In addition, in order for a student to be eligible  for Title IV funds, the college must ensure that the student meets the  following requirements, among others: (1) has a high-school diploma or a  recognized equivalent (such as a General Educational Development   certification), or completes a secondary-school education in a  home-school setting as recognized under state law, or is determined to  have an “ability-to-benefit” from the education by a method approved by  Education or a state, or the college; (2) is working toward a degree or  certificate in an eligible program; and (3) is maintaining satisfactory  academic progress once in college. Results of Undercover Testing

The experience of each of our undercover students is unique and cannot  be generalized to other students taking courses offered by the for-profit  colleges we tested or to other for-profit or nonprofit colleges. During the  course of our testing at the selected colleges, we documented our  observations related to the following phases of the student experience:  enrollment, cost, financial aid, course structure, substandard student  performance, withdrawal, and exit counseling. In addition, on the basis of  our observations for the courses we tested, 8 of the 15 colleges appeared  to follow existing policies related to academic dishonesty, exit counseling,  and course grading standards. At the 7 remaining colleges, we found  mixed results. Of the 7  colleges, as discussed below, instructors at 2 colleges appeared to act in  a manner inconsistent with college policies regarding academic  dishonesty, instructors at 4 colleges appeared to act in a manner  inconsistent with course grading standards, and 3 colleges appeared to  act in a manner inconsistent with federal regulations on exit counseling. Enrollment: We attempted to enroll undercover students at 15 colleges,  and were successful in enrolling at 12. Two colleges (Colleges 13 and 14)  declined our student’s request for enrollment based on insufficient proof  of high-school graduation. College 15 stated that it  did not accept any home-school credentials but accepted our fictitious  closed-school diploma and allowed us to begin class, but rescinded our  acceptance after 1 week of classes, stating a lack of high-school  accreditation as the reason for expulsion. Only 10 of our students actually received federal loan  disbursements, according to documentation we received; the other 2  students were expelled without the college requesting or receiving any  federal student aid funds (Colleges 3 and 12). In no instances did we observe that a  college collected federal student aid funds after the withdrawal date of  any of our students (that was not fully refunded immediately). Our students took 31 classes in total at an average cost of $1,287 per  class. These costs included such items as tuition, books, and technology  fees. Since our students were just starting their  respective programs, most classes were introductory in nature, such as  Introduction to Business, Introduction to Computer Software,  Keyboarding, and Learning Strategies and Techniques. Individual  courses ranged in length from 4 weeks to 11 weeks, and our students  took from 1 to 4 courses concurrently. Examples of Instructor or College Behavior Not in Accordance with  Policies or Standards    At College 4, our student submitted work in one class that did not  meet the requirements of the assignment (such as photos of political  figures and celebrities in lieu of essay question responses). Withdrawal: Generally, our students who were not expelled for  performance or attendance reasons were able to withdraw from their  respective colleges without incident. Two of our three expelled students received  no federal student loans and therefore their colleges were not required to  provide federally mandated exit counseling (Colleges 3 and 12). We have referred the names of  the colleges that did not provide exit counseling to the Department of  Education. Appendix I: Objectives, Scope, and Methodology

Because of your interest in the student experience at for-profit colleges,  we agreed to conduct undercover testing by enrolling in online classes  under degree-granting programs. We selected 15 for-profit colleges and,  once enrolled, engaged in behaviors consistent with substandard  academic performance. However, there exists a possibility that tested entities  were able to determine that our students were fictitious and therefore  altered their behavior based on the assumption that they were under  observation. Finally, we selected the remaining 9 for-profit colleges using a systematic  selection process. At each of the 15 selected colleges, we attempted to enroll using fictitious  identities and one or two possible fictitious pieces of evidence of high- school graduation–a home-school diploma or a diploma from a closed  high school. We enrolled in each college for  approximately one term, as defined by the college. To engage in behaviors consistent with substandard academic  performance, we used one or more of the following strategies for each  student: (1) failure to attend class, (2) failure to submit assignments, (3)  submission of objectively incorrect assignments (e.g, submitting incorrect  answers on multiple-choice quizzes), (4) submission of unresponsive  assignments (e.g., submitting pictures when prompted to submit an  essay), and (5) submission of plagiarized assignments.
Why GAO Did This Study

