NACAC, CEPP, DOJ: Too Many Acronyms!
I got a little behind with my blog posts this fall, but there’s actually been a number of interesting developments in the college admissions world that I’ve been meaning to share. Now that November 1 is over, I’m excited to get back to blogging regularly!
In late September, while I was at the National Association for College Admission Counseling (NACAC) conference in Louisville, the membership voted to remove three provisions from our Code of Ethics and Professional Practices (CEPP). These changes have caused a wave of feedback across students, families, and college counselors...but what do these changes really mean for your college application process?
I’m unpacking the details in this post with a condensed, all-you-need-to-know version. Hopefully, families will be able to stay on top of the implications of these changes.
The History
NACAC’s long-time code of ethics, the Statement of Principles and Good Practices (otherwise known as the SPGP - another acronym!) had a big revamp back in 2017. The SPGP was a bit lengthy and some felt that it was outdated, so the creation of the CEPP (Code of Ethics of Professional Practices) was really welcomed. No matter the name, the purpose of these documents has always been the same: to protect students during the college admissions process.
Over the past two years, the Department of Justice (DOJ) launched a major investigation against NACAC, believing that some CEPP guidelines are overly restrictive for both applicants (in terms of their ability to negotiate costs) and institutions (in terms of being restricted in their recruitment abilities).
The CEPP requires colleges to standardize their use of application plans, along with guidelines. For example, Early Decision is supposed to mean the same thing everywhere, and so forth. Colleges were not permitted to advertise exclusive incentives for Early Decision.
Additionally, all colleges had to abide by specific rules around the May 1st enrollment deadline: admissions representatives were not permitted to “knowingly recruit” students after that date who had already committed to other institutions. Along the same lines, they couldn’t solicit transfer applications from those students, either.
As a result of mounting legal bills, the organization decided to remove provisions from the CEPP to address these concerns. These provisions--you guessed it--include the Early Decision application incentives, recruiting after the May 1st college decision deadline, and the transfer student restrictions.
Early Decision
Before these changes, the CEPP outlined that colleges could not offer any incentive (special housing, financial aid packages, and special scholarships) to students to encourage them to apply under a binding Early Decision deadline. They were allowed to share the differences between admission rates, but that was it.
After the NACAC vote, this measure was removed from the CEPP:
"Colleges must not offer incentives exclusive to students applying or admitted under an early decision application plan. Examples of incentives include the promise of special housing, enhanced financial aid packages, and special scholarships for early decision admits. Colleges may, however, disclose how admission rates for early decision differ from those for other admission plans."
What does this mean? In short, colleges can now offer incentives under a binding Early Decision program. As our seniors know, Early Decision is a sign of serious commitment to the school and is only appropriate when it is a clear first choice and the student and his family are aware of the financial obligations if accepted. I am actually a big fan of using Early Decision as part of a student’s overall strategy, but it has to be a thought-out decision after careful consideration of the potential drawbacks.
Now that this provision relating to incentives has been removed, it’s sort of like “anything goes” in terms of what can be promised; high-pressure sales tactics are fine. If you receive any strange offers from colleges incentivizing an ED/ED II application, please let us know! These incentives may cloud some of the serious implications of an ED commitment--and they are not always guaranteed.
Check out High Point’s ED Incentives for an example of incentive offerings (you will need to click on the “Early Decision” link.
My guess is that the Class of 2021 will see much more of this than the Class of 2020, because of the additional time for the institutions to make policy changes.
May 1st Deadline/Transfers
I remember May 1st of my senior year so clearly: everyone was anxiety-ridden just weeks before, but then a switch flipped and they were all walking around proudly sporting t-shirts from their future colleges. May 1st is known as the “national decision deadline” for students to finalize their college admissions decisions. In the past, nothing changed after that date unless a student was admitted elsewhere off a waitlist. Both the SPGP and CEPP prohibited colleges from providing last-minute incentives (scholarships, housing, other benefits, etc.) to students to change their minds.
