Note: This article was updated 9/23/2020.
Dear Mr. Ethics,
Is it ok to accept a ride on a party bus sponsored by EducationRama Technology, our computer software provider? I know we have to be careful about relationships with lenders, but this vendor doesn't sell anything to our students, and my boss is ok with it. Plus, this bus sounds like a ton of fun—they even have a margarita machine!
Ready To Ride
NASFAA's Code of Conduct states "No amount of cash, gift, or benefit in excess of a de minimis amount shall be accepted by a financial aid staff member from any financial aid applicant (or his/her family), or from any entity doing business with or seeking to do business with the institution." "De minimis" refers to a level of risk that is too small to be concerned with—NASFAA has defined this as no more than $20 (roughly the value of a moderate quality t-shirt) and $60 for any meal events/receptions. You'll note that the Code specifies vendors that are doing business with the school itself—not just with your students. So I do think you need to watch your step. You probably would not give preference to this vendor, but conflict of interest is all about perception and disclosure. You also should imagine how your actions would appear if they were made public, either through your own disclosure or if the press discloses it. Could your actions —both on the party bus and afterward--be construed as demonstrating favoritism? Unlike a lunch, where it's easy to go "dutch," separating out your expenses on a party bus would be much more difficult, if not impossible. My advice is to keep your reputation above reproach and avoid the party bus altogether!
Mr. Ethics has touched on this topic before.
Publication Date: 4/13/2015