Bob Johnson's Blog on Higher Education Marketing

January 2012 Archives

Deceptive Advertising: Without injury to consumers, the FTC won't notice

An earlier post on using possible Pell Grant eligibility as a lead generation tool raised the question of whether or not individual schools might be held liable by the Department of Education and/or the Federal Trade Commission for third-party efforts by lead gen firms on their behalf.

After reading an advisory report prepared by the Association of Private Sector Colleges and Universities, I'm inclined to think that liability in the email Pell Grant example I wrote about is not a high probability.

Marketing that bothers the Department of Education

First, download a copy of the APSCU's Student Recruitment Task Force Report: "The Misrepresentation Rule and Third-Party Vendors." My conclusions after reading the report:
  • The Department of Education is most concerned about misleading advertising when it refers to outcomes such as employment promises and income earnings.
  • If advertising didn't cause substantial harm (as in getting people to spend money based on misleading employment claims), deception itself isn't likely to be noticed.
  • No matter the deception, an expectation that schools pre-approve of everything done by lead gen firms if done for a collection of schools is less strong than when an action is taken on behalf of an individual school. (This Pell Grant effort was done on behalf of many institutions who might have later received leads after screening.)
"Unethical or unscrupulous" violates FTC standards

The APSCU report includes an appendix on page 19, "General Marketing and Advertising Law Overview," that links to several useful publications from the Federal Trade Commission. Yes, "unethical or unscrupulous" advertising violates consumer fairness standards. Those are somewhat vague terms, however, and it is unlikely that the FTC would bother itself with an individual case that could not link an unethical campaign with substantial harm to consumers.

The Pell Grant email campaign, and other like it, therefore is not likely to draw attention from either the DOE or the FTC. See the original email in my first blog post and decide for yourself if it was "unethical or unscrupulous."

Reasons why this Pell Grant campaign was unethical and unscrupulous  

In my opinion, this campaign was both unethical and unscrupulous for at least two reasons:
  • I was "prequalified" for a $5,550 award only because I am a U.S. citizen. The firm sending the email had no idea of my income or my education costs at a future school. Technically accurate for some, but quite a stretch overall.
  • The call to action was to "click here" to apply for "this amazing opportunity." But once I clicked, there was never a mention again about Pell Grants or what it took to receive one.
Would you include this Pell Grant campaign in your Annual Report?

Your opinion may differ from mine. But I suspect that few of the schools included at various points beyond the email would include this campaign as an example of their advertising efforts in an Annual Report to alumni and friends.

A resolution for 2012

Make a New Year's resolution: if you participate in collective lead generation efforts, ask your firm to see the advertising in advance. Decide if something is ethical and scrupulous. If you're not proud of it, why are you doing it?

That's all for now.
Greetings in the new year to everyone, here in the U.S. and around the world.

This first 2012 newsletter includes several items on the best of 2011 and predictions about what to expect in the coming year, from 32 words PR writers should avoid to 30 social media predictions "from the pros" to a new MIT effort to increase the value of its free online course offerings. The usual eclectic mix of topics included here will continue.

As always, I hope to meet many of you at conferences this year. At the end of the newsletter you can find recommended events in Philadelphia, Atlanta, Chicago, and Boston.

And now, here are your marketing news and notes for January 2012. Happy New Year!
Highest Student Loan Debt in 2010: The Top 10 Schools

Huffington Post has created one of those lists that nobody wants to be on, especially in a time of increased concern over the cost of higher education. This Top 10 list for a 4-year degree starts with Eastern Nazarene University at an average of $51,336 and ends with Bard College at $44,910.

Three of the 10 are in Massachusetts. See if your competitors are on the list that starts at
Lowest Student Loan Debt in 2010: The Top 10 Schools

The Huffington Post people are also highlighting 10 schools with the lowest loan debt levels for a 4-year degree. This list opens with Alice Lloyd College at a $3,108 average and closes with Cameron University at $7,200. One Ivy League university is on the list at $4,385.

See 10 low debt schools, including the only public university included, at
30 Social Media Predictions for 2012 "From the Pros"

Start your social media new year by reviewing the predictions of 30 experts gathered by Social Media Examiner.

