MDT mystery shops colleges on a regular basis. Just today we received an email from a college saying, ‘Start your career this week’.
Yes, ‘this week’.
That’s beyond a misrepresentation, that’s an impossibility.
In case you missed it, the US Dept of Ed announced their ‘secret shopping’ of colleges to uncover misrepresentative communications. If you haven’t seen it, you can review their notice here.
Let’s forget the Dept of Ed for a moment. For the sake of setting clear expectations with prospective students, there’s nobody we know in higher ed who would disagree that institutions cannot imply that you could ‘Start your career this week’.
In all the mystery shopping we do every year, we get visibility into what everyone is saying. And the truth is, from our perspective, most institutions do a pretty good job of publishing clear and accurate messages. But messaging is very subjective, and the Dept of Ed is going to be looking through their own lens as they scan your website, fill out your forms, and speak with your admissions reps. Based on our years of experience navigating matters like misrepresentation in marketing communications, these are the…
Top 3 Immediate Marketing Priorities for Your Institution
We’re a marketing agency, not a law firm.
This isn’t legal advice; check with your counsel for legal guidance on this.
Action 1: Scan all your public and outbound communications for ‘red flag’, trigger words.
If we were leading US Dept of Ed initiative, we’d start by automating the search for keywords that are most often associated with misrepresentation. It’d be a fast and efficient approach to zero in on potential problem areas.
From that perspective, we recommend you start with a scan of your website, your emails, your texts, your admissions scripts and so on for keywords that have the potential to trigger scrutiny. This can be as easy as hitting ‘CTRL F’ within your copy documents. Classic words to re-evaluate are: ‘placement’, ‘start’, ‘outcomes’, ‘job’, ‘salary’, ‘employer’. And words like ‘free’ should just be removed altogether.
Doing this scan and reevaluation of ‘red flag’ keywords across public and outbound communications is the quickest, easiest, initial action you could take that could protect your institution from deeper scrutiny.
Action 2: Consider changing definitive statements to conditional statements
Definitive statements often get read as guarantees.
Guarantees are off limits.
Example: ‘Earn your degree in eighteen months’.
This is a definitive statement we often see used. And if the program being promoted is, in fact, an eighteen month program, why would saying this be a problem? From our perspective, this could be considered misrepresentative because, even though the program is an 18-month program, that does not guarantee that a student will be able to complete it within eighteen months. Maybe they don’t pass a class, pushing back their graduation. And then that student could possibly point to your messaging they saw when they enrolled and argue that they were promised a degree in eighteen months. Right or wrong, this could create a challenge for you.
So Here’s how to change that. When we’re copywriting for institutions, we reword phrases like this to something like: “You could earn your degree in as little as eighteen months.” Not as compelling of a message, longer winded, but changing the phrase from a definitive statement to a conditional statement by using the word ‘could’ and the phrase ‘as little as’, you can communicate the same general point, while doing it in a way that is not guaranteeing anything.
Protect your potential students and your institution’s reputation with guidance on compliant marketing communications. Schedule your consultation today.
Action 3: Support definitive statements with data
If your institution makes a definitive statement, be sure to apply concrete, updated data from a reputable source to support that statement.
Certain stats are easier to support than others. Graduation rates are a relatively easy stat to defend. You control all this data, you report it to the government and accreditors. You could reference the data from IPEDS. This is a stat that you could apply successfully.
Now consider the promotion of career salaries. This is a more common practice with career colleges because a student can enroll in a program that trains them for a single, specific career. Salary data is a much harder stat to lock down because:
- You don’t have control over this data, instead you’re dependent on 3rd party resources like Bureau of Labor Statistics,
- Salaries for the same job are different across different markets,
- Even if you have local, updated, well-sourced data on this, you need to be very careful about how you communicate it so as to not infer in any way that a student should expect to earn that promoted salary by going to your college.
This reason alone leaves so much room for interpretation that we advise against promoting these stats except for particular scenarios.
Also consider that an inherent, administrative challenge with applying stats in your communications is that they need to get regularly updated. Considering all the content you’re likely creating, it’s very easy to lose track of where all your stats live. There may be an obscure landing page you built years ago, put a stat on, and simply forgot about it. Despite that being an innocent mistake, it could create challenges. Our recommendation is to be very selective on where you apply your stats, track their location within your content, and schedule annual reviews and updates of those stats.
Also consider that an inherent, administrative challenge with applying stats in your communications is that they need to get regularly updated. Considering all the content you’re likely creating, it’s very easy to lose track of where all your stats live. There may be an obscure landing page you built years ago, put a stat on, and simply forgot about it. Despite that being an innocent mistake, it could create challenges. Our recommendation is to be very selective on where you apply your stats, track their location within your content, and schedule annual reviews and updates of those stats.
…administrative challenge with applying stats in your communications is that they need to get regularly updated.
Bonus Action: Apply these same 3 actions to 3rd party data resellers
Everything we just spoke about needs to be addressed, but some institutions also work with third party data aggregators who resell prospective student data. Every one of these companies operates in a different way, but many operate with limited transparency into their promotional messaging that drives inquiry generation.
If you’re working with companies like this, you’re responsible for taking Actions 1-3 with them as well. Ask them:
- What keywords are they using?
- Are they making definitive statements?
- How are they applying and sourcing their stats?
A great resource for understanding what to look out for with 3rd party data resellers can be found in CECU’s Compliance and Best Practices in Student Generation Guide. You can download it here or go to www.career.org/student-inquiry-guide.
Final Thoughts
In all the higher ed marketing messages we’ve reviewed over the last year, we’ve found that most schools handle communications very well. That’s not because of the US Dept of Ed, it’s because clear and accurate communications through the enrollment process is beneficial for both the institution and the prospective student.
But you may, inadvertently, have messaging that hasn’t been reviewed recently. Perhaps legacy content that needs to be refreshed. Perhaps stats that need updating. Take action now and follow the steps above to avoid delivering a ‘Start your career this week’ message.
If you have any questions related to this, we’re happy to connect. You can find our calendar here or go to bit.ly/mystery-shopping-questions.
