Military Policies & Information

Prospective students are directed to receive approval from the student’s Education Services Officer (ESO), military counselor or Service prior to enrollment.

Military students have access to disability counseling to assist Service members with the completion of studies and with job search activities.

Dr. Katherine Walker Payne

Manager of Disability Services — Center for Accessibility & Learning Equity

kwalkerpayne@spalding.edu

(502) 873-4192

Deb Whistler

Career Development Coordinator — Career Development

career@spalding.edu

(502) 873-4355

Spalding University supports students who are members of the United States armed forces and reserve units. An undergraduate or graduate student who is a member of the U.S. military, National Guard or other armed forces reserve unit who is called or ordered to active duty elsewhere may be granted a Military Leave of Absence (MLOA) from the University for the period of active duty and up to one year after returning from active duty. Students with the MLOA need not apply for readmission or pay readmission fees. MLOA allows those students to preregister for classes during their priority registration period prior to the term when they plan to return to campus.

The Military Leave of Absence notification must be submitted to the Registrar’s Office prior to the student’s departure from the University, must be accompanied by a copy of the military orders indicating the date on which the student must report for active duty elsewhere. When students are called to active duty after classes begin, they should refer to the university withdraw policy for a complete withdrawal from the current term, in addition to filing the MLOA for subsequent terms. If students receive financial aid and/or live in a Spalding residence hall, they are responsible for contacting the Office of Financial Aid and/or Office of Residence Life. For further assistance with the MLOA. please contact the Office of the Registrar at registrar@spalding.edu.

Spalding University strives to be an institution of high integrity and is committed to ensuring that recruitment and enrollment activities conducted at the University promote such an environment. The purpose of this policy is to ensure compliance with federal laws and regulations in order to prevent and eliminate fraudulent and aggressive recruitment of students (including but not limited to veterans and Military Service members) to the University.

Responsible Office: Office of Financial Aid

Scope: All departments, employees, and agents of Spalding University must comply with this policy.

Spalding University ensures compliance with Program Integrity Rules consistent with federal regulations (34 C.F.R. 668.71-668.75 and 668.14) and the Department of Defense (DoD) Voluntary Education Partnership Memorandum of Understanding (MOU) regarding restrictions on misrepresentation, recruitment, and payment of incentive compensation.

The University, its agents, including third-party lead generators and marketing firms, will:

• Ban inducements, including any gratuity, favor, discount, entertainment, hospitality, loan, transportation, lodging, meals, or other item having a monetary value of more than a de minimis amount, to any individual or entity, or its agents including third-party lead generators or marketing firms other than salaries paid to employees or fees paid to contractors in conformity with all applicable laws for the purpose of securing enrollments of Service members or obtaining access to tuition assistance funds. Educational institution-sponsored scholarships or grants and tuition reductions available to military students are permissible.
• Refrain from providing any commission, bonus, or other incentive payment based directly or indirectly on securing enrollments or federal financial aid (including tuition assistance funds) to any persons or entities engaged in any student recruiting, admission activities, or making decisions regarding the award of student financial assistance. These restrictions do not apply to the recruitment of foreign students residing in foreign countries who are not eligible to receive Federal student assistance.

Tuition Sharing: The U.S. Department of Education generally views the payment based on the amount of tuition generated as an indirect payment of compensation based on success in recruitment and therefore a prohibited basis upon which to measure the value of the services provided. This is true regardless of the manner in which the entity compensates its employees.

However, the Department does not consider payment based on the amount of tuition generated by an institution to violate the incentive compensation ban if that payment compensates an unaffiliated third party that provides a set of services that may include recruitment services. The independence of the third party (both as a corporate matter and as a decision-maker) from the institution that provides the actual teaching and educational services is a significant safeguard against the abuses the Department has seen heretofore. When the institution determines the number of enrollments and hires an unaffiliated third party to provide bundled services that include recruitment, payment based on the amount of tuition generated does not incentivize the recruiting as it does when the recruiter is determining the enrollment numbers and there is essentially no limitation on enrollment.

As a Title IV institution, the University remains responsible for the actions of any entity that performs functions and tasks on its behalf. These responsibilities include ensuring that employees are not paid for services that would convert these payments into prohibited incentive compensation because of the activity the employees engage in.

Refrain from high-pressure recruitment tactics such as making multiple unsolicited contacts (3 or more), including contacts by phone, email, or in-person, and engaging in same-day recruitment and registration for the purpose of securing Service member enrollments in non-credit courses or programs.

The U.S. Department of Education (DOE) has issued guidance on the prohibition on incentive compensation that includes FAQs and examples, including examples of activities that are subject to the prohibition and hose that are exempt, and the types of payments that are considered forms of incentive compensation and those that are not. This guidance is available on the DOE’s website at https://www2.ed.gov/policy/highered/reg/hearulemaking/2009/compensation.html.

34 C.F.R. 668.71-668.75 and 668.14; Department of Defense Memorandum of Understanding; Federal Student Aid Program Participation Agreement; NACAC’s Code of Ethics and Professional Practices