FRAUD BOGUS DOCUMENTS AND INSTITUTIONS
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1 UNICA Recognition Workshop, Lausanne, 31 March - 1 April, 2006 FRAUD BOGUS DOCUMENTS AND INSTITUTIONS Presenter: Contents: Ms. Ann M. Koenig Southwest Regional Director, Credential Evaluation Services Introduction: Why is Fraud a Problem? Documentation Request and Review Suspicious Documents from Recognized Institutions Suspicious Institutions: Diploma Mills Resources and References AACRAO, the American Association of Collegiate Registrars and Admissions Officers, was established in 1910 as a non-governmental, non-profit professional membership association. Today it represents more than 9000 individuals working in the areas of enrollment and student records management, from about 2300 institutions in the United States and over 35 other countries. AACRAO International Education Services support the international admissions and student record management work of higher education institutions, through research and publication, training programs, foreign credential evaluation services, and consulting services. Ann M. Koenig has worked with AACRAO since Over the last 18 years she has worked in three private foreign credential evaluation services in the United States, and held positions in admissions, student records management and academic advising at Cardinal Stritch University (Milwaukee, Wisconsin), University of Maryland University College program in Schwäbisch Gmünd, Germany, Golden Gate University (San Francisco), and the University of California, Berkeley. Ms. Koenig is an active member of AACRAO, NAFSA: Association of International Educators, and EAIE. She is the author of An Overview of the Educational Systems of Albania (ECE, 1993), co-author of the PIER report on Poland (1992), and contributor to A Guide to Educational Systems Around the World (NAFSA, 1999), Foreign Educational Credentials Required, 5 th Edition (AACRAO, 2004), and AACRAO s quarterly journal College and University. As a specialist in the regions of east/central Europe and Eurasia, she is currently writing for an AACRAO book on the educational systems of Central Asia. Ms. Koenig has given numerous presentations on topics related to educational systems, credential evaluation, best practices, document fraud and diploma mills. She works with an international group of researchers from the education, government, security and consumer protection sectors who informally call themselves the fraud busters and give presentations and workshops at AACRAO, NAFSA, EAIE and many other conferences. Articles written by Ms. Koenig and her fraud buster colleagues will be featured in a new AACRAO guidebook on bogus documents and institutions to be published in AACRAO INTERNATIONAL EDUCATION SERVICES Main Office: One Dupont Circle NW, Suite 520 Southwest Regional Office, Scottsdale, Arizona: Washington DC Ann M. Koenig, Southwest Regional Director Tel: Fax: Tel: , Fax: Web: [email protected] [email protected] 1
2 INTRODUCTION: Why is fraud a problem? Why is verification of suspicious documents and institutions important? Ethical Reasons When applicants or students at a higher education institution are able to reach their academic goals on the basis of unexamined, suspicious or fraudulent documentation or when individuals receive favorable evaluations of foreign degrees or diplomas based on inauthentic documents - the result is wholesale encouragement and reward of fraud. The higher education institution (HEI) or the foreign degree evaluation service becomes a passive supporter of the fraudulent activity. This devalues the quality of the education at the institution and the diplomas or degrees in that country. It also identifies the institution or agency as an easy target for future fraudulent activity. Legal Reasons By not checking thoroughly on documentation presented by applicants, students, or foreign degree holders, institutions or evaluation agencies might not be upholding their legal responsibilities. If an HEI, whether public or private, has been given permission by immigration authorities to enroll international students, but does not carefully review their papers, the HEI could be violating the law. If an evaluation office does not check on the authenticity of diplomas and degrees, it could have legal liability in cases where fraud is discovered. In most countries, being a part of legal systems that regulate migration, immigration, short-term stays by non-citizens, use of credentials for employment, etc., gives HEIs and evaluation services legal obligations. Practical Reasons The reputation of an HEI, an evaluation office, or even a whole country suffers when the word gets out that it supports fraud, either passively by not being diligent, or actively by encouraging fraud. Good, honest students or applicants stay away; dishonest students or