5.36 Recruitment of Students
To ensure compliance with federal laws and regulations regarding ethical recruitment and enrollment activities conducted at Riverland Community College. Specifically, Section 478(a)(20) of the Higher Education Act (HEA) and its implementing regulations at 34 C.F.R. 66814, as well as the College’s Memorandum of Understanding with the Department of Defense.
Applicability
Riverland Community College prohibits the award of any commission, bonus, or other incentive payment based in any part, directly or indirectly, upon success in securing enrollments or the awarding of financial aid to any person or entity who is engaged in any student recruitment, admission activities, or making decisions regarding the awarding of financial assistance. In accordance with the HEA, this restriction does not apply to the recruitment of foreign students residing in foreign countries who are not eligible to receive federal student assistance.
In addition, in accordance with the Department of Defense Memorandum of Understanding, the College will refrain from high-pressure recruitment tactics aimed at Service Members, which includes making multiple unsolicited contacts (3 or more) including contacts by phone, email, or in-person, and engaging in same-day recruitment and registration for the purpose of securing Service Member enrollments.
Scope
Students.
Definitions
Commission, Bonus, Incentives: A sum of money or something of value, other than a fixed salary or wages, paid to or given to a person or an entity for services rendered.
Securing enrollments or the award of financial aid: Activities that a person or entity engages in at any period through completion of an educational program for the purpose of the admission or matriculation of students or the award of financial aid to students. These activities include contact in any form with a prospective student, such as, but not limited to: contact through preadmission or advising activities, scheduling an appointment to visit the enrollment personnel or any other office of the College, attendance at such an appointment, or involvement in a prospective student’s signing of an enrollment agreement or financial aid application.
These activities do not include making a payment to a third party for the provision of student contact information for prospective students, provided that such payment is not based on: (1) any additional conduct or action by the third party or the prospective students, such as participation in preadmission or advising activities, scheduling an appointment to visit the enrollment personnel or any other office of the College or attendance at such an appointment, or the signing, or being involved in the signing, of a prospective student’s enrollment agreement or financial aid application; or (2) the number of students (calculated at any point in time during an educational program) who apply for enrollment, are awarded financial aid, or are enrolled for any period of time, including through completion of an educational program.
Entity or person engaged in any student recruitment or admission activity or in making decisions about the award of financial aid: (1) With respect to an entity engaged in any student recruitment or admission activity or in making decisions about the award of financial aid, any institution or organization that undertakes the recruiting or the admitting of students or that makes decisions about and awards Title IV, HEA program funds; and (2) with respect to a person engaged in any student recruitment or admission activity or in making decisions about the award of financial aid, any employee who undertakes recruiting or admitting of students or who makes decisions about the awards Title IV, HEA program funds, and any higher level employee with responsibility for the recruitment or admission of students, or making decision about awarding Title IV, HEA program funds.
Enrollment: The admission or matriculation of a student into an eligible institution.
Inducement: Any gratuity, favor, discount, entertainment, hospitality, loan, transportation, lodging, meals, or other item with a monetary value of more than a de minimis amount to any individual, entity, or its agents including third party lead generators or marketing firms.
Service member: A current or former member of the uniformed services which includes: (a) the Armed Forces; (b) the commissioned corps of the National Oceanic and Atmospheric Administration; and (c) the commissioned corps of the Public Health Service.
Enforcement
Violations of this policy may result in appropriate disciplinary measures in accordance with the Minnesota State System Office Employee Code of Conduct and applicable collective bargaining agreements.
Related Policies, Procedures, or Forms
- Section 487(a)(20) of the Higher Education Act
- 34 C.F.R. 66814
Date Implemented: New-May 2023
Responsible Division / Author: Student Services / VPASA
Date Revised: