NACAC's International Student Recruitment Commission â An Update
NACAC’s International Student Recruitment Commission – An Update
AACRAO Annual Conference April 1, 2014 David Hawkins, Director of Public Policy & Research, NACAC Eddie West, Director of International Initiatives, NACAC
www.nacacnet.org
Session Objectives 1. Discuss historical restrictions on commissioned recruitment based on professional identity and occurrences of waste, fraud and abuse from the 1950s to present.
2. Summarize the findings and recommendations of NACAC's Commission on International Student Recruitment. 3. Provide information about forthcoming guidance from NACAC on the use of agents in international student recruitment. www.nacacnet.org
Professional Identity and Ethics NACAC introduced restriction against commissioned recruiting in 1951. Why?
•Concerns about ways in which commissioned recruitment affects students •Professional identity: NACAC’s Statement of Principles of Good Practice (SPGP) used to state that admission officers are professionals, not salespeople
www.nacacnet.org
Professional Identity and Ethics 1980 “Wingspread” gathering between AACRAO, College Board, and NAFSA: •Accurate representation of information to prospective international Students •Establishment of effective institutional policies on international student recruitment, admission and support services •Avoiding “contractual arrangements with agents who require fee-for-enrollment payments." Subsequently revised, resulting in a statement similar to the NACAC Commission’s recommendation.
www.nacacnet.org
Fraud and Abuse in the Federal Student Aid programs Recurring waves of waste, fraud and abuse: - 1970s: U.S. Education Commission: Terence Bell - 1980s: U.S. Education Department: Bill Bennett - 1990s: U.S. Senate: Nunn Commission - 2000s: U.S. Senate: Harkin/HELP Report
Business model: Leverage information asymmetry to harvest federal aid money using highly incentivized recruitment, resulting in misrepresentation, high-pressure sales tactics www.nacacnet.org
Fraud and Abuse in the Federal Student Aid programs
www.nacacnet.org
www.nacacnet.org
Current Government Investigations/Regulations • • • • • • •
Department of Education Consumer Financial Protection Bureau Justice Department Department of Defense/Veterans Affairs State Attorneys General Congressional authorizing committees State legislatures
All seek to eliminate negative effects of commissioned, high-pressure recruitment. www.nacacnet.org
Enrollment Comparisons
344% Increase
389% Increase
Source: Digest of Education Statistics, 2012
Source: IIE Open Doors
www.nacacnet.org
NACAC Commission Objectives NACAC Commission convened to reconcile conversation converging with: •Historic standards of practice •Ongoing fraud and abuse in federal aid programs centered on commissioned recruitment •Rapid increase in enrollment of international students using incentivized recruitment Conclusion: NACAC experience does not suggest that the association will ever fully 'endorse' commissioned recruitment, but Commission recognized that "NACAC must engage the reality of commissioned agency in international contexts" if it wishes to promote change and protect ethical practice.
www.nacacnet.org
Commission Recommendations How are international students, educational institutions, and college counseling and admission profession best served?
NACAC maintains institutions should not use commissioned agents, but if they must do so, they must ensure: 1.) Institutional accountability 2.) Transparency 3.) Integrity
www.nacacnet.org
Institutional Accountability • Oversight difficulties • Patchwork of regulatory and (differing) accreditation requirements • Institutional due diligence
www.nacacnet.org
Integrity • Professional experience and identity • Preservation of the U.S. higher education experience, while not projecting “U.S.-centric” assumptions • Lack of awareness of professional practices and standards within institutions, among higher education professions
• Colleges should not take risks internationally that they are unwilling to take domestically
www.nacacnet.org
Transparency • Standards in other countries, as well as voluntarily at some U.S. institutions • Misrepresentation as a key potential result of incentivized recruitment • Challenge of double-dipping, potential problems associated with nondisclosure
www.nacacnet.org
Current Work • NACAC Committees collaborating on guide for colleges and universities considering – and currently working with – commissions-based international student recruitment agencies • •
Emphasis on Transparency, Integrity and Accountability http://www.nacacnet.org/about/Governance/Comm/Pages/default.aspx
• Committees examining NACAC Statement of Principles of Good Practice (SPGP), to develop internationally-relevant guidance
www.nacacnet.org
Transparency in action • The terms of transactions between agencies, institutions, and students shall be clear and transparent •
•
Institutions providing clear, conspicuous disclosure of their agency partnerships, to students and their families Institutions should only work with agencies under contract, including clear stipulations and scope of services
www.nacacnet.org
Integrity in action • The actions of all involved in recruiting shall follow established ethical guidelines • • •
Adhering to NACAC’s Statement of Principles of Good Practice (SPGP) AACRAO Bill of Rights and Responsibilities for International Students and Institutions, and guidelines of other professional associations Ensuring that campus student services are coordinated and sufficient to support international students and provide them a high quality educational experience
www.nacacnet.org
Accountability in action • Abiding by state and federal laws, and regional accreditation standards, regarding recruitment • Researching and documenting an institutional approval process for working with agencies •
Ex: official signatory, contract language, thorough vetting process
• Exercising responsibility for actions of the institution’s agency partners, including sub-agencies • Providing sufficient training for agency partners, and ensuring frequent communication • Ensuring an adequate feedback loop to monitor that students receive the services they were promised during recruitment, and taking appropriate actions when they have not www.nacacnet.org
Questions? Comments? David Hawkins: [email protected] Eddie West: [email protected]
www.nacacnet.org
AACRAO Annual Conference April 1, 2014 David Hawkins, Director of Public Policy & Research, NACAC Eddie West, Director of International Initiatives, NACAC
www.nacacnet.org
Session Objectives 1. Discuss historical restrictions on commissioned recruitment based on professional identity and occurrences of waste, fraud and abuse from the 1950s to present.
