Mitch Leventhal22 June 2013 Issue No:277
After 15 months of deliberations, the United States’ National Association for College Admission Counseling (NACAC) Commission on International Student Recruitment has all but agreed that commission-based recruitment is permissible – but its report only feebly addressed what comes next.
Its recommendation that commission-based international student recruitment be tolerated is severely tempered by its incomplete coverage of developments on the ground, and its supplemental recommendations, which appear to pander to a variety of vested interests.
Further, the general tenor appears to be designed to slow down the legitimate efforts of colleges and universities, and their private sector marketing partners. Perhaps we could not have expected more from a commission with such divergent views.
But the reality is that the outcome reflects a much deeper existential malaise within NACAC, as well as a lack of coherence in US policy. If we all open our eyes, we will see the elephant in the room: NACAC’s exercise is not really about the future of commission-based recruitment. Rather, it is all about the future role of NACAC itself, an organisation that has largely remained at the margins of international recruitment in the past and is now struggling to regain the centre during an era of unprecedented change in international recruitment.
And there is no hiding the fact that NACAC is deeply divided on how to address this change.
The NACAC commission’s report is a strange hodgepodge of fact, wishful thinking, evasive manoeuvres, procrastination and, sadly, obfuscation.
The one point upon which the majority of the commission apparently agreed was that member institutions engaged in commission-based recruitment should not be punished. This concession must have resulted from their growing awareness that hundreds of NACAC members, of all stripes and including Ivy League institutions, are engaged in this practice to some degree.
Thus, the commission opted to avoid recommending a policy that would have immediate negative consequences for NACAC, such as the expulsion of a substantial number of member institutions, or an irreparable schism within the organisation.
So it punted what Commission Chair Philip Ballinger referred to as recommendations “of an interim nature”. These are not sufficient. Not for NACAC, and not for American higher education. The commission’s most momentous recommendation came down to changing the word "will" to "should": institutions should not pay commissions to agents. Thus the commission managed to nod and shake its head simultaneously, perhaps hoping that dissenting parties would each read into it only what they want to see.
The NACAC commission recommended additional actions around the usual buzzwords about which everyone agrees – best practice, accountability, transparency and integrity. But oddly, it carefully avoided addressing the most significant recent industry developments in those very areas, once again appearing to make progress without actually recommending any real action.
It is important to remember that the industry developments to which I refer resulted from the need of colleges and universities for assistance in the absence of NACAC leadership in the area of international recruitment practice.
Questionable assertions
Stranger still, although unrelated to the central question of agency compensation, the NACAC commission went out of its way to uncritically praise the State Department’s EducationUSA advising network, even advocating that it should be the very first stop for any institution’s international recruitment strategy.
As if, by virtue of being operated by a federal department jointly with its prime educational contractor, the Institute of International Education (IIE), EducationUSA sui generis reflects best practice and industry standards.
This assumption is highly questionable. At a minimum, greater transparency regarding EducationUSA is needed. After all, what’s good for the goose is good for the gander.
But it goes deeper. One alarming example is the recent arrest for bribery and visa selling of consular officer Michael T Sestak – the face of EducationUSA in Vietnam. How can we know whether this case represents a lone wolf, or is emblematic of a broader problem with student visa operations? What is being done to repair America’s reputation overseas?
Many institutional recruitment officers have stories about unusual or unexpected visa denials and approvals from around the world. What can be done to assure institutions that everything possible has been done within consular affairs and EducationUSA to improve access to American higher education by international students?
IIE would like to be viewed as a venerable and unbiased party to this debate. In reality, the federal government provides 60% of its operating revenue for managing EducationUSA, along with other initiatives.
Marginalisation
As for industry standards and best practices; if the NACAC commission was so concerned with these, why then did it studiously avoid any discussion of the most significant development in this area (to which I alluded earlier) – the work of the American International Recruitment Council, or AIRC?
The commission’s report dedicated a scant three paragraphs to AIRC – out of 65 pages! This deliberate marginalisation of AIRC is self-destructive. NACAC and its members would be better served if they took a hard and honest look at what has been achieved by AIRC.
AIRC is a registered standard-development organisation founded by US accredited post-secondary institutions in 2008. AIRC’s industry-developed standards for recruitment agencies and best practices for institutions were derived and extended from the best practices that had already emerged in Australia, the UK and other parts of the world.
The agency certification process developed by AIRC is the first enforceable standards process binding on international recruitment agencies, wherever they are in the world. In its five years of existence, AIRC has grown to more than 200 US accredited institutional members, including top-echelon schools. Forty-eight AIRC-certified agencies are operating in 88 countries through hundreds of branch offices.
Ironically, the very countries cited by the commission as leaders in agency recruitment are now looking closely at the AIRC process to determine whether it may, in fact, represent the next stage of international collaboration around industry standards and regulation, since its framework clearly surpasses the London Statement in terms of rigour and enforceability.
These same countries wonder why the US government is unable to engage in meaningful multi-lateral dialogue about recruitment industry standards, even as other countries forge ahead.
Given these facts, AIRC’s achievements should have been a central focus on both the NACAC commission report and its recommendations. Yet, the commission scrupulously avoided inflaming NACAC stalwarts who appear to be threatened by the development of enforceable industry standards by an organisation not their own.
The NACAC commission report once again exposed profound disagreement among federal departments, with the Department of State deploring the practice of agency recruitment, the Department of Homeland Security participating in agency trade shows and sponsoring agency events, and the Department of Commerce actively brokering (for a fee) introductions between institutions and agents around the world.
Even among federal departments there appears to be no agreement on best practices. In this no-man’s land where everybody wants to be king, the NACAC commission has missed another opportunity to lead. So what is to be done? Here are my suggestions:
Colleges and universities are deeply hampered by the contradictory policies among competing federal departments, and a generally non-consultative approach vis-à-vis the higher education industry.
This federal disharmony also harms those states that have economic development strategies that are, in part, tied to their public higher education institutions effectively recruiting talent and deriving revenue from around the world.
Two years ago, in a commentary published in the Chronicle of Higher Education, I described other failures of policy and vision and argued for the creation of a federally mandated national higher education export council to transcend competing agendas, break down misconceptions, and forge a coherent national strategy.
I argued then that such a council should include key higher education associations and leaders from institutions and the private sector. In 2011, this call was met largely with indifference. President Obama, please take action now.
* Mitch Leventhal is vice-chancellor for global affairs at the State University of New York.
Its recommendation that commission-based international student recruitment be tolerated is severely tempered by its incomplete coverage of developments on the ground, and its supplemental recommendations, which appear to pander to a variety of vested interests.
Further, the general tenor appears to be designed to slow down the legitimate efforts of colleges and universities, and their private sector marketing partners. Perhaps we could not have expected more from a commission with such divergent views.
But the reality is that the outcome reflects a much deeper existential malaise within NACAC, as well as a lack of coherence in US policy. If we all open our eyes, we will see the elephant in the room: NACAC’s exercise is not really about the future of commission-based recruitment. Rather, it is all about the future role of NACAC itself, an organisation that has largely remained at the margins of international recruitment in the past and is now struggling to regain the centre during an era of unprecedented change in international recruitment.
And there is no hiding the fact that NACAC is deeply divided on how to address this change.
The NACAC commission’s report is a strange hodgepodge of fact, wishful thinking, evasive manoeuvres, procrastination and, sadly, obfuscation.
The one point upon which the majority of the commission apparently agreed was that member institutions engaged in commission-based recruitment should not be punished. This concession must have resulted from their growing awareness that hundreds of NACAC members, of all stripes and including Ivy League institutions, are engaged in this practice to some degree.
Thus, the commission opted to avoid recommending a policy that would have immediate negative consequences for NACAC, such as the expulsion of a substantial number of member institutions, or an irreparable schism within the organisation.
So it punted what Commission Chair Philip Ballinger referred to as recommendations “of an interim nature”. These are not sufficient. Not for NACAC, and not for American higher education. The commission’s most momentous recommendation came down to changing the word "will" to "should": institutions should not pay commissions to agents. Thus the commission managed to nod and shake its head simultaneously, perhaps hoping that dissenting parties would each read into it only what they want to see.
The NACAC commission recommended additional actions around the usual buzzwords about which everyone agrees – best practice, accountability, transparency and integrity. But oddly, it carefully avoided addressing the most significant recent industry developments in those very areas, once again appearing to make progress without actually recommending any real action.
It is important to remember that the industry developments to which I refer resulted from the need of colleges and universities for assistance in the absence of NACAC leadership in the area of international recruitment practice.
Questionable assertions
Stranger still, although unrelated to the central question of agency compensation, the NACAC commission went out of its way to uncritically praise the State Department’s EducationUSA advising network, even advocating that it should be the very first stop for any institution’s international recruitment strategy.
As if, by virtue of being operated by a federal department jointly with its prime educational contractor, the Institute of International Education (IIE), EducationUSA sui generis reflects best practice and industry standards.
This assumption is highly questionable. At a minimum, greater transparency regarding EducationUSA is needed. After all, what’s good for the goose is good for the gander.
But it goes deeper. One alarming example is the recent arrest for bribery and visa selling of consular officer Michael T Sestak – the face of EducationUSA in Vietnam. How can we know whether this case represents a lone wolf, or is emblematic of a broader problem with student visa operations? What is being done to repair America’s reputation overseas?
Many institutional recruitment officers have stories about unusual or unexpected visa denials and approvals from around the world. What can be done to assure institutions that everything possible has been done within consular affairs and EducationUSA to improve access to American higher education by international students?
IIE would like to be viewed as a venerable and unbiased party to this debate. In reality, the federal government provides 60% of its operating revenue for managing EducationUSA, along with other initiatives.
Marginalisation
As for industry standards and best practices; if the NACAC commission was so concerned with these, why then did it studiously avoid any discussion of the most significant development in this area (to which I alluded earlier) – the work of the American International Recruitment Council, or AIRC?
The commission’s report dedicated a scant three paragraphs to AIRC – out of 65 pages! This deliberate marginalisation of AIRC is self-destructive. NACAC and its members would be better served if they took a hard and honest look at what has been achieved by AIRC.
AIRC is a registered standard-development organisation founded by US accredited post-secondary institutions in 2008. AIRC’s industry-developed standards for recruitment agencies and best practices for institutions were derived and extended from the best practices that had already emerged in Australia, the UK and other parts of the world.
The agency certification process developed by AIRC is the first enforceable standards process binding on international recruitment agencies, wherever they are in the world. In its five years of existence, AIRC has grown to more than 200 US accredited institutional members, including top-echelon schools. Forty-eight AIRC-certified agencies are operating in 88 countries through hundreds of branch offices.
Ironically, the very countries cited by the commission as leaders in agency recruitment are now looking closely at the AIRC process to determine whether it may, in fact, represent the next stage of international collaboration around industry standards and regulation, since its framework clearly surpasses the London Statement in terms of rigour and enforceability.
These same countries wonder why the US government is unable to engage in meaningful multi-lateral dialogue about recruitment industry standards, even as other countries forge ahead.
Given these facts, AIRC’s achievements should have been a central focus on both the NACAC commission report and its recommendations. Yet, the commission scrupulously avoided inflaming NACAC stalwarts who appear to be threatened by the development of enforceable industry standards by an organisation not their own.
The NACAC commission report once again exposed profound disagreement among federal departments, with the Department of State deploring the practice of agency recruitment, the Department of Homeland Security participating in agency trade shows and sponsoring agency events, and the Department of Commerce actively brokering (for a fee) introductions between institutions and agents around the world.
Even among federal departments there appears to be no agreement on best practices. In this no-man’s land where everybody wants to be king, the NACAC commission has missed another opportunity to lead. So what is to be done? Here are my suggestions:
- To all institutions engaged in commission-based recruitment, in the name of transparency and of the protection of students, come out of the closet. Publicly disclose your agency relationships and engage with appropriate standards-development organisations and professional bodies.
- To the NACAC board, if you truly want to break out of your
organisational malaise, then go beyond the commission’s minimalist
recommendations. Officially join as a partner with AIRC in the
continuing development of best practices and standards, and encourage
your own members to do so as well.
Establish a liaison committee with AIRC to ensure that NACAC’s concerns are integrated into the AIRC standards-setting process. Partner with AIRC to create global recruitment events that build upon NACAC’s domestic recruitment expertise and AIRC’s regulatory approach to global recruitment.
If the NACAC board proposes this, and if the membership consents, then NACAC will have a chance to participate in the effort to establish standards and best practice in international student recruitment, and will regain credibility and respect. If NACAC limps forward as it currently is – and as the commission recommends – then its relevance in the international arena will continue to erode.
- To President Barack Obama, recognise that American
international education policy is profoundly broken, and that this is
harming our global competitiveness – both in attracting global talent
and in earning foreign exchange.
Colleges and universities are deeply hampered by the contradictory policies among competing federal departments, and a generally non-consultative approach vis-à-vis the higher education industry.
This federal disharmony also harms those states that have economic development strategies that are, in part, tied to their public higher education institutions effectively recruiting talent and deriving revenue from around the world.
Two years ago, in a commentary published in the Chronicle of Higher Education, I described other failures of policy and vision and argued for the creation of a federally mandated national higher education export council to transcend competing agendas, break down misconceptions, and forge a coherent national strategy.
I argued then that such a council should include key higher education associations and leaders from institutions and the private sector. In 2011, this call was met largely with indifference. President Obama, please take action now.
* Mitch Leventhal is vice-chancellor for global affairs at the State University of New York.
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