Misrepresentation

The institution reviews marketing materials, website content, and admissions scripts for accuracy before publication. Claims about job placement, licensure pass rates, or typical earnings must be supported by evidence and properly sourced. When a misstatement is discovered, it is corrected promptly and any affected students are notified if required. The Department investigates complaints and can impose sanctions after a finding.

Example: an online program’s homepage states “90 percent of graduates are employed in their field within three months” without data to support the claim. The statement is a misrepresentation. The institution removes it, posts corrected outcome data, and may face a compliance action if the claim was deemed substantial.

Puffery is vague boasting that is not a factual claim. A data error that is promptly corrected may not rise to substantial misrepresentation. Program-integrity rules also cover incentive compensation and state authorization; misrepresentation is the specific prohibition on false or misleading statements.

Publishing outdated or cherry-picked outcome statistics. Allowing admissions representatives to make verbal guarantees about job placement or aid amounts. Failing to correct third-party marketing content that the institution controls or benefits from.