Hard to pick a favorite, but mine just might be Number 8, Regularly Creating Unique Content Becomes Essential. Three predictions focus on a more important role for YouTube and two speak to a revitalization of email.

Pick the ones that will best keep your social media strategy alive and well at
Digital and Print: How Newspapers Might Survive

Almost everyone believes that print will survive in the marketing mix, and perhaps it will do that. What is less certain is how that survival will take place.

For one view of the future of newspapers, read the thoughts of John Paton, a key industry person who started as a copy aide with The Toronto Sun in 1977.

In a nutshell, Paton believes the industry has to "stop listening to newspaper people" searching for how to revive print and move to digital as rapidly as possible in light of continuing drops in revenue from print operations.

The NY Times reports more on his views at
Best Publication Conversions to iPad in 2011

If print publications are fading, the tablet environment might be the best place for newspapers and magazines to thrive in the digital age.

AdAge highlights 10 newspapers and magazines that it believes have made noteworthy migrations to the iPad platform. Check the list at

To see how universities are adapting view books to the tablet format, download these examples to your iPad: University of Dayton at and Salve Regina University at and University of Chicago at
MIT: A Significant Marketing Moment

MIT has been offering free online course materials (for more than 2,000 courses) for about 10 years now in a unique form of self-study. To date, no formal recognition for taking these courses has been available.

Now, reports the Chronicle of Higher Education, MIT will introduce in the spring certificates that acknowledge course completion. Certificates will incur a cost, but nothing near the price of tuition for a student registered for an MIT degree. People will still have the option to study without seeking a certificate.

Is this a significant development in the higher education marketplace? Absolutely.

Read more about the future emerging in a time of cost concern at
32 Words PR Writers Should Avoid

Resolutions are not my thing, but we should all resolve to read through this list from Tom Gable and ban as many of these words and phrases as we can from our writing in 2012.

Some of my favorites: cutting edge, outside the box, state-of-the-art, and synergy.

Tom presents these as the favorites of lazy PR writers. See how many you agree with at
Mobile Marketing: The Outlook for 2012

Mobile Marketing has issued a 43 page PDF with an eclectic range of comments, observations, and predictions for the upcoming year.

Usefulness will vary with the extent of your knowledge and experience with mobile marketing, but I suspect that everyone will find something of interest as you scan the 22 topics on the contents page. Read a summary of the report, including notes on platform fragmentation, texting, and social media, and download the full document at
$5,550 Pell Grant Eligibility to Entice Email Click Through

A flurry of emails arrived in my mailbox in December built around the theme that as a U.S. citizen I was prequalified to receive a $5,550 Pell Grant. The goal was to get me to click on a link and arrive at a landing page built by a lead generator.

The Pell Grant offer? That was not mentioned again. This, I submit, is the type of marketing that does not give higher education a good name.

To see the email offer itself, the 10 qualifying questions asked after I got to the landing page, and the four schools recommended after that, visit
Big-Time College Sports: Is Immunity Weakening?

Is public scrutiny of higher education sports programs going to increase in 2012?

Penn State got the most attention in 2011, but a Bloomberg Business Week article in December reminded us of Ohio State's football coaching fiasco as well, including the university president's comment that he hoped the football coach was not going to fire him. References are made to head coaching situations at other major universities.

The Bloomberg article by Al Hunt calls for a government intervention to restore accountability. Absent that, he is not optimistic about serious change. Review his reasoning at
Conferences and Webinars in 2012

Attend a conference in 2012 to share questions and answers with people who are building a competitive advantage in higher education marketing.

Thanks again to everyone who attended a presentation in 2011 and enlivened and enlightened a session with your questions and comments.

May 8-10, Philadelphia: J.BoyePhiladelphia12 Web and Intranet Conference. Sessions and registration at

May 24-25, Atlanta: Academic Impressions Conference: "Writing Right for the Web: Improving Your Content." Program content and registration at

July 11-13, Chicago: ACT Enrollment Planners Conference. Visit the conference website at

July 30-August 1, Boston: eduWeb2012. Conference website is at

Expand the marketing skills of people on your campus. Host a campus workshop on any of the conference topics listed here.

Contact me at
That's All for Now 

Be a marketing champion on your campus.

Bob Johnson, Ph.D. (
Bob Johnson Consulting, LLC
Bob Johnson Consulting, LLC

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