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1 Competing for the Cyber-Savvy; challenging the competitor you never knew you had. George M Brown Academic Director – Le Cordon Bleu Australia Pty Ltd – http://www.lecordonbleu.com.au Director - Degreeoftruth Pty Ltd – http://www.degreeoftruth.com.au Days Road, Regency Park, South Australia, Australia 5010 Abstract This paper, coupled with an online virtual presentation, seeks to provide tools and strategies for Australian higher education providers to protect and differentiate their educational products in an increasingly confusing online market. The presentation will argue that whilst young prospective candidates for higher education may be perceived as being ‘cyber savvy’, those seeking information and considering enrolment in online courses are still confused about terms such as ‘accredited’, ‘approved,’ or ‘authorised’. The writer suggests that the Internet has fuelled this problem by providing an anonymous, cost-effective marketing environment whereby any individual may tap into this lucrative market and provide programs of instruction which are not equivalent to those traditionally offered by established universities. As a policy background, the paper will profile the evolution of virtual universities, the proliferation of these Internet providers, and the difficulties consumers are faced when trying to differentiate legitimate virtual universities from online degree/diploma mills. In searching for strategies to solve this dilemma, a selection of common characteristics degree/ diploma mills possess will be provided. The paper will then explore the marketing strategies and tactics employed by some of these organizations and discuss how Australian providers can best learn from their online expertise. The paper concludes by over viewing the steep increase in degree/diploma mill activity on the Internet. Highlighting the new policy initiatives initiated by the Australian Government to protect Australia's higher education sector, the paper will argue for further proactive monitoring of virtual university activity on the Internet so as to ensure policy initiatives are effectively implemented, monitored, and refined. Key Words Virtual Universities Degree Mills Diploma Mills Accreditation Online Marketing Introduction ‘Low-rent unis spin Webs of secrecy’, ‘Not worth the paper’, ‘The plague of fake unis’, ‘Mail-order Bachelors’, ‘Is your degree fake?’ These are but a few of the myriad of headlines adorning the front pages of Australian education publications over the past few years and, more recently, in the last six months. Is the media over-

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Competing for the Cyber-Savvy; challenging the competitor you never knew you had.

George M Brown

Academic Director – Le Cordon Bleu Australia Pty Ltd – http://www.lecordonbleu.com.au

Director - Degreeoftruth Pty Ltd – http://www.degreeoftruth.com.au

Days Road, Regency Park, South Australia, Australia 5010

Abstract This paper, coupled with an online virtual presentation, seeks to provide tools and strategies for Australian higher education providers to protect and differentiate their educational products in an increasingly confusing online market. The presentation will argue that whilst young prospective candidates for higher education may be perceived as being ‘cyber savvy’, those seeking information and considering enrolment in online courses are still confused about terms such as ‘accredited’, ‘approved,’ or ‘authorised’. The writer suggests that the Internet has fuelled this problem by providing an anonymous, cost-effective marketing environment whereby any individual may tap into this lucrative market and provide programs of instruction which are not equivalent to those traditionally offered by established universities. As a policy background, the paper will profile the evolution of virtual universities, the proliferation of these Internet providers, and the difficulties consumers are faced when trying to differentiate legitimate virtual universities from online degree/diploma mills. In searching for strategies to solve this dilemma, a selection of common characteristics degree/ diploma mills possess will be provided. The paper will then explore the marketing strategies and tactics employed by some of these organizations and discuss how Australian providers can best learn from their online expertise. The paper concludes by over viewing the steep increase in degree/diploma mill activity on the Internet. Highlighting the new policy initiatives initiated by the Australian Government to protect Australia's higher education sector, the paper will argue for further proactive monitoring of virtual university activity on the Internet so as to ensure policy initiatives are effectively implemented, monitored, and refined. Key Words Virtual Universities Degree Mills Diploma Mills Accreditation Online Marketing Introduction

