
Public Comment Letter Regarding Improving the Guidance on the Incentive Compensation and Bundled Services
March 16, 2023
CHEPP submitted the following public comment to the U.S. Department of Education as part of its process to improve guidance on the incentive compensation prohibition, particularly with respect to bundled services. Since 2011, higher education institutions have been permitted to use revenue sharing, or paying contracted entities based on per-student enrollment, when those entities provide a bundle of services, including marketing and recruitment. In this letter, CHEPP outlines how to preserve the revenue share model while also ensuring that these relationships are in the best interest of students. CHEPP also provides the Department with reporting and transparency requirements to consider using for these revenue share relationships.