applicants find a home. And fraud is expensive; dealing with fraudsters takes time, money, and human and other resources away from honest applicants, and the process of trying to fix a problem case, or rebuild an entire reputation, uses resources that could have been spent much more wisely. Source: Devlin, Edward: Why Verification of Suspicious Foreign Records is Important, AACRAO College and University quarterly journal, Spring 2002, pp , What is the solution? Be PROACTIVE. Be prepared for FRAUD.! Educate yourself and your colleagues. Become knowledgeable about educational systems, documentation practices, and events that impact on education. Learn how to identify, collect and effectively use reliable sources of information. Take fraud seriously. Do not rely on lists, but rather learn how to analyze and research documents to confirm the documents that applicants or students present.! Establish a standard approach to reviewing and evaluating documents.! Include a verification procedure in every case. The level of research needed to confirm the documentation can vary from case to case, but every document should be confirmed.! Establish policies regarding fraud and inform your applicants of the consequences of presenting bogus documentation. Share information with your colleagues. We must work together to BE A PART OF THE SOLUTION! 2
3 Documentation Request and Review Goal 1: Assemble a complete file of acceptable, authentic documentation. A. Determine what documentation is needed, based on the purpose of the evaluation.! Outline what type of documentation is required from each country in order to reach a decision. Learn as much as you can about the record-keeping practices of the countries from which you receive large numbers of students, so that the requirements that you set are appropriate.! Ask for the applicant s educational history, beginning with the start of secondary school.! Establish a policy on the use of translations in the evaluation process.! Build a reference collection to help you keep up to date in this area print and Internet resources on country and documentation information, file copies of authentic documents, network of trusted colleagues. B. Be proactive. Provide clear information to applicants about the document requirements.! Be precise and clear about the documentation required; how and when documentation is to be received by the institution; whether any documentation will be returned to the applicant; what to do if the student has documentation that will never be re-issued as an original document. Use indigenous terminology for the documentation. Give clear guidance as to how the applicant can request official documentation and have it sent to you.! Make it your goal to receive a complete file of appropriate documentation from every applicant without having to do a follow-up request for additional/different documents and establish your communication and processing systems to support this goal.! Establish a consistent procedure for follow-up on incomplete application files and communicate it to applicants clearly. C. Establish guidelines on how to handle cases in which documentation appears to be unavailable. It is very rare that no documentation exists, but events such as war and natural disasters do sometimes destroy records. Cases in which these might be a factor should be handled on an individual basis within your institution s established guidelines. In such cases, it is essential to have a network of resources for information on the current situation in the area and assistance in establishing communication with authorities in the effected area. D. Establish guidelines for the consequences of submitting falsified, altered, forged, fraudulent, bogus documentation or information, and communicate those consequences to applicants clearly. Goal 2: Determine the level of authenticity of the documentation. A. Establish a methodical approach to document review and follow it consistently.! Review all documents submitted by applicants with care.! Reconstruct the applicant s life story using biographical data, educational history and the academic documents. Arrange the documents in chronological order and compare to the person s life story.! Using reliable resources, confirm the information presented on the documents: Name, location and recognition status of the institution * Dates of attendance * Level and type of program of study and curriculum * Grades, marks, or other performance assessments * Course credits or weighting * Award of a credential. B. If you find discrepancies or inconsistencies, investigate!! Document: Is a document from a recognized institution questionable? Request verification!! Institution: Is the status of the institution questionable? Confirm its status! 3
