UW System Administrative Policy 205 (formerly G18)

Employment of Student Help

Original Issuance Date: July 1, 1991
Last Revision Date: October 7, 2024

1. Policy Purpose

The intent of this policy is to provide financial assistance to students in the form of assistantships and part-time employment. This policy sets forth the University of Wisconsin (UW) System operating policies for employment of student employees, including compensation, scheduling, and institutional and system administration responsibilities.

2. Responsible UW System Officer

Associate Vice President and Chief Human Resources Officer

3. Scope

This policy applies to student employees of UW System institutions.

4. Background

This policy sets forth the University of Wisconsin System operating policies for employment of student employees, as the Wisconsin Statutes do not define procedures relating to student employees. UW System Administrative Policy 215 (SYS 215), Payment Methods and Timing for Payroll, addresses payroll payment policies.

University financial aid programs provide students four basic forms of assistance: grants, loans, assistantships, and part-time employment. Students may be hired to assist administrators, faculty, and staff in carrying out their duties in the UW System.

Please reference SYS 1237, Student Employment, regarding provisions specific to student employment and guidance for complying with the Patient Protection and Affordable Care Act of 2010 as those requirements relate to student workers.

5. Definitions

Educational institution:

  • Accredited institution of higher learning;
  • a technical college;
  • a vocation or trade school;
  • and a high school.

Student employee: An employee, at least sixteen (16) years old[1], of the UW System who:

Summer employment: Summer employment extends to students enrolled for the summer term; students registered during the prior spring term who are planning to continue as students during the fall semester; or new students or pre-registered continuing students accepted for the next fall term.

6. Policy Statement

A. Hourly Student Employee

Students are normally compensated on an hourly basis and are paid through the regular student payroll system.

B. Non-Hourly Student Appointments and Employment

Student employees in this category are paid through the regular payroll system.  All hours worked must be tracked and reported in the payroll system. If hours are not entered into the payroll system, a lump sum of eight (8) worked hours for each day on payroll in a given pay period will be reported and designated for purposes of the Affordable Care Act (ACA) reporting. Due to ACA requirements, the number of employees in this category should be limited to students with very unusual or special circumstances.

C. Compensation

When a job that can be performed by a student is established to include an employment relationship as defined in SYS 236, Utilization of Independent Contractors, every attempt should be made to establish an hourly wage rate as a compensation basis. Under special conditions, student employees may be paid on a non-hourly basis. In establishing compensation levels, the rates shall:

  1. Reflect local student employee job market conditions.
  2. Comply with applicable state and federal statutes, and policies of the Board of Regents of the University of Wisconsin System.
  3. When hourly, not exceed the minimum of the salary range for classified employees with similar duties and shall provide compatibility between regular student rates and work-study rates as governed by federal regulations promulgated by the U.S. Department of Education. Exceptions may be granted by the Chancellor (or designee) at each institution.

D. UW System Administration Responsibilities

  1. Develop and approve broad operating policies and procedures.
  2. Communicate to the institutions the federal and state regulations governing student employment and, in particular, the statutory changes affecting such employees.
  3. Provide counsel and coordination of administrative services to the institutions as required to support the development of consistent and uniform student employment and payroll policies, administrative procedures, and technical systems.
  4. Monitor the student employment program through management audits of student employment and payroll systems.
  5. Through the UWS Service Center, produce the following for each student employee:
    1. An earnings statement that includes:
      1. The employee’s name
      2. Gross earnings
      3. Net earnings
      4. Federal and state taxes
      5. Social Security (if any)
      6. Identification of the pay period
      7. Year-to-date totals for gross earnings as well as for federal, state, and Social Security tax deductions
    2. A W-2 income tax statement at the end of each calendar year.

