Last September, during its 2013 National Conference, the National Association for College Admission Counseling (NACAC) approved a change to its Statement of Principles of Good Practice that would allow member colleges and universities to use commissioned agents to recruit students outside the United States. As amended, the Statement admonished institutions using commissioned agents to “ensure accountability, transparency, and integrity” in their relationships.
The amendments were set to become effective after a one-year moratorium during which NACAC was to determine their potential implications. Over the last year, NACAC’s Admission Practices Committee and International Initiatives Advisory Committee produced a number of proposals for clarifying the concepts of “accountability, transparency, and integrity” for NACAC members. During its National Conference in September, NACAC adopted additional changes via further amendments to the Statement. The amendments were published in NACAC’s 2014 Statement on October 4, 2014.
Through these amendments, NACAC clarified the meaning of accountability by requiring member institutions to monitor, affirmatively, the conduct of commission-based agents acting on their behalf. To ensure transparency, the amended Statement instructs members to use a “conspicuous statement on their website that indicates their institution uses agents who are compensated on a per capita basis.” Finally, to ensure integrity, the amended Statement instructs members to deal “ethically and impartially with applicants and other stakeholders honoring commitments and acting in a manner that respects the trust and confidence placed in the institutions and the individuals representing them.”
The amendments to the Statement of Principles are, of necessity, written at a high level. To provide additional detail, on September 16, 2014, NACAC issued International Student Recruitment Agencies: A Guide for Schools, Colleges and Universities. In addition to reiterating the concepts of accountability, transparency and integrity embodied in the amended Statement, the Guide provides a number of suggested best practices for contracting with commission-based recruiting agents. These include:
● Screening for conflicts of interest involving agents having relationships with institutional personnel
● Requiring use of an institutional template agreement for agency relationships (the Guide contains an extensive list of recommended provisions for such agreements), rather than agents’ template contracts
● Prohibiting agents from “double dipping” by charging students and/or parents in addition to receiving commissions from the institution, and requiring agents to disclose institutional compensation arrangements to students and parents
● Posting information about agency relationships on institutional websites
● Developing an “agency manual” establishing an institution’s requirements for its agents, and offering training for agency staff on those requirements
● Continuously evaluating the campus impact of the use of commissioned agents