The Catholic University of America

Responsibilities of the Counselor, Work Study Manager

Federal Work-Study Program (42 U.S.C. § 2753(b)(1)(C) and 34 C.F.R. § 675.22)

The regulations contains the requirements universities must follow when participating in the federal grants for work-study programs. The law and regulations for the federal work-study program contain prohibitions on using the funds for "sectarian" or religious purposes. Federal law requires the institution of higher education receiving the federal work-study funds to sign an agreement that the funds will not be used for the "construction, operation, or maintenance of so much of any facility as is used or is to be used for sectarian instruction or as a place of religious worship." See 42 U.S.C. § 2753(b)(1)(C). Further guidance on this subject can be found at 34 C.F.R. § 675.22 that states that the work performed by the student receiving work-study money must be in the public interest. Work is not in the public interest if it "primarily benefits the members of a limited membership organization such as a credit union, a fraternal or religious order, or a cooperative." See 34 C.F.R. § 675.22(b)(1). Work study funds must be used in accord with the University’s Program Participation Agreement.

The regulations also prohibit the use of federal work-study funds in any partisan or nonpartisan political activity, or lobbying at the federal, state or local level. A student performing work under the Federal Work Study program should not engage in any direct lobbying communication, or in any grass roots lobbying communication. "Direct lobbying communication" is any attempt to influence legislation through communication with any member or employee of a legislative body, or any government official or employee who may participate in the formulation of the legislation. "Grass roots lobbying communication" is any attempt to influence any legislation through an attempt to affect the opinions of the general public or any segment thereof if the communication refers to specific legislation, reflects a specific view on the legislation, and encourages the recipient to take action with respect to the legislation. For more nuanced definitions of lobbying see 26 CFR § 56.4911-2.

At the University the only off campus work study jobs are National Catholic School of Social Service (NCSSS) field placements (all non-profit agencies), and placements with the DC Reads Program and the Jumpstart Program.

Additional regulatory requirements include:

1.         Payment of at least the federal minimum wage (or the state or local minimum wage if higher).

2.         A community service requirement for 7% of the funds.

3.         Adherence to the test for financial need in awarding work study funds.

Responsibilities: The Counselor, Work Study Manager, in coordination with the Office of Payroll and the Office of Career Services, is responsible for ensuring all of the foregoing conditions are met, as well as any applicable requirements set forth in the as set forth in the Federal Student Aid Handbook:  The Federal Work Study Program (Volume 6, Chapter 2).

Related Policies

Graduate Financial Aid Policy

Undergraduate Financial Aid Policy

Resources

ED Gov. Federal Work Study Program

Student Financial Aid Handbook: Operating a Federal Work Study Program