AACRAO Proposed Standards

The following is the text of a letter from Dr. Mitch Leventhal, AIRC President and Chairman, to Wanda Simpson Munson, AACRAO President, in response to AACRAO's proposed Professional Practices and Ethical Standards which were released on March 12, 2010.
Hello Wanda and Jerry,
I am writing to you in my capacity as Chair and President of the American International Recruitment Council (AIRC) out of a collegial concern about portions of your recent email regarding the new AACRAO Professional Practice and Ethical Standards (copied below).
AIRC's interests are in increasing professionalism in the use of agents for international student recruitment.  AIRC is incorporated as a 501c3 not-for-profit corporation which is officially registered as a Standard Development Organization with both the U.S. Department of Justice and the Federal Trade Commission. As you are probably aware, AIRC has been growing rapidly in both size and influence . We now have nearly 100 institutional members. Our Board of Directors and Certification Board are comprised of several highly respected international educators and admissions officers.  We also believe that our membership reflects only a very small proportion of US institutions which are actually working with agents on a commission basis. Based on our market intelligence, we estimate that there are presently between 500 and 1,000 institutions which hold commission-based contracts with agents. In short, this movement is gaining significant momentum, and it is vital that all organizations for whom US admissions standards and recruitment are core have a realistic understanding of developments.
My concern with one of the points in your proposed Standards is the phrase to “Avoid practices in the recruitment and enrollment of international students that would not be ethical or legal in the recruitment or enrollment of domestic students…”  There is  a contradiction between this standard and the explicit wording of Title IV. According to Title IV:
“(b) By entering into a program participation agreement, an institution agrees that – (22)(i) It will not provide any commission, bonus, or other incentive payment based directly or indirectly upon success in securing enrollments or financial aid to any person or entity engaged in any student recruiting or admission activities or in making decisions regarding the awarding of title IV, HEA program funds, except that this limitation does not apply to the recruitment of foreign students residing in foreign countries who are not eligible to receive title IV, HEA program funds.”  [bold italics added]

The proposed AACRAO standard is essentially saying that institutions should disregard what the law explicitly permits. AIRC believes that this will contribute to further confusion, which would not be desirable to higher education.
I would like to point out to you that AIRC has developed the most comprehensive ethical and practice standards that exist for international student recruitment and that many of our standards reflect those listed in the remainder of your document . A copy of the AIRC Standards is attached (along with a recent presentation made to AIEA). I would also like to draw your attention to AIRC’s Vision Statement and Mission Statement (http://airc-education.org/Vision.htm), both of which address very directly the concerns that we share with AACRAO and related organizations:

AIRC Vision Statement
“AIRC was conceived and created by accredited U.S. colleges and universities as a non-profit Standards Development Organization in order to address known deficiencies in the higher education marketplace through the adoption of ethical standards. Such standards are used successfully by a range of associations concerned with the intersection of business and professional practice.

AIRC believes that international students considering a U.S. education make an investment not only in their future, but in the future of U.S interests when they return home, mature, and build new business and diplomatic partnerships. AIRC believes these students’ investment decisions should be made with the most in-depth knowledge available to ensure the investment is sound and objective.  

AIRC also believes that the internationalization of U.S. institutions of higher education is a vital step to their educational missions. This process is best served by attracting students from other countries who are well matched to the institution and whose expectations are met by transparent knowledge of the institution’s strengths and weaknesses.  Few institutions have the staff or budget to adequately perform this role and therefore in-country agencies with recognized standards and practices are critical to realizing this mission. Agency compliance with AIRC standards makes it possible for institutions to choose agencies that have adopted these recognized standards, are well trained on all aspects of U.S. higher education, and which have consented to periodic external review as part of a comprehensive certification process.  AIRC professional development processes ensure that both agents and institutions can collaborate in ways which enhance the interests of the students while meeting the goals of both institutions and agencies.

Finally, AIRC believes that U.S. strategic and economic interests continue to be served by attracting the best and brightest students into our higher education system. Our colleagues and friends in Australia and the United Kingdom share this belief.   They have demonstrated that the creation of recognized and ethical standards in the recruitment agent industry is a highly effective means of ensuring an enduring match between students and institutions and that students are treated honestly and with respect, thereby improving both student mobility and the productivity of the educational process.“
AIRC Mission Statement
“The AIRC is a 501c3 non-profit organization controlled by accredited United States post-secondary educational institutions.  

The purposes of the organization are to:

  • Develop standards of ethical practice pertaining to recruitment of international students to American educational institutions, such standards to address two constituencies: educational institutions and student recruitment agents;
  • Develop best practices and training to assist overseas student recruitment agents and institutions themselves to better serve both students seeking admission to American educational institutions, and
  • Establish a framework through which participating agents can have their practices certified. In addition, the organization may undertake other activities as are necessary to accomplish its goals.”

I believe that the time has come for AACRAO and AIRC (as well as NACAC and other related bodies) to share a  dialogue on the issue of professionalism in the use of agency based recruitment.  AIRC was created to directly address these issues, since no other organization was exclusively focusing on them. Our members are deeply concerned with ethical practice and legal compliance, and are also loyal members of AACRAO and other organizations. AIRC will continue to grow rapidly, and we believe that our work in the area of Standards needs to be understood by any organization which is attempting to influence the industry. I encourage you to review AIRC’s standards and advise us on where they are deficient from the perspective of AACRAO.  I also encourage you to consider a revision of the standard proposed, which will surely sow confusion and consequent non-compliance.

I look forward to discussing this at your earliest convenience.


Mitch Leventhal, PhD
Chair & President, American International Recruitment Council (AIRC)
Vice Chancellor for Global Affairs, State University of New York (SUNY)
116 East 55th Street - New York, NY 10022