Model Standards for Non-US Based International Student Recruitment Agencies
Model Standards for Non-US Based International Student Recruitment Agencies
The lack of regulation and consistency around the recruitment and enrollment of F-1 international students at U.S. secondary schools raises ethical concerns, and also opens the door for misaligned expectations among the various parties involved in the administration of the enrollment process.
As hosts of international students, US secondary schools may partner with agencies both within the United States and abroad to recruit and enroll new international students. However, without guidance on best practice for collaborating with third-party recruitment agencies, expectations around this complex process, particularly from a student perspective, can be unclear; risk can be high. At the higher education level, colleges and universities are expected to act with transparency, integrity, and accountability; secondary-level practices should align with these standards.
In response to these issues, the CSIET Advisory Board has developed comprehensive Model Standards for international student recruitment at the secondary level.
STANDARD 1: STEWARDSHIP
A. Agencies must commit to a training process, as determined by the partner school, for initial and continued education about the school and admission process;
B. Agencies demonstrate the ability to carry out fiduciary responsibility to all program participants;
C. Agencies act ethically, honestly, professionally, responsibly and in the interest of students and natural parents at all times;
D. Agencies have a clear process for the submission and adjudication of complaints;
E. Agencies adhere to local and international law wherever and whenever applicable.
STANDARD 2: TRANSPARENCY
A. Agencies accurately disclose U.S partner agencies, sub-agents and educational institutions with whom they have a documented business relationship. Specifically, agencies must disclose to students/natural families the names of their partner agencies, sub-agents and schools;
B. Agencies disclose their ownership, governance and organizational structure in an accurate and detailed manner;
C. The nature of the partnership between the agency and US partner institution is clearly stated in the form of a contract or written agreement;
D. Written agreements/contracts between the agency and school are signed by both parties; agreements/contracts display all itemized fee schedules, refund policies and other policies as applicable by law; such contracts/agreements avoid any misrepresentation and do not make promises or guarantees that cannot be met;
E. Written agreements/contracts between the agency and student/natural parents must clarify that the agency does not collect any commissions based on financial aid or scholarship; also, contracts with students/natural parents stipulate confidentiality and the limits therein, as guaranteed by privacy laws; these contracts/agreements display all itemized fee schedules, refund policies and other policies as applicable by law; such contracts/agreements avoid any misrepresentation and do not make promises or guarantees that cannot be met;
F. Agencies stand by the veracity of documentation, including: financial capability, grades, transcripts, teacher recommendations, English language capability and any other documentation/scores used for the purpose of admissions;
G. Agencies fully disclose the practice of collecting payments/fees/commissions:
- If agencies receive payments from students/natural families, this practice must be disclosed to partner schools;
- If agencies receive commissions from partner schools, this practice must be disclosed to students/natural parents;
- If agencies compensate sub-agents, independent contractors, consultants and/or franchisees, this practice must be disclosed to students/natural parents and partner schools.
H. Agencies shall not knowingly be a party to a placement based solely on athletic skill and ability, whether initiated by a student, a natural or host family, a school, or any other interested party. Agencies should provide transparency and report to partners/schools any F-1 student for whom participation in interscholastic varsity athletics was the sole motivating factor at the time of application.
I. Agencies shall secure written, student-specific acceptance from the DSO (Designated School Official), PDSO (Principal Designated School Official), school principal or other designated responsible school administrator prior to the international student’s departure from his or her home country.
STANDARD 3: ENGAGEMENT
A. Agencies train their recruitment personnel (including, but not limited to, employees, sub-agents, independent contractors, consultants and franchisees) annually in relevant standards, practices, procedures and content areas. Recommended resources include:
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- The US secondary school education system;
- Principles of Good Practice (NAIS, NAFSA, TABS);
- Enrollment Management Practices (EMA, AISAP);
- CSIET Standards for Long Term International Student Exchange Programs;
- US Regulatory Requirements (SEVP);
- International Student Recruitment Standards/Guidance (*AIRC, NACAC Code of Ethics).
- The US secondary school education system;
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B. The agency shall respond in a timely and appropriate fashion to complaints received from international students, natural parents, schools or others concerned with the program and its quality.
STANDARD 4: PARTNERSHIP
A. The agency is accountable for actions taken and representations made by partners (including, but not limited to sub-agents, independent contractors, consultants and franchisees). All partners must adhere to CSIET’s Model Standards on International Student Recruitment.
