Gainful Employment Disclosure Template
In November 2013 the U.S. Department of Education announced their released of the Gainful Employment Disclosure Template. In their announcement, the Department of Education set forth a due date, January 31, 2014, in which institutions must use the output document to meet the currently effective GE program disclosure regulatory requirements. This new template only applies to Title IV eligible instructional programs (degree and non-degree). Since the due date has already come and gone, this disclosure template should already be in place. But if not, here are some helpful links and topics to get the information in the correct format as quickly as possible. First access the disclosure template application.
Be prepared to enter the following information for each program:
• The institution’s six-digit OPEID
• Six-digit CIP code for the GE Program
• The credential level of the GE Program
After the above information is entered, the institution will then complete the template with specific information about the GE program that is consistent with GE Electronic Announcement #25. Once the form is complete, the template application will generate a zip file containing the GE program’s disclosure page, which the institution will host on their own website.
Once the zip file has been created, institutions must prominently provide a direct link from the home page of the GE Program website to the program’s disclosure page that was generated by the disclosure template application. Any other mention of the GE Program (admissions, academic or general information) must also contain a direct link to either the program’s web home page or to the GE Program disclosure page generated by the application.
For further information visit the Quick Start Guide for GE Disclosure Template.
Have questions about the Gainful Employment Disclosure Template? Contact IntegriShield at support@integrishield.com or call us at 816.994.1313.
Financial Aid Fraud Rings: Is your school at risk?
In the higher education field, we all know that distance learning is the way of the future. Online learning has provided many people with the access to receive a quality education when, in the past, they have not had this opportunity. However, taking away the face-to-face aspect of education has allowed some individuals to abuse this opportunity. With the increase in the amount of people utilizing online learning, we also see a significant increase in the amount of financial aid fraud that is happening. Groups of people are starting financial aid fraud rings and making off with hundreds of thousands of dollars in Department of Education financial aid funds.
How do they do it?
These groups, which can consist of any number of individuals, submit multiple financial aid applications to schools. Typically, these schools are focused on online learning and have a low tuition cost. The individuals do the bare minimum in the courses they have elected to take to make sure they meet the participation requirements. Once they have received the excess of their financial aid funds, they disappear.
How can you detect this activity?
There are a couple different things you can look for:
- Multiple FAFSA applications submitted using the same IP address.
- Multiple FAFSA applications submitted using the same address, phone number, e-mail address etc.
- Multiple FAFSA applications submitted from the same area with similar household situations (i.e. single parent households with one or more children).
- Offenders typically pester the financial aid staff for information on when they will receive their funds. They can become aggressive and will threaten to report the person or the school to their congressman or the Department of Education.
How do you handle these situations?
- Delay the financial aid process for these individuals as much as possible. Select for verification or require participation in online orientations or other lengthy processes.
- If possible, set up a team of a few people from different departments to specifically identify and handle such cases.
- Delay the posting of financial aid funds on suspicious students.
- Report any suspicious activity to the Office of the Inspector General.
The Importance of Brand Management
In the internet era, the virtual marketplace has become the primary forum for brands to build equity and trust with their customers.
Brand management ensures that companies effectively communicate with their customers and build customer lifetime value (CLTV) through longer lasting relationships. Effective communication means sending a cohesive message to target customers and ensuring that external influences do not mislead the conversation. Customers, critics, competitors, and anonymous users are willing and able to publicize unauthorized, defamatory, and negative connotations of brands on third-party and social networking websites. The result is often commoditization of the product or service in the customer’s mind, and weakened CLTV.
A recent study by Fleishman-Hillard indicated in a survey sample that 89% of consumers use search engines as predestination to making purchasing decisions. Whether on a laptop, smartphone, or tablet, the study indicates that consumers have become more influenced by their search engine results than the opinions of relatives and friends.
It is imperative that companies utilize technology to manage their brands online, and gain a competitive advantage in their industry. Companies that are able to identify, remediate and report on violations of brand standards on search engines, social networking, and unaffiliated websites are better suited to improve customer equity, and manage their customer relationships effectively.
