Vlog: TCPA Ruling
All marketers are familiar with the wide-sweeping TCPA legislation that has been consumer focused regarding unwanted calls and text messages. Now, the FCC wants to close loopholes and has indicated more restrictions are on the horizon.
Are you unsure of the impact this may have on your organization? Watch the short 4 minute clip below as IntegriShield President Jennifer Flood answers the questions we frequently get from marketers and clients.
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Minnesota Increases Scrutiny of For-Profit Colleges
In the past year, for-profit schools in Minnesota have been coming under increased scrutiny. The state’s Office of Higher Education has created a new watchdog which sends out “secret shoppers” to monitor whether schools are misleading or dealing honestly with prospective students. Schools giving misleading information about job-placement rates or how much money graduates could earn in their field are just a couple of examples that would raise concerns with these shoppers.
The new state watchdog has started to compare notes with Minnesota State Attorney General’s Office. This this office can suspend or shut down a school that gives students misleading information, including institutions that a court or government proceeding concludes they have engaged in fraud or misrepresentation.
Monitoring your staff can shield your institution from potential fines and penalties. Some areas to proactively monitor for compliance 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.
- 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.
- Financial Aid: Not every student will qualify for financial aid. It is important to provide this clarification and transfer prospective students to a financial aid representative to receive further information.
Get more tips for analyzing and improving the performance of your admission staff, email Shawn Graybill or call 888-547-7110 today.
Vlog: The FTC and Updated Rules on Testimonials
Do you use bloggers and social media to promote your company, school or products? The FTC has released new monitoring method requirements.
Watch as our president, Jennifer Flood, explains how that may impact your organization:
Follow IntegriShield on Twitter and LinkedIn for more compliance news.
Is Your School Prepared?
Career Colleges have been called into question by the policy community regarding the quality of data used to estimate the value of student outcome. To restore credibility, ACICS has introduced an improved placement verification and quality assurance process. The largest fundamental change is member institutions will be required to record and maintain placement information and meta-data beyond what is required in the ACICS Campus Accountability Report.
Key ACICS Council Changes to Implement:
- Maintain sufficient supporting data for placement verification. This information must be submitted to ACICS upon request
- On a recurring basis, maintain supporting documentation to provide to an ACICS visit team, state or federal agency; should minimally include the following:
- Placement by Title – the student’s job title, the published list of titles for which the program prepares students, and a list of the skills required by the graduate’s job.
- Placement by Skills – a description of the skills taught in the program and a list of the skills required by graduate’s job.
- Placement by Benefits – Student attestations are required only for students whose placements are based on “the benefit as a catalyst in obtaining or maintaining the position.”
In addition, ACICS has modified the visit team process to be more robust to verify files of graduates who are classified as placed or unavailable for placement. IntegriShield can help your institution manage the new robust files with:
- Written documentation such as Verification of Employment form, Waiver of Placement etc…
- Recorded MP3 audio of all phone calls
- Email correspondence and detailed notes about each graduate
Contact IntegriShield (opens in a new window) for more information on how we can help with these new changes. Call us at 888-547-7110 or send us an e-mail at sales@integrishield.com.
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.
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
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.