In response to the recent indictment of 50 people charged with participating in a scheme to cheat on standardized tests and/or to bribe college athletic officials to help gain admission of students on false pretenses to elite universities, the U.S. Department of Education (“Department”) has commenced a preliminary investigation of schools named in the criminal investigation. Although the Department’s investigation is purportedly to determine if the named schools failed to comply with their obligations under Title IV of the Higher Education Act of 1965 (“HEA”), and is currently limited to eight universities, it has potentially broad implications for all institutions of higher education.
As suggested by the nature of the documents and information requested by the Department from the universities under investigation – admissions policies and standards, admissions data submitted to accrediting agencies, recruiting and marketing materials, audit reports and compliance reviews – it appears that the Department’s primary interest is whether the schools have in any way misrepresented their admissions practices and requirements. This has broad implications for every college and university in the United States that does not operate an open admissions policy.
Every school should consider this a wake-up call and an opportunity to conduct a top-to-bottom review of its admissions practices and procedures. Are your prospective students being admitted or denied pursuant to the holistic review process set forth in your admissions policies? Are your admissions practices consistent with the admissions standards and protocols advertised by the school? Where do gaps exist, and why? Who, outside of the Admissions Office, has influence over admittance decisions? What controls are in place to prevent improper considerations? When you discern gaps or weaknesses in your admissions process, how do you address and fix them?
Given the stakes riding on admissions decisions and the pressures faced by students and their parents, university officials, and admissions officers, it is surprising how few schools ever conduct internal audits or comprehensive reviews of their admissions programs. Admissions data is too easy to manipulate, false information in application files too easy to include, for auditors to not be included in the control process. At some elite schools, applications are reviewed, and admission decisions made in as little as eight minutes. Admissions officers are not investigators, their role is not to play detective, and they cannot be expected to catch every irregularity. Systems need to be put in place that will prevent abuses and misrepresentations.
Integrity in admissions matters. Prospective students and consumers expect that applicants will be considered on their individual merits when applying to college. The Education Department is paying closer attention due to current events, and its interest in this issue extends beyond technical compliance with financial aid guidelines. Schools would be well-served to pro-actively ensure that their own houses are in order. Now is the time to review your institution’s admissions practices and procedures and take steps to minimize identified vulnerabilities by doing the following:
- Conduct an independent review of all admissions policies and procedures, marketing and recruiting materials, information published on websites, and data provided to accrediting agencies and external reviewers.
- Review policies and procedures governing recruitment and the interactions among applicants, admissions officers, and other persons involved in the process, including internal recommenders.
- Identify any gaps in information flows, recordkeeping, verification, or other procedures that risk circumventing the admissions process and control systems.
- Perform data analytics to help identify anomalies in admissions profiles or data.
- Revise admissions policies and practices to sufficiently address any gaps or vulnerabilities in accordance with best practices.
- Implement a system of internal audits and controls to ensure compliance with the revised policies and procedures.
The process of selecting students for admission is a critical component of how colleges and universities across the country fulfill their mission. Most schools seek to admit a talented and diverse group of students who are well-prepared for and positioned to succeed in a challenging academic environment. Ensuring that the admissions process is administered with integrity and fairness and considers each applicant solely on his or her individual merit apart from outside pressures or external influences is an important component of university admissions. At least, that is what most institutions of American higher education publicly proclaim. Recent events have challenged institutions to look inward and correct discrepancies between stated protocol and reality. Is your school up for the challenge?
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