Several people have asked for my thoughts on the LeanIn.org unpaid internship controversy. I love Facebook CEO Sheryl Sandberg’s Lean In, a compelling look at ambitious women in the workforce and the factors that have traditionally kept us out of the highest-paid and most senior-level positions.

I also run the internship program at the nonprofit Center Theatre Group, where all of our internships must be taken for credit or are compensated with a stipend.

Here’s what Rachel Thomas, LeanIn.org’s President, had to say via Facebook after a job posting for an ‘unpaid internship’ at the organization started making the rounds:

Like many nonprofits, LeanIn.Org has attracted volunteers who are passionate about our mission. We’ve had four students ask to volunteer with us. They worked flexibly when they could, and often remotely.

These volunteers helped support our message and community, and gained valuable experience doing so. They did not displace or delay the hiring of paid employees. The posting that prompted this discussion was for a position that doesn’t fall within LeanIn.Org’s definition of a “volunteer.”

This non-apology is so strangely written that it’s hard for me to know where to start.

Here’s the main thing I take from it, and it’s actually pretty disturbing:

LeanIn.org is using ‘intern’ and ‘volunteer’ interchangeably. Thomas, speaking on behalf of her organization, is confusing two distinct categories.

This comes immediately after this patronizing intro:

“We recognize there is an ongoing public debate on the appropriate use of unpaid interns. So we want to share the facts with you and our community.”

This word, “fact?” And “intern?” And “volunteer?”

You keep using these words.

I do not think they mean what you think they mean.

Ms. Thomas, nonprofit volunteers do not need to “gain valuable experience,” and they can and often do “displace or delay hiring of employees.”

That language refers to the Fair Labor Standards Act’s (FLSA’s) criteria for internships.

Here are some basic differences between the two categories:

Internships are training programs, and the “training must be for the benefit of the trainee,” to quote the FLSA. In fact, “The employer that provides the training derives no immediate advantage from the activities of the trainees, and on occasion the employer’s operations may actually be impeded .” Read: they are not cheap or free labor.

.” Read: they are not cheap or free labor. Internship learning experiences must include close observation (mentorship), so working remotely is not a good indication that you have provided a rewarding internship experience.

Volunteers, conversely, usually do work that directly benefits the nonprofit. They do not need to be mentored, do not need to be trained, and can be utilized in lieu of paid, regular employees.

There are many blog posts and web resources that go into the differences between volunteers and interns at length. For example, this excellent Blue Avocado article spells out additional best practices and quotes relevant parts of the FLSA.

In a nonprofit setting, it can be difficult to ensure internships are crafted to not only fulfill legal requirements, but also to serve the best interests of each intern.

Much of my job running CTG’s internship program involves saying no. I say no to supervisors who want their interns to work “as much as possible,” and to interns who are so happy to be involved that they try to expand their 10 hour/week stipend position into 20 or 30 hours.

Here’s what I say to them:

The internship is for the benefit of the intern. It is a learning experience, not free labor. If your department needs help with basic tasks such as stuffing envelopes, filing, or data entry, I empathize and suggest you think about getting a regular volunteer to help.

Because volunteers are different. Outside of CTG, I am on the staff of an all-volunteer small theatre company, Circle X Theatre Co. As a volunteer, I can do whatever I want, and whatever is needed, for as many hours a week as I care to give. I clean bathrooms. I stuff envelopes. I do hours of data entry. It’s my choice as a volunteer, and I’m doing it to help the nonprofit organization, not for a learning or career benefit. Right now, Circle X has a (paid) summer intern, and she will not be cleaning toilets. The internship. Is for the benefit. Of the intern.

And to the interns: this is bigger than you, so no, I will not make an exception and let you work full-time. Up until a few years ago, CTG almost exclusively took interns from a large, local private university with very high tuition. As the program has opened up, we’re starting to see more people from public schools, including the two-year community colleges near our organization. The reason our positions are designed to be super part-time (10 to 16 hours a week for undergraduates, with the schedule built around the intern’s) is the stipend amounts we have available are quite low ($500 – $700 for ten weeks). They’re designed to allow a student to also hold a part-time job that pays the bills.

I do not want lack of economic privilege to be a barrier to participation in this workforce development program. When we raise the stipends for these time-bound educational opportunities to a living wage, we can increase weekly hours. Programs such as the Oregon Shakespeare Festival’s FAIR pay interns $1,000/month and provide housing. When CTG is able to do that, we will absolutely create additional opportunities, likely full-time, 10-week summer internships.

I don’t foresee a time when we would extend those opportunities beyond 13 or 14 weeks, though; the point of an internship is to train & release, allowing the intern to ‘lean in’ to the next career opportunity.

The more I think about LeanIn.org’s posting and strange response, the more it seems indicative of the widespread misunderstanding of the role of interns in the nonprofit sector. We have a pressing need for workforce development, especially career training opportunities accessible to young people of color (research suggests that executive nonprofit leaders AND current students in nonprofit management Masters programs are 80-90% white) and people without economic privilege.

Unpaid internships and the increasing number of low-paying nonprofit management jobs that require Masters degrees can price people out of nonprofit management careers. Humane, student-focused, and compensated internships introduce emerging professionals to the field and can provide a leg up in the competitive nonprofit landscape.

Lean In talks about the importance of equity– and of recognizing when systems are inherently inequitable. The best thing for Thomas, Sandberg and the LeanIn.org organization to do would be to use this opportunity to clarify the roles of interns vs. volunteers, apologize, and vow to do better.

Unfortunately, it looks like they’re trying to justify their bias by manipulating language, defending their actions, and refusing to admit fault.

Which sounds a lot like the tactics that keep women out of top-level, high-paying positions.

I’ll end with some quotations from Lean In:

“We cannot change what we are not aware of, and once we are aware, we cannot help but change.”

“The promise of equality is not the same as true equality.”

“Larry implored us to exert more control over our careers. He said McKinsey would never stop making demands on our time, so it was up to us to decide what we were willing to do. It was our responsibility to draw the line.”

“I feel really grateful to the people who encouraged me and helped me develop. Nobody can succeed on their own.”

Here’s hoping Sandberg will take her advice, and provide equal and accessible opportunities for training and mentorship within her own organization.