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    June 2019

    How Institutions Can Respond to “Operation Varsity Blues”

    In March 2019, the FBI revealed an investigation into a college admissions scheme whereby parents paid to have SAT scores altered or falsified athletics credentials to gain their child’s admission to elite universities. Nearly 50 arrests were announced, including the alleged “ringleader,” a private admissions counselor who created the scheme, handled the test altering, and bribed athletics coaches and administrators. Parents have pleaded guilty, and the FBI has indicated that more arrests and charges will be forthcoming.

    This scandal is expected to have long-term impacts on education institutions and their admissions practices. To ensure your college is taking measures to prevent similar fraud, consider the following actions.

    Admissions Practices

    Conduct a comprehensive audit of your college or university’s admissions process:

    • Review the entire process from beginning to end; pay close attention to document security (to be sure nothing can be altered) and decision-making. Consider hiring an outside firm or consultant to test for vulnerabilities.
    • Scrutinize admissions decision-points and consider who has influence over individual decisions; consider requiring the agreement of more than one decisionmaker at these crucial points.
    • Identify situations or activities—beyond athletics—that receive special admissions considerations, such as an orchestra or theater program. Consider how decisions are made and reviewed by the admissions department and senior administrators. Take steps to ensure a powerful coach or staff member doesn’t wield unchecked influence over the admissions process. Evaluate whether special considerations should continue or how controls can be strengthened.
    • Review whether your application requires a separate attestation—beyond that required by the Common App—regarding the truthfulness of the application and supporting materials. Specifically reserve the right to rescind admission if you find that an applicant submitted false or fraudulent materials. (Also, determine whether your student discipline policy allows you to discipline a student who lied during the admissions process but has since matriculated.) If you later discover that some admissions material was falsified, the attestation and disciplinary policy may provide the ability to rescind an admission or discipline a student. Schools involved in the scandal have dismissed students who participated.
    • Follow a process when seeking to rescind admission or dismiss any student you determine participated in a fraudulent admissions scheme. Dismissed students are suing institutions seeking to take disciplinary action.

    Athletics Recruiting

    Because of the scheme’s focus on fraudulent athletic recruiting, conduct a separate review of athletics department recruiting processes. Coaches are often granted significant latitude in recruiting student athletes; consider adding safeguards such as:

    • Requiring that more than one decisionmaker vet and approve recruits to determine if they meet team needs and playing level. Also, the decisionmaker should include someone who is not a head coach or an assistant coach of that team.
    • Conducting a comprehensive review of athletic department compliance policies and following up to address any deficiencies. Demonstrating that you take all aspects of compliance seriously will discourage employees from attempting to skirt your system.
    • Reviewing department personnel to identify vulnerable or disgruntled employees. Some of the coaches implicated in the admissions scandal received significant monetary bribes. Those coaches or other personnel who are lower-paid or unhappy in their positions may be more vulnerable to exploitation.
    • Identify instances of athletic recruits not practicing with or competing on the teams for which they were recruited. While that fact itself is not unusual, a comprehensive review may reveal troubling patterns that should be investigated.

    Employee Policies

    Review personnel handbooks and policies, paying close attention to codes of ethics and prohibitions against illegal or fraudulent behavior. Also review your protections for whistleblowing.

    • Consider strengthening or directly addressing fraud.
    • Review and revise, if necessary, policy language on employees accepting gifts or donations.
    • Consider your mechanism for fielding anonymous complaints or concerns.  Some employees may be reluctant to come forward about wrongdoing by powerful coaches or other figures.
    • Be sure your institution has qualified investigators at the ready if you receive reports of admissions or other recruiting irregularities.

    Crisis Communications

    Because the FBI investigation is ongoing and more parents, students, and institutions may be implicated, create a plan for responding if your institution is named in the corruption scheme.

    • Review your crisis communications plan; specifically, consider how your institution will communicate the actions it has taken to address admissions process vulnerabilities.
    • Consider how your institution would respond to reports that admitted or current students (or their parents) participated in the scheme. While privacy law will limit what you can say about individuals, be prepared to field questions about how the school intends to address allegations of wrongdoing.


    Regardless of whether you make changes to policies or procedures, conduct training for the admissions department, advancement, athletics, and other constituencies that may exert special pressure on your admissions process. The training should cover your admissions process and policies as well as employee ethics and behavior policies and expected practices.

    • Set the tone from the top—open your training with a message from your President that clearly sets expectations: (1) the admissions process will be conducted with integrity, (2) improper, unethical, or illegal behavior will not be tolerated; and (3) employees will be disciplined appropriately for policy violations.
    • Provide training on:
      • The institution’s admissions policies
      • Relevant athletics policies, or policies on recruiting other “special category” students
      • Employee rules, ethics requirements, and expected behavior
      • How to report concerns or suspected policy violations

    Other Consequences

    In response to this scandal, changes to the admissions process may be coming. The NCAA has announced plans to investigate the recruiting practices of the schools named in the charges. Legislation has been proposed in California to mandate changes to the admissions process of public institutions and private institutions that receive state grant funds. Finally, both the U.S. Congress and the U.S. Department of Education have announced they are investigating schools named in the charging documents to see if any oversight laws may have been broken. Schools should be prepared for fallout to continue and take steps now to strengthen their admissions process.


    Improving Athletics Compliance in Higher Education

    The Media is Outside. What Now?

    Crisis Communications: Avoid These Mistakes

    Beware Retaliation Against Whistle-Blowers

    Turning the Tide II: Harvard Graduate School of Education Report on Admissions

    By Heather A. Salko, senior risk management counsel


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