Institutional Policy on Prohibition of Incentive Compensation

Policy Statement

Lake Erie College shall not provide any commission, bonus, or other incentive payment, directly or indirectly, based on securing enrollments or the award of federal financial aid, including but not limited to Title IV, Higher Education Act (HEA) funds and Department

of Defense Tuition Assistance (TA) funds, to any person or entity engaged in:

• Student recruitment activities;

• Admissions activities;

• Making decisions regarding the awarding or disbursement of student financial assistance; or

• Any activities intended to secure student enrollments or federal financial aid eligibility.

 

This prohibition applies to all College employees, contractors, consultants, agents, and third-party organizations performing services on behalf of the institution.

 

Compensation for employees involved in recruitment, admissions, or financial aid shall be based on factors such as job performance, professionalism, customer service, compliance with institutional policies, quality of work, retention initiatives, or other non-

enrollment-related performance measures. Compensation shall not be based, in whole or in part, on the number of students recruited, enrolled, admitted, awarded financial aid, or receiving Tuition Assistance or other federal education benefits.

The College also prohibits entering into agreements with any third party that provide incentive compensation based on the success in securing student enrollments or federal student financial aid.

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Compliance

The Office of Admissions, Office of Financial Aid, Human Resources, and all supervisors responsible for personnel engaged in recruitment, admissions, or financial aid activities are responsible for ensuring compliance with this policy.

Any employee or contractor found to be in violation of this policy may be subject to disciplinary action, up to and including termination of employment or contract, and any other actions required to maintain institutional compliance with federal regulations.

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Institutional Policy on Ethical Recruitment Practices for Military-Affiliated Students

Policy Statement

Lake Erie College prohibits the use of high-pressure recruitment tactics in the recruitment of prospective students, including Service members and individuals eligible for military education benefits.

The College shall not:

• Make multiple unsolicited recruitment contacts with a prospective student for the purpose of securing enrollment. Unsolicited contacts include, but are not limited to, telephone calls, emails, text messages, social media messages, or in-person contacts initiated by the institution without the student's request.

• Engage in same-day recruitment and registration or enrollment practices that pressure or encourage a prospective student to enroll before having sufficient opportunity to consider their educational options, financial obligations, and available resources.

• Use misleading, coercive, aggressive, or deceptive recruiting practices designed to influence a prospective student's enrollment decision.

• Pressure prospective students to make immediate enrollment decisions or discourage them from seeking advice from family members, military Education Services Officers (ESOs), counselors, or other trusted advisors.

Recruitment communications shall be professional, informative, and responsive to the expressed interests and needs of prospective students. Admissions staff may respond to student inquiries, provide requested information, and conduct reasonable follow-up communications when a prospective student has expressed interest in the College.

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Prospective students retain the right to discontinue communications with the College at any time. Upon receiving a request to cease communications, Lake Erie College will promptly honor the request in accordance with applicable laws and institutional communication procedures.

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Compliance

All admissions personnel, recruiters, contractors, and third-party representatives acting on behalf of Lake Erie College are required to comply with this policy. Employees will receive appropriate training regarding ethical recruitment practices and applicable federal and Department of Defense requirements.

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Violations of this policy may result in corrective action, including disciplinary measures, termination of employment or contractual agreements, and any additional actions necessary to maintain institutional compliance with federal and military education benefit regulations.

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Military Educational Counseling

Lake Erie College encourages all active-duty Service members to consult with their Military Service's Educational Services Officer (ESO) or education counselor before enrolling. Your ESO or counselor can help you understand your military education benefits, Tuition Assistance eligibility, degree planning, and service-specific requirements to ensure you make informed educational decisions.

We are happy to work alongside your ESO or education counselor to support your educational goals and answer any questions you may have throughout the admissions process.

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Return of Unearned Military Tuition Assistance (TA) Funds Policy

Military Tuition Assistance (TA) is awarded to a student under the assumption that the student will attend school for the entire period for which the assistance is awarded. When a student withdraws from a course or otherwise ceases attendance prior to completing the period for which Tuition Assistance was awarded, the student may no longer be eligible for the full amount of TA funds originally awarded.

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In accordance with the Department of Defense Voluntary Education Partnership Memorandum of Understanding and DoD Instruction, Lake Erie College will return any unearned Tuition Assistance funds to the appropriate military Service branch on a proportional basis through at least the 60 percent point of the enrollment period for which the funds were provided. Unearned TA funds will be calculated based on the student's official withdrawal date or last date of attendance, as applicable.

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Once a student has completed more than 60 percent of the enrollment period, no Tuition Assistance funds will be returned.

In instances where a Service member withdraws due to a military service obligation, Lake Erie College will work with the student and the appropriate military Service branch to identify reasonable solutions that minimize student indebtedness, consistent with Department of Defense requirements.