Your website is your front door. Is it inviting to compliance infractions? The following suggestions are offered as general advice about how to comply with the requirements in the Higher Education Act (HEA) and the regulations set forth by the Department of Education (DOE), Federal Trade Commission (FTC), Federal Communications Commission (FCC) and various accrediting bodies for content provided on institutional websites. As you update your website with content in the following categories, remember to keep these items in mind:
Accreditation
- Accreditation statement must be easily accessible
- The term “accredited” may only be used if the institution indicates by which agency or organization it is accredited
- Include names of associations, agencies, or governmental bodies that accredit, approve, or license the institution’s programs
- Procedures for obtaining or reviewing documents describing accreditation, approval or licensing should be present
Admissions
- Provide all required criteria expected to be completed by students prior to enrollment
- Include all educational requirements
- Ensure contact information is provided for prospective students
Career Services/Employability
- Detailed and clear explanation of offerings that the Career Services department provides
- Clearly indicate that education, not employment, is being offered
- Omission of banned terms, such as “career placement”
- Any references to employment or salary predictions must be accurate, sourced and never guaranteed
Consumer Information
- Easily accessible link, preferably on homepage, containing HEA disclosure information
- Use consumer-friendly labels and language, when possible
- Use a common set of content titles
Gainful Employment Disclosures
Financial Aid
- Qualification rules
- How applicants can learn about qualifying
- Full references to financial aid availability must include the disclaimer “for those who qualify”
- All scholarship offerings must be sourced
Job Availability and Placement Claims
- May only provide information pertaining to potential salary that accurately portrays the normal range and starting salaries in the occupation for which training is provided
- Salary information must also include the source of the information, which is valid
Net Price Calculator
- Tool that students can use to estimate their “net price” to attend a particular college or university
- Must use the template provided by the DOE or an institution may develop a customized version that must include, at a minimum, the same elements as the Department’s version
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
Statistics
- All statistics listed in website copy must be accurately sourced with current year
TCPA Requirements
- Consent language present on lead forms
- Language must include all components within the FCC definition
- If opt-in box is present, it should not be pre-checked
Testimonials/Endorsements
- Must be actual statements
- Some accreditors do not allow institutions to use testimonials from current students on their website
- Prior consent of the author must be on file
Transferability of Credits
- Include any established criteria the institution uses regarding the transfer of credit earned at another institution
- Provide a list of institutions with which the institution has established an agreement
At the end of the day it is important to be diligent with your compliance process. We recommend auditing your content regularly to ensure it meets the industry standards and guidelines you are expected to follow.