‘Low-rent unis spin Webs of secrecy’, ‘Not worth the paper’, ‘The plague of fake unis’, ‘Mail-order Bachelors’, ‘Is your degree fake?’ These are but a few of the myriad of headlines adorning the front pages of Australian education publications over the past few years and, more recently, in the last six months. Is the media over-

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reacting and trying to sensationalize a minor problem, or has the proliferation of virtual degree/ diploma mills on the Internet seriously challenged the integrity of the Australian higher education system? Without doubt, these online entrepreneurs are profiting from these digital ventures, but at what cost to the integrity, credibility and profitability of established Australian higher education providers? This paper, along with the accompanying ‘virtual’ presentation, will seek to discuss these issues and propose a set of proactive measures designed to educate and protect potential students, Australian higher education providers and the Federal/ State higher education agencies. Virtual universities – sorting the wheat from the chaff.

In seeking to characterize the virtual university, it is interesting to analyze the literal meaning of the nomenclature. The word virtual in an educational context is defined by Dolence & Norris (1995: 53) as 'existing in intent and not form' whilst Silvio (1999:1) sees virtualisation as, 'both the process and the result of processing and communicating through computer data, information and knowledge'. Using the two words together could therefore imply that a virtual university is a 'close to the real thing' university provider. Such a simple definition, however, does not lend itself well to the entrepreneurial providers of this new form of university and should be challenged. For example, Gilbert (1996) disagreed with this simple analysis, asserting that the terms 'real' and 'virtual' should not be used as contrasting concepts. Despite this caveat, the definitions of Dolence & Norris (1995) and Silvio (1999) are useful and clear for the purpose of this paper. Clearly the virtual university has become a force to be reckoned with, though Heeger (2000) asserts the online university will not replace the traditional brick-and-mortar institution. Gilbert (1996), Vice Chancellor of the University of Melbourne, has epitomized this view suggesting that, ‘the greatest universities of the twenty-first century will be spatially definable communities that are nevertheless completely at home in cyberspace'. Four years later, Gilbert's predictions became reality with his announcement of Universitas 21 joining forces with News Corporation and Microsoft, some of the most powerful multimedia conglomerates on the planet. Although this proposed alliance did not finally eventuate, another large company, Thompson Learning, embraced the opportunity to partake in this global venture. Gladieux & Swail (1999) found virtual universities as having their roots in correspondence schools (or non-traditional providers). Stuart (1994:3) saw the virtual university as 'not one where virtual reality kits would be required, but the ability of the home based student to experience all of the learning and personal development experiences available to the student who is physically located in a university campus'. Levine (2000:2) concurs, suggesting that with technology advancing at such a rapid pace, this will soon become a reality. He reasons that 'instead of telling students about 15th century Paris, for example, we will take them there. And when a student can smell the smells - which must have been putrid, walk the cobblestones, go into buildings, how will a stand-up lecture compete?' This may not yet be a reality, however, the rapid advances in technology appear to suggest that such experiences may soon be available to the 'virtual learner'. Young (2000) alludes to virtual