E. Institutional Responsibilities

  1. The Chancellor of each institution (or designee) is assigned the responsibility to operate its student employment program, including implementation of UW System policies and procedures, institutional compensation plans and monitoring processes.
  2. The Chancellor shall appoint a committee to review and advise on the operation of the institution’s student employment wage plan.
  3. The Chancellor (or designee) shall determine which student employment jobs will be compensated on a non-hourly pay basis (salaried).
  4. The Chancellor (or designee), with advice of the appointed Committee, shall establish a rate structure that is consistent with the compensation policies in this policy, and that will:
    1. Allow for an adjustment to the hourly and non-hourly rates if there is a change in the assigned work responsibilities or the student achieves relevant work experience.
    2. Establish a maximum rate which cannot be exceeded without approval of the university official designated by the Chancellor to monitor the student employment program.
  5. The Chancellor shall establish guidelines relating to the maximum amount of time which can be worked by student employees. Student employment should be part time or temporary, except during breaks between academic terms and during the summer. See Section 6G: Constraints for additional provisions that apply to student hourly employees which references SYS 1237, Student Employment, to maintain compliance with the Affordable Care Act.
  6. Institutions shall communicate to their student employees the conditions of employment, performance expectations, and insurance coverages (FICA, Worker’s Compensation). Such understanding can be facilitated by written communications.
  7. Hourly and non-hourly student employees shall be paid on a bi-weekly schedule.
  8. Provide or make available through automated means tax and earnings statements to student employees.
  9. Each institution shall maintain student payroll records which constitute adequate financial records and audit trails, including the certification of time and effort as required by federal regulations (OMB Circular A-21).

F. Nondiscrimination and Affirmative Action

Regent Policy Document 17-4, Equal Opportunity and Affirmative Action in Employment, applies to student employment. RPD 17-4 states:

It is, and continues to be, the policy of the University of Wisconsin System to adopt and support measures designed to prevent and eliminate discrimination against employees and prospective employees of the University of Wisconsin System on the basis of race, color, religion, sex, gender identity or expression, national origin, age, or physical handicap.

As a part of this policy, the University of Wisconsin System is committed to the implementation of affirmative action employment programs to recruit, employ, and promote qualified women and minorities. System administrators and the University faculties shall continue to take such steps as may be necessary to accelerate the final elimination of any and all vestiges of discrimination because of race, color, religion, sex, gender identity or expression, national origin, age, or physical handicap that may still exist in the employment policies, practices and/or procedures of the University of Wisconsin System.

G. Constraints

In addition to this policy, the following provisions apply to student hourly employees:

  • Student hourly employees do not have grievance or layoff rights.
  • Student hourly employees are nonexempt (hourly) employees under the provisions of the Fair Labor Standards Act (FLSA).
  • Student hourly employees are typically undergraduate students, employed “at-will,” have no expectation of continued employment, and their hours worked do not count toward full-time equivalent (FTE) count for the UW System or a specific institution.
  • Under s. 108.02(15)(i), Wis. Stats., student hourly employees enrolled as students are not eligible for unemployment insurance benefits.
  • Under s. 40.02(25)(b), Wis. Stats., student hourly employees are non-benefits eligible for employer-sponsored health insurance coverage through the UW System.
  • Under s. 102.03, Wis. Stats., student hourly employees are covered by Worker’s Compensation.
  • Student hourly employees should not be permitted to work more than the hourly limits established by SYS 1237, Student Employment, to maintain compliance with the Affordable Care Act.

[1] Individuals under the age of 18 may be subject to various child labor laws and regulations. These laws and regulations may require work permits and place restrictions on work hours and type of employment.
[2] Special exemptions may exist for non-resident alien students. Questions regarding these special circumstances should be directed to the UW Service Center or UW System Human Resources.

7. Related Documents

UW System Administrative Policy 215, Payment Methods and Timing for Payroll
UW System Administrative Policy 206, Student FICA Exemptions
s. 36.15, Wis. Stats.
s. 36.19, Wis. Stats.
UW System Administrative Policy 236 ,Utilization of Independent Contractors 
UW System Administrative Policy 1251, Appointment Terms and Designation of Positions
Internal Revenue Service Revenue Procedure 2005-11
UW System Administrative Policy 1237, Student Employment

8. Policy History

Revision 4: October 7, 2024

Revision 3: June 7, 2022

Revision 2: June 28, 2019

Revision 1: August 20, 2007

First approved: July 1, 1991

9. Scheduled Review

September 2029