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ARTICLE · 05 JUNE 2014

Students In Clinical Training Program Were Not Employees Under The FLSA

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A federal trial court in Florida recently issued a significant decision on the issue of unpaid trainees under the FLSA.

United StatesEmployment and HR
FordHarrison LLP
FordHarrison LLP
Tammie Rattray
Tammie Rattray
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A federal trial court in Florida recently issued a significant decision on the issue of unpaid trainees under the FLSA, finding that 25 former students of Wolford College were not employees when they participated in a clinical training program as part of the college's Masters of Nurse Anesthesia program. 

Background

The 25 students were enrolled in Wolford's College's Master's degree program with the goal of becoming Certified Registered Nurse Anesthetists (CRNAs). While at Wolford, the students participated in a clinical training program supervised by medical doctors and CRNAs with the practice group Collier Anesthesia. The clinical program was required by law for the students to become licensed as CRNAs. Although the students knew that the clinical training was required and unpaid, they later filed a collective action lawsuit against the college, Collier Anesthesia, and two individuals for minimum wage and overtime payments under the Fair Labor Standards Act

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