Pol-Military Program Integrity
policy modified Wed Oct 12 2022 09:42:22 GMT-0400 (Eastern Daylight Time)
University of Louisville
Military Program Integrity
February 8, 2022
This policy applies to the University of Louisville and its departments, educational units/programs, employees, and others acting on behalf of the University.
REASON FOR POLICY
This policy was established to help ensure compliance with program integrity rules consistent with the regulations issued by the Department of Education (34 CFR 668.71 – 668.75, 668.18 and 668.14) and the requirements outlined in the Department of Defense (DoD) Voluntary Education Partnership Memorandum of Understanding (MOU) related to misrepresentation, recruitment, payment of incentive compensation, and tuition assistance. This policy will provide efforts to eliminate unfair, deceptive, and abusive marketing aimed at Service Members. Its purpose is to also strengthen compliance with both Department of Education and Department of Defense policies and requirements regarding withdrawals and Readmission requirements for Service Members.
The University of Louisville (University) is committed to protecting the best interests of all students, including students who are Service Members and complying with all applicable laws and regulations. The University has adopted the following rules to eliminate unfair, deceptive, and abusive marketing aimed at Service Members:
1) No one may offer an inducement, 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 to military students are permissible.
2) No one may provide 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.
3) No one may engage in high-pressure recruitment tactics for the purpose of securing Service Member enrollments. Such tactics include making multiple unsolicited contacts (three or more), including contacts by phone, email, or in-person, and engaging in same-day recruitment and registration.
4) No one may make, directly or indirectly, any substantial misrepresentation and/or misleading statements about the nature of the education program, the nature of any financial charges, the employability of graduates, or the relationship with the U.S. Department of Education.
To strengthen compliance with DoD tuition assistance program requirements, the University Military Initiatives Program will provide guidance to the University’s educational units/programs about the posting of tuition assistance information on the University’s website and the importance of periodically reviewing it for accuracy. The educational units/programs will also be informed of their responsibility to notify prospective students, who self-identify as Service Members eligible for tuition assistance, of the following DoD MOU requirement:
All tuition assistance for an eligible Service Member must be requested and approved prior to the start date of the course. This approval is required on a course-by-course basis and only for the specific course(s) and class dates that the Service Member requests. The Service Member may not be enrolled in the course until after the tuition assistance has been approved by the individual’s Educational Service Officer, military counselor, or service. The Service Member will be solely responsible for all tuition costs without this prior approval. This requirement does not prohibit an educational institution from pre-registering a Service Member in a course to secure a course slot.
The University’s Financial Aid Office will provide information and application processes for Title IV student aid programs, scholarships, fellowships, grants, loans, etc. to all students, including Service Members who are tuition assistance recipients.
To strengthen compliance with both Department of Education and DoD policies and requirements regarding withdrawals due to Uniformed Services obligations, the following rules apply:
1) To withdraw due to a Uniformed Services obligation a student must complete a “Military Duty Request to Withdraw” form, which can be found on the Office of Military and Veteran Student Services website.
2) When requesting the withdrawal students have three options, they can request; a) a complete withdraw, b) an incomplete in the course, or c) grade as is (depending on work completed in course).
3) Decisions about grading or incompletes are decisions made by the faculty based on the work you have completed to date and the rules governing the course.
4) There is a full 100% refund for classes from which the student withdraws and no adjustment for classes in which they remain enrolled, even if they are requesting a grade of incomplete in those classes.
As a rule, if a student is aware that they will be required to miss substantial portions of an academic semester due to Uniformed Services commitments, they should consider not registering for courses that academic term.
To strengthen compliance with both Department of Education and DoD Readmission requirements for Service Members, the University has established the following rules:
1) Member of, performs, has performed, applies to perform, or has an obligation to perform, service in the Uniformed Services based on that membership, application for membership, performance of service, application for service, or obligation to perform service.
2) The University will readmit a student as described in paragraph 1) of this section with the same academic status as the student had when the student last attended the University or was last admitted to the University. The student must be readmitted into the next class or classes in the student’s program beginning after the student provides notice of intent to reenroll, unless the student requests a later date of Readmission or there are unusual circumstances that require the student to be readmitted at a later date. “Same academic status” means the University will readmit the student:
- To the same program to which the student was last admitted by the University or, if that exact program is no longer offered, the program that is most similar, unless the student requests or agrees to admission to a different program;
- At the same enrollment status that the student last held at the University, unless the student requests or agrees to admission at a different enrollment status;
- With the same number of credit hours or clock hours completed previously by the student, unless the student is readmitted to a different program to which the completed credit hours or clock hours are not transferable;
- With the same academic standing (e.g., with the same satisfactory academic progress status) the student previously had; and
If the student is readmitted to the University in the same program, for the first academic year in which the student returns, the University will assess the tuition and fees that the student was or would have been charged for the academic year during which the student left the University or the University will assess up to the amount of tuition and fees that other students in the program are charged for that academic year, unless veterans' education benefits or other Service Member education benefits will pay the amount in excess of the tuition and fees charged for the academic year in which the student left the University.
If the student is admitted to a different program, and for subsequent academic years for a student admitted to the same program, the University will assess no more than the tuition and fees charged to other students in the program for that academic year.