To learn more about IntegriShield’s online brand management services, call (816) 994-1313 or contact Jeremy Wassmer at jwassmer@integrishield.com today.
Understanding Bait and Switch Advertising in the EDU Sector
Knowing where and how your school appears is virtually a full-time job in and of itself in the vast community of online marketing. Whether or not your school contracts with a third-party vendor for the purpose of lead generation and online presence, the unauthorized use of your brand is a consistent problem.
Many schools are typically unaware of the extent of their brands’ presence on third-party websites and lead forms. Even institutions that do not buy leads still exist on the web and lead forms are readily available when paired with certain key terms. Unauthorized use of your school name allows room for the possibility of bait and switch techniques.
You might ask yourself:
- We don’t work with this website, so how heavily is it actually trafficked?
- How many potential students per month or per year are utilizing the lead form found on this page?
- Since we don’t purchase online leads, who receives this information?
- What is done with lead information after it is submitted by the prospective student?
Deceptive advertising is a growing problem in the EDU space, and it is important to stay ahead of the game. A prospective student’s information in the hands of someone else or a competitor is of no use to you and can serve as a direct cut to your company’s revenue.
In order to prevent the possibility of baiting and switching of your brand, it is important to employ routine monitoring to identify how and where your school is being advertised. If you buy leads from online vendors, confirm that sites you find are part of their affiliate networks and that they’re meeting compliance regulations.
To learn more about compliance monitoring and brand management, call 888-547-7110 or email IntegriShield today.
Compliant Landing Pages
Nowadays there are many rules and regulations for online marketing, making it difficult to know what should and should not be present on landing pages. In order to be sure your landing page is compliant check out this list of key factors and requirements.
• Privacy Policies: When collecting an inquiry’s information a privacy policy including a statement informing them of what you plan on doing with their information and how you plan on contacting them is necessary. To contact potential inquiries via phone or email is illegal without their permission.
• TCPA Consumer Consent: In addition to the privacy policy, TCPA language is required on a lead form when you are collecting contact information stating how you plan on contacting the inquiry. This protects consumers from unwanted autodialed and/or robocalls. An example of compliant TCPA language is as follows;
By entering my information and clicking “SUBMIT” I am providing express consent to be contacted by via email, phone and text, including my wireless phone number, regarding product and servicing information using automated technology. Standard message and data rates may apply to text messages. I also understand that I may be contacted by this school via email and/or phone.
• Program Disclosures: When programs are present on your site, you need to provide inquiries with program disclosure information. The U.S Department of Education released a new template for consumer information documents in November of 2013 requiring a new layout for program disclosure information in effect by the end of January 2014 . Although not required on all landing pages we also recommend that program accreditation statements are provided to inquiries. However, not just the acronym, the statement in its entirety. Some accrediting bodies require that you provide their address and/or phone number, you will need to check with the accrediting body guidelines for this information.
• Accurate Information: Lastly, when creating a landing page you want to make sure that all of the information presented is correct. The most common mistake is providing outdated or incorrect information such as logos, programs, statistics, addresses, web copy and so forth. IPEDS and Client websites are two great tools for verifying the most accurate information. IPEDS is a data collection program for the National Center for Education Statistics, and information is collected over three periods (Fall, Winter, and Spring) each year. Institutions are required to fill out these surveys if they participate in any federal financial assistance program authorized by Title IV.
For questions or concerns regarding landing pages, please contact IntegriShield at support@integrishield.com.
Copyright Infringement: Abuse vs. Fair Use
The primary protection given to copyright owners is the right to authorize others to reproduce their work. Unauthorized distribution of copyrighted works often result in infringement cases as copyright owners state their incontestable claim to their own works and distribution.
This level of protection is limited however by a policy titled, “Fair Use”. Section 107 of the copyright law (title 17, U.S. Code) lists various purposes for reproducing copyrighted material protected under Fair Use such as: criticism, comment, news reporting, teaching, scholarship and research. Section 107 lists four factors that help determine the use:
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- The purpose and character of the use, including whether such use is of commercial nature or is for nonprofit educational purposes
- The nature of the copyrighted work
- The amount and substantiality of the portion used in relation to the copyrighted work as a whole
- The effect of the use upon the potential market for, or value of, the copyrighted work
Even with these factors spelled out for the public, there remains an unclear definition of what the perimeters are for using material that result in blurred lines between Copyright Infringement and Fair Use.
