Policies/EducateONE Organizational Policy § 2.9.00. Student Assistance Policy

Article I. EducateONE Organizational Policies

EducateONE Organizational Policy § 2.9.00. Student Assistance Policy.

(a) Purpose.

(1) In order to advance equal opportunity, individual merit, educational excellence, lawful standards, student access, and the charitable educational purposes of EducateONE, this policy authorizes EducateONE to provide student assistance in any lawful form that EducateONE determines, in its discretion, supports educational access, participation, achievement, readiness, continuity, safety, family responsibility, or other mission-related purposes.

(2) Student assistance shall be administered according to applicable law and the principle that persons should be considered as individuals, based on lawful and mission-consistent considerations.

(3) Student assistance shall not be administered through unlawful discrimination, racial preference, identity-based entitlement, private inurement, impermissible private benefit, donor earmarking for specific individuals, conflicted control, or any other practice that would jeopardize EducateONE’s charitable, educational, or tax-exempt purposes.

(4) Nothing in this policy shall be interpreted to require EducateONE to use any single method, formula, category, priority, procedure, or selection model for student assistance unless such method, formula, category, priority, procedure, or selection model is required by applicable law, binding grant terms, donor restriction, contract, accreditation requirement, or separate EducateONE policy.

(b) Scope.

(1) This policy applies to student assistance provided by EducateONE, SchoolONE, PreschoolONE, UniversityONE, and any other controlled EducateONE institution, school, program, service, activity, or operation.

(2) For purposes of this policy, “student assistance” means any lawful assistance, support, benefit, aid, payment, waiver, reduction, service, item, or other thing of value provided to or for the benefit of a student, applicant, prospective student, enrolled learner, program participant, family, guardian, or other person within a charitable, educational, or mission-related class served by EducateONE.

(c) Discretion Preserved.

(1) EducateONE may provide student assistance when EducateONE determines, in its discretion, that the assistance advances EducateONE’s charitable, educational, student-support, access, participation, continuity, or mission-related purposes.

(2) EducateONE may consider any lawful and mission-consistent basis for student assistance.

(3) EducateONE is not required to use the same basis, process, amount, condition, duration, priority, or form of assistance for every student, program, institution, funding source, or circumstance.

(4) EducateONE may approve individualized assistance when doing so is lawful, mission-consistent, and not prohibited by this policy.

(d) Charitable and Educational Class.

(1) Student assistance shall be administered for the benefit of a charitable, educational, or mission-related class served by EducateONE.

(2) EducateONE shall not establish or administer student assistance merely to benefit one or more pre-selected individuals for noncharitable private purposes.

(3) Nothing in this policy prohibits EducateONE from providing assistance to a specific individual when EducateONE determines that the assistance furthers EducateONE’s charitable, educational, student-support, access, participation, continuity, or mission-related purposes and is not otherwise prohibited by this policy.

(e) Prohibited Practices.

(1) EducateONE shall not provide, approve, administer, or continue student assistance in a manner that:

(A) results in private inurement;

(B) creates impermissible private benefit;

(C) creates an excess benefit transaction;

(D) is controlled by a donor for the benefit of a specific individual selected by the donor;

(E) is controlled by a conflicted person for the direct or indirect private benefit of that person or a related person;

(F) is administered through unlawful discrimination, unlawful racial preference, unlawful quota, unlawful racial balancing, identity-based entitlement, or other unlawful preference;

(G) is unrelated to EducateONE’s charitable, educational, student-support, access, participation, continuity, or mission-related purposes;

(H) is used as disguised compensation, a rebate, a kickback, a refund, an improper inducement, or an improper private benefit; or

(I) otherwise jeopardizes EducateONE’s charitable, educational, or tax-exempt purposes.

(f) Donor Control.

(1) EducateONE may accept donor-restricted contributions for student assistance when the restriction is lawful, charitable, educational, mission-consistent, and consistent with this policy.

(2) EducateONE shall retain discretion and control over student assistance funds.

(3) EducateONE shall not accept or administer a contribution that requires student assistance to be provided to a specific individual selected by the donor.