This measure was also removed from the CEPP during the recent vote:
"College choices should be informed, well-considered, and free from coercion. Students require a reasonable amount of time to identify their college choices; complete applications for admission, financial aid, and scholarships; and decide which offer of admission to accept. Once students have committed themselves to a college, other colleges must respect that choice and cease recruiting them."
Also removed…
"Colleges will not knowingly recruit or offer enrollment incentives to students who are already enrolled, registered, have declared their intent, or submitted contractual deposits to other institutions. May 1 is the point at which commitments to enroll become final, and colleges must respect that. The recognized exceptions are when students are admitted from a wait list, students initiate inquiries themselves, or cooperation is sought by institutions that provide transfer programs."
What does this mean? This has largely the same impact as the ED change. On May 1st, students are fully committing to an institution financially. These incentives, again, may cloud their judgment and cause second-guessing. While we are hopeful that colleges will still respect the previous ethical guidelines and each student’s right to make their college choice free from harassment, we will not know how this change will make an impact until after May 1st. Perhaps one of the most interesting aspects involves the fact that the constant pressure may continue even after a student enrolls in college!
Here’s the last measure removed from the CEPP:
"Colleges must not solicit transfer applications from a previous year’s applicant or prospect pool unless the students have themselves initiated a transfer inquiry or the college has verified prior to contacting the students that they are either enrolled at a college that allows transfer recruitment from other colleges or are not currently enrolled in a college."
This has started already, as a number of colleges have started reaching out to freshmen enrolled at different institutions, offering them incentives to transfer.
The Wild, Wild West
Here’s the craziest part - in addition to outright removing the measures above, NACAC has put a moratorium on enforcement on every other provision that remains. Yes, you read that right. It’s like telling your kids: I’m getting rid of the rule about your curfew. I’m keeping the rest of our house rules, but I’m letting you know now that I won’t enforce anything. Hmm….
Actually, I don’t blame NACAC at all: they did what they had to do. But in the post-Varsity Blues world, it is going to be interesting to see how this all plays out. If you are interested in reading all of the (no-longer-enforced) provisions in the new CEPP, you can do so here.
What Now?
Amongst all these changes, there still lies some ambiguity.
Will NACAC member institutions choose to uphold the values of the eliminated CEPP guidelines?
What about the guidelines that do exist that aren’t being enforced?
At this time, we don’t know anything for sure, but here’s what I anticipate happening (keep in mind these views are my own and do not represent NACAC, nor those of any of the other professional organizations to which I belong).
Enrollment deposits may rise to sky-high levels. Right now they are mostly around $300-500 or so. If a student decides not to attend the school to which they have deposited, they lose that deposit, but that’s not the real penalty of breaking an enrollment contract. The real penalty has always been that the student will not be able to enroll anywhere else, because all of the schools stuck to the SGPG/CEPP guidelines. What kind of financial commitment will make it hard for a full-pay parent to walk away if their child gets an acceptance to their dream school after their high school graduation? Not $1000, that’s for sure. Probably not $10,000 either, in my opinion.
Colleges may be extra-conservative in their admissions decisions, knowing that their predictive models may be invalid. In these situations, it’s always better to err on the side of conservatism. It’s easy to fill the class from the waitlist, but as we saw this year with Virginia Tech, it’s not so easy to manage the overcrowding that can result from the opposite situation.
Students will have negotiating power for merit scholarships. This is a good thing, at least!
Regular Decision round will become much more unpredictable than it already is because of (a) the increased interest in ED incentives and (b) the May 1 date becoming meaningless. I have started telling my juniors that we cannot call any school a “safety” during Regular Decision if the school offers ED - no matter how high the acceptance rate. It’s just too unpredictable now and we can’t bank on it.
Students will be put in high-pressure sales-pitch situations. This is unlikely to happen at the most selective schools, but I could definitely see it happening at moderately competitive ones. This has been common with waitlists - colleges may call and give the student 24 hours to decide. It’s hard to be in that situation. Mom and dad out of town? Too bad! A deadline is a deadline. I can definitely see this becoming a “thing” during every round.
This will be an interesting year, for sure. Again, we ask that all of our clients (current and past!) report unusual activity to us so that we can help everyone make the best possible decisions!