Being there’s no quantified amount of copyrighted work that may be used without permission, and simply citing the original owner is insufficient acknowledgement, protection under Fair Use is often disputed.
Those seeking additional protection to use copyrighted work should seek the permission of the original work’s author. When permission is unobtainable, it is recommended to seek consultation of legal representation to determine the fair usage of a protected work.
Crowdfunding Introduced to Consumer Reviews
In an attempt to bring order and transparency to the crowdfunding industry, a website named CrowdsUnite was created in 2012. Crowdfunding encourages investments in small and mid-sized businesses by allowing groups of investors to network and raise money for startup companies. It surfaced after the Jumpstart Our Business Startups (JOBS) Act was signed in 2012. However, funding efforts from non-accredited investors pose a threat to the new opportunities for businesses. With over 700 global platforms available, it can be a challenge for an individual to validate trustworthy funding sites.
CrowdsUnite creator, Alex Feldman, has since introduced consumer reviews to help combat this issue. Going on two years their website thrives with a 10% monthly growth rate of unique visitors. In the past year, IntegriShield has also heightened efforts to bring the importance of brand equity to the forefront. The success of CrowdsUnite backs the importance of consumer review sites and exemplifies how such sites can make or break a company.
“Consumer review sites, such as CrowdsUnite, can be a great resource for consumers but more importantly can act as a platform to build a company’s brand equity,” noted Jennifer Flood, IntegriShield’s Managing Director. “One false or inflammatory review can severely damage a company’s brand equity, which is why my team stresses the importance of monitoring review sites for our clients.”
In response to a high-demand for compliance monitoring, IntegriShield launched Infringement Detection alongside a suite of successful compliance monitoring services. Click here to get started learning the best practice for your company to monitor your brand equity or copyrighted and trademarked material.
Identity Theft
Identity theft has become a sprawling problem for those of us well connected to the information age. Recent security breaches in Target and Neiman Marcus has brought the problem into our forefront shattering expectations that this is a concern only for those that choose to purchase and handle their business online. Attacking a couple of the world’s leading retailers is a bold step for those thought to dwell only near the checkout tab at unreliable online retailers. The unexpected nature, coupled with the tactical timing made for a front page world-news worthy story. Individuals were urged to be proactive about changing their account information and to contact their banks in order to monitor their bank accounts. We ask ourselves, is this enough?
Here at IntegriShield we value individual privacy and right of those individuals to protect their property. Here are some tips to help us all navigate through the tech jungle:
– Know where you shop, become aware of the store’s privacy policy and whether they sell your information to third party companies. This is especially true for companies that entice you with coupon offers only once you submit more information.
– READ privacy policies. They are there for a reason, I know we are all blissfully happy with the belief that they all “basically” say the same thing but if you are required to agree to their privacy terms before purchasing, then most likely they are worth looking into.
– Make sure that the back of your cards read PLEASE SEE ID. This ensures that the person taking your card verifies your identity. You will be surprised at how often this practice gets overlooked even as more companies make it a requirement.
– Know your rights. Discuss identity theft protection with your bank; make sure that you understand their policies and what services you pay in order to stay protected.
– Make it a habit to look through your bank statements, if in doubt flag it and ask questions. It is also a good idea to round most of your purchases to the nearest whole amount, this makes most unusual purchases stand out.
– Be cautious of all information you post online, whether it is professional or personal. This information exists in a data pool that is easily accessible to those prowling for information in order to use it for financial gain.
– Lastly, don’t make it easy for anyone trying to steal your information. Make passwords and PINS that are simple to recollect but hard for others to crack. If it is something that someone can guess after getting to know you then it is not safe as a password. How long you have had a password is also important. The best way to protect yourself is to become an enigma and make it hard for others to guess your next move.
