1.0 Purpose

To ensure that Germanna complies with U.S. Department of Education (DOE) and U.S. Department of Defense (DOD) regulations that prohibit the college from misrepresenting the nature of its educational programs, financial charges, the employability of college graduates and ban the use of certain tactics to secure student enrollment.

2.0 Policy

In order to eliminate unfair, deceptive, and abusive marketing aimed at Service members, Germanna will:

  1. Ban inducements, including any gratuity, favor, discount, entertainment, hospitality, loan, transportation, lodging, meals, or other item having a monetary value of more than a de minimis amount, to any individual or entity, or its agents including third party lead generators or marketing firms 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. Educational institution sponsored scholarships or grants and tuition reductions available to military students are permissible, and;
  2. 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, and;
  3. Refrain from high-pressure recruitment tactics such as 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.

This applies to the college itself and its agents including third party vendors and service providers.

3.0 Procedures

Any violation of these policy guidelines by Germanna staff or faculty could lead to disciplinary action up to and including termination.

4.0 Definitions – Misrepresentation

Any false, erroneous or misleading statements to any student, Prospective student, member of the public, accrediting agency, state agency, or U.S. Agency, or any agent or employee of such an agency. A misleading statement includes any statement that has the likelihood or tendency to mislead under the circumstances or any statement that omits information in such a way as to make the statement false or erroneous.

Prospective Student

Any individual who has contacted the college to request information about enrolling or who has been contacted directly by the college or indirectly through advertising about enrolling.

TA Funds

Military Tuition Assistance paid to eligible members of the Army, Navy, Marines, Air Force, and Coast Guard to be used towards tuition expenses. The money is usually paid directly to the institution by the individual services.

5.0 References

Department of Defense Instruction 1322.25
Department of Education 34 C.F.R 668.71-668.75/668.14

6.0 Point of Contact

Director of Marketing and Recruitment

7.0 Approval and Revision Dates

Cabinet: Approval Date - 04/28/21
Leadership Council: Approval Date - 04/29/21

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