B.The agency collaborates with US-based agencies and schools that operate in a manner consistent with CSIET Standards for Long Term International Student Exchange Programs.
C. The agency partners with US schools on the basis of criteria consistent with CSIET’s Model School Policy (Section 4, School Expectations of International Student Exchange Programs).
Submitted by the CSIET Advisory Board on International Student Recruitment on 05-28-2019. Approved by the CSIET Board of Directors on 06-12-2019.
Glossary of Terms
Recruitment Terms Glossary
Acceptance
The process or fact of entering or being allowed to enter a US secondary school.
Admissions
The process of recruitment and selection of new students.
Agent
A paid, non-US based international business entity authorized to represent or act on behalf of a US secondary school, international student, and/or natural parent for the purpose of international student enrollment in a US secondary school. Payment methodology must be made transparent to all parties.
Athletic Recruitment
Any act of influence toward the purpose of admission or enrollment of a student based on his/her athletic abilities, whether initiated by a student, a natural or host family, a school, or any other interested party. This practice is not permitted.
Commission
An amount of money, typically a set percentage of the value involved, paid to an agency in a commercial transaction.
Confidentiality
During the recruitment process, protecting a client’s/constituent’s personal or private information from inappropriate/illegal dissemination.
Disclosure
During the international student recruitment process, the act of releasing all relevant information that may influence decisions made by international students, natural parents, programs or schools. This includes and is not limited to: accurate representation of college admissions processes/outcomes, accurate tuition amounts, authentication of application materials, detailed pricing, student screening methods, host family screening methods, payment methodology, verified agency-school relationships, verified English language proficiency, and vetted living arrangements.
English Language Proficiency
As determined by the partner secondary school: (1) the ability of students to comprehend written and spoken English; (2) the ability to use the English language to communicate meaning in spoken and written contexts; (3) an admissions requirement to be considered during the international student application process.
First-year Students
Students who apply as first-time secondary school matriculants are known as first-year students. These students typically have no previous experience in a US high school.
Formal Business Relationship
An association or partnership between individuals, schools, or international student recruitment agencies entered into for commercial purposes and sometimes formalized with legal contracts or agreements.
Independent Educational Consultant
A professional hired and paid not by the school, but by students and their parents for personalized advice on the high school search, application and admission processes.
International Student Recruitment
Organized activity (carried out by a non-US based international student recruitment agency on behalf of a US secondary school, international student, and/or natural parent) that includes at least one of the following processes: promoting programs/schools, screening students, assisting with the completion of secondary school applications for admissions, aculturating and orienting international students prior to their departure from their home country, arranging travel for international students, and communicating with schools/school officials prior to international student arrival to the US.
Laws and regulations
Agencies must observe, where applicable, local, state, provincial, and federal or national laws and regulations (both in the US and the home country). This includes, but is not limited to, student privacy, misrepresentation, incentive compensation, the issuance of visas, security, conflicts of interest, civil rights, non-discrimination, disabilities, disclosures, reporting, and transparency. In the US these include, for example, the Illegal Immigration Reform and Immigrant Responsibility Act (Public Law 104-208), the Family Educational Rights and Privacy Act (FERPA), the Americans with Disabilities Act (ADA), and federal, state, and local civil rights laws and regulations that prohibit discrimination.
Long-term
Of a semester or more in duration.
Matriculate
To enroll, register, insert oneself in a list as a student in a US secondary school.
Misrepresentation
The action or offense of giving false or misleading information.
Offers of Admission
Official offers of admission are statements of acceptance that may be transmitted by mail, electronically, or on official websites as determined and approved by the secondary school’s chief enrollment officer.
Official Transcript
An official transcript is an official academic record that features a student’s course of study at an institution. Information usually includes courses taken, a progress rubric, and other indicators of the student’s academic development and achievement.
Partner(ship)
A type of relationship in which international student recruitment agencies and/or secondary schools pool skills and other resources to recruit international F-1 students.
Publicly Disclosed
Revealed on public websites and in print materials.
Secondary Schools
In the United States, secondary schools refer to the high schools (and in some cases, middle schools) that students typically attend before they begin college. They may be public or private/independent and offer general, technical, vocational, and/or college preparatory coursework. The term may also include statewide agencies or private organizations that certify home-schooled students. In the CSIET Advisory List, High schools include grades nine through 12.
