What follows is essential
reading for all students, doctoral program DCTs, and internship
program Training Directors about drug testing and other pre-employment
requirements. If you think you already know the issues, you could be
mistaken, as things have changed significantly just in the past few years
(e.g., over-the-counter availability of certain products which, if consumed, could
lead to failure of a drug test and termination from an internship).
We ask that all DCTs discuss these issues with their students who are
seeking internship this year.
DRUG TESTING
Some internship programs perform drug testing prior to and/or during the
internship year. One of the most misunderstood issues in this area is
with regard to the recreational and medical use of marijuana (cannabis) as well
as products containing THC (tetrahydrocannabinol) or CBD (Cannabidiol).
Some students assume that having a prescription for marijuana/cannabis,
being matched to an internship program that is located in a jurisdiction that
allows the recreational use of marijuana/cannabis, or obtaining a medicine
over-the-counter (e.g., CBD oils) means that their use of these substances will
be acceptable to internship programs. However, this is a very risky and
potentially incorrect assumption, as some internship programs prohibit
the use of marijuana/cannabis, THC, and/or CBD in SOME or ALL circumstances,
and will refuse to hire a student who tests positive regardless of medical
need, the presence of a prescription, the fact that it was obtained over-the-counter,
or its legal status.
STUDENTS: If you use any of these substances, regardless of its
purpose or legal status, you should carefully review sites' materials to ensure
that you apply to sites that will allow you to use such substances. If a
site's materials are unclear, you should consult with sites' HR departments to
get clarification of their policies. We strongly encourage you to get
such clarification in writing. While we appreciate that asking for
clarification can feel difficult or risky to do, the consequences of not being
clear can be devastating.
INTERNSHIP PROGRAMS: We recommend that you consult
regularly with your Human Resources department in order to stay aware of any
changes that have occurred to relevant policies. Please ensure that your
public materials are as clear and accurate as possible in terms of any drug
testing that is performed and the expectations for employees and interns as far
as drug use is concerned. In particular, please be aware that the medical
use of marijuana/cannabis has become increasingly common among the general population,
and thus clearly articulating your policies regarding the medical and
recreational use of marijuana/cannabis, THC, and CBD would be helpful to
applicants.
PRE-EMPLOYMENT SCREENINGS
APPIC Match
Policy # 8b states, "Appointments of applicants to internship
positions may be contingent upon the applicants satisfying certain
eligibility requirements. Such eligibility requirements must be clearly
specified in the internship programs' written materials and provided to
applicants in advance of the deadline for submitting rankings for the
APPIC Match."
STUDENTS: It is important to understand that most sites consider
interns to be employees, which means that they have the same expectations of
interns as they do of any other employee. Many sites now conduct
background checks, drug testing, or other pre-employment screenings that a
student must pass in order to be employed as an intern. Remember that the
APPIC Match Policies allow you to be denied appointment or dismissed if you
fail any pre-employment screenings. Thus, careful attention to
sites' pre-employment requirements is essential as you decide where to apply
and which programs to rank. If in doubt, don’t make assumptions — ask the
site for clarification (you can ask to speak to the Training Director or to an
HR representative). Keep in mind that, in some cases, criminal records
that have been sealed or expunged may be included in these
background checks. Failure to fully and accurately disclose background
information may also be deemed to be a failure resulting in denied employment.
In order to be employed as an intern, you will be required to provide
documentation of your identity as well as your authorization to work in the
U.S. (for U.S. internships) or Canada (for Canadian internships).
INTERNSHIP PROGRAMS: Match Policy #8b requires the advance
disclosure of your site's eligibility requirements so that students can
understand these requirements and make informed decisions about whether or not
to apply to or rank your site. Most importantly, it minimizes the
possibility of your program being matched to an applicant who is ineligible for
hire. Thus, if your site has such pre-employment requirements, please
ensure that your public materials (web site, brochure, APPIC Directory listing,
etc.) are as clear and detailed as possible. Specifically:
a. Please be clear about your eligibility requirements and, as much as
possible, what constitutes a "pass" and a "fail." For
example, it is generally not enough to simply say that you conduct a
"background check," since that doesn't tell the applicant what past
behavior is and is not acceptable (e.g., will a misdemeanor constitute a pass
or a fail?). Similarly, saying that you conduct "drug testing"
doesn't clearly specify what your expectations are of the applicant in terms of
their drug use (e.g., is marijuana/cannabis/THC/CBD use acceptable? If
so, under what circumstances?). The goal here is to be as disclosive as
possible in order to minimize the possibility that an ineligible student will
apply (or, worse, get matched) to your site.
b. We recognize that, in some circumstances, HR policies are vague and it
can be challenging to meet what is outlined in the previous paragraph.
Thus, it is essential that you work closely with your Human Resources
department in order to craft wording that is clear and covers all of your
institution's policies and eligibility requirements for employees. We
have seen a number of situations where HR determines that the student has
failed a requirement that wasn't disclosed in advance, often because the Training
Director wasn't aware of the requirement or how it would be administered,
interpreted, or enforced.
While the COVID pandemic appears
to have eased for now, many sites continue to have vaccination requirements of
employees, including interns. These requirements may include both COVID
and non-COVID (e.g., measles, rubella, tuberculosis) vaccinations.
Training Directors are reminded to please keep their public materials updated
to reflect policy developments in this area. Applicants who are unable or
unwilling to be vaccinated may need to make some difficult choices with regard
to their participation in the upcoming Match process, and we would like to
provide the following guidelines for these students:
1. Most importantly, don't make assumptions about any
site. If a site's published materials are silent on its vaccination
policies, you should not assume that you will be allowed to work at the site
without being vaccinated. Nor should you assume that a policy won't be
established in the coming weeks and months.
2. For sites that require vaccination of its employees, you should not
assume that you will be granted an exemption, nor should you assume that
certain accommodations will be provided. This includes individuals who
are unable to be vaccinated for medical reasons.
3. It is imperative that you talk directly with the site to understand
their current policies as well as the possibility of policies changing in the
future.
4. Students seeking internship should only rank sites for which they have
confirmed that their vaccination status will be acceptable to those
sites. Individuals seeking postdoctoral positions should only accept a
position if they have confirmed the acceptability of their vaccination status
with that site.
5. If a site's vaccination polices change after you
have been placed at that site, you will likely be required to conform to the
site's new policy. Failure to do so may result in being terminated from
the training program. While APPIC can assist in attempting to negotiate
solutions in such situations, vaccination policies are often established at the
Federal, State, or Provincial level and thus there may be little to no
flexibility.