Overview and Scope

This Policy is written to ensure compliance with the adherence to Section 487 (a) (20) of the Higher Education Act (HEA) which prohibits Columbia College from providing incentive compensation to employees or third-party entities for their activities in securing student enrollments or awarding Title IV, HEA program funds. This law took effect July 2011 and these “Program Integrity Rules” cover a broad range of issues intended to promote integrity in Title IV. These rules apply to all Title IV eligible institutions and thus apply to Columbia College, as a participant in Title IV, HEA programs. All related College departments are subject to and must comply with (and ensure that their policies and procedures comply with) this Policy.


Policy Statement

Columbia College strictly prohibits awards in any kind of commission, bonus, or other incentive payment based in any part, directly or indirectly, upon securing enrollments or awarding financial aid, to any individual 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. These restrictions do not apply to the recruitment of international students residing in foreign countries who are not eligible to receive Federal student assistance.



  1. Determine whether any individual or entities are being (or will be) paid incentive compensation (i.e., commission, bonus payments, merit salary adjustments, promotion decision, or other type of incentive payment for their services to the College).
    1. If yes, go to Step 2 below.
    2. If no, you can stop following this written procedure.
  2. If you responded yes to Step 1, the next step is to determine whether the payment of incentive compensation, or any part of thereof, is directly or indirectly based upon either:
    1. The individual’s or entity’s success in securing enrollments (defined as activities engaged in for the purpose of the admission or matriculation of students for any period of time), or
    2. An individual’s or entity’s involvement in the awarding of financial aid. 
    3. If no, the payment is permissible and you no longer need to follow this written procedure.
    4. If yes, the payment is prohibited under the Program Integrity Rules, and you must immediately take steps to cease any incentive payment and report accordingly.
  3. Review your compensation practices with any staff or entity who may be involved in enrollment, admissions, or financial aid activities to determine if any current or future incentive compensation or bonus structures offered to them are prohibited under Section 487 (a) (20) of the Higher Education Act. For more information, please refer to the Department of Education website here



A few examples of exemptions include:

  1. Marketing activities such as:
  • Broad information dissemination;
  • Advertising programs that disseminate information to groups of potential students;
  • Collecting contact information;
  • Screening pre-enrollment information to determine whether a prospective student meets the requirements that an institution has established for enrollment in an academic program;
  • Determining whether an enrollment application is materially complete, as long as the enrollment decision remains with the institution
  1. Student support services offered after the point at which financial aid is allowed to be disbursed for a payment period, including:
  • General student counseling;
  • Career counseling;
  • Financial aid counseling, including loan management;
  • Online course support – both professional services and computer hardware and software;
  • Academic support services, including tutoring, aimed at student retention, whether that support is provided prior to attendance in classes or after attendance has begun


Violations of this policy, including failure to avoid a prohibited activity or obtain required approvals, will be addressed according to the applicable College policies and procedures. These may include disciplinary actions including termination of employment from Columbia College.