We have to come to peace with the fact that as our world dives deeper into the information age it will become harder to protect your information from those that are determined to get it. As a society we have to become more diligent about protecting our privacy and our right to exercise it. If you would like some more information about protecting your identity visit the Consumer Information page on the Federal Trade Commission’s website.
Not Your Average Defendant
Copyright infringement affects brands of every size, shape and income. From A-List celebrities to small mom and pop corporations, various media outlets provide a vast canvas for the misuse of trademarked materials. Over the last century, celebrities have struggled with unauthorized use of their materials, where others sought to infringe upon their successes for financial gain. In 2003 Maureen Marder, better known as the inspiration behind the 1983 movie “Flashdance,” sued Jennifer Lopez claiming Lopez and her label, Epic , illegally portrayed Marder’s life story in her 2003 video, “I’m Glad.” The case was dismissed in 2005 due to Marder’s lack of copyright ownership.[1]
In more recent years the “Beliber” himself was sued for $10 million alongside Usher for copyright Infringement for their collaboration “Somebody to Love.” In May 2013 Devin Copeland and Mareio Overton, both songwriters, claimed that Justin Bieber’s hit, “Contained several lyrical and stylistic similarities to the song of the same name they penned in 2008.” As of June 2013 Bieber filed a motion for dismissal due to lack of jurisdiction and improper venue, but no conclusion has been made.[2] If one song wasn’t enough to break the bank, Robin Thicke was sued for infringement for three. Marvin Gaye’s family filed a lawsuit in October 2013 claiming that Robin Thicke ripped off a handful of Gaye’s songs. Among the three songs in question, Thicke’s summer hit “Blurred Lines” followed by ,“Love After War” and “Make U Love Me.[3]” Currently this case is still in court.
Although the star of many infringement lawsuits, the entertainment industry is not the only field threatened by copyright infringement, small companies and large enterprises run the same risk of infringement by failing to properly track and monitor their copyrighted material online. The internet has created an infringement war zone with misused material found on websites, social media and blogs. IntegriShield’s Infringement Detection service has created a virtual safe haven for companies searching for a way to monitor their copyrighted material. Don’t let others make a profit from abusing your copyrighted material. For more information on how to protect your brand call 816.994.1313 or request information.
[1] http://caselaw.findlaw.com/us-9th-circuit/1422830.html
[2] http://www.law360.com/articles/454208/bieber-looks-to-duck-10m-copyright-suit-over-hit-song
[3] http://articles.latimes.com/2013/oct/31/entertainment/la-et-ms-marvin-gaye-lawsuit-robin-thicke-blurred-lines-20131031
FTC Joins the Fight Against Private Sector Schools
The FTC joined forces this week with the Obama administration’s fight against private sector colleges. The agency released new guidelines this week in hopes to crack down on deceptive advertising, promotions, marketing and sales made by private sector colleges featuring vocational programs.
The new guidelines followed the tip sheet recently released by the FTC to help veterans better scrutinize private sector colleges, in hopes the same guidelines can help all students.
Seven of the eight comments received by the FTC submitted by numerous accrediting agencies were in favor of retaining the guidelines noting, “Many instances of fraud in the industry and urged that the guides be strengthened and enforced more vigorously.” APSCU however commented against retaining all guidelines, suggesting rather retain the guidelines only for unaccredited or unlicensed institutions stating that the guidelines were unnecessary, “and would create additional burdens for institutions that are licensed by a stat or accredited by a DOE recognized accrediting agency.”
Overall the Commission proposed four modifications to the guidelines including:
- Guides addressing misrepresentations of salaries, job placement, completion rates and time frames.
- Guides addressing misleading statements indicating that a program would render a student eligible to take a licensing exam.
- Guides stating that misrepresenting a student’s admissions test score as a deceptive practice, hindering their success to complete the program.
- Guides to address transfer of credits, assistance to language barriers, source of funding for student loans and crime statistics.
The FTC’s new guidelines went effective November 18th 2013. Contact IntegriShield today and make sure your institution is in compliance with the new guidelines.