Title:	Recruitment of Students, Policy On
Policy Owner:	The Division of Enrollment Planning & Management
Applies to:	University Employees, Volunteers, Trainees and Others
Campus Applicability:	All Campuses
Effective Date:	August 23, 2021
For More Information, Contact	Office of the Vice President for Enrollment Planning & Management
Contact Information:	(860) 486-1463
Official Website:	https://epm.uconn.edu/

PURPOSE

To ensure compliance with federal laws and regulations regarding ethical recruitment and enrollment activities conducted at the University. Specifically, Section 487(a)(20) of the Higher Education Act (HEA) and its implementing regulations at 34 C.F.R. 668.14, as well as the University’s Memorandum of Understanding with the Department of Defense.

APPLIES TO

Employees, volunteers, trainees, and other persons whose conduct, in the performance of work for UConn, is under the direct control of UConn, whether or not they are paid by UConn. 

DEFINITIONS

Commission, Bonus, Incentives means 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 means activities that a person or entity engages in at any point in time through completion of an educational program for the purpose of the admission or matriculation of students for any period of time 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 office or any other office of the institution, 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 office or any other office of the institution 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 of 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 means the admission or matriculation of a student into an eligible institution. 

Inducement means any gratuity, favor, discount, entertainment, hospitality, loan, transportation, lodging, meals, or other item have a monetary value or more than a de minimis amount to any individual, entity, or its agents including third party lead generators or marketing forms. 

Service Member means 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; and (c) the commissioned corps of the Public Health Service. 

POLICY STATEMENT

The University of Connecticut 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 University 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 or associated procedures may result in appropriate disciplinary measures in accordance with University By-Laws, General Rules of Conduct for All University Employees, and applicable collective bargaining agreements.

PROCEDURES/FORMS
Contact the Division of Enrollment Planning and Management with questions.  

POLICY HISTORY

Policy created effective: August 23, 2021 [Approved by President’s Senior Team]

Revisions:  November 11, 2021 [Approved by the President]