Sub-Agent
A recruitment agency/agent that works with an international student recruitment agency to recruit international students into US secondary schools via the international student recruitment agency’s agreement with these partner schools.
Transfer students
Matriculants from one high school to another. The definition of a transfer student and related policies are determined by the receiving institution, and in some cases, state athletic associations.
Transparency
The terms of transactions between agencies, schools, natural parents and international students shall be clear and transparent. Requirements for transparency include, but are not limited to: providing clear and conspicuous disclosure of arrangements by international student recruitment agencies with third party agents, visible to prospective students and natural parents; providing clear and conspicuous disclosure of arrangements by international student recruitment agencies with US secondary schools, visible to prospective students and natural parents; ensuring that terms of transactions between international student recruitment agencies, US schools and international students/natural parents are clear and published.
Varsity Athletics
The highest/most advanced level of interscholastic athletic competition among US secondary schools.
Non-Immigrant Visa Related Glossary
Bureau of Educational and Cultural Affairs
A division within the US Department of State that works to inform both US students wishing to study abroad and international students wishing to come to the United States for cultural, educational, or professional exchange.
Designated School Official (DSO)
All SEVP-certified schools are required to have one DSO. These individuals are responsible for communicating regularly with SEVP. This individual is typically an international student’s greatest resource on campus when it comes to the visa process, maintaining student status, and following proper regulations and guidelines once in the United States.
F-1
Non-immigrant student visa; issued to international students who are attending an academic or English language program at a US secondary school. Students must maintain student status while studying with this visa, which means maintaining a full-time course load.
I-17
Form “Petition for Approval of School for Attendance by Nonimmigrant Student;” this form is required to be completed and then certified by SEVP before any school in the United States can enroll nonimmigrant students.
I-20
Certificate of Eligibility for Nonimmigrant Student Status; issued to admitted F-1 and M-1 students by an SEVP certified school. Required for nonimmigrant visa application and for entry into the US.
I-94
Arrival/Departure Record for foreign visitors; Customs officials will compile visitors’ I-94 arrival/departure information automatically from their electronic travel records for air and sea ports of entry or via paper forms for land border ports of entry. Nonimmigrant visitors who need to access their I-94 number can go to the U.S. Customs and Border Protection website.
Permanent resident
Lawful permanent residents, also known as green card holders, are non-citizens who are lawfully authorized to live permanently within the United States.
Principal Designated School Official (PDSO)
All SEVP-certified schools are required to have one Principal Designated School Official, who serves as the main point of contact for SEVP. Schools with PDSOs can have additional Designated School Officials (DSOs), whom they are required to update SEVP about and monitor recertification.
Student and Exchange Visitor Information System (SEVIS)
A web-based system developed by the DHS to maintain information on SEVP-certified schools and the F and M visa students that come to study at them. SEVIS also maintains information on the exchange visitor, program sponsors, and J-1 visa holders, which are managed through the Department of State. Through SEVIS, the essential I-20 forms are issued to students looking to obtain F or M status visas, student records are transferred to other institutions, the certification of educational institutions as SEVP-certified are approved and monitored.
Student and Exchange Visitor Program (SEVP)
Part of the National Security Investigations Division that manages schools, nonimmigrant students (F or M visas) and their dependents.
U.S. Customs and Border Protection (CBP)
Comprehensive border management and control by combining customs, immigration, border security and agricultural protection all under CBP. Students will deal with employees of CBP when they enter and depart the United States.
U.S. Department of State
A department of the United States federal government that is focused on accomplishing America’s mission of diplomacy at home and around the world. Within the Dept. of State, the Bureau of Education and Cultural Affairs oversees the J-1 Secondary Exchange Program and issues DS – 2019 forms that, when issued to international students allow for application to receive a J-1 student exchange visa.
U.S. Immigration and Customs Enforcement (ICE)
Enforces federal laws governing border control, customs, trade and immigration to promote homeland security and public safety.
United States Department of Homeland Security (DHS)
A department of the United States federal government with responsibilities in public security, immigration and customs, cyber security, and disaster prevention and management. DHS also issues the I-17 form needed by US secondary schools to apply for certification to enroll F-1 international students.