Aggressive Recruitment

Sponsor:	Office of Enrollment Management
Contact:	Director of Veteran and Military Education
Category:	Communications and Marketing
Number:	500.038
Effective Date:	6/15/2020
Implementation History:	First draft 2020
Keywords:	DOD MOU, aggressive recruiting, recruitment, Principles of Excellence
Background Information:	SUNY Empire State College (College) signed the current version of the Department of Defense Memorandum of Understanding (DOD MOU) in July 2014, renewed July 2019. The DOD MOU allows the College to accept federal tuition assistance (TA) specifically for Service members. Additionally, SUNY Empire abides by the Principles of Excellence; regulations set forth by President Obama’s Executive Order 13607 ensuring that student veterans, service members and family members have certain information, support and protections while using Federal education benefits.

Purpose

This policy ensures the college does not participate in fraudulent and aggressive marketing tactics when recruiting military members using TA. This policy incorporates the requirements of the Principles of Excellence, to protect veteran and 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, SUNY Empire State College

“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 family members using Federal education benefits.

Applicable Legislation and Regulations

New York State Public Officers Law §74

Related References, Policies, Procedures, Forms and Appendices

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