time-based One-Time Password) using an authenticator app.
New Passkey Features:
You may have already noticed the new Passkey option available on the iSolved login screen.
Passkeys use public-key encryption for security, which means authentication requires two separate keys: one that is stored on your device(s), and the other with iSolved where your account is held.
Passkey Setup Radio Toggle:
There is a new toggle option for users who haven’t yet enabled a passkey-making setup simple and accessible.
Passkey Setup Page:
After toggling the Passkey Setup on and following the normal login process using the password and verification requirements, there is a dedicated, easy-to-follow page, to guide users through passkey activation.
Passkey Log In Button:
For the users who have already configured a passkey, the Passkey Log In option is instantly visible for users, enabling fast and secure access.
Passkey Enabled Confirmation:
A message confirming when passkey functionality has been successfully turned on.