(4) A donor recommendation regarding a potential recipient is nonbinding and shall not be treated as a condition of the donor’s contribution.

(g) Conflicts of Interest.

(1) Student assistance decisions shall be administered consistently with EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy.

(2) A person with a conflict of interest shall not control or approve student assistance that would provide a direct or indirect private benefit to that person or a related person.

(3) The existence of a relationship between a potential recipient and a director, officer, employee, donor, contractor, volunteer, or other person connected to EducateONE does not automatically prohibit assistance if the conflict is disclosed, the conflicted person does not control or approve the assistance, and the assistance is otherwise lawful and consistent with this policy.

(h) No Entitlement Created.

(1) This policy does not create any right or entitlement to student assistance.

(2) EducateONE retains discretion to approve, deny, modify, reduce, suspend, discontinue, renew, condition, or decline student assistance, unless otherwise required by applicable law, binding grant terms, contract, donor restriction, or separate EducateONE policy.

(3) Prior approval of student assistance does not create a right to future assistance.

(i) Records.

(1) EducateONE shall maintain records reasonably sufficient to document that student assistance was approved for a lawful charitable, educational, student-support, access, participation, continuity, or mission-related purpose.

(2) Records shall be maintained in accordance with EducateONE’s records-retention practices and any applicable law, grant term, contract term, donor restriction, accreditation requirement, or program requirement.

(j) Relationship to Other Requirements.

(1) This policy supplements and does not replace any applicable law, grant requirement, contract requirement, donor restriction, accreditation requirement, program rule, financial-control policy, conflict-of-interest policy, nondiscrimination policy, school policy, or institution-specific policy.

(2) If another binding requirement imposes stricter requirements on a specific student assistance fund, program, award, recipient, school, institution, or activity, EducateONE shall comply with the stricter requirement for that specific fund, program, award, recipient, school, institution, or activity.

(k) Interpretation.

(1) This policy shall be interpreted broadly to preserve EducateONE’s ability to provide lawful, innovative, mission-consistent student assistance while maintaining compliance with applicable charitable, educational, tax-exempt, nondiscrimination, private-benefit, conflict-of-interest, donor-restriction, and recordkeeping requirements.

(2) Nothing in this policy shall be interpreted to prohibit EducateONE from providing assistance that is lawful, charitable, educational, mission-consistent, and not otherwise prohibited by this policy.

(3) If any provision of this policy is determined to be inconsistent with applicable law, the provision shall be interpreted or limited to the extent necessary to comply with law while preserving the maximum lawful discretion of EducateONE.

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Source Note

This policy was developed for EducateONE to establish broad authority and legal guardrails for student assistance while preserving institutional flexibility. The structure, numbering, source-note placement, and drafting approach follow EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide. The purpose language is adapted from EducateONE Organizational Policy § 2.8.00. Non-Discrimination Policy. The conflict provisions are aligned with EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy. This policy is also informed by IRS Form 1023 Schedule H guidance concerning scholarships, fellowships, educational loans, and other educational grants to individuals; IRS guidance concerning individual grants and private benefit; federal civil-rights principles concerning merit, equal opportunity, and unlawful discrimination; and federal education guidance concerning racial preferences in scholarships and other educational programs.

References

Internal Revenue Code section 501(c)(3).

Internal Revenue Code section 4958.

Internal Revenue Code section 4945(g).

Treasury Regulation section 53.4945-4.

IRS Form 1023, Schedule H, Organizations Providing Scholarships, Fellowships, Educational Loans, or Other Educational Grants to Individuals and Private Foundations Requesting Advance Approval of Individual Grant Procedures.

IRS, IRC Section 4945(g) Individual Grants.

Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity.

Executive Order 14281, Restoring Equality of Opportunity and Meritocracy.

U.S. Department of Education, Dear Colleague Letter: Title VI of the Civil Rights Act in Light of Students for Fair Admissions v. Harvard, February 14, 2025.

EducateONE Organizational Policy § 2.8.00. Non-Discrimination Policy.

EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy.

EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide.