Advocacy Alert: FSA Announces Use of Secret Shoppers

The Middle States Commission on Higher Education (MSCHE) wants to bring to the attention of all constituents the recent announcement regarding Secret Shoppers to Evaluate Recruitment and Enrollment Practices and Monitor Title IV Compliance.

On March 14, 2023, the Federal Student Aid (FSA) Office of Enforcement announced that secret shoppers would be used to identify issues with institutions’ representations of their programs. According to the announcement, “[p]ractices that secret shoppers will look for may include—but are not limited to—misrepresentations related to the transfer of credits into or out of the school, job placement rates, completion rates, withdrawal rates, future earning potential of graduates, the career services offered by the school, the total cost of attendance, the amount of Title IV aid available to students, and the institutional or programmatic accreditation, along with any other violations of the Title IV regulations.”

Read the announcement from FSA.

MSCHE is an institutional accreditor and title IV gatekeeper, and many institutions access title IV through MSCHE accreditation. Part of the work of MSCHE is ensuring institutions remain in compliance with applicable federal requirements, including through their title IV responsibilities. As an institutional accreditor, MSCHE requires institutions to provide evidence of compliance with federal recruitment and enrollment regulations and MSCHE policy, procedures, standards, and requirements, including those that address transfer of credits and the student experience. The accreditation processes of MSCHE provide opportunities for verification of compliance, including a rigorous accreditation review cycle, thorough monitoring procedures, a well-established substantive change approval process, and customer service-oriented complaints process.

In November 2022, the United States Department of Education (USDE) and FSA also invited the submission of tips and information from knowledgeable sources on potential violations by institutions.

Read the invitation from USDE and FSA.