MSCHE Submits Comments to USDE Regarding Review of the Prohibition on Incentive Compensation for College Recruiters

President Dr. Heather F. Perfetti submitted a letter on behalf of the Middle States Commission on Higher Education (MSCHE) in response to the request for information by the United States Department of Education (USDE) regarding the review of the Prohibition on Incentive Compensation for College Recruiters.

As stated in the announcement, “In 2011, the Department issued guidance related to the ban [on incentive compensation], which created an exception for third parties if they provide a bundled set of services, which can include recruitment…Given the growth in online enrollment and associated federal student debt, the Department is seeking public input to understand the impact of this exception and whether any updates are necessary to the guidance.”

USDE Notice: U.S. Department of Education Launches Review of Prohibition on Incentive Compensation for College Recruiters

On February 21, 2023, MSCHE released an advocacy alert encouraging institutions to respond to the call for comment by the deadline on March 16, 2023.

“Our agency subscribes to the principle that institutions must maintain appropriate levels of oversight for educational programs and services through the maintenance of systematic processes that ensure the institutional capacity to carry out its oversight responsibilities,” stated Dr. Perfetti in the letter. “Existing MSCHE policy, procedures, standards, and requirements attempt to balance the need for innovation by institutions that is grounded in best practices with awareness of the challenges that third-party provider arrangements can present.” In addition, the letter notes that the Department could provide more specific guidance for accreditors and institutions about expectations relating to written arrangements.

Read the full letter.