3) If the University determines that the student is not prepared to resume the program with the same academic status at the point where the student left off or the student is unable to complete the program, the University will make reasonable efforts at no extra cost to the student to help the student become prepared or to enable the student to complete the program including, but not limited to, providing refresher courses and allowing the student to retake a pretest at no extra cost to the student. The University is not required to readmit the student if the University determines there are no reasonable efforts the University can take to prepare the student to resume the program at the point where he or she left off or to enable the student to complete the program. “Reasonable efforts” means actions that do not place an undue hardship on the institution. “Undue hardship” means an action requiring significant difficulty or expense when considering the overall financial resources of the institution and the impact otherwise of such action on the operation of the institution.
4) The University will deem any student whose absence from the University is required by reason of service in the Uniformed Services as eligible for Readmission to the University as long as:
- The student gives advance oral or written notice (it does not need to indicate whether the student intends to return to the University) to the University’s Office of the Registrar and/or the Office of Military and Veteran Student Services as far in advance as possible under the circumstances, unless precluded by Military necessity;
- The cumulative length of all absences from the University for service in the Uniformed Services (only the time the student spends performing services) does not exceed five years; and
- The student gives oral or written notice of intent to return to the University’s Office of the Registrar and/or the Office of Military and Veteran Student Services no later than three years after the completion of the period of service. If the student is hospitalized for or recovering from an illness from an injury incurred in or aggravated during the performance of service in the Uniformed Services, the student has up to two years after the end of the period that is necessary for recovery from such illness or injury to provide the notice of intent to return.
Any student who did not give advance written or oral notice of service in accordance with paragraph 4a) of this section may meet the notice requirement by submitting, at the time the student seeks Readmission, an attestation to the Office of the Registrar and/or the Office of Military and Veteran Student Services that the student performed service in the Uniformed Services that necessitated the student's absence from the University.
5) A student’s failure to apply for Readmission within the periods described per this policy will not automatically forfeit their eligibility for Readmission to the University, but their Readmission eligibility will be subject to the University’s established leave of absence policies and general practices.
6) The student seeking Readmission must provide to the Office of the Registrar and/or the Office of Military and Veteran Student Services documentation to establish that the student has not exceeded the service limitation and the student’s eligibility for Readmission has not been terminated due to an exception. Documents that satisfy this requirement include, but are not limited to, the following:
- DoD 214 Certificate of Release or Discharge from Active Duty.
- Copy of duty orders prepared by the facility where the orders were fulfilled carrying an endorsement indicating completion of the described service.
- Letter from the commanding officer or someone of comparable authority.
- Certificate of completion from military training school.
- Discharge certificate showing character of service.
- Copy of extracts from payroll documents showing periods of service.
- Letter from National Disaster Medical System (NDMS) Team Leader or Administrative Officer verifying dates and times of NDMS training or Federal activation.
Documents that are necessary to establish eligibility for Readmission will vary from case to case. All documents may not be available or necessary in every instance. The University will not delay or attempt to avoid a Readmission of a student by demanding documentation that does not exist, or is not readily available, at the time of Readmission.
Termination of Readmission Eligibility
A student's eligibility for Readmission to the University under this policy will terminate upon the occurrence of any of the following events:
- A separation of such person from the Armed Forces (including the National Guard and Reserves) with a dishonorable or bad conduct discharge.
- A dismissal of a commissioned officer permitted under section 1161(a) of title 10, United States Code by sentence of a general court-martial; in commutation of a sentence of a general court-martial; or, in time of war, by order of the President.
- A dropping of a commissioned officer from the rolls pursuant to section 1161(b) of title 10, United States Code due to absence without authority for at least three months; separation by reason of a sentence to confinement adjudged by a court-martial; or a sentence to confinement in a Federal or State penitentiary or correctional institution.
All university departments, educational units/programs, and employees are expected to comply with this policy. Failure to comply with the policy could result in disciplinary action of employees, suspension of educational programs/ courses, and/or the DoD terminating the voluntary education partnership MOU agreement with the University.
Individuals should report known or suspected violations of this policy to the Director of the Military Initiatives Program, the University Integrity and Compliance office at firstname.lastname@example.org, or to the University’s Compliance and Ethics Hotline, which allows for anonymous reporting.
Military Necessity – includes a mission, operation, exercise, or requirement that is classified; or a pending or ongoing mission, operation, exercise, or requirement that may be compromised or otherwise adversely affected by the public knowledge.
Readmission – for purposes of this policy Readmission applies to a UofL student who is a member of Uniformed Services and has withdrawn from a program due to Uniformed Services obligations and is applying to be readmitted to the University.
Service Member – a member of Uniformed Services, consisting of the armed forces (Army, Navy, Air Force, Marine Corps, Space Force, and Coast Guard), the Commissioned Corps of the National Oceanic and Atmospheric Administration (NOAA), and the Commissioned Corps of the Public Health Services.
Uniformed Services – service, whether voluntary or involuntary, in the Armed Forces, including service by a member of the National Guard or Reserve, on active duty, active duty for training, or full-time National Guard duty under the Federal authority, for a period of more than 30 consecutive days under a call or order to active duty of more than 30 consecutive days.
The Director of the Military Initiatives Program is responsible for oversight and interpretation of this policy.
Departments, educational units/programs, employees, and others acting on behalf of the University are responsible for complying with this policy.
Departments and educational units/programs are responsible for informing their employees or others acting on behalf of their department or educational unit/program about this policy.
Executive Vice President and University Provost
RESPONSIBLE UNIVERSITY DEPARTMENT/DIVISION
Military Initiatives Program
University of Louisville
This policy was approved by the President’s Leadership Team on February 8, 2022.
The University Policy and Procedure Library is updated regularly. In order to ensure a printed copy of this document is current, please access it online at http://louisville.edu/policies.