Complying with the Title IV Misrepresentation Rule

( https://www.ecfr.gov > title-34 > subtitle-B > chapter-VI)

How Can Institutions Avoid Violating the Misrepresentation Rule?

The following strategies can help institutions to mitigate their risk of misleading current or prospective students about the employability of program graduates:

• Substantiate all program-related claims (e.g., graduate placement rates, student testimonials) with evidence that can be easily produced in the event of legal action
• Follow established rules of statistical significance and available guidelines (e.g., NACE survey response rate guidelines ) when conducting graduate surveys or other data collection efforts
• Ensure that all website material, marketing collateral, and other information remains up-to-date
• Do not include any information on marketing collateral, website pages, or other institutionally affiliated publications that you cannot definitively verify and defend

Source:EAB’s Tool 5: Misrepresentation Rule Briefing Sheet

Communicating data about OHIO’s Student Outcomes:

Always include (at least) the following information:

1. Cohort year(s)
2. Degree level(s)
3. College, School, or program(s) for which you are reporting
4. Knowledge Rate, using the phrase “…of graduates whose outcomes were known…”
5. Cite the source of the information, i.e.,  OHIO Outcomes Dashboard (link)

Please reach out to  IEA if you have any questions or need clarification on available data.

Example 1:

One hundred percent (100%) of the 2021-22 bachelor's degree graduates in Mathematics, including Actuarial Science, Applied Mathematics, Mathematical Statistics, whose outcomes were known were either employed, in school, or both.  The knowledge rate for this cohort was 82%.

OR

100% of Mathematics graduates whose outcomes are known were either employed or in school or both (2021-22 baccalaureate completers, 82% knowledge rate).  OHIO Outcomes Dashboard  (link)

Example 2:

The average full-time earnings for University College baccalaureate graduates from the 2021-22 cohort was $51,949. Notes: 84% knowledge rate  OHIO Outcomes Dashboard  (link)

1. What proportion of OHIO graduates are employed one year after graduating and how long did it take them to be employed? What is their average annual wage and what are the trends?
2. What proportion of OHIO graduates pursue further education and how soon after graduating?
3. How does employment and further education outcomes for OHIO graduates vary by degree level, college, field of study, major, or any combination of the above?

1. Students’ career and academic advisement
2. Evidence for accreditation and program reviews
3. Recruitment of and marketing to new students

1. Ohio Department of Jobs and Family Services (ODJFS): provided employment data for graduates through a matching of records between OHIO and ODJFS Unemployment Insurance (UI) system. It is important to note that matched data only tracks employment in Ohio. It excludes federal employees and self-employed.
2. Career and Further Education (CAFE) Survey: provided supplemental employment data on graduates’ whose records were not found in the ODJFS match.  
3. National Student Clearinghouse (NSC):  provided further education data through a match of records with NSC that provides national post-secondary enrollment and completion data.
4. OHIO’s Graduation Application Survey: provided further employment and education data, self-reported in the student’s last semester prior to graduation from OHIO.