This week, two of EAB’s foremost enrollment-management experts and a distinguished enrollment leader from one of our partner colleges met to discuss the recent changes to NACAC’s Code of Ethics and Professional Practices (CEPP). We shared the conversation with the broader enrollment community through a live webcast.
Key issues covered in the conversation included:
- Whether schools will embrace the aggressive recruitment practices enabled by the changes
- Whether the changes harm or help students
- Whether schools will raise deposit requirements and how this will impact low-income students
Panelists for the session were:
- Rob Alexander, Millsaps College’s Vice President for Enrollment and Communications
- Alex Bloom, Associate Director of Research for EAB’s Enrollment Management Forum
- Madeleine Rhyneer, VP of EAB Consulting Services and Dean of Enrollment Management
The recording below has been edited for conciseness and clarity.
Three key changes, many implications
Madeleine Rhyneer: I wanted to start off with a bit of a recap. NACAC members recently voted to change key elements of NACAC’s code of ethics and professional practices (CEPP) in response to pressure from the Department of Justice.
Our discussion today will focus on three changes in particular. The first is that schools may now offer incentives for early-decision candidates. The second is that schools are no longer prohibited from recruiting students who have already deposited with or otherwise committed to other schools. The third is that schools may now recruit students who are enrolled at other four-year colleges or universities.
I had a chance to discuss these developments with a lot of enrollment leaders at this year’s NACAC meeting, prior to the vote, which gave me a pretty good feel for what concerns the broader group of our peers.
A few themes kept cropping up. One was that quite a few schools were already engaging in practices prohibited by the CEPP, even prior to the vote. Another was a concern that the change in rules might compel enrollment managers (EMs) to engage in hard-sell recruitment practices that are not in students’ best interests. Several people mentioned the likelihood of schools raising enrollment deposits. Many talked about the need to fix barriers facing transfer students, including problems related to credit articulation. Many enrollment leaders I spoke with also expect to see an increase in the summertime “poaching” of their committed admits.
Alex, is this similar to what you’ve been hearing?
Alex Bloom: It is. And I wanted to speak specifically on the point you mentioned about what happens during the summer. Given the new vulnerability there, it’s important for schools to be doing all they can to hang on to students. Ensuring coordinated communications is a good start.
Given all the different college offices that prospective students interact with, there’s all kinds of opportunity for things to go awry—students being invited to sign up for classes before they’ve deposited, that kind of thing. Mistakes like this, even if they might seem trivial to you, can make students doubt your institution’s competence and therefore make them more vulnerable to poaching by competitors.
MR: Rob, I’m also keen to get your perspective, as a practitioner, on the changes. What’s top of mind for you?
Rob Alexander: There’s plenty that I, and lots of chief enrollment officer colleagues around the nation, are working on at the moment. For example, thinking through what sort of code of ethics we might develop for ourselves in lieu of the CEPP rules—one focused on what’s best for students and families. We actually see strategic opportunity there. We’re also thinking about a more reactive type of response as well—what we’ll do if and when students start coming to us with new aid offers from competing schools at the 11th hour.
What is actually most helpful for students?
MR: We’ve just had a related question come in on the line—what, really, serves students best when it comes to the kind of rules that were in the CEPP? I can tell you that a lot of my peers considered the CEPP rules to be truly beneficial for families, because they made the process of choosing a school less confusing. Many of these same enrollment leaders say they’re going to stick with the rules even though they don’t have to, because they believe it’s the right thing to do. Which is incredibly noble and ethical and principled. But they’ll also need to think through how they’ll respond if they start seeing their competitors behaving differently.
AB: Let’s also not forget the counterargument that the change in rules is a good thing for students—which, of course, is the DOJ’s perspective. If you’re a student who can be flexible about which school you pick, holding out through the summer could increase your odds of getting a better deal. If there’s some hope that the new regime will be advantageous to students, I think this is where the main benefit will lie.
