Signs that NACAC will repeal ban on commission-based agents for international student recruitment

The National Association for College Admission Counseling’s Commission on International Student Recruitment (NACAC) has issued a pre-release version of its final report in which it recommends that the ban on using commission-based agents be removed. It advises that NACAC change its policy wording from telling its members that they “may not” provide incentive-based remuneration for agents to “should not.” The Commission would like to see NACAC members who do choose to provide incentives to agents follow set, mandatory practices. These would be categorised under “institutional accountability,” “transparency,” and “integrity.” Furthermore, they could include requirements to disclose the terms of relationships with agents to students and families, and to establish "an adequate feedback loop to monitor that students receive the services they were promised during recruitment." While the NACAC Commission does not recommend that education institutions work with agents, its recommendation to change from a prohibition – “may not” – to a more advisory tone – “should not” – is a big step away from its historical stance on agents. When in 2011, it said that its ban on members paying agents by commission applied to both domestic and overseas recruitment activities, more than 300 public comments ensued (see here for a NACAC document analysing them). This is why the Commission was formed in the first place. The final Commission report will be forwarded to the NACAC Board of Directors and if they adopt the recommendations, any changes made to the association’s Statement of Principles of Good Practice based on the Commission’s recommendations must be approved by members via the NACAC Assembly at their upcoming conference in Toronto this September.

Pre-release report to be lauded for its pragmatism

While the pre-release version of the NACAC Commission on International Student Recruitment takes pains to remind readers that its recommendation to lift the ban is not an endorsement of using commission-based agents, it also notes that its recommendation is based in the dynamism of international education and recruitment for it. Mr Philip A. Ballinger, assistant vice president for enrolment and director of admissions at the University of Washington, who served as the Commission’s chair, explained:

“The Commission acknowledged that the environment for international student recruitment practices is dynamic, not static. This means that while incentive-based agency and its use are prevalent in many countries, change is possible and is occurring... This may mean that NACAC must engage the reality of incentive-based agency in international contexts if it wishes to promote change.”

On the one hand, the Commission noted:

“Although many members of the Commission have serious concerns about student welfare within the general context of commissioned agency, there are institutions and organisations which appear to use such agency responsibly and demonstrably for the good of the students they serve.”

On the other, it warned that it:

“… perceives that many institutions may not be fully aware of the potential legislative, accreditation-related, and potentially punitive risks they incur by too broadly and uncritically using commissioned agency to recruit and enrol students.”

Use of case studies in the report

Several case studies of US colleges and universities are presented in the report, including the following range:

• No agency contracts (i.e., internal admissions staff handle recruitment);
• Sub-par agency relationships and feedback loops (i.e., where there is not enough oversight by the university of how its agents are representing it to students and where there is not sufficient measurement of enrolment gains attributable to agents);
• Productive agency relationships.

Here is an excerpt from the report of the latter type of case study, which was of Green River Community College (Washington), which currently ranks 10^th among roughly 10,000 US community colleges in international student enrolment:

“Green River has found that working with reputable educational advisory agencies with extensive knowledge of the college has been particularly beneficial to students, their parents, the agencies themselves and to Green River."

"Green River staff visit its top agencies twice a year, and agency officials visit the college usually once a year, so the agents are intimately familiar with Green River. The college works through its agents to involve parents in their students’ experience in the US, increasing support and accountability to make their children more successful. Agents also identify and work with partner schools, helping to make such relationships stable and productive. College officials frequently present to prospective students and their parents at partner schools with an alumnus, his or her parents, a partner school official and the agent all speaking and interacting. Green River has found that this depth of relationships, generally of long standing and focusing on the actual experience of the students themselves, to be the key ingredient of the college’s overseas marketing success.” This degree of professional responsibility and long-term thinking is to be applauded, and it would be wonderful if such a model could be widely replicated across the US, at every level. In fact, it is a model that would serve institutions across the world very well.

ICEF’s position

At ICEF, we consider the new NACAC position (if the Commission’s recommendation is accepted) to be a logical response to the current American international student recruitment environment. It recognises the growing use of commission-based agents, yet maintains its consideration that such a practice can be problematic, yet in the end does not ban it given how unrealistic that would be. We consider the new “should not” position a challenge to agencies and institutions alike that do work together (or are considering a relationship) to establish the highest possible standards of contracts, of working relationships, of feedback and quality assurance mechanisms, and of self-regulation. We strongly urge all with a stake in international student recruitment to the US to read the entire NACAC Commission document, as it is very articulate and contains excellent examples, research, and points-of-view.