Special Tests and Provisions – Incentive Compensation Federal Agency and Program: AL number 84.007, 84.063, 84.268 U.S. Department of Education
Student Financial Assistance Cluster Award Period: July 1, 2022 – June 30, 2023
Criteria: According to 34 CFR 668.14(b)(22)(i), an institution agrees in its Program Participation Agreement that “it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly,
upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged
in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA
program funds.” A commission, bonus, or other incentive payment is a sum of money or something of value,
other than a fixed salary or wages, paid to or given to a person or an entity for services rendered (34 CFR
668.14(b)(22)(iii)(A)). With respect to Merit-based adjustments, the regulation specifies in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or
the award of financial aid; and profitsharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds.
Condition: Certain of the College’s admissions employees received merit-based adjustments to their annual
compensation which were based in part upon success in securing enrollments.
Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i).
Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34
CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and
other entities may make merit-based adjustments to employee compensation provided that such
adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the
award of financial aid; and profit sharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions
employees which were based in part upon success in securing enrollments.
Questioned costs: None.
Repeat Finding: No.
Recommendation:
We recommend that management review and update its annual performance review process and forms to
ensure that the College is not awarding any commission, bonus, or other incentive payment based in any
part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person
or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding
the award of title IV, HEA program funds.
Views of Responsible Officials:
The College revised the annual Performance Management Review form to expressly prohibit a performance
metric for securing enrollment. All personnel have been retrained.
Special Tests and Provisions – Incentive Compensation Federal Agency and Program: AL number 84.007, 84.063, 84.268 U.S. Department of Education
Student Financial Assistance Cluster Award Period: July 1, 2022 – June 30, 2023
Criteria: According to 34 CFR 668.14(b)(22)(i), an institution agrees in its Program Participation Agreement that “it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly,
upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged
in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA
program funds.” A commission, bonus, or other incentive payment is a sum of money or something of value,
other than a fixed salary or wages, paid to or given to a person or an entity for services rendered (34 CFR
668.14(b)(22)(iii)(A)). With respect to Merit-based adjustments, the regulation specifies in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or
the award of financial aid; and profitsharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds.
Condition: Certain of the College’s admissions employees received merit-based adjustments to their annual
compensation which were based in part upon success in securing enrollments.
Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i).
Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34
CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and
other entities may make merit-based adjustments to employee compensation provided that such
adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the
award of financial aid; and profit sharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions
employees which were based in part upon success in securing enrollments.
Questioned costs: None.
Repeat Finding: No.
Recommendation:
We recommend that management review and update its annual performance review process and forms to
ensure that the College is not awarding any commission, bonus, or other incentive payment based in any
part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person
or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding
the award of title IV, HEA program funds.
Views of Responsible Officials:
The College revised the annual Performance Management Review form to expressly prohibit a performance
metric for securing enrollment. All personnel have been retrained.
Special Tests and Provisions – Incentive Compensation Federal Agency and Program: AL number 84.007, 84.063, 84.268 U.S. Department of Education
Student Financial Assistance Cluster Award Period: July 1, 2022 – June 30, 2023
Criteria: According to 34 CFR 668.14(b)(22)(i), an institution agrees in its Program Participation Agreement that “it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly,
upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged
in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA
program funds.” A commission, bonus, or other incentive payment is a sum of money or something of value,
other than a fixed salary or wages, paid to or given to a person or an entity for services rendered (34 CFR
668.14(b)(22)(iii)(A)). With respect to Merit-based adjustments, the regulation specifies in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or
the award of financial aid; and profitsharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds.
Condition: Certain of the College’s admissions employees received merit-based adjustments to their annual
compensation which were based in part upon success in securing enrollments.
Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i).
Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34
CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and
other entities may make merit-based adjustments to employee compensation provided that such
adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the
award of financial aid; and profit sharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions
employees which were based in part upon success in securing enrollments.
Questioned costs: None.
Repeat Finding: No.
Recommendation:
We recommend that management review and update its annual performance review process and forms to
ensure that the College is not awarding any commission, bonus, or other incentive payment based in any
part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person
or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding
the award of title IV, HEA program funds.
Views of Responsible Officials:
The College revised the annual Performance Management Review form to expressly prohibit a performance
metric for securing enrollment. All personnel have been retrained.
Special Tests and Provisions – Incentive Compensation Federal Agency and Program: AL number 84.007, 84.063, 84.268 U.S. Department of Education
Student Financial Assistance Cluster Award Period: July 1, 2022 – June 30, 2023
Criteria: According to 34 CFR 668.14(b)(22)(i), an institution agrees in its Program Participation Agreement that “it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly,
upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged
in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA
program funds.” A commission, bonus, or other incentive payment is a sum of money or something of value,
other than a fixed salary or wages, paid to or given to a person or an entity for services rendered (34 CFR
668.14(b)(22)(iii)(A)). With respect to Merit-based adjustments, the regulation specifies in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or
the award of financial aid; and profitsharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds.