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universities in the United States (namely Kentucky Virtual University, Magellan University, Michigan Virtual University and the University of Texas TeleCampus) creating 'virtual football teams', aimed at 'increasing spirit among virtual institutions' (Young 2000:1). Susman (Young 2000:2) the CEO of Kentucky Virtual University, believes the 'next phase is to figure out what games you can play with members anywhere in the world to…create community, so students don't feel so isolated from each other.' Cunningham, Ryan, Stedman, Tapsall, Bagdon, Flew & Coldrake (2000) suggested that the virtual university may be envisaged in two ways: an educational institution offering all conventional university services via the latest communication technologies or as a 'hollow' organisation which has unbundled its services and subcontracted them to other organisations. Cornwell, Kimber & Lewis (1999) see a virtual university as any institution that delivers higher education courses in distance mode making use of electronic telecommunications. Other characteristics within their definition include the lack of attendance of the student on campus, in some cases no physical campus and in some models, the infrastructure and organisations is itself deemed 'virtual' - existing entirely on-line. Furthermore, they suggest that the terms 'virtual university', ‘online university', 'cyber university' and 'global university' are used interchangeably to define the 'university without walls'. Seeing 1995 as the beginning of web based education Sclater (1998:1), suggests that the term 'virtual university' is used to 'describe ventures ranging from the development of web-based courses at 'bricks and mortar' universities to the creation of entirely new enterprises dedicated solely to the delivery of online distance education'. Such a plethora of attempts to characterize a virtual university clearly overlap and do not easily lend themselves to defining what a virtual university is. The flexibility of the Internet with regard to the amount and variety of information able to be transmitted has permitted a diverse range of virtual university models to emerge. In seeking to categorise the models, Krempl (1997) suggested two basic types: the single mode, seen to be a totally virtual environment whereby students complete all course requirements off campus and the dual mode, a model utilising a mix of virtual learning in a traditional on campus setting. Sclater (1998:1) & Whittington & Slater (1998:2) expanded these classifications and assert that virtual universities can be classified under three broad headings; virtual front ends, collaborative ventures and new institutions. In addition to these, Cunningham et al (1997, 2000) performed exhaustive research in the area of the Corporate University model. Dissecting each of these models is important in order to identify the core rationale of this paper: 1) Virtual front ends - these are defined as 'real' universities creating a web

presence for the purposes of providing information to staff and traditional students. Phillips, Wellman & Merisotis (1998) call this model 'enhancements to traditional campus-based instruction'. A separate site may be created to deliver on-line courses from the university. There are many examples that may be found on the Internet as traditional providers move to web based, distance education. These models can be seen as 'going it alone', either using existing staff to convert material for online delivery or employing specialist instructional designers to

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convert material. Michigan State University (http://vu.msu.edu) and the University of South Australia (http://www.unisa.edu.au) are but two examples of the thousands of universities around the world that are venturing down this path.

2) Collaborative ventures - this model is a rapidly emerging trend whereby already established traditional universities combine their marketing strength and academic credibility at one main web entrance. Usually, each individual university in the consortium provides the degree granting authority, accreditation and quality assurance (Lewis 1999). A variation to this is Western Governors' University (http://www.wgu.edu), founded in 1997, which draws upon academic institutions from over 16 states in the USA. WGU has achieved Distance Education and Training Council (DETC) accreditation and now has candidate status for Regional Accreditation from a national consortium of accrediting agencies - an outcome on this accreditation application is still not available. This collaborative model can be seen as useful to devolve risk, whilst concurrently capitalizing on economies of scale resulting from such ventures. Clyde Virtual University (http://cvu.strath.ac.uk) was one of the first examples, bringing together four traditional Scottish universities partly funded by the UK government in 1995. In more recent times there has been a significant rise in this form of model; the most recent examples are Universitas 21 (http://www.universitas.edu.au), University of Phoenix, Western Governors, Next Ed (collaborating with Stanford University, the University of Southern Queensland (of which 75% of its student body study online), the Global University Alliance (http://www.gua.com) and the Australian Catholic University and La Trobe University.

3) Corporate, non-award - Cunningham et al (1997 & 2000) concentrated the majority of their research on these particular educational institutions, hypothesising that this model posed a major threat to the market provision of higher education in Australia. Their incisive research found that the term 'corporate university is an umbrella term which covers two different manifestations of an organisations education/ training goals' (Cunningham et al, 2000; 13). This means that the corporate university is either a 'rebadged' internal human resource training facility for multinational corporations or, more significantly, a 're-visioned' human resource training facility 'with the goal of achieving tighter control and ownership over the learning process by more clearly linking learning programs to real business goals and strategies' (Meister 1998:ix). Cunningham et al's (1997 & 2000) research concluded that this particular model did not pose a significant threat to the traditional or virtual form of the established university as the majority did not offer recognised degree programs; it may be argued, however, that the use of the word ‘university’ by these organizations further fuels confusion in the marketplace.

