Higher Education Compliance Survey Results: What Are Schools Really Doing
Transcript of Higher Education Compliance Survey Results: What Are Schools Really Doing
RESULTS OF THE 2012 HIGHER EDUCATION COMPLIANCE SURVEY
Steve Smith, Managing Director of Product Management
Jeff Herz, Director of Compliance & Internal Operations
Reach, Recruit & Enroll the Right Students
July 1: ED Program Integrity Regulations
• Broad Misrepresentation rules cover any inaccurate content
• Any company that directly or indirectly has a relationship with the school is affected
• Serious Ramifications for schools
• Title IV eligibility suspended/revoked
• Heavy fines
• Reputational risks
CUnet Compliance Survey Methodology
• GOAL = Benchmark how schools are dealing with the regulations
• Conducted in October-November 2011 among 51 professionals working in for-profit schools
• Average online student enrollment was 6,222;average on-campus student enrollment was 5,744
12.0%
88.0%
Publicly Traded
Not Publicly Traded
Survey Results – Compliance Guidelines
• Not everyone is ready to deal with the regulations; nearly 1 in 5 schools has not even updated their compliance guidelines
Survey Results – Staffing Changes
• Nearly all schools (96%) have added new staffing resources to address compliance
0%
20%
40%
60%
80%
100%
Hired internal compliance staff
Hired third-party/agency
Increased your reliance on agency/partner
64%
40% 29%
11%
18%
18%
18% 36%
38%
7% 7% 16%
What Staffing Changes Have You Made to Deal with Regulatory Compliance?
Don't Know/ Not Applicable
No plans
In process
Completed
Survey Results: Contract Changes
• Schools (86%) are holding their vendors accountable through their pocketbooks, demanding transparency and exerting more control
52.0%
54.0%
56.0%
58.0%
60.0%
62.0%
64.0%
66.0%
Indemnification Liability Creative approval process
Transparency
57.1%
65.7%
57.1%
62.9%
If your school renegotiated contracts with vendors, which terms were impacted?
Survey Results: Vendor Response Times
• Schools are demanding that vendors respond quickly to violations
• 69% require major violations to be resolved in under 24 hours; 10 percent allowing up to 48 hours for resolution.
61.1% 19.4%
19.4%
Do you treat major and minor violations differently?
Yes
No
Not sure
Survey Results: Vendor Changes
• Schools are not afraid to eliminate vendors that represent a higher risk
40%
24%
29%
7%
Percentage of schools that have stopped working with vendors due to compliance concerns
Completed
In process
No plans
Don't Know/ Not Applicable
Survey Results: Compliance Monitoring
• Nearly everyone recognizes the need for compliance monitoring, yet fewer than 1/3 of respondents (31%) have both manual & automated monitoring in place
0%
20%
40%
60%
80%
100%
Added manual compliance monitoring
Added automated compliance monitoring
71%
42%
20%
22%
4%
18%
4%
18%
Have you implemented compliance monitoring?
Don't Know/ Not Applicable
No plans
In process
Completed
Survey Results: Overall Impressions
• Now that much of the dust has settled, it seems that most in the industry see the regulatory changes as good for the sector at large
67% agreed the regulations have been unfairly punitive to non-profits
73% agreed the regulations represent necessary changes for the sector, despite the challenges
56% agreed that the regulations will ultimately have a positive impact on the quality of prospective inquiries from vendors
Key Takeaways
Schools are relying heavily on shifting accountability over to vendors….
AND YET….
At the end of the day, schools are ultimately the ones with the most to lose
in the case of a compliance breach.
Key Takeaways: What Should You Do Now?
1. The regulations are broad; simply renegotiating vendor contracts may not be enough to mitigate risk.
2. Schools should invest in tools and strategies to ensure their partners remain compliant.
3. The best defense is a comprehensive compliance monitoring strategy consisting of tools, people & processes.
CUnet’s Compliance Statement
• Committed to leadership in the quickly-evolving area of compliance through significant investments in:
• People: Dedicated internal team of compliance experts (MOQC)
• Processes: Clearly defined set of operational processes to monitor, enforce and address misrepresentation
• Technology: Significant investments in technology solutions, backed by our industry-leading Sparkroom platform
• View CUnet’s complete compliance statement here: http://cunet.co/compliance_statement
Phase 1 Phase 2 Phase 3 Phase 4
Compliance Best Practice
What is the Enforce Process?
FULLY MANAGED COMPLIANCE MONITORING
Major Violations Examples
• Nature of educational program.
• Nature of financial charges.
• Employability of graduates.
• Relationship with the Department of Education.
Violation Resolution: Example Timeline
Penalties • Affiliate paused immediately,
causing all inquiries sent to be non-billable
• IO cancelled if violation is not remedied within 5 days
The term “Fast Track” is in use without the additional content that has to follow the phrase “in as little as 20 months”
The ad below implies that the gvt is providing grants for getting a degree
Minor Violations Examples
• Vague Language
• Unauthorized Creative
• Missing Accreditation
• “Science – Master’s Degree” where the degree is “Masters of Science Degree”
• Outdated Logos
Violation Resolution: Example Timeline
Penalties
• 5 days to get issue resolved before affiliate is paused
• Campaign paused after 10 days until issue is resolved
Our Technology: Sparkroom Monitor
Software that supports the compliance experts by:
• Storing URL information for monitoring
• Crawling the URLs nightly and comparing against previous records
• When different, take an image snapshot and copy HTML for change analysis
• Recording when manual audits are performed
Enforce: Case Study
CUnet Enforce Case Study Count Pages Reviewed and Audited 5459
Total number of unique URL’s monitored 1259
New URL's proactively found with Violations 165
Total Violations Identified 604
Open Violations 91
Major Violations identified 19
Minor Violations identified 72
Enforce: Case Study Violations
Nature of Education Program
65%
Missing Accreditation / Disclaimer
14%
Missing required field 14%
Unauthorized Client branded copy or creative
7%
Breakdown Of Violations
Special Offer for LeadsCon Attendees
Get a Free Compliance Review from CUnet
• Reviewing existing compliance process
• CUnet will run your URL list through Sparkroom Monitor, identifying areas of risk
• CUnet will provide overall page scores, list of banned terms found and an overall risk assessment
• If you are interested, please contact:
• Jeff Herz ([email protected]) 201-477-7793
Questions?
For additional questions:
Jeff Herz
201.477.7793
Steve Smith
steve. [email protected]
416.323.1366 x 41224