2. Summarize the findings and recommendations of NACAC's Commission on International Student Recruitment. 3. Provide information about forthcoming guidance from NACAC on the use of agents in international student recruitment. www.nacacnet.org
Professional Identity and Ethics NACAC introduced restriction against commissioned recruiting in 1951. Why?
•Concerns about ways in which commissioned recruitment affects students •Professional identity: NACAC’s Statement of Principles of Good Practice (SPGP) used to state that admission officers are professionals, not salespeople
www.nacacnet.org
Professional Identity and Ethics 1980 “Wingspread” gathering between AACRAO, College Board, and NAFSA: •Accurate representation of information to prospective international Students •Establishment of effective institutional policies on international student recruitment, admission and support services •Avoiding “contractual arrangements with agents who require fee-for-enrollment payments." Subsequently revised, resulting in a statement similar to the NACAC Commission’s recommendation.
www.nacacnet.org
Fraud and Abuse in the Federal Student Aid programs Recurring waves of waste, fraud and abuse: - 1970s: U.S. Education Commission: Terence Bell - 1980s: U.S. Education Department: Bill Bennett - 1990s: U.S. Senate: Nunn Commission - 2000s: U.S. Senate: Harkin/HELP Report
Business model: Leverage information asymmetry to harvest federal aid money using highly incentivized recruitment, resulting in misrepresentation, high-pressure sales tactics www.nacacnet.org
Fraud and Abuse in the Federal Student Aid programs
www.nacacnet.org
www.nacacnet.org
Current Government Investigations/Regulations • • • • • • •
Department of Education Consumer Financial Protection Bureau Justice Department Department of Defense/Veterans Affairs State Attorneys General Congressional authorizing committees State legislatures
All seek to eliminate negative effects of commissioned, high-pressure recruitment. www.nacacnet.org
Enrollment Comparisons
344% Increase
389% Increase
Source: Digest of Education Statistics, 2012
Source: IIE Open Doors
www.nacacnet.org
NACAC Commission Objectives NACAC Commission convened to reconcile conversation converging with: •Historic standards of practice •Ongoing fraud and abuse in federal aid programs centered on commissioned recruitment •Rapid increase in enrollment of international students using incentivized recruitment Conclusion: NACAC experience does not suggest that the association will ever fully 'endorse' commissioned recruitment, but Commission recognized that "NACAC must engage the reality of commissioned agency in international contexts" if it wishes to promote change and protect ethical practice.
www.nacacnet.org
Commission Recommendations How are international students, educational institutions, and college counseling and admission profession best served?
NACAC maintains institutions should not use commissioned agents, but if they must do so, they must ensure: 1.) Institutional accountability 2.) Transparency 3.) Integrity
www.nacacnet.org
Institutional Accountability • Oversight difficulties • Patchwork of regulatory and (differing) accreditation requirements • Institutional due diligence
www.nacacnet.org
Integrity • Professional experience and identity • Preservation of the U.S. higher education experience, while not projecting “U.S.-centric” assumptions • Lack of awareness of professional practices and standards within institutions, among higher education professions
• Colleges should not take risks internationally that they are unwilling to take domestically
www.nacacnet.org
Transparency • Standards in other countries, as well as voluntarily at some U.S. institutions • Misrepresentation as a key potential result of incentivized recruitment • Challenge of double-dipping, potential problems associated with nondisclosure
www.nacacnet.org
Current Work • NACAC Committees collaborating on guide for colleges and universities considering – and currently working with – commissions-based international student recruitment agencies • •
Emphasis on Transparency, Integrity and Accountability http://www.nacacnet.org/about/Governance/Comm/Pages/default.aspx
• Committees examining NACAC Statement of Principles of Good Practice (SPGP), to develop internationally-relevant guidance
www.nacacnet.org
Transparency in action • The terms of transactions between agencies, institutions, and students shall be clear and transparent •
•
Institutions providing clear, conspicuous disclosure of their agency partnerships, to students and their families Institutions should only work with agencies under contract, including clear stipulations and scope of services
www.nacacnet.org
Integrity in action • The actions of all involved in recruiting shall follow established ethical guidelines • • •
Adhering to NACAC’s Statement of Principles of Good Practice (SPGP) AACRAO Bill of Rights and Responsibilities for International Students and Institutions, and guidelines of other professional associations Ensuring that campus student services are coordinated and sufficient to support international students and provide them a high quality educational experience
www.nacacnet.org
Accountability in action • Abiding by state and federal laws, and regional accreditation standards, regarding recruitment • Researching and documenting an institutional approval process for working with agencies •
Ex: official signatory, contract language, thorough vetting process
• Exercising responsibility for actions of the institution’s agency partners, including sub-agencies • Providing sufficient training for agency partners, and ensuring frequent communication • Ensuring an adequate feedback loop to monitor that students receive the services they were promised during recruitment, and taking appropriate actions when they have not www.nacacnet.org
Questions? Comments? David Hawkins: [email protected] Eddie West: [email protected]
www.nacacnet.org