4) New institutions - these entities are universities created for the sole purpose of developing their own courses and delivering them online. They generally have no campus, physical library or significant physical facilities and, in most cases, the number of full-time faculty can be counted on one hand (Newmann 1999). Although Cunningham et al (2000) found no 'robust' examples of this particular model, Jones International University http://jiu-web-a.jonesinternational.edu/eprise/main/JIU/home.html is probably the most prominent, accredited institution operating today, whilst the most controversial in

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Australian higher education circles is Greenwich University http://www.university.edu.nf . The remaining multitude of standalone, entirely virtual universities fitting this particular model are difficult to delineate from the emerging degree/diploma mills, outlined later in the paper. Sclater (1998) asserts that the new institution model and those quality institutions that choose to adopt this version, will have the greatest difficulty in bridging the credibility gap. The writer concurs, suggesting that government agencies throughout the world have a duty of care to provide significant online information for prospective consumers of this type of educational model.

Of the models profiled in this study, perhaps the first two are the most reflective of present, accredited virtual university activity on the Internet. However, as Gladieux & Swail (1999) found, the lines blur between public and private, for-profit and not-for-profit and a variety of entrepreneurial combinations in between. Nevertheless, consumer demand for either model of online provision does not seem to be curtailing. Booker (1999) suggests that demographic, political, corporate and technological forces will not allow a slow revolution towards virtual universities; moreover, he claims that it is the demand for non-traditional education in an even more flexible format that has catapulted the open, non-traditional university model into the domain of the virtual university. With such demand and variety of providers available, it is important for consumers of online education to understand how to differentiate between legitimately accredited online providers and Internet degree/ diploma mills. The following sections will address these important issues. Accreditation – the good, the bad and the downright ugly.

The word ‘accreditation’ implies that an organisation or process has received some form of endorsement and has reached a certain standard. In an education system, accreditation indicates that a provider has met requirements laid down by an independent, external body. The American higher education system ascribes to such a definition, with accreditation of higher education providers underpinning the credibility of various universities. Bear & Bear (1999:36) define accreditation from such a context, being 'validation - a statement by a group of persons who are, theoretically, impartial experts in higher education, that a given school, or department within a school, has been thoroughly investigated and found worthy of approval'. From an Australian perspective, the definition of accreditation is in a similar vein. Woodhouse (Proposed Australian University Quality Assurance System 1999) defines accreditation as an evaluation of whether an institution qualifies for approval. This status may permit the institution to operate, enable its students to be eligible for grants or qualify for certain employment. Anderson, Johnson & Milligan (2000:viii) define accreditation as, 'the process whereby an authority, recognised by institutions and government, determines that an institution offering courses in higher education may become self-accrediting, or offer its own higher education awards subject to periodic review. An accreditation agency certifies that the standards for a course are appropriate for the award to which it leads; and that the methods are appropriate for the purpose.'

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Building on these definitions, Harman & Meek (2000:5) suggest accreditation has developed three particular meanings in Australia:

1) The process, a review or assessment conducted by a government agency to enable a Minister or an approved authority, acting under the authority of appropriate legislation, to approve or recognise a higher education course and/ or award as being of an appropriate standard and being delivered in an appropriate manner. In some cases accreditation of a higher education institution means that from then on it is able to accredit or certify the quality of its own courses, while in other cases accredited institutions must also seek accreditation for each course.

2) Processes carried out by a government registration body to enable graduates of a particular courses to practise in the State or Territory.

3) Assessment and recognition carried out by professional associations in such areas as engineering, accounting, law, and architecture. If the course is accredited, graduates are eligible for membership of the professional association.

