STATEMENT from the Project on Predatory Student Lending on ED’s “Dear Colleague” Letter on Online Program Manager Guidance
BOSTON (January 16, 2025) – The Project on Predatory Student Lending (PPSL), the leading legal organization representing student borrowers against predatory for-profit colleges, issued the following statement on the Department of Education’s “Dear Colleague” letter to institutions of higher education, outlining guidance and a warning about institutions’ responsibility to prevent misrepresentations by their Online Program Managers.
PPSL, along with Altshuler Berzon LLP, represents the plaintiff students in the class action lawsuit Luna v USC, in which students of the University of Southern California’s (USC) online Master of Social Work (MSW) program allege that USC deceived students by representing that its online MSW program is the “same” academic program as USC’s on-campus program, including by hiding that its online MSW program was, until recently, outsourced almost entirely to a for-profit education company, 2U, Inc. The Department of Education cites the Luna case in the “Dear Colleague” letter as one example of alleged misrepresentations that helped alert the Department to the necessity of this guidance.
The Department of Education letter highlights some of the issues raised by the lawsuit, including that students are likely to be deceived when OPM employees: directly or indirectly misrepresent themselves as employees of an institution of higher education; do not have the equivalent training and expertise as university employees; disguise their role in recruitment; and inaccurately represent an online program as having the same qualities and services as an on-campus program conducted by the university itself, including with respect to instructors, curriculum, advisors, placement coordinators, or registrars.
Statement from Eileen Connor, President and Executive Director of PPSL:
“This letter calls out just how dangerous the OPM industry is to our higher education system. PPSL has been on the front lines of fighting predatory for-profit colleges for more than a decade and we know the playbook. As the USC students have alleged in the Luna case, these companies, under the banner of well-known schools, use aggressive marketing and recruitment to mislead students to get them enrolled, max them out with student loans, and then take their profit without delivering what was promised, to the detriment of students and their families.
We hope the new administration will take the concerns expressed in this letter seriously and take steps to ensure that OPMs cannot use students and the federal student loan system as a profit center.”
About the Project on Predatory Student Lending
The Project on Predatory Student Lending (PPSL) is the leading legal organization representing student borrowers against predatory for-profit colleges and the policies that enable institutions to exploit and cheat students. PPSL uses bold, strategic litigation and advocacy to demand accountability in the higher education space and influence policy solutions to create a more just and affordable education system. PPSL represents more than one million student borrowers and its work has resulted in cancellation of more than $22 billion of fraudulent student loan debt.