Condition: Certain of the College’s admissions employees received merit-based adjustments to their annual
compensation which were based in part upon success in securing enrollments.
Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i).
Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34
CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and
other entities may make merit-based adjustments to employee compensation provided that such
adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the
award of financial aid; and profit sharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions
employees which were based in part upon success in securing enrollments.
Questioned costs: None.
Repeat Finding: No.
Recommendation:
We recommend that management review and update its annual performance review process and forms to
ensure that the College is not awarding any commission, bonus, or other incentive payment based in any
part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person
or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding
the award of title IV, HEA program funds.
Views of Responsible Officials:
The College revised the annual Performance Management Review form to expressly prohibit a performance
metric for securing enrollment. All personnel have been retrained.
Special Tests and Provisions – Incentive Compensation Federal Agency and Program: AL number 84.007, 84.063, 84.268 U.S. Department of Education
Student Financial Assistance Cluster Award Period: July 1, 2022 – June 30, 2023
Criteria: According to 34 CFR 668.14(b)(22)(i), an institution agrees in its Program Participation Agreement that “it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly,
upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged
in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA
program funds.” A commission, bonus, or other incentive payment is a sum of money or something of value,
other than a fixed salary or wages, paid to or given to a person or an entity for services rendered (34 CFR
668.14(b)(22)(iii)(A)). With respect to Merit-based adjustments, the regulation specifies in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or
the award of financial aid; and profitsharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds.
Condition: Certain of the College’s admissions employees received merit-based adjustments to their annual
compensation which were based in part upon success in securing enrollments.
Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i).
Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34
CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and
other entities may make merit-based adjustments to employee compensation provided that such
adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the
award of financial aid; and profit sharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions
employees which were based in part upon success in securing enrollments.
Questioned costs: None.
Repeat Finding: No.
Recommendation:
We recommend that management review and update its annual performance review process and forms to
ensure that the College is not awarding any commission, bonus, or other incentive payment based in any
part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person
or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding
the award of title IV, HEA program funds.
Views of Responsible Officials:
The College revised the annual Performance Management Review form to expressly prohibit a performance
metric for securing enrollment. All personnel have been retrained.
Special Tests and Provisions – Incentive Compensation Federal Agency and Program: AL number 84.007, 84.063, 84.268 U.S. Department of Education
Student Financial Assistance Cluster Award Period: July 1, 2022 – June 30, 2023
Criteria: According to 34 CFR 668.14(b)(22)(i), an institution agrees in its Program Participation Agreement that “it will not provide any commission, bonus, or other incentive payment based in any part, directly or indirectly,
upon success in securing enrollments or the award of financial aid, to any person or entity who is engaged
in any student recruitment or admission activity, or in making decisions regarding the award of title IV, HEA
program funds.” A commission, bonus, or other incentive payment is a sum of money or something of value,
other than a fixed salary or wages, paid to or given to a person or an entity for services rendered (34 CFR
668.14(b)(22)(iii)(A)). With respect to Merit-based adjustments, the regulation specifies in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34 CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and other entities may make merit-based adjustments to employee compensation provided that such adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or
the award of financial aid; and profitsharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds.
Condition: Certain of the College’s admissions employees received merit-based adjustments to their annual
compensation which were based in part upon success in securing enrollments.
Context: The College was not in compliance with the requirements around incentive compensation outlined within 34 CFR 668.14(b)(22)(i).
Cause: The College was unaware of the regulation specifying in 34 CFR 668.14(b)(22)(ii) that, notwithstanding 34
CFR 668.14(b)(22)(i), eligible institutions, organizations that are contractors to eligible institutions, and
other entities may make merit-based adjustments to employee compensation provided that such
adjustments are not based in any part, directly or indirectly, upon success in securing enrollments or the
award of financial aid; and profit sharing payments so long as such payments are not provided to any
person or entity engaged in student recruitment or admission activity or in making decisions regarding the
award of title IV, HEA program funds. Effect:Merit-based adjustments in the amount of $2,541 were awarded to certain of the College’s admissions
employees which were based in part upon success in securing enrollments.
Questioned costs: None.
Repeat Finding: No.
Recommendation:
We recommend that management review and update its annual performance review process and forms to
ensure that the College is not awarding any commission, bonus, or other incentive payment based in any
part, directly or indirectly, upon success in securing enrollments or the award of financial aid, to any person
or entity who is engaged in any student recruitment or admission activity, or in making decisions regarding
the award of title IV, HEA program funds.
Views of Responsible Officials:
The College revised the annual Performance Management Review form to expressly prohibit a performance
metric for securing enrollment. All personnel have been retrained.