4 Suspicious Documents from Recognized Institutions: The Process of Requesting Verification Step 1: Preparing a Request for Verification Preliminary Steps:! Using reliable resources, identify the party to whom the verification request should be sent.! Locate the appropriate contact information for this office or person.! Consider the most effective way to send the request (postal service, fax, , etc.).! Consider which language to write in to get official information and to facilitate a timely response. Composing the Request:! Consider creating a standardized form or letter for verification requests. Customize it as necessary for each case, taking into consideration the culture of official correspondence of the country.! Clearly indicate the request for verification in the opening of the letter, and give identifying information about the document holder so as to make the person s identity clear.! Introduce yourself, your institution, and the reason for the evaluation.! Make a copy of the documentation and enclose it with the letter.! Be clear and specific about what information you need to receive from the verifier. Include a reference code (identifying information for you) and ask the verifier to include it in the response.! Ask for the verifier s name, title, and contact information, for follow-up in this case or future reference.! Include your contact information for the response.! Request confidentiality.! Thank the reader and offer to assist in the future with information from your institution or office. Communicating with Applicants about Requests for Verification:! This calls for a good bit of psychology and professional judgment, considered on a case-by-case basis.! Options range from informing the applicant about the inconsistencies in the documentation to saying nothing at all, depending on what role you think the applicant might play in the suspected fraud situation.! Consult and work with trusted, experienced colleagues to develop good professional judgment. Step 2: Tracking the Verification Process Create a Verification file where you can track and maintain notes on each case, and crossreference these files with other files for the individual. Save originals of all correspondence, including envelopes, courier receipts, etc. Keep them in plastic folders so as to avoid damage or contamination. Use the Verification file as a resource for valuable information. Step 3: Processing the Response and Taking Follow-Up Action Assessing the Response! What is the source of the response? Where/whom did it come from? Is it official?! Is the information provided complete? Conclusive? If not, what further action needs to be taken?! What if the verifying authority requests further information or documentation from the evaluator? What if a verification fee is requested? Acting on Conclusive Confirmation of Fraudulent Documentation! Act quickly to follow up according to the policies and protocols your institution has established. 4
5 Tracking the Verification Process using your Verification File! Use the Verification File to keep notes about the verification process, as well as documentation on each case.! Review the circumstances of the verification process in each case, and incorporate any new twists, perspectives or reflections into your institution s approaches to verification cases. Phase 4: Sharing Verification Success and Information with Your Colleagues Help protect the integrity not only of your institution, but the whole higher education community, by letting your colleagues know the details of your verification success stories. Solidarity in being proactive and getting the word out to colleagues is a powerful tool to help fight fraud! SAMPLE VERIFICATION REQUEST LETTER Re: Request for verification of documentation of XXX Dear Sir / Madam / Colleagues: XXX has applied for admission/transfer credit at our institution. A copy of the XXX that he / she submitted is / are enclosed. Would you please review this documentation and confirm below whether or not it is authentic, then sign and date where requested, and stamp or seal it with your office s official stamp/seal. Yes, this documentation is authentic. It accurately reflects the institution s official record. No, this documentation is not authentic. Signed Name (in print) & Title Date Official seal/stamp of the office Fax number / address for further contact: Then please return this letter to us by fax or by postal service at the following address: XXXX We appreciate your cooperation and thank you for your assistance. Sincerely, 5