RA: There’s another potential advantage as well, having to do with opportunities for counseling students. Lots of regions we recruit from don’t have robust high school counseling. For seniors from these regions, the whole of their understanding of the timing and processes of depositing and committing might be based on whatever their local state colleges do.
I could imagine the new rules enabling increased flexibility for how these students are approached and therefore also creating new opportunities for our own admission staff to counsel them and help them find their best option. This could benefit some populations that have historically “undermatched,” for example.
Schools that flout the rules
MR: I wanted to bring us back to a few questions that have come in from our attendees. One concerns whether it’s still acceptable to ask students for a commitment by May 1. I haven’t heard anything to the contrary and I don’t see a lot of schools dropping that practice anytime soon. It’s hard to imagine how things would work without some fixed point on the calendar by which we get an answer from students.
We’ve also had a comment come in on the phenomenon we mentioned earlier of schools violating CEPP. This commenter says her institution faced this kind of competition last year. She goes on to note that her school stuck to the NACAC guidelines but did not report the schools that violated them.
AB: I’m glad someone brought this up. It’s true that some schools were circumventing the guidelines or flouting them more brazenly. It’s also true that there’s not much you could actually do about it, in practical terms. The only recourse you had was to report the violation to NACAC, and the related enforcement mechanisms didn’t offer very compelling consequences. If you’re in a market where this kind of thing has already been going on, things might not look all that different moving forward.
MR: I wanted to share another question submitted. If a student commits to one school and declines other schools’ offers, can those other schools still continue to reach out to that student? Technically, the answer is yes. This is covered by the second provision I mentioned at the outset of our discussion, which says that you can continue to talk to students who are committed to another institution.
RA: I do think that institutions making any aggressive moves will need to be mindful of the risk of alienating students in this scenario, especially to the extent that students have signaled a desire to opt out from further contact. Considering that these students could be prospects for transfer or graduate school recruitment in the future, you’ll want to stay on their good side.
Does early decision still mean anything?
MR: A couple of attendees have sent in questions about binding early-decision programs. One asks whether they are toothless. Another asks if early decision means anything anyway, since the CEPP changes remove prohibitions on recruiting committed students. It’s true that the changes make early-decision students fair game. It’s also likely that some schools will up the attractiveness of their early-decision incentives, which further complicates the equation.
AB: I wanted to comment on the idea of the changes making early decision programs toothless, which I don’t think is necessarily the case. It’s helpful to channel the DOJ’s perspective on this point. I suspect they made a conscious decision to protect early decision because it’s a case of students voluntarily opting into an agreement with a school. But it’s true that the enforcement mechanism is soft. If a student breaks that early-decision commitment and ends up enrolling elsewhere, recourse would mean asking that second school to force that student out, which I don’t think anyone would want.
Higher deposit requirements and their implications
MR: We’ve had a question on the line about raising the dollar amount for enrollment deposits and the potential impact of that on students from low-income families. Alex, is that something you’d like to speak to?
AB: I do think schools are going to have to work at balancing the need for a more binding level of deposit with the need to maintain access for lower-income populations. Options to consider would include tiering the level of deposit required based on ability to pay—you could have one level for Pell Grant eligible students and another for more affluent students. You could imagine various approaches to making the enrollment deposit progressive in a way that does not hinder access.
MR: I think this is an area where we’ll all need to be mindful. Let’s say, just making up a number here, that a school raises their deposit from $300 to $1,500. Surely there would be some students with very low or zero EFC who would not be able to pay that amount.
I did want to make a few closing observations. A couple of session attendees underscored for us the ultimate question here, which is whether colleges and universities will become more aggressive in their recruitment now that the guidelines have been relaxed.
I should note that I’ve just recently joined EAB, so I have very recent experience of being a practitioner like many of you. And based on that experience it’s hard to picture a market that’s even more competitive than what we’re already familiar with. But I do think that’s where things are headed. And whether you see that as an opportunity or a threat, you’ll want to be thinking through what conversations you need to be having within your organization to prepare and what your plan’s going to be.
Hopefully today’s conversation will help you take few preliminary steps in that direction.