December 6, 2023

In the instruction “Dear Colleague” with the title (GEN-23-03) Requirements and Responsibilities for Third Party Service Providers and Institutionsthe definition of external service providers has been significantly expanded to include student recruitment and retention services, development of curriculum and course materials, delivery of instruction, assessment of student learning, and dissemination of marketing materials.

Leaders across the sector say the additions will significantly increase the number of third-party providers who will now be subject to additional government oversight.

It also states that students may not apply for Title IV federal aid funding if the servicer or subcontractor is outside the U.S. or is owned or operated by someone other than a U.S. citizen or lawful permanent resident of the U.S.

Speak with PIE NewsVice President of Revenue Planning and Institutional Placement at 3 Enrollment Marketing, Inc, Bryan Gross argued that this could have huge implications.

“According to the experience I’ve had with institutions and using them [online program management]“Most schools are very careful to follow the current regulations and requirements when it comes to Title IV funds,” said a former AIRC executive board member.

“The potential for negative impact on [study abroad] cannot be overstated”

Melissa Torres, president and CEO of The Forum on Education Abroad, told The PIE that if the guidelines go into effect as written, “the potential for a negative impact on the ability of colleges and universities to provide high-quality overseas experiences to their students cannot be overstated.” .

The result, she predicted, would likely be “the complete cessation of participation of students receiving Title IV funds, which could negatively impact retention and graduation rates because study abroad is widely recognized as a high-impact practice.”

Similarly, Sara Dart, Senior Vice President of Education Ireland, shared her concerns with PIE about the potential global impact this guidance could have on the entire study abroad “ecosystem”.

“It has the potential to negatively impact every type of mobility from faculty programs supported by small local providers to long-term bilateral exchange agreements,” she said.

Webster University’s Associate Vice President for International Enrollment Samrat Ray Chaudhuri spoke with The PIE about the potential impact on international recruiting and on TNE.

“Overseas campuses of US universities that partner with a foreign university or foreign government often use services including recruiting as part of their overseas operations,” he said.

“The new DOE guidance does not clarify how such institutional partnerships will survive because the partner institutions are not owned and operated by US citizens or permanent residents,” he continued.

Chaudhuri said that many small colleges and private tuition-run universities depend on agents to recruit international students and suggested that the transition to a direct recruitment approach would likely prove extremely difficult.

He said colleges employ their own recruiters overseas or regularly send their teams abroad to reduce costs. “This is very expensive and will not be feasible for smaller colleges and universities in terms of sustainability.”

Chaudhuri said that in some countries, parents and students want to meet agents in person. “It’s a culturally crucial aspect for building trust. Especially if the institution doesn’t have a big brand.”

Director of International Admissions at the University of Delaware, Song Hoffman, agreed. “International recruitment agencies, especially some ’boutiques’, can often serve as great links between parents, students and institutions, reducing cultural and language barriers,” she told The PIE.

Chaudhuri predicted that if the guidelines remain intact, with so much competition from countries that allow international recruiters, it could be “a free fall for US international numbers”.

Dart expressed deep concern about the fairness factor, arguing that the new guidelines “have the potential to significantly widen the already existing access gap”.

“Education abroad should be clearly and unequivocally excluded from these guidelines”

She noted that study abroad “is already beyond the reach of many students, and limiting access to Title IV funding will only make it worse, making study abroad accessible only to those with the means to pay out of pocket.”

Likewise, Torres argued, “Education abroad should be clearly and unequivocally excluded from these guidelines so that students who rely on federal financial aid — students who often come from underrepresented and underserved populations — are not disadvantaged by their peers.

The US DOE has extended the public comment period until March 28, with the guidance set to take effect on September 1.

The Education Abroad Forum has scheduled a webinar for its members on Friday, March 17, and as of today, over 700 participants are registered.

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