In order to try and put the term ‘accreditation’ into a global context, Dr John Bear, a world reknowned writer and authority in non-traditional education and degree/ diploma mill fraud, has developed what are affectionately known as Generally Accepted Accrediting Principles (GAAP). For an institution of higher learning to possess globally 'recognised' accreditation, it must meet at least one of the following criteria (Bear & Bear 1999:42): • The institution has been evaluated by British Royal Charter and an Act of

Parliament has been passed to enact the university's operation; • Accredited by an agency recognized by the U.S Department of Education; • Accredited by an agency recognized by CHEA (Council on Higher Education

Accreditation) Washington, U.S; • The institution is listed in one or more of the following publications:

Ø The International Handbook of Universities (a UNESCO publication); Ø The Commonwealth Universities Yearbook; Ø The World Education Series, published by PIER (Projects in International

Education Research), a joint venture of AACRAO (the American Association of Collegiate Registrars and Admissions Officers) and NAFSA (the Association of International Educators) with the participation of the College Board;

Ø The Countries Series (published by NOOSR, National Office for Overseas Skills Recognition, Australia)

Although an informal classification system, GAAP provides an excellent checklist for those who move in the circles of academia. However, what does accreditation really mean to the prospective young, supposedly ‘cyber savvy’ online customer, seeking to enroll in an online degree program? Greenwich University has already challenged the

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standing of GAAP, as this university has an Act of Parliament assented to by both the Norfolk Island Legislative and the Commonwealth of Australia. Greenwich advertises itself throughout the world, particularly in Asia, as a ‘fully accredited Australian university’. Institutionally, Greenwich certainly has an Act of Parliament to authorize its operations, however the degrees it confers are, at present, not Australian. Greenwich is not listed on the Australian Qualifications Framework (AQF) register; the degrees it issues are, in essence, Norfolk Island degrees, not AQF degrees. How acceptable are these in the world of academia and would other universities around the world accept these as pre-requisites for other programs? Whilst Greenwich University is certainly a rare exception to the case, there are literally hundreds of virtual universities claiming accreditation from a myriad of unrecognized accrediting agencies. The unfortunate reality is that any university can be ‘accredited’ – it all depends by whom. Examples abound with regard to unrecognized accreditation; the following are but a few exemplars. The World Association of Universities and Colleges (www.web-hed.com/wauc), is an unrecognized accrediting agency run out of a secretarial service in Nevada, USA. The WAUC claims to accredit over twenty-two universities worldwide, including the universities owned and managed by the founder of the WAUC. In 1999, one of its members, Taft, sued the WAUC as it alleged the WAUC had not performed a site visit upon its organization order to establish its bona-fides. During discovery part of the lawsuit, the WAUC was unable to provide any evidence suggesting it had conducted a site visit on any of its member institutions. With this type of case, one would have thought that the agency would not be permitted to operate. Unfortunately, due to the ease of online communication and the increase in globalization, organizations such as the WAUC are able to accredit operations throughout the world. For example, Bacani & Rohlfs (2000) found that the Indonesian government does not recognize the diplomas awarded by one WAUC member, the Distance Learning Institute in Jakarta. The two-year-old school, however, is still allowed to operate. St Clements University (http://www.stclements.edu) whose website is registered in Adelaide, South Australia and legal entity is on the island of Grand Turk in the Turks and Caicos Islands in the West Indies, is another accredited member of the WAUC and promotes it programs heavily into Asia. In addition, another unrecognized agency, the ‘International Accreditation for Universities, Colleges, Institutes, Organizations and Professionals’ (www.iauci.org) also accredits St Clements University, along with a string of other unrecognized universities. Another Australian run university, The University of Asia, which used to be run out of Darwin, Northern Territory and Adelaide, South Australia claimed accreditation from the following accrediting agencies:

• The Australian Universities Association (Australia) http://www.aua-ausuniversitiesasc.org

• The Association of World Universities and Colleges (Switzerland) http://www.wauc.ch

• The Commonwealth Universities Association (United Kingdom) http://www.cwlthuniversitiesassoc.org.uk & http://www.cwlthuniversitiesassoc.org

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• The International Association of Accredited Universities (Europe) • Uniworld Association Inc. - An International Accreditation Organization of

Universities and Colleges http://www.uniworld.org Coincidentally, each of the above agencies websites and domains belonged to the University of Asia. The above examples are mere snapshots of a disturbing increase in online activity – the virtual-environment easily permits virtual activity. How can an online student find a bona fide institution and how can they ensure that the degree they earn will be recognised? Without doubt, recognized accreditation is imperative for the prospective student, particularly those seeking to pursue an undergraduate degree and transfer this qualification into a post-graduate program. A recent survey conducted by Dr John Bear was presented to the American Association of Collegiate Registrars and Admissions Officers at their national convention in April 2001, and confirms this assertion. The survey sampled 335 registrars covering questions pertaining to 13 categories of schools, from regionally accredited to state-licensed. The results were quite succinct; to the statement if a registrar would recognize a qualification issued by a university that is: "Accredited by an agency that is not recognized by CHEA or the U.S. Department of Education," one registrar said they "almost never" accept such degrees; 16 said they "might possibly;" and 318 said "never." Defining the Degree/ Diploma Mill

Porter (1972) suggests the term 'degree mill' has been loosely used to describe any institution with questionable standards, lacking appropriate accreditation. Suggesting they are the 'corrupters of degree integrity', Spille, Stuart & Sullivan (1997; p.vii), further define a diploma mill as 'a person or an organisation that sells degrees or awards degrees without an appropriate academic base and without requiring sufficient academic achievement at the post secondary level' (Spille et al 1997; 28; Koepell 1998:2). Phillips (2000) provides a similar definition, allocating the term to any university that operates primarily to make money or issue degrees/credentials without any thought to ensuring that education occurs. Some authors use the terms 'diploma mill' and 'degree mill' synonymously. For example, SnoNet (2000) states that a ‘degree mill’ (or diploma mill) is an institution that grants degrees with little or no work involved, whilst Laws (2000), suggests that a diploma mill (or degree mill) is often defined as an illegal institution that grants bogus degrees in exchange for money and without requiring the student to show proof of course mastery, or to do any substantive coursework or testing. A plethora of information exists pertaining to the degree/ diploma mill quandary, emanating largely from the United States of America where the problem institutions have festered since as early as 1876. This, according to the writer, is mainly due to two reasons:

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• Accreditation of universities is a voluntary process in the United States of America. As such, the US has been historically seen as the 'Mecca' for degree/ diploma mills, the majority choosing not to lend themselves to independent verification of their courses.

• US jurisdictions such as South Dakota, Louisiana, Hawaii and now Montana have

historically possessed poor legislation governing the creation of universities and the use of the word 'university' in business nomencla ture. Whilst jurisdictions such as Hawaii have now passed appropriate legislation, it is only through active and consistent enforcement (such as what is occurring there presently) will degree/ diploma mills be discouraged to ‘set-up-shop’ in these states.

In the United States, Geber (1999) suggests, diploma mills appear to be a unique post World War Two phenomenon, capitalising on the then GI Bill which sparked explosive demand for post-secondary education. In order to combat this problem, the National Home Study Council was formed in 1926 'partly to identify the good schools and set them apart from the charlatans'. During the 1960's, diploma mills lost business due to the emergence of community colleges offering low tuition fees and accessible higher education for all. However, the 'credentialism' era of the 80's saw them once again flourish, whilst the onset of the Internet in the 90's has provided an inexpensive means to reach millions of people (Geber 1999). Degree/ diploma mills have become such a problem in the US, that some legitimate universities have taught subjects on the topic. Miller (1991) recounts an undergraduate subject called 'Diploma mills' where she was required to investigate three diploma mills and report on her results. Her findings suggested that the main force behind the prosperity of degree/ diploma mills was the confusion surrounding accreditation, approval, authorization and licensing. This still appears to be the main area diploma mills exploit due to the layperson's lack of knowledge and confusion about accreditation. Phillips (2000) found diploma mills advertised widely as being "fully accredited", "nationally accredited" or "accredited worldwide." Advertising heavily in magazines, the Internet, newsgroups and providing impressive looking Web sites, Phillips (2000) found that they are indeed "accredited", but by unrecognised agencies often created by the institutions themselves. This 'smokescreen' of legitimacy is what Bear & Bear (1999) suggest are the main reason degree/ diploma mills are prospering, as it very difficult to legally define what is meant by the term "diploma mill" or "degree mill". In addition, it is important to note that many US institutions, which experts say mislead students 'do not appear to have broken any state or federal law' (Guernsey 1997:6). Educators and law enforcement officials are evidently reluctant to prosecute and slow to keep up with the growing rate of online diploma mills (Mayfield 2000). The terms 'degree mill' or 'diploma mill' are not found in any Australian literature; however they are used commonly in American writings, particularly by various education bodies. The Office of Degree Authorisation for the state of Oregon, USA, cites Webster's Third New International Dictionary definition of a diploma mill, as: 'An institution of higher education operating without supervision of a state or