Once comprised of local, sole-proprietor ownership, the nation's for-profit institutions now range from small, privately owned schools to publicly traded corporations. Enrollment in such colleges has grown far faster than in traditional higher-education institutions. Moreover, during the 2009-2010 school year, for-profit colleges received almost $32 billion in grants and loans provided to students under federal student aid programs, as authorized under Title IV of the Higher Education Act of 1965, as amended. Because of interest in the student experience at for-profit colleges, GAO was asked to conduct undercover testing by enrolling in online classes under degree-granting programs. To conduct this testing, GAO selected 15 for-profit colleges using a selection process that included the 5 largest colleges and a random sample and attempted to enroll using fictitious identities. Once enrolled, each fictitious student engaged in behaviors consistent with substandard academic performance. Each fictitious identity enrolled for approximately one term, as defined by the college. The experience of each of GAO's undercover students is unique and cannot be generalized to other students taking courses offered by the for-profit colleges we tested or to other for-profit or nonprofit colleges. GAO intended to test colleges that were unaware of its true identity. However, there exists a possibility that these colleges identified GAO's fictitious students and altered their behavior based on the assumption that they were under observation. This product contains no recommendations. Where applicable, GAO referred information to the Department of Education for further investigation.

What GAO Found

During the course of undercover testing, GAO documented its observations related to enrollment, cost, financial aid, course structure, substandard student performance, withdrawal, and exit counseling. Overall, GAO observed that 8 of the 15 colleges appeared to follow existing policies related to academic dishonesty, exit counseling, and course grading standards. At the 7 remaining colleges, GAO found mixed results. For example, one or more staff at these colleges appeared to act in conflict with school policies regarding academic dishonesty or course grading standards, or federal regulations pertaining to exit counseling for student loans, while other staff acted consistent with such policies. Enrollment: GAO attempted to enroll its students using fictitious evidence of high-school graduation--either a home-school diploma or a diploma from a closed high school--at all 15 colleges and successfully enrolled in 12. Two declined GAO's request for enrollment based on insufficient proof of high-school graduation. Another allowed GAO's student to begin class, but rescinded acceptance after 1 week, citing lack of high-school accreditation. Cost and Financial Aid: GAO's students took 31 classes in total at an average cost of $1,287 per class. These costs included such items as tuition, books, and technology fees. All 12 students were eligible for federal student aid, but only 10 actually received disbursements; the other students were expelled without receiving disbursements. We did not observe that a college collected federal student aid funds after the withdrawal date of any of our students (that was not fully refunded immediately). Course Structure: GAO's students were enrolled in introductory classes, such as Introduction to Computer Software and Learning Strategies and Techniques. Courses ranged in length from 4 to 11 weeks, and students took from one to four courses concurrently. Courses generally consisted of online discussion forum postings; writing assignments; multiple-choice quizzes and exams; and skills exercises, such as keyboarding tests or computer exercises. Substandard Academic Performance: GAO's students engaged in substandard academic performance by using one or more of the following tactics: failure to attend class, failure to submit assignments, submission of objectively incorrect assignments, submission of unresponsive assignments, and plagiarism. At 6 colleges, instructors acted in a manner consistent with school policies in this area, and in some cases attempted to contact students to provide help outside of class. One or more instructors at 2 colleges repeatedly noted that the students were submitting plagiarized work, but no action was taken to remove the student. One or more instructors at the 4 remaining colleges did not adhere to grading standards. For example, one student submitted photos of celebrities and political figures in lieu of essay question responses but still earned a passing grade. Withdrawal and Exit Counseling: Three of GAO's students were expelled for performance or nonattendance. Eight of the 9 students withdrew from their respective colleges without incident. At the remaining school, GAO's request to withdraw was never acknowledged and the student was eventually expelled for nonattendance. 3 students did not receive federally mandated exit counseling, advising students of repayment options and the consequences of default.