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The Business of Branching Out

As the number of U.S. branch campuses continues to grow – increasing from 24 in 2002 to 82 last year, according to a report from the London-based Observatory on Borderless Higher Education – concerns about questionable business practices at these potentially lucrative overseas outposts grow as well.

“If one starts looking under the rocks of this whole international business, one will find lots of sleazy things under there,” said Philip G. Altbach, a professor and director of the Center for International Education at Boston College. “A lot of this stuff exists because it is overseas and it’s a non-regulated environment and therefore both institutions in this country and also the other sponsoring countries, the Brits and the Australians and so on and so forth, can do things that are not watched very carefully and that might not be acceptable at home – but are somehow acceptable overseas,” Altbach said.

A Monday Baltimore Sun article highlighted what the reporter called “a case study of the lightly regulated trend’s promises and potential risks.” The article, which was hotly contested by university officials, described a contractual relationship that the University of Maryland University College has entered into with ST International for the recruitment and administration of its doctor of management program in Taiwan. A spokesman for the university confirmed Monday that the company, STI, receives 25 percent of each student’s tuition dollars — an arrangement that wouldn’t seem to pass muster if the program were based in the United States, where federal law bars colleges from paying recruiters based on how many students they enroll.

To minimize the university’s financial risk, the 69 Taiwanese students also are required to sign an upfront contract committing to the cost of the three-year program (valued, according to the program’s executive director, Bryan Booth, at $45,600) — unlike their peers enrolled in the program domestically.

The part-time doctor of management program has 189 students enrolled stateside, and is designed to offer practical business training with dissertations based in literature and theory but still tightly tied to actual industry needs, said Claudine SchWeber, a full professor in the domestic program. Recent dissertation topics include “A CIO Decision-Making Framework for Technology Investments in Higher Education” and “Improving the Quality of Information Technology (IT) Security Audits for Federal Agencies.”

UMUC’s president, Susan C. Aldridge, stressed that ST International, which initially approached the university about the possibility of offering its management program on a pilot basis in Taiwan, is compensated not just for student recruitment, but also for the support services, infrastructure and logistical assistance that it offers. Essentially, the contractor provides the infrastructure and the logistical support — including pre-screening applicants for the university, which makes the admissions decisions — while UMUC provides the academic content and the faculty.

“It’s a mistake to say that this dollar amount is strictly for recruitment — it’s not,” Aldridge said. “The amount that’s paid covers classroom space, covers computer labs, covers all the equipment, lunches and meals for students, logistical and on-the-ground transportation for the faculty when they’re there, making hotel arrangements for the faculty, office space for the faculty and Internet while they’re there, as well as recruitment,” Aldridge said.

However, critics have raised questions about whether the same arrangement, if implemented in the United States, would violate federal law by tying the compensation of a company that engages in recruitment (among other services) to the volume of students in the program — and wonder why such an arrangement should be tolerated overseas, regardless of the inapplicability of federal laws there.

“If an institution is engaging in practices [overseas] that would either be illegal or outright unthinkable or unacceptable here, it’s a problem,” said Barmak Nassirian, associate executive director at the American Association of Collegiate Registrars and Admissions Officers. “You can’t have that kind of straightforward commission deal here in the U.S. for Title IV participating institutions,” Nassirian said, a reference to accredited colleges where students are eligible for federal financial aid funds.

“You have to believe that revenue has something to do with this. Why else would an institution engage in these kinds of practices? It’s certainly not academically justifiable,” said Nassirian. “My sense, very vaguely from afar without naming names, is that certain regions of the world are perceived as offering good business opportunities, and the temptation therefore is to simply plant a flag there and occupy a space that you might be concerned might go to someone else.”

“It’s in our mission as a university to serve students around the world,” said Aldridge, UMUC’s president. About 50 percent of the university’s students are located overseas, thanks in part to the institution’s historic role in maintaining contracts with the U.S. military. Domestically, about 85 percent of students are distance education learners. “We take the responsibility very seriously. We take the integrity of our academic programs very seriously.”