6 Suspicious Institutions: Diploma Mills What is a diploma mill? What do we mean by bogus institutions? A diploma mill or degree mill is an organization or individual that! produces and sells diplomas, degrees, transcripts, or other academic records that are! meant to give the impression of academic achievement, but really represent little or no study. Such credentials are bogus fakes that give a false impression of educational achievement.! Worthless documents from bodies that are not real, or not recognized, educational institutions! Fraudulent misrepresentations of documents issued by legitimate institutions Why is the problem of diploma mills so widespread? Some reasons include:! high value of academic credentials in the employment sector; market value! low risk of being caught due to low level of scrutiny! low risk of legal action if caught, because of legal loopholes! easy to obtain by Internet! lower cost than for a bona fide education (money, time, effort, stress, etc.) How do diploma mills operate? Look for the red flags. Diploma mills operate in many of the same ways that other fraud operations work by imitating legitimate activity. Diploma mills make themselves look like real universities.! Name: The institution has a distinguished or traditional sounding name, or a name similar to a well-known or legitimate institution. Take-offs on British names, and the names of reputable institutions in the US, are marketable: University of Palmers Green, Ashford University, University of Dorchester, variations on Oxford, Cambridge, Berkeley, Stanford.! Physical location: The university has a Web site but there is no evidence, or there is conflicting information, about its actual physical address. It gives the impression of being a foreign university, but may be operating in a completely different place. It uses edu, ac, or uk in the URL, giving the impression of being a US or British institution. The only way to contact the university is by sending your contact information.! Recognition: The Web site includes false, misleading or meaningless claims of accreditation, recognition, affiliation, membership, or other types of status that are meant to give the impression of legitimacy, but really mean nothing in the legitimate higher education community.! Speedy degrees: The amount of time required to get the degree is suspiciously fast. A large amount of credit, or the whole degree, might be given based on life experience only; send us your CV and receive a degree.! Costs: The Web site shows a lump sum costs for the various degrees and transcripts. Different rates might be charged for including specific courses, grades, majors, etc. on the transcript. Payment may be acceptable by credit card. There might be special deals or discounts if one buys now.! Sample documents: Samples of diplomas and transcripts are shown on the Web site.! Groups of diploma mills: Several university Web sites may operate from the same computer. You can do a who is search to find the IP (Internet Protocol) address and owner of the Web site, then search for Web sites with the same IP address. 6
7 Diploma Mills Exploit Issues of Recognition and Accreditation Some ways include claiming:! That accreditation or recognition is not needed, not important, too subjective or otherwise not appropriate, not in line with the institution s mission or philosophy, etc. This is less prominent now than in the past. Now more diploma mills claim to be accredited by bogus accreditors.! Accreditation from an unapproved or bogus accreditor. Instead of fighting accreditation as in the past, many diploma mills simply created their own accreditors. Problem solved!! To be accredited by an organization whose name sounds very similar to that of one of the approved US regional or national accrediting associations.! To be authorized by, recognized by or affiliated with a U.S. organization that has no authority in the sphere of education. (e.g. Member of Better Business Bureau; licensed by the State of..)! To be authorized or recognized in a country outside of the U.S. by a body that has no authority in the sphere of education (or is not recognized by the body that does have authority), or in a country/entity that has no legitimate body for supervising education or supervising higher education. Examples: National Board of Education in Liberia, a bogus entity; some cantons of Switzerland (that have no higher education); several Caribbean islands; some Pacific islands. What makes a higher education institution or degree legitimate? How do you confirm the status of the institution? A. In the United States - Accreditation:! Accreditation is the process of quality control and the mechanism for mutual recognition. It is nongovernmental, voluntary, peer-review process.! Regional or national accreditation of the institution as a whole! Professional or program accreditation of programs of study offered by regionallyaccredited institutions! The process of legally establishing an educational institution is regulated by law in each state. However, having legal permission to operate is NOT equivalent to being accredited.! Accrediting associations are reviewed and approved the US Department of Education and the Council for Higher Education Accreditation (CHEA). The accreditation status