“Things You Can No Longer Say or Write After July 1st” affecting US Title IV schools.
An audio recording and notes as presented from our Conference Call Presented by Shane Sparks and Gregg Meiklejohn of Enrollment Resources Inc.
- Avoid using the BLS stats on national averages, if it does not accurately reflect local employment. Recommended to use local stats that are documented and avoid BLS generalized employment references
- Avoid salary claims – don’t make them unless you can prove it from graduate stats
- Avoid generalized placement statistics that are not accurate – whether it’s student, accreditor or government
- No Help Wanted advertising whatsoever – avoid posting ads in the help wanted section of classifieds and on “job postings” for sites such as craigslist, kijiji. Need to check to see if your lead providers and affiliates are doing this.
- Relationship to employers promoted to suggest connections IMPLY better job opportunities
- “Lifetime placement” – don’t make this claim in case the program may not be available in the future or for any other reason that you may not be able to stand behind this claim.
- What you don’t say can hurt you – preconditions of employment being one of them (criminal record requirements, existing medical conditions etc – policy needs to be in place pre-enrollment)
- Implied strong employment outcomes – claims needs to be based on documented outcomes
- Avoid terms such as “in Demand”, “Fastest growing career”, “high job placement”, “good jobs”, “high salary” and the like unless these are accurate and documented locally.
- You’ll want to keep the tone to “financial aid for those who qualify”. Not promote your department as having an advantage in the application process. Keep things factual.
- Scholarships – need to be true (discounts are not representative of scholarships)
- Misinforming students right to refuse financial aid
- Avoid terms such as “state of the art”, “modern”, “cutting edge” if this is not 100% representative of your school
- Small class sizes – needs to be 100% true
- Can not state approval or endorsement by the Department of Education to the quality of the education programs. It’s suggested that you apply this to your accrediting agencies as well if they are stated on any promotional material.
- Avoid terms such as Start a Career in XXX in as little as …. – this would be a false claim as it’s likely not 100% true in all cases
- Do not claim program length without noting which study type it is (part time/ full time)
- Certified – avoid general claims to certification. If you mention certification, you must disclose the certification body and whether that particular certification will meet any preconditions of employment.
- Can not state any employment opportunities without disclosing if further training or certification is required and if your program meets the requirements for preparing for certification. Must disclose whether the program meets all employment requirements.
- Suggest credit transfers without disclosing any limitations
- Misleading statements about faculty expertise or experience
Overall: What you don’t say may hurt you – don’t leave out any details that could be misinterpreted or misleading. Base everything on fact.
- You need to monitor what others are saying about you as well as “indirect” statements about your school that are not factual will be a problem.
- Affiliates come to mind – need to monitor the conversion about your school on the web and protect your reputation. You may need to draft a cease and desist order to distribute if needed to cover your bases.
You can not use phrases like “lifetime Career Assistance” – or “grads can always take refresher courses” – no one can reasonably guarantee that their school will always be around or that they will always be involved in the same course offerings.
If you use Job Outlook statistics, make sure they are regional. National statistics could be a form of misrepresentation because those stats are not necessarily representative of the kind of job prospects graduates will have in your town. Any job stat should be genuinely representative of the community the grad will be entering into.
The DOE is asking for disclosure about things that might inhibit a grad from securing employment, for example, if a criminal record would make them unemployable in a given field. However the actual regulation says something about disclosing whether or a not a disability would make someone ineligible and the lawyer on the last webinar stated that saying something like a person with a disability would be unable to enroll in your school would open you up to way more problems than with the DOE – so this is one on which to tread lightly.
Scholarships must be scholarships. Meaning scholarships must be funding with criteria which students apply for. You can not use the word “scholarship” when you mean “discount”. For example, you can’t have a “$500 scholarship for those who enroll by May 1st.”
Be very careful about overstating the age and quality of training devises – schools should avoid phrases like “state of the art” unless being absolutely cutting edge is really their selling point. For example, if your computer labs use Windows 2007, you shouldn’t say things like “modern” cutting edge equipment.
A good thing to start thinking about is keeping records of the performance of your graduates because really, if you can’t prove something with your own grads – employment rate etc. – you probably can’t use it in promotional material.
Schools may need to start being transparent about whether or not their credits are transferable. For example, credits from a school that is “Nationally Accredited” rarely transfer to a “regionally accredited” school.