But at the same time, Aldridge added, referring to the risks of operating a program abroad without a knowledgeable third-party vendor, “We must ensure in these environments that we are fiscally prudent and that we safeguard the university. That does mean that we may have to put in some restrictions and constraints that we don’t have here because they are so far away.”

“The [Baltimore Sun] article tried to make some point, ‘Well, the federal government doesn’t allow this in the United States.’ That’s a completely different matter because the law is very explicit that this is to prevent inappropriate recruiting of students who are eligible for federal financial aid,” said William E. Kirwan, chancellor of the University of Maryland system, of which UMUC is a part. “The federal regulations are for a very appropriate purpose which don’t seem to me to apply in the case to overseas students, all of whom have master’s degrees, and they’re certainly not eligible for federal financial aid.”

While federal laws of course don’t apply overseas, and experts decry a lack of oversight of branch campuses and programs operating through the auspices of U.S.-based institutions abroad, they are subject to some degree of scrutiny through the accreditation process. Judith S. Eaton, president of the Council for Higher Education Accreditation, said that federal regulations stipulate that the addition of a branch campus constitutes a “substantive change” (in accreditation-speak) for an institution and therefore any new locations would be subject to review.

However, the regulations also provide some flexibility — so colleges with established track records abroad may not be subject to the same scrutiny. Accrediting agencies don’t play the gate-keeping role when it comes to federal financial aid funding for campuses or programs overseas, but a home university’s accreditation status could theoretically be jeopardized by substandard operations abroad, Eaton said.

“The commission in the past has said when something isn’t meeting the commission’s expectations, ‘Basically fix it or get rid of it,’ ” said Barbara E. Brittingham, director of the Commission on Institutions of Higher Education at the New England Association of Schools and Colleges and a former dean at a university in the United Arab Emirates. (The New England association does not accredit UMUC).

President Aldridge’s former institutional home, Troy University in Alabama, also had a relationship with ST International that, while currently dormant, officials are looking to possibly restart. Tom Davis, a spokesman for Troy, said that while STI was paid to recruit students and provide administrative support, the company did not receive per-student payments.

Back at UMUC, Aldridge said officials would be evaluating the doctor of management program in Taiwan, still in its pilot phase after opening in 2006, to determine its long-term viability. The third cohort of students just began the program after spending an orientation in Maryland, and the university has committed to stay in Taiwan for at least three more years while those students complete their degrees.

Elizabeth Redden

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Comments

Great. Just Great.

Let’s sap the Title IV program a little more, shall we?

And while we’re at it, let’s see how we can get around laws and ethics. Find a loophole. That makes it okay.

kgotthardt, at 7:30 am EDT on September 18, 2007

Perhaps colleges and universities should agree to obey the law and the ethical code of Barmak Nassirian before embarking on overseas adventures. When will Barmak write this code? How can we sign up? Sounds like Inside Higher Education is trying to create news instead of report it.

Fred, at 7:30 am EDT on September 18, 2007

what is a “branch campus"?

But what is a “branch campus”?

“While federal laws of course don’t apply overseas, and experts decry a lack of oversight of branch campuses and programs operating through the auspices of U.S.-based institutions abroad, they *are* subject to some degree of scrutiny through the accreditation process.”

There are massive problems with “branch campuses,” both defining precisely *what* they are (i.e., operationalized thresholds, technical definitions) and what constitutes a “branch campus” fro accreditors, and how and when to report them as “substantive changes” *to* the accreditors.

If you start to go through the “list” of Title IV institutions at an accreditor’s website, you will find “branches” listed there that have been closed for years, that never included classrooms to begin with but were libraries instead, etc. Facilities at one site will be listed as a “branch campus” while identical facilities somewhere else will not, etc.You get the picture.

It may be accurate to say federal regulations stipulate that the addition of a branch campus constitutes a “substantive change” (in accreditation-speak) for an institution and therefore any new locations would be subject to review, but all this is irrelevant if you are unable to determine what constitutes a branch campus, and then unable hold institutions and the accreditors and the federal government accountable to it.

Glen S. McGhee, Dir., at Florida Higher Education Accountability Project, at 8:50 am EDT on September 18, 2007

Ethical Code for Admission Practices

In partial response to “Fred"’s comment and as a general observation about the issue, this issue is clearly not a case of Inside Higher Ed or Barmak Nassirian manufacturing news or information for their own sakes.