of an institution or program of study can easily be verified by contacting CHEA or the US Department of Education.! In general, regionally-accredited institutions only accept degrees and credits from other regionallyaccredited institutions. This is why appearing to be regionally accredited is important to diploma mills. Resources: Council for Higher Education Accreditation (CHEA): - See links Degree Mills and Accreditation and Database of Institutions and Programs Accredited by Recognized US Accrediting Organizations on the CHEA home page. US Department of Education: Office of Postsecondary Education Database of Institutions and Programs Accredited by Agencies and State Approval Agencies Recognized by the US Secretary of Education: Diploma Mills and Accreditation: 7
8 The six US regional accrediting associations: Middle States Association of Colleges and Schools (MSA) Delaware, District of Columbia, Maryland, New Jersey, New York, Pennsylvania, Puerto Rico, US Virgin Islands, Overseas New England Association of Schools and Colleges (NEASCSC) Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, Overseas North Central Association of Colleges and Schools (NCA) Arizona, Arkansas, Colorado, Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri, Nebraska New Mexico, North Dakota, Ohio, Oklahoma, South Dakota, West Virginia, Wisconsin, Wyoming, institutions of the Navajo Nation Northwest Association of Schools, Colleges and Universities (NW) Alaska, Idaho, Montana, Nevada, Oregon, Utah, Washington Southern Association of Colleges and Schools (SACS) Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, Virginia, Extraterritorial Western Association of Schools and Colleges (WASC) California, Hawaii, US-affiliated Pacific islands, Pacific basin, east Asia B. In Many Other Countries Government Recognition:! In most countries, education is regulated by national or regional law and governments are responsible for the establishment, funding, operation, administration and supervision of educational institutions. Public institutions, as well as private institutions that have the same legal standing as public institutions, are officially recognized.! The evaluator must determine whether a foreign institution is recognized as a degree-granting institution by the appropriate legitimate educational authority in its own location, according to its legal and quality assessment systems for institutions offering bona fide academic awards. Recent Developments: Bogus Services Have Expanded Some diploma mills now also offer:! US high school diploma / high school equivalency credentials! Degree and transcript verification services! Foreign credential evaluation services, if the diploma mill purports to be a foreign institution! Apostille services, if the diploma mill purports to be a foreign institution Resource: Accreditation Mills by Allen Ezell, article in AACRAO C & U quarterly journal, Summer
9 Electronic Tools for Researching Red Flags Tool The entity s Web site look for the red flags Identity of the owner of the Web site (IP search) Location: Reverse address look-up (USA) Royal Mail Web site (UK) Reverse phone number look-up (USA) Satellite maps Accreditation / recognition Play the game yourself respond to spam, show interest in obtaining a degree, collect and document the information you receive Example IP Who Is Google Earth Check resources listed above Several Some International Approaches to Fighting Diploma Mill Fraud Itay: Italy's internet dottores risk jail: Japan: NHK-TV, public TV station in Japan, produced an episode of its program Gendai: Close Up on the topic of diploma mills, featuring taping at the Diploma Mill workshop at the AACRAO 2005 Annual Conference in New York City and interviews with Allen Ezell and George Gollin, and trips around the US to visit purported diploma mill operators. The program aired in Japan in Japanese. Liberia: Ministry of Education Identifies Illegal Learning Institutions: Government Finally Closes St. Luke [medical school]: Netherlands: Ministry of Education, Culture and Science launches Web site in July 2005 to inform educational institutions, employers and the general public about the problem of diploma mill fraud: (in Dutch) Sweden: Bluffuniversitet och falksa examsbevis Sverige och världen (Fake Universities and Bogus Degrees Sweden and the World) report published by the Swedish National Agency for Higher Education (in Swedish) summary in English: Caribbean off-shore medical schools: Chronicle of Higher Education international feature section on off-shore medical schools, levels of regulation of Caribbean medical schools, watchdog groups, maps October 28, Sun, Sand and an M.D. Offshore Medical Schools Operate with Minimal Oversight A Hissing Match on Bonaire A Pioneering Offshore Medical School Gains Credibility The Egg Man and Other Anti-Fraud Activists 9
