Compliant Website Checklist
Institutions are under strict scrutiny surrounding their online advertising efforts. But, it’s also imperative for the institution’s website to be in compliance with the standards and regulations set forth by the Department of Education (DOE), Federal Trade Commission (FTC), Federal Communications Commission (FCC), your accrediting body and industry standards. Below is a checklist of points to consider when reviewing the information provided on your website.
Compliant Website Checklist:
Accreditation
- Visibility of accreditation statement
- Representation of accreditation – full and complete accreditation information – acronyms and banned terms omitted
- Easily navigable – at least within one click of the homepage
Admissions
- Provide all required criteria expected to be completed prior to enrollment
- Include all educational requirements
- Contact information provided for prospective students
Career Services
- Detailed and clear explanation of offerings that the Career Services department provides
- No job placement guarantees
- Omission of banned terms, such as “career placement”
Gainful Employment Disclosures
- Clear presence of disclosure information
- Disclosure information is in the required Gainful Employment Disclosure Template developed by the DOE
Financial Aid
- Qualification rules
- How applicants can learn about qualifying
- Financial aid eligibility disclaimer present
Program Descriptions
- Timeframe for completion listed correctly
- Program length disclaimer
Program Listings
- Listings are accurate and approved by the DOE
- Acceptable states for admissions
- Citations provided for statistics listed on the page
TCPA Requirements
- Consent language present on lead form
- Language must include all components within the FCC definition
Testimonials
- Must be actual statements
- Some accreditors do not allow institutions to use testimonials from current students on their website
Stay tuned for our next webinar where we’ll cover this topic in more depth! Get early access to webinar information. (opens in a new window)
Avoiding TSR Violations
Since it’s onset in 1995, the Federal Trade Commission (FTC) has amended the Telemarketing Sales Rule (TSR) (opens in a new window) several times in order to respond to developments in telemarketing schemes. The amendments allow for liability for third parties. For example, education lead generators that have provided “substantial assistance or support” to any seller while knowing, or consciously avoiding knowing, that the seller or telemarketer is engaged in activity in violation of the TSR.
What do these amendments mean for lead educators and for-profit schools?
- The TSR covers calls made with multiple purposes, if one of the purposes is the sale of goods or services. So, companies who use robocalls to sell goods or services risk violating the TSR.
- Liability is broad under the TSR. Liability is not limited to the company that made the calls. It’s also illegal to “provide substantial assistance or support” to a seller or telemarketer when you know or consciously avoid knowing they’re violating the Rule. The TSR makes it clear that “but I wasn’t the one doing the dialing” isn’t a defense.
- The states and feds are united in the fight against illegal telemarketing. The FTC, Department of Justice, and State Attorney Generals remain committed to working together to protect consumers from illegal telemarketing.
How can you avoid a violation?
- Make sure the prospective inquiry gives the educational lead generator company express written permission to call, even if their telephone number is on the national Do Not Call Registry.
- The educational lead generator or school will not require any purchase of goods or services in order to obtain student consent.
- Written consent must include the student’s telephone number and signature.
- The student will receive phone calls as a result of submitting the Request for Information (RFI) form on the educational lead generator’s website (or other collateral) and checking the box that gives express permission.
Addressing the Use of Endorsements and Testimonials for Your Institution
One of the prominent marketing uses in the education industry today is the use of testimonials to endorse a school. The power of a testimonial shows that success at a particular school not only can happen, but that it has happened. Using case studies to show the effectiveness of an institution’s training program certainly speaks volumes to individuals considering the lengthy commitment of returning to school.
Testimonials can go so far as to endorse a school that they can easily be used to mislead and entice individuals with exaggerated or false claims. Due to excessive use of testimonials the FTC has written guidelines on the dos and don’ts to shape education marketing compliance. Here is a list of guidelines to comply with when using testimonials in marketing materials:
- If a testimonial endorses a service and the result for that endorser was not a typical result, the advertiser must disclose the expected results of that service
- Any transaction that is made between an advertiser and the endorser must be disclosed in the advertisement
- Endorsers not representing “actual customers” must be adjoined with a disclaimer stating the testimonial is not from an actual customer
- Testimonials have timetables. If an endorser provided a testimonial at a time when they were an actual user, the testimonial must still reflect a “current” opinion of that endorser
- Wording cannot be distorted to endorse an advertiser
Testimonials are important as they serve as a connecting point between a successful user and a potential user. Staying in compliance for use of testimonials is just as important and can be followed given thoughtful consideration.
Student Data Tells a Story
…and it’s one that we need to listen to.
To the extent that you can understand and connect with students and prospective students, you will see engagement and enrollment go up.
The proprietary EDU industry is getting ever more competitive and in the end, the brands that learn to listen, respond, track and report student data in an efficient, meaningful way will come out on top. So what does it look like to listen, respond, track and report on your students?
Listen.
Students are voting with their feet and with their money all the time. domain names The best way to get more votes is to know demographic information as it relates to enrollment.
Respond.
Going beyond just knowing demographic information, it takes a savvy school to draw out analysis and application from that information. Your programs may need to change. Your facility may need to change. Your voicing may need to change. How will you know if you don’t have a firm grasp on the pulse of student information?
Track.
Tracking the status of your students in an efficient manner is an operational necessity. Regulations surrounding gainful employment make it ever more imperative that your system meets the Big Data needs of your student information.
Report.
Having a centralized Student Information System gives you the security of knowing you are prepared for accrediting body visits. This kind of system simplifies your workflow and gives you and your staff your time back.
A Rise in the Trade Industry
In America, unemployment is twice as high for those with high school diplomas versus a 4 year college graduate. However, that doesn’t mean high school graduates need to spend the time or money on a 4-year school.
Millions of trade industry jobs are open and ready for those with specific job skills training, some even paying more than the average 4 year college graduate’s starting salary. Those from the baby boom era are coming close to retirement and more of these trade jobs will be available for millennials. There are around 600,000 electrician positions today and half of these will become available within 10 years. Baby boomers will be retiring from trades and America will need more young people trained to take over these positions. However, not enough young people will have the opportunity to gain the proper training due to the removal of vocational programs in high schools.
Thankfully, the private-sector colleges and universities are available to make up for the lack of encouragement high school students are receiving. Private-sector schools are a necessity to educate those in the trades industry since the skills that students learn are job specific and are usually taught by individuals that have worked in the field.
Private-sector schools have strengths over the typical 4-year state school. The faculty members are dedicated to watching their students succeed, often taking extra measures such as tutoring and one-on-one learning. Private-sector schools are focused on helping place graduates in jobs specific to the training they received. Small class sizes and hands-on learning are additional benefits to a student’s experience.
For millennials looking for an alternative to the expense and time of a 4-year state school, take a look into the trades industry. There are many opportunities to gain the job specific training needed and succeed in a fast paced industry.
For more information on the economic impact of trade jobs visit the Association of Private Sector Colleges and Universities’ Knowledge Center.
A Note from the President
Happy New Year! Looking back, 2014 was an exciting year for IntegriShield. We more than doubled our client base, grew our team significantly, expanded our software services and developed some fantastic new products for our clients. Relationships were strengthened as we continued to listen to our clients and understand the political and regulatory climate in which they operate. As with anything, we must look back to find our lessons, take note, and MOVE FORWARD!
Access to Results-Driven Experts
We have an exceptional team of professionals that work for IntegriShield—each is dedicated to the client’s needs and finds a solution to every problem. That is true professionalism and I am very grateful for the group that continues that make this a successful company. Many of them have been with the company since its inception, and the new faces have helped drive us harder into 2015. We have a culture in our company that lets the individual choose and create his or her career path. If you can think it, you can achieve it!
Setting Goals with Integrity and Innovation
Our success thrives on producing results for clients and we are on pace for 60% growth across the board. While these 2015 goals are aggressive, I remain confident that we will hit them. We can do this in the following ways:
- Put the client first.
We build solutions for our clients. If we continue to put them first and listen to different needs of each client, both parties will be destined for success.
- Continue to learn.
IntegriShield is also a consulting company providing insight for clients and others in the industry. We find opportunities to collaborate with thought leaders to enrich in the industries we serve. Visit our Webinars (opens in a new window) page to find out more!
- Go above and beyond.
Anyone can do just enough to get by, but IntegriShield has always been driven to do more. Work harder. Put in that extra hour. Do more research. Build one more product. We do not compete—we win.
IntegriShield has all of the tools necessary to put us over the top, which is an experience we are pleased to share with our clients. After careful preparation, the company is ready to absorb rapid growth. The processes are in place and the right staff dedicated to driving success is ready. I’m excited for 2015 and honored to be on board with them.
All The Best,
Jennifer Flood
IntegriShield to Host Fraudulent Lead Generation Webinar
Over the last couple of weeks, articles have surfaced shedding light on lead generating practices that are less than exemplary. Many in the for-profit sector are concerned and unsure how to move forward. With the recent scrutiny of the industry, it is important to make sure that you are doing your best to protect your organization. IntegriShield can offer helpful tips and information to keep your organization safe.
Watch for our webinar regarding fraudulent lead generation and how you can protect your organization coming in January.
Takeaways from DOE’s Gainful Employment Ruling
October 30th marked the release of the final version of The Education Department’s “Gainful Employment” rule. The long awaited ruling has been a topic of much discussion and is still being contested by the Association of Private Sector College and Universities (APSCU).
While the debate ensues, here are some takeaways from the ruling:
1. Career programs are no longer accountable for their cohort default rates. The cohort default rate represents the percentage of borrowers defaulting on their student loans.
2. Instead, career programs will be weighed only for their graduates’ debt-to-earnings ratios. The debt-to-earnings ratio measures the ability of a borrower to manage payments and repay debts based on their income.
3. The Education Department expects nearly 1,400 programs to fail the rule in the first year. Programs that fail the test on multiple reviews will not be able to award federal aid to students.
The For-Profit college sector has already taken action against the Education Department. APSCU officially filed suit against the Department’s Gainful Employment ruling last week. The suit asks that the United States District Court declare the regulation unlawful and set aside the regulation.
A briefing schedule is expected to be set in the next few months.
VAWA Reauthorization: What it means for your school.
With the recent requirement changes imposed by the Violence Against Women Reauthorization Act (VAWA), your school may need to revisit your policies for reporting crimes on campus.
VAWA has imposed these changes under its Campus Sexual Violence Act making it mandatory for colleges and universities to report on domestic violence, dating violence and stalking. Other requirements include adopting certain student discipline procedures and policies to address and prevent campus sexual violence.
Although reporting on such events may be embarrassing, honesty is always the best policy when it comes to these issues. Hiding incidents will only hurt your school in the long run. Having a solid message on the web side-by-side your reports allows student to feel secure knowing that you’re doing your best to keep them safe.
Not only will your students, current and prospective, feel secure; you will as well knowing that your school is compliant with these regulations.
Inspect What You Expect—Monitoring Your Admissions Staff
Your admissions staff is the face and voice of your institution, the first people to speak with your prospective students and inform them about the excellent opportunities that your school offers. What training and initiatives are you taking to ensure that they are making every effort to bring more students in the door? How are they answering questions surrounding compliance-related topics that have gotten so many schools into trouble?
Monitoring your staff can lead to a significant increase in conversion rates and shield your institution from potential fines and penalties. Some areas to monitor may include:
- Scripts: Providing scripts for your representatives to follow enables them to touch on key benefits of your institution and direct the conversation toward enrollment.
- Setting Follow-up Appointments: With each individual communication, a representative should be scheduling the next step with the prospective student whether it be a follow-up phone call or inviting them in for a campus visit.
- Citing Statistics and Job Placement: When a prospect inquires about job placement or expected salaries, statistics provided must be accompanied by an official source such as the Bureau of Labor Statistics. Employment can never be promised.
- Credit Transferability: Credits will never transfer 100 percent of the time, and it is essential to clearly state that credits are subject to review by the school and cannot be guaranteed.
- Financial Aid: Not every student will qualify for financial aid, and it is important to provide this clarification and transfer prospective students to a financial aid representative to receive further information.
Monitoring your admissions team to pinpoint areas in need of improvement is essential to overall business productivity. Not only are you able to protect your institution from the price of noncompliance and making false guarantees, you are also helping increase enrollment numbers and therefore directly amplifying your institution’s revenue.
To learn more about analyzing and improving the performance of your admissions staff, contact our Sales Team at sales@integrishield.com or call (816) 994-1313 today.