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professional agency and granting diplomas which are either fraudulent or because of the lack of proper standards, worthless’ (Oregon Student Assistance Commission, 2000). Similarly, the U.S. Office of Education in March 1974 defined a degree mill as: "An organization that awards degrees without requiring its students to meet educational standards for such degrees established and traditionally followed by reputable institutions." (NCAHF 1997). Despite the US government having identified the problem of degree mills, Arnstein (1982:552) suggests there are three main reasons why authorities have done little to stamp out the problem:

1. The U.S has a strong tradition of pluralism, of encouraging diversity. This makes it very difficult to categorise universities and colleges, no matter who undertakes sorting this task.

2. A long tradition of state and local control operates in conjunction with the

pluralist tradition. At least two major federal laws enjoin federal officials from interfering in the internal affairs of colleges.

3. At least one Cabinet member tried to stamp out diploma mills and failed. He

held a news conference and asked the U.S. commissioner of education for a list of offending schools, only to learn that the problems of definition and due process are so great that the list was terribly short and almost certainly incomplete. The effort died quickly.

Clearly the existence of the degree/ diploma mill is a troubling barrier to the search for legitimate online higher education, both for the student and the bona fide provider. As such, in order to put the paper in perspective and provide strategies to detect degree/ diploma mills, it is necessary to attempt to delineate between the two types of models. Criteria for defining a degree/ diploma mill

It is important to appreciate that there are many definitions and subsets of degree/ diploma mills; however, as the US Select Committee on the Ageing (Fraudulent Credentials 1985) suggests, there are no definitive criteria to characterize the constitution of a diploma/ degree mill as a variety of evidence must be presented to form a conclusion. Nevertheless, in searching for a working typology, Snyder (1974) and Patrick O'Neill (1991) suggest there are two types, which the writer ascribes to. Firstly, citing the 'briefcase college' definition as espoused by Patrick O'Neill (1991:82), or 'Type 1' as suggested by Snyder (1974), these particular organizations operate from mailboxes, mail forwarding or telephone answering services. Offering degrees at all levels in all disciplines, they sell degrees under fictitious names or sell imitations that resemble degrees from bona fide institutions. In addition to this, some sell transcripts, letters of recommendation (Spille & Stuart et al 1997), class rings, graduation photos and yearbooks (Patrick O'Neill 1991).

