Recruitment of Students Policy

Purpose

To ensure compliance with federal laws and regulations regarding ethical recruitment and enrollment activities conducted at Minnesota State Community and Technical College. Specifically, Section 487(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 (DoD).

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 of time 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” means (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 and awards Title IV, HEA program funds, and any higher level employee with responsibility for recruitment or admission of students, or making decisions 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.

Policy

Minnesota State Community and Technical 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.

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.

References

Section 487(a)(20) of the Higher Education Act

34 C.F.R. 66814