The following is a guest post by Gavin Moodie, a higher-education policy analyst at RMIT University, in Australia.
In view of the debate about paying agents commissions for recruiting international students, it may be useful to give a perspective from Australian universities, which have long paid agents a commission for each student they recruit.
One of the reasons Australian institutions are comfortable with commission-based agents is because they established one of the biggest, IDP, in 1969. Originally known as the International Development Program, most Australian universities have been closely involved in its development.
But while commission-based agents aren’t contentious in Australia, they aren’t necessarily problem free. Here are five lessons Australia has learned from its experience with agents over the years--lessons that universities and government officials in the United States can use to help them decide their own approach to agents.
Make institutions explicitly responsible for their agents. A college is legally liable for its agents’ actions within their apparent authority so most potential problems with agents may be avoided by regulating colleges well. Colleges’ responsibilities should be made explicit by establishing a framework or guidelines for managing their education agents. The framework should include criteria for selecting agents, a standard agency agreement, induction and training for agents and their staff, and guidelines for monitoring agents. The certification standards of the American International Recruitment Council are a good start.
Require public disclosure of key information about agents. One important lesson for Australia was to require both public and private colleges to disclose key information about their recruiting agents. Minimally colleges should be required to publish the names of their agents on their Web site so that prospective students may check that an agent is authorized to represent their preferred institution.
Monitor continuously, not periodically. An agent’s contract renewal is the usual time to review an agent’s work for a college. But an agent’s performance needs constant monitoring and support. Likewise international education develops and changes so fast that the relevant authorities need to monitor colleges’ maintenance of appropriate quality and standards continuously. Reviewing performance as part of an accreditation every five years is not sufficient to identify and remedy issues before they become problems.
Regulate according to risk. While regulation is important, too much burden can be imposed on colleges and regulators by monitoring every college the same. Colleges and universities have different levels of risk in managing their agents and this should be reflected in different levels of regulation. The colleges that seem to have most difficulty managing and disciplining their agents are small, less prestigious, and rely too heavily on one agent. They don’t have as many resources and as much authority as established universities, which have staff members dedicated to managing the agents in their region. They need to be monitored more closely than bigger universities with a reputation to protect.
Consider an independent international student ombudsman. Some students, especially those from countries without a strong tradition of internal administrative remedies, are not confident of college review processes. They doubt that internal reviews can be independent and may fear that they or their grades would be in trouble if they complain to their college about an agent or other concerns. An independent office for international students is an important protection of their rights. The overseas student ombudsman established by the Australian federal government gives current and prospective international students confidence that their complaints are investigated thoroughly and fairly, helps institutions manage internal complaints effectively, and reports on problems and broader issues that it identifies from its investigations. The office includes a former international student of a private college.
Undoubtedly commission-based agents may cause problems. But most agents serve their students and colleges well. The correct response to potential problems with agents is not to ban them outright, but to implement processes that protect students while allowing them to benefit from the services offered by reputable agents.