[As published in Beauty Link Magazine by AACS]

Student outcomes are an increasing focal point for accreditors and the U.S. Department of Education (DOE). The final chapter in the student life-cycle now demands more detailed reporting than ever before.  If collecting accurate information from recent graduates has become a challenge for your team, then you are not alone.

This article will share insight on how your institution can prepare for the changing environment and improve your employment verification process.

Regulating Accountability

Back in late 2016 Democratic Senators Elizabeth Warren (D-MA), Dick Durbin (D-Ill) and Brian Schatz (D-HI) introduced new legislation aimed at improving the college accreditation process.

The Accreditation Reform and Enhanced Accountability Act (AREAA) would address strengthening accreditation standards and requiring accreditation agencies to be more responsive to allegations of misconduct.  Under the act, the Department of Education would be empowered to require accreditors to consider a variety of student success metrics when determining eligibility — including “retention rate, graduation and payment rate, transfer rate, student earnings after graduation, and job placement rates.” —. The DOE is currently prohibited from setting such standards.  Accreditors would also be required to respond more quickly when their certified colleges come under federal or state investigation or face lawsuits for “fraud or abuse, deceptive practices, or material harm to students enrolled.”

AREAA would also restrict “conflict of interest” in the accreditation process by prohibiting individuals holding administrative and other roles, or individuals with financial stakes in an institution, from being involved in the certification process of that school. The bill also bars federally registered lobbyists from participating in that same certification process.

Increased pressure on accreditors may result in increased pressure on your school team to produce more detailed graduate data. To help simplify the process, consider dissecting your employment verification into three phases.

Phase One – Preparing for a Changing Environment

The Information for Financial Aid Professionals (IFAP) website provides federal regulatory context when gathering your placement rates. For details, you can do a search of:  IFAP Consumer Information Disclosures at a Glance, CFR 668.41(d) and 34 CFR 668.14(b)(10). Schools must make available to current and prospective students information regarding the placement in employment of, and types of employment obtained by, graduates of the school’s degree or certificate programs.

Also, schools must identify the source of the placement information, plus any timeframes and methodology associated with it.

When an institution advertises job placement rates as a means of recruiting students to enroll, it must make this data available to prospective students; at or before the time the prospective student applies for enrollment.  Here are a few items that need to be made available:

• The most recent data regarding the graduate’s employment if relevant to the field in which they obtained their degree.
  • Remember to include any applicable methodology in obtaining this information

• The most recent available information regarding the types of employment obtained by graduates, such as full-time, part-time, contract, etc.
  • Must also include any applicable methodology in obtaining this information

• Any other information necessary to substantiate the truthfulness of the advertisements from the point of view of the “reasonable” consumer, including, but not limited to:
  • Applicable Student/Graduate Testimonial Affidavit
    • Express vs. Implied Claim substantiation
  • Privacy Policies and Terms
  • Sufficient Evidence to Support the Advertising Claim (i.e. survey results, etc.)
  • Consumer Disclosure Information

• Relevant state licensing requirements for the profession which the course of instruction is designed to prepare students.

Phase Two – Third Party Verification

With an understanding of the regulatory environment, the next phase explores four simple ways to go the “extra mile” in providing detailed reporting of employment verification. While assisting in placement can be a struggle, proper reporting is just as important to validate the hard work it takes to assist individuals after graduation. Whether you work in-house or with a third-party verifier, remember to record all follow-up attempts and verifications of the following areas:

Job Description

A job title is not always enough to collect. Titles can sometimes be vague; even when they are not, they cannot completely define an individual’s role in employment. For example, a cosmetology graduate working at a beauty salon does not necessarily prove the individual is utilizing the skills learned during his or her program.  Identifying the graduate’s tasks or responsibilities can more clearly relate education to professional status.

Hire Date and Duration

A hire date can validate the education an individual received. Showing that hire dates are within a reasonable amount of time following program completion offers relevance in the education choice made by the individual.

Contact Information

Always cite your sources. If you are meeting with a supervisor that is verifying the employment of one of your graduates, get their name. If you are talking to them on the phone, be sure to record the phone number that you used to reach them. This information is crucial in the event of an audit, as the auditor will most likely be utilizing that same information you collected during your graduate employment verification process.

Get Employer Feedback

Employers may offer some constructive criticism on your modules. For example, maybe there are newer standards employers seek during the hiring process. This feedback can help enhance your programs, keeping them up-to-date with the trends of the industry, and keep your graduates best prepared when trying to enter the workforce. Feedback can also help with maintaining employer relations, especially being alerted to any potential openings that employers may have that can be filled by your graduates.

But what happens when you have an unverified graduate? One major obstacle when it comes to graduate reporting is actually finding them. Some third-party verifiers can help with this process and expand on your own efforts with access to new employment databases. On the other hand, if you encounter a graduate with an “unemployed” status, it is important to have a process for following up with these individuals. Whether the communication is done in-house or through a third-party, you may consider providing placement assistance or additional time to seek employment.

Occasionally you will find graduates who are not going to work in their field for a valid reason, such as active military duty or continued education. A Waiver of Placement, indicating that said graduate does not wish to OR is unable to pursue employment in regards to the field in which they obtained their degree, should be recorded for these individuals. An example to consider: If a massage therapy student graduates with a certificate in Massage Therapy, but later is steadily and happily employed in accounting, then a waiver of placement would apply because he or she would most likely not be using the earned certificate in Massage Therapy. Remember to collect details on timeframe and written & electronic signatures for your records.

Phase Three – Data for Institutional Improvement

Finally there are several changes you can make in this phase to improve your graduate data. Start with refining graduate questionnaires to address report “buckets”. Layer questions to collect as much information as possible. Offer multiple choices and prioritize most important information at the beginning.

If you are using a third-party, make sure this relationship is clear to all graduates and develop a formal methodology statement on how you gather graduate information for your accreditor. Obtain signatures of approval for contacting a graduate’s employer during the exit process. Explain the “why” to help improve your process for confirming and processing your graduates. Be openly communicative with students on the information you want to collect, why it will be collected and any confidentiality requirements.

As regulators and accreditors focus more on the final chapter of the student life-cycle it is important to start optimizing your process now to gather more accurate graduate data. Hopefully these three phases will serve as a starting point to help your team navigate through the challenges of employment verification. Whether you manage this process in-house or through a third-party vendor, it’s time to prepare for the changing environment and be vigilant with your compliance.