C16: Recruiting

Responsibility for Maintenance: Academic Affairs; Veterans and Military Services

I. Policy Statement 

Onondaga Community College is bound to follow a Code of Ethics related to the recruitment of students, including Service members and their dependents.

II. Reason for Policy 

This policy will ensure compliance with program integrity requirements consistent with the regulations issued by the Department of Education, specifically 34 C.F.R 668.71-668.75 and 668.14, related to restrictions on misrepresentation, recruitment, and payment of incentive compensation.

III. Applicability of the Policy 

All members of the College community should be familiar with this policy.

IV. Related Documents 

 

V. Contacts 

 SubjectOffice Name Title or Position Telephone Number Email/URL 
 General QuestionsAcademic AffairsProvost & Senior Vice President(315) 498-2594provost@sunyocc.edu
Service Member Specific Questions Office of Veterans and Military ServicesAssistant Director(315) 498-2293 s.p.white21481@sunyocc.edu  

 

VI. Definitions 

InducementsAny gratuity, favor, discount, entertainment, hospitality, loan, transportation, lodging, meals, or other item having a monetary value of more than a de minimus amount
Service Member or Dependent Current and former active duty, guard and reserve military members and their dependents
MisrepresentationAny false, erroneous or misleading statement an eligible institution, one of its representatives, or any ineligible institution, organization, or person with whom the eligible institution has an agreement to provide educational programs, or to provide marketing, advertising, recruiting or admissions services makes directly or indirectly to a student, prospective student or any member of the public, or to an accrediting agency, to a State agency, or to the Secretary. A misleading statement includes any statement that has the likelihood or tendency to mislead under the circumstances. A statement is any communication made in writing, visually, orally, or through other means. Misrepresentation includes any statement that omits information in such a way as to make the statement false, erroneous, or misleading. Misrepresentation includes the dissemination of a student endorsement or testimonial that a student gives either under duress or because the institution required the student to make such an endorsement or testimonial to participate in a program.
Substantive misrepresentationAny misrepresentation on which the person to whom it was made could reasonably be expected to rely, or has reasonably relied, to that person's detriment.
Prospective StudentAny individual who has contacted an eligible institution for the purpose of requesting information about enrolling at the institution or who has been contacted directly by the institution or indirectly through advertising about enrolling at the institution.

 

VII. Procedures 

As part of efforts to eliminate unfair, deceptive, and abusive marketing aimed at Service members the Onondaga Community College will:

  • Ban inducements, including any gratuity, favor, discount, entertainment, hospitality, loan, transportation, lodging, meals, or other item having a monetary value of more than a de minimis amount, to any individual or entity, or its agents including third party lead generators or marketing firms other than salaries paid to employees or fees paid to contractors in conformity with all applicable laws for the purpose of securing enrollments of Service members or obtaining access to Tuition Assistance (TA) funds. Educational institution sponsored scholarships or grants and tuition reductions available to military students are permissible, and;
  • Refrain from providing any commission, bonus, or other incentive payment based directly or indirectly on securing enrollments or federal financial aid (including TA funds) to any persons or entities engaged in any student recruiting, admission activities, or making decisions regarding the award of student financial assistance, and;
  • Refrain from high-pressure recruitment tactics such as 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.

Approved by the OCC Board of Trustees June 22, 2021