For Immediate Release                                           

Tanya Ang – (202) 838-5050
Walter Ochinko – (202) 838-5050

August 19, 2020

New Analysis Finds Proprietary Colleges, Including Some with a History of Misleading Marketing, Are Using the COVID-19 Pandemic in Facebook Advertising Campaigns

 Veterans Advocacy Group Urges Oversight by Policymakers of Schools with a History of Misleading and Aggressive Recruiting

Washington, DC – A report released today by Veterans Education Success shows that more than two dozen proprietary postsecondary institutions are using the COVID-19 pandemic and the uncertainty around on-campus college programming this fall in their advertising and marketing campaigns. Most schools tout their online degree program and some of the advertising targets veterans and military-connected students. At least twelve of the institutions have settled charges for misleading recruiting tactics in the past.

Veterans Education Success examined the social media ads of 27 schools appearing between February and April 2020 on Facebook, Instagram, Facebook Messenger, and Facebook’s Audience Network, an interest sparked by increased social media marketing after states began a pandemic lockdown. Kivvit, a company that designs and manages advertising campaigns for clients, analyzed the Facebook advertising of 416 nonprofit and proprietary U.S. higher education institutions between March 12 and May 19, 2020, and found a 7 percent increase during the pandemic.

The 27 schools studied by VES were chosen based on one of four factors: 1) were profiled in the U.S. Senate Committee report on proprietary schools (2) had faced law enforcement action for consumer protection violations (3) were promoted by lead generation companies that may not adequately disclose to students the companies’ paid relationship to the schools they promote or (4) converted from proprietary to nonprofit status or were acquired by a public sector institution.

Among the major findings of the report were that ads by more than half of the 27 schools referenced—directly or indirectly—the COVID-19 pandemic. Many ads appeared to feature COVID-19 pandemic imagery or directly referenced the pandemic. Ads also featured degrees or certificates in healthcare, a nod to the national attention focused on our healthcare workforce, whose heroic work has been hailed during the pandemic. The ads followed a familiar script in promising low tuition, scholarships, the ease of transferring credits, and online instruction.

“We have been here before and need to be vigilant to ensure that history doesn’t repeat itself,” said Carrie Wofford, president of Veterans Education Success. “During the last recession, many proprietary schools targeted veterans and underserved minorities, encouraging them to enroll with the promise of a high-quality education and great job prospects. In reality, many students were saddled with worthless degrees and mountains of student loan debt. Many of these schools’ healthcare programs charged students a hefty tuition for careers that required only a high school diploma. Oversight by policymakers is warranted.”

We identified six common advertising approaches used by 27 schools in their advertising:

  • Ads referenced, or appeared to reference, the COVID-19 pandemic, either through indirect reference (e.g., ads discussed homeschooling during “uncertain times” or praising “healthcare heroes”) or mentioned COVID-19 directly;
  • Ads featured healthcare-specific roles and appeared to target prospective students interested in working in healthcare;
  • Ads touted an institution’s online programs and referencing the benefits of online learning;
  • Ads promised low cost or scholarships;
  • Ads referenced the ease of transferring credits from another institution; and
  • Ads appeared to target servicemembers and veterans, a frequent target of proprietary schools because of the 90/10 loophole, which allows proprietary schools to circumvent the cap on Title IV funds the schools would otherwise face by counting GI Bill and military tuition assistance as non-federal revenue. It is worth noting that the majority of the ads also appeared to target underserved minorities.

Proprietary colleges are incentivized to target servicemembers and veterans for enrollment because of a loophole in the “90/10 rule,” a federal law that limits proprietary schools from receiving more than 90 percent of their revenue from Title IV federal student aid. GI Bill and active duty military tuition assistance are not listed in the statute, a loophole that colleges have exploited to use veterans’ and servicemembers’ funds to offset the cap on federal funds the schools otherwise face. As a result, for every $1 of military-connected student benefits a school receives from Veterans Affairs or the Department of Defense, it can collect $9 more from Title IV funding.

The study comes at an important time because, according to a separate but related report by Veterans Education Success, postsecondary enrollment typically spikes during an economic downturn. The report notes that the experience of the past 12 years and the recession of 2007-2009 suggests the need for vigilance as unemployment mounts and some schools sense an opportunity to profit from the impact of the pandemic-induced recession on postsecondary enrollment. VES also points out after examining the outcome of the last recession that “only 39 percent of students who enrolled in a two-year institution in 2008 had a degree six years later,” according to the National Student Clearinghouse. In essence, they encourage all students and those using their GI Bill money to do their homework when choosing the right education for them.

Read the entire report on postsecondary COVID-19 advertising for detailed information.


Veterans Education Success is a veteran advocacy organization whose mission is to advance higher education success for veterans, service members, and military families, and to protect the integrity and promise of the GI Bill and other federal education programs. The organization offers free legal services, advice, and college and career counseling to servicemembers, veterans, their survivors, and families using federal education benefits – and helps them participate in their democracy by engaging with policymakers. Veterans Education Success also provides policy expertise to federal and state policymakers, and conducts non-partisan research on issues of concern to student veterans, including student outcomes and debt levels. Additional information is available at