10 Diploma Mill Resources and References from the United States Degree Mills: The Billion-Dollar Industry that has Sold over a Million Fake Diplomas by Alan Ezell and John Bear Prometheus Books, 2005, US $25: Special Report: Degrees of Suspicion published by Chronicle of Higher Education, June 25, 2004: The Scourge of Fake Diplomas, Degree Burns, by Clay Risen, The New Republic, January 23, 2006 Degree.net Web site by Ten Speed Press - ; Consumer-oriented articles on issues in US higher education, including diploma mills and accreditation, presented by the publisher of the Bears Guides (see below under John Bear). U.S. Federal Trade Commission: Avoid Fake Degree Burns by Researching Academic Credentials: Degree Mills: Degrees of Deception: Fraud and Education: The Worm in the Apple, Harold J. Noah and Max A. Eckstein, Rowman & Littlefield Publisher, Inc., 2001 Don t Judge a College by Its Internet Address, Chronicle of Higher Education, Nov. 26, 2004: Also by John Bear, Ph.D., internationally-known expert on diploma mill activity: Diploma Mills The $200 Million a Year Competitor You Didn t Know You Had, John Bear, Ph.D., 2001: The Bears Guides published by Ten Speed Press. These books list many fake, substandard and dubious institutions and their equally fake, substandard and dubious accreditors. Available from the publisher and many commercial booksellers. Older editions are sometimes available through used book Web sites. Also by Allen Ezell, retired FBI agent and diploma mill expert: Testimony to the US federal Committee on Education in the Workforce, Subcommittee on 21st Century Competitiveness on the topic Are Current Safeguards Protecting Taxpayers Against Diploma Mills? Articles in AACRAO C & U quarterly journal: Diploma Mills Past, Present, and Future, Winter 2002; Transcript Fraud and Handling Fraudulent Documents, Winter 2005; Accreditation Mills, Summer 2005 By George Gollin, University of Illinois at Urbana-Champaign physics professor and diploma mill researcher: Unconventional University Diplomas from Online Vendors or Fraud, Corruption and Scandal: Buying a Ph.D., August Overview of how diploma mills operate - Information Resources Concerning Unaccredited Degree-Granting Institutions, compilation of various resources, including news items and public legal documents: By Alan Contreras, State of Oregon, Office of Degree Authorization: Diploma Mills. Oregon Student Assistance Commission, Office of Degree Authorization: A Case Study in Foreign Degree (Dis)approval, International Higher Education, Summer 2003, Center for Higher Education, Boston College: International Diploma Mills Grow with the Internet, International Higher Education, No 24, Summer How Reliable is National Approval of University Degrees?, International Higher Education, No 29, Fall
11 From Other Sources: Degree duplicity by Mark Clayton, The Christian Science Monitor, June 10, 2003: United States Government Accounting Office Purchases of Degrees from Diploma Mills Fake School Reveals Holes in Loan Program, CNN.com Chairman Collins: Loophole Allows Taxpayer Dollars to Pay for Federal Workers Diploma Mill Degrees. Selected Resources for Foreign Credential Evaluators Ministry of Education Web sites (Governments on the Web: World Higher Education Database, International Association of Universities: ENIC-NARIC Network: Eurybase 2001: Anabin, database of country information from the German ENIC-NARIC: Country Education Profiles, Australian Education International: Association of African Universities: Association of Commonwealth Universities: - ACU Members Unión de Universidades de América Latina: South East European Education Cooperation Network: EAIE Resources: Admissions Officers and Credential Evaluators (ACE): (ACE materials from conference presentations); ACE External Web site: (many valuable resources for credential evaluation) AACRAO Resources: AACRAO publications [World Education Series, AACRAO Country Guide Series, PIER Reports on country/regional educational systems, Foreign Educational Credentials Required (2003)]: AACRAO Annual Meetings, handout materials from conference presentations; AACRAO International Education Services: NAFSA: Association of International Educators: Admissions and Credential Evaluation Network: d_credential; OSEAS-ADSEC Link Project, ADSEC home page: Education Systems Worldwide: NAFSA ADSEC Bibliography through 2000: publication A Guide to Educational Systems Around the World, 1999 National outreach and student advising networks in other countries Examples: British Council: DAAD: EducationUSA network: Publications from governmental and non-governmental organizations in other countries Country experts, authors of country/regional resource works, conference presenters, workshop leaders, consulates/embassies, institutional contacts within the country. 11
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