16 C.F.R. Part 254: Private Vocational and Distance Education Schools ("Vocational School Guides") #543519-00010

Submission Number:
Barmak Nassirian
American Association of Collegiate Registrars and Admissions Officers
Initiative Name:
16 C.F.R. Part 254: Private Vocational and Distance Education Schools ("Vocational School Guides")
October 16, 2009 Federal Trade Commission Office of the Secretary Room H-135 (Annex V) 600 Pennsylvania Avenue NW Washington DC 20580 To the Commission: I write to submit the following comments regarding the Federal Trade Commission's "Vocational School Guides Review, Matter No. P097701." The American Association of Collegiate Registrars and Admissions Officers (AACRAO) is a nonprofit association of more than 10,000 higher education admissions and registration professionals who represent approximately 2,500 institutions throughout the United States. Our members serve as the gatekeepers for institutional admissions and for the awarding of academic credit and credentials. Over the past decade, our members have become increasingly concerned about the proliferation of entirely unaccredited entities that purport to provide education and training. In most states, there is little state oversight for these providers and the Federal Trade Commission serves as the only federal agency with legal jurisdiction over the activities of these entities. Some of these providers, we believe, are mere diploma mills that do little by way of actual teaching or training and are, in fact, solely in business to sell credentials of devious value. Others vary enormously in the quality of the services that they offer and the costs their customers incur for the training provided. We believe consumers need to be extraordinarily vigilant with regard to all unaccredited institutions and would encourage the Commission to specifically review its oversight authority in this arena. We urge the Commission to pay particular attention to entities offering education and training on the web since we have noticed a disproportionate number of cases of consumer fraud by web-based entities over the course of the past decade. While consumer fraud by unaccredited providers constitutes a significant problem, our members are also concerned about waste, fraud and abuse by accredited institutions that participate in the Department of Education's student financial aid programs. We have urged the Department to take stronger steps to improve program integrity, but would encourage the Commission to also play a more active role in protecting consumers from questionable practices of the Title IV-participating institutions over which it has jurisdiction. Particular attention should be paid to deceptive advertising, high pressure sales tactics, misrepresentation regarding transferability of credit and withdrawals and false claims regarding dropped placement rates, potential earnings and total charges. Especially because these institutions are eligible for federal financial aid, we believe the Commission should mandate specific disclosures regarding borrowing levels and actual lifetime default rates. Attached please find AACRAO's statement on program integrity that we submitted to the Education Department. Sincerely, Barmak Nassirian Associate Executive Director, External Relations