Aggressive Recruitment

Sponsor:

Office of Enrollment Management and Marketing

Contact:

Director of Veteran and Military Resource Center

Category:

Communications and Marketing

Number:

500.038

Effective Date:

06/15/2020

Implementation History:

First draft 2020

Keywords:

DOD MOU, aggressive recruiting, recruitment, Principles of Excellence

Background Information:

Empire State University (the “University” or “SUNY Empire”) signed a Department of Defense Memorandum of Understanding (“DOD MOU”) in July 2014, which was renewed in July 2019 and March 2024. DOD MOU allows the University to accept federal tuition assistance (“TA”) specifically for service members. Additionally, SUNY Empire abides by the Principles of Excellence set forth within Executive Order 13607 issued in April 2012 ensuring that student veterans, service members and their family members have certain information, support and protections while using federal education benefits. The latest revisions reflect updates to regulations for higher education institutions within the Johnny Isakson and David P. Row, M.D. Veterans Health Care and Benefits Improvement Act of 2020 (“Isakson and Roe Act”).

Purpose

This policy ensures the university does not participate in fraudulent and aggressive marketing tactics when recruiting service members using tuition assistance. This policy incorporates the requirements of the federal government’s Principles of Excellence to protect veterans and their family members using federal education benefits from predatory recruitment tactics.

Definitions

“Inducements” means any gratuity, favor, discount, entertainment, hospitality, loan, transportation, lodging, meals, or other item having a monetary value of more than a de minimus amount.

“Service members” means active duty, guard, and reserve military members.

Statements

In accordance with the Department of Defense Memorandum of Understanding, Empire State University:

“bans inducements to any individual or entity (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 TA funds as part of efforts to eliminate
aggressive marketing aimed at Service members.

Additionally, SUNY Empire will refrain from high-pressure recruitment tactics as part of efforts
to eliminate aggressive marketing aimed at Service members. Such tactics include 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.

And finally, SUNY Empire will 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. These tactics are
discouraged as part of efforts to eliminate aggressive marketing aimed at Service members.”

Per Executive Order 13607, the same aggressive marketing policy to ban predatory recruitment tactics will be implemented to support and protect student veterans and their family members using federal education benefits.

With the ratification of the Isakson and Roe Act of 2020, the University will abide by the amended recruitment policy, which prohibits the University from making three or more unsolicited contacts to covered [by VA education benefits] individuals, including by phone, email, or in-person, during any one-month period. Covered individuals are those who are eligible to receive federal educations benefits through the U.S. Department of Veterans Affairs.

Applicable Legislation and Regulations

New York State Public Officers Law §74

Johnny Isakson and David P. Row, M.D. Veterans Health Care and Benefits Improvement Act of 2020

Related References, Policies, Procedures, Forms and Appendices

SUNY Code of Ethical Conduct for University Officers; Policy Document #6000