There is a long-standing ethical code, called the “Statement of Principles of Good Practice (SPGP),” maintained by the National Association for College Admission Counseling (NACAC), which requires that member colleges and universities “not offer or accept any reward or remuneration from a secondary school, college, university, agency, or organization for placement or recruitment ofstudents.”

Affirmatively, the SPGP states that college members:

a. will be compensated in the form of a fixed salary, rather than commissions or bonuses based on the number of students recruited; b. will not contract with secondary school personnel for remunerations forreferred students.

The reason why the admission profession chose to self-regulate in this instance is that reducing the basis for compensation to the number of students enrolled in any circumstance introduces an incentive for recruiters to actively ignore the student interest in the transition to postsecondary education.

The issue of the limits of this code (at water’s edge) has been a source of controversy for quite some time, and, as this article shows, will not likely abate anytime soon.

David Hawkins, Director of Public Policy at NACAC, at 11:35 am EDT on September 18, 2007

More Facts

Here is one important correction of facts.

Besides the facts that STI receives 25% of each student’s tuition dollars as commission, and STI collects the entire course fees up-front from the Taiwanese students, with the approval of UMUC, tuition fees for students (Taiwanese as well as others) recruited by STI is established in an amount higher than the published rate of UMUC in the United States, which is referred to as the “Augmented Rate” in the MOA between UMUC and STI. The augmented rate is negotiated for each cohort. The current UMUC approved augmented rate is 10% higher than the published rate, and is justified for STI expenses (the telemarketing related expenses plus one week per semester classroom facilities cost). Therefore, the actual commission is more than 35% and 25% is the share of net profit. An interesting case study is the profit sharing plan.

From someone who knows the facts.

A Teacher, at 8:30 am EDT on September 19, 2007

Incentive Compresentation

The federal rules only apply to Title IV recipients as stated below. NACAC has Ethical Principles but has not addrewsses the International question when asked. Several perhaps many colleges use international recuitment firms on a percentage basis. I am not taking a position either way just clarifying facts.

“The second category is composed of the remaining 11 safe harbors. It describes the conditions under which a school may make an incentive payment to an individual or entity that could potentially be construed as based upon securing enrollments or financial aid. The safe harbors in this category describe the conditions under which such a payment may be made. If an incentive payment arrangement falls within any one safe harbor, that payment arrangement is not covered by the statutory prohibition. The payment or compensation plans included in the safe harbors cover the following subjects: 1. adjustments to employee compensation; 2. recruitment into programs that are not eligible for Title Federal Student Aidprogram funds;”

Rick, at 6:00 pm EDT on September 19, 2007

UMUC against Marylanders?

This school and program sound horrible. Aren’t US laws there to protect innocent consumer students against predatory or deceptive practices by US businesses? UMUC sure does seem to act more like a for-profit business than a non-profit state university in this story. Yet these foreign students are even required to sign enrollment contracts that lock them into paying the full cost of over $45,000 to UMUC? Maybe the foreign students don’t know the truth about UMUC’s marketing? I had even heard that UMUC advertisements may be misleading students by associating the UMUC faculty and its programs with the prestigious University of Maryland College Park, as opposed to with UMUC. If this is so, then this sounds like knowing false advertising by a state government institution. It sounds like these foreign students also need to be protected from predatory practices. Finally, if STI receives 25% of each student’s tuition dollars, then this discount would be unfair to Maryland residents who have their state taxes supporting this state school. This is against Marylanders. When you look at the UMUC website, UMUC charges both in-state and out-of-state students the same high rate of $950 per credit hour for the UMUC “doctorate” program. Shouldn’t Maryland residents be entitled to an in-state discount if foreign out-of-state students receive such a 25% discount? I’m sure some Marylanders looking for a quick and easy doctorate could get a group of their friends together if UMUC wants to provide discounts for groups. UMUC may seem to be a money maker, but hopefully the administration above the president will be lead by ethics and morals to seriously look into it and not just look the other way.

Mary Land, at 5:30 am EDT on September 30, 2007

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