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The second type is those which pose as non-traditional (Arnsetin, 1982) or Type 2 institutions, sharing attributes of the Type 1 model, 'but with some token work involved and all by correspondence' (Snyder, 1974:93). Defined as 'universities without walls' these are difficult to differentiate from legitimate institutions as they 'emulate a legitimate non-traditional program, including accreditation from a phoney agency, yet post standards' (Patrick O'Neill 1991:82). Levicoff (2000) subscribes to the Type 1 and Type 2 definitions, suggesting the two terms ‘degree mill’ and ‘diploma mill’ should be separated. He argues that a diploma mill is a school that will sell a degree or diploma outright, or a school that requires such a minimal amount of work (such as a ten-page dissertation for a doctorate). On the other hand, he sees a degree mill as a school that actually requires some academic work, perhaps even a substantial amount, but significantly less than comparable, legitimately accredited programs (Levicoff, 2000). An extensive body of literature exists covering the broad characteristics which typical degree/ diploma mills possess; however none endeavour to break these down into the Type 1 or Type 2 models as described above. Bear & Bear (1999) list, in alphabetical order, over twenty-one pages of degree mills that have either been closed down due to fraudulent activity or still operate and have been exposed by various publications; there are, however, no explicit criteria on how they are classified in this section of their publication. To assist in definitions, Levicoff (1992) suggests over 75 criteria for identification of a degree/diploma mill, whilst Porter (1972) and Stewart and Spille (1988) provide a comprehensive list of qualities most degree mills possess. Whilst impossible to discuss each of the criteria in detail, the writer has developed the following short list of compiled characteristics taken from leading authors in the field:

• The organisation claims accreditation from an unrecognised accrediting agency and/ or agency that sounds like a legitimate accrediting agency (Fraudulent Credentials 1985; Levicoff, 1992; Askins, 1996:13; Stewart & Spille 1988; Guernsey, 1997; Snyder 1974; Thomas, n.d; Rowh 1997; Kenyon 1999; Lord 1998; Better Business Bureau of Hawaii in Omandam 1997).

• The word 'authorised' is emphasised instead of 'accredited'; some organisations criticize formal accreditation, stressing they are 'different, non-traditional and alternative' thus implying they do not need to seek approval from a recognised independent body (Patrick O'Neill, 1991; Better Business Bureau of Hawaii in Omandam 1997)

• Most claim to be associated with some obscure religious sect and on this basis claim religious exemption (Spille & Stewart 1988; Snyder 1974; Rowh 1997; Hasenauer 1997)

• The organisation has a name similar to a well-known college or university in addition to using the words 'international' or 'US' to project prestige and far flung program activity. (Fraudulent Credentials 1985; Stewart & Spille, 1988:29,30; McQuaid, 1988 in Patrick O'Neill, 1991; College is Possible - Legitimate Learning; Rowh 1997; Kenyon 1999; American College Advisory Service.

• The domain lookup of the universities website provides contact details of either a PO Box, a mail forwarding company or fictitious location. Contact phone numbers are either to a call centre, answering machine or mobile phone.

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• The website promoting the institution have the same elements as those of an accredited college - a university seal, message from the president, links to catalogues of courses and on-line application forms (Guernsey, 1997). In addition, they also offer school rings, sweaters, pins and membership cards (Fraudulent Credentials 1985; Levicoff, 1992; Stewart & Spille, 1998; Snyder 1974).

• The organisation frequently changes its address, sometimes moving from state to state. (Levicoff, 1992; Stewart & Spille, 1988:30; College is Possible - Legitimate Learning; American College Advisory Service).

• The address may sound impressive, but mail is only received thorough a post office box (Levicoff, 1992; Stewart & Spille, 1988; Better Business Bureau of Hawaii in Omandam 1997).

• Institutions use photos of other institutions and use P.O. Boxes and mail forwarding services for correspondence (Porter 1972; Spille & Stewart 1988; Askins, 1996; American College Advisory Service; Lord 1998).

• Most claim to have libraries and classrooms and other essential facilities, but usually they just have a desk and a telephone. (Porter, 1972:31). Campus facilities are either of a poor standard or do not exist (Dejnozka & Kapel in Patrick O'Neill, 1991).

• Operators of the degree mills usually have degrees from other degree mills and other faculty members are usually non-existent or untrained (Porter, 1972:31). The majority of staff have degrees from unaccredited institutions and/ or degrees from the institution itself (Levicoff 1992).

• Graduates' success is over emphasised, profiling excessive endorsements from alumni and lists of organisations where students are employed (Levicoff, 1992; Stewart & Spille, 1988).

• Admission requirements are minimal or do not exist (Porter, 1972:31, Spille & Stewart, 1988