International Education News l The PIE News l Sector reacts to latest US DOE third-party guidance

In the Dear Colleague Letter guide entitled (GEN-23-03) Requirements and Responsibilities for Third-Party Providers and InstitutionsThe definition of third-party providers has been significantly expanded to include services for student attraction and retention, curriculum and course material development, instruction delivery, student learning assessment, and distribution of marketing materials.

Industry leaders say these additions will significantly increase the number of third-party providers now subject to additional government oversight.

It also notes that students are not eligible to apply for Federal Title IV funding if the service provider or subcontractor is located outside the United States or is owned or operated by someone who is not a US citizen or lawful permanent resident of the US.

Speak with The PIE NewsVice President of Revenue Planning and Institutional Positioning at 3 Enrollment Marketing, Inc. Bryan Gross claimed the impact could be huge.

“Based on the experiences I have had with institutions and their use [online program management]most schools are very keen to comply with applicable regulations and requirements when it comes to Title IV funds,” said the former AIRC board member.

“The potential for negative impacts on [study abroad] cannot be overrated”

Melissa Torres, President and CEO of The Forum on Education Abroad, told The PIE if the guidelines go into effect as currently written, “the potential for negative impacts on the ability of colleges and universities to provide their students with quality educational experiences abroad offer, this cannot be exaggerated”.

She predicted the outcome would likely be a “complete halt to participation by students receiving Title IV funding, which could negatively impact their retention and graduation rates as study abroad is widely recognized as a high impact practice.” “.

Likewise, Senior Vice President of Education in Ireland, Sara Dart, shared her concerns with the PIE about the potential global impact this guidance could have on the entire study abroad “ecosystem”.

“It has the potential to negatively impact any type of mobility, from faculty-led programs supported by small local providers to long-standing bilateral exchange agreements,” she said.

Webster University Associate Vice President for International Enrollment Samrat Ray Chaudhuri spoke to The PIE about the potential impact on both international recruitment and TNE.

“Overseas campuses of US universities that work with a foreign university or government often use services, including recruiting, as part of their overseas operations,” he explained.

“The new DOE policy does not clarify how such institutional partnerships will survive since the partner institutions are not owned and operated by US citizens or permanent residents,” he continued.

Chaudhuri said many small colleges and tuition-driven private universities rely on agents to recruit international students and suggested moving to a direct recruitment approach was likely to prove extremely difficult.

He pointed to the cost-inhibiting factors for colleges that employ their own overseas recruiters or regularly send their teams abroad. “This is very expensive and will not be possible for smaller colleges and universities from a sustainability point of view.”

Chaudhuri said in some countries, parents and students want to meet agents in person. “Building trust is a culturally essential aspect. Especially if the institution does not have a big brand name.”

The University of Delaware’s director of international admissions, Song Hoffman, agreed. “International recruitment agencies, especially some ’boutique’ agencies, can often serve as great links between parents, students and institutions, breaking down cultural and language barriers,” she told The PIE.

If the guidelines remain intact and there is so much competition from countries that allow international recruiters, Chaudhuri predicted it could be “a free fall for US international numbers”.

Dart expressed his deep concern about the equity factor, claiming that the new policy “has the potential to significantly widen the access gap that already exists”.

“Education abroad should be clearly and unequivocally exempted from these guidelines”

She noted that studying abroad “is already beyond the capabilities of many students and the Title IV restriction on access to funding will only exacerbate this, leaving study abroad only accessible to those who have the means to make it out.” to pay in my own pocket”.

Likewise, Torres argued, “Education abroad should be clearly and unequivocally exempted from these guidelines so that students who rely on federal financial assistance—students who often come from underrepresented and underserved populations—are not disadvantaged compared to their peers.”

The US DOE has extended the public comment deadline to March 28, with the guidance set to take effect on September 1.

The Forum on Education Abroad has scheduled a webinar for its members on Friday 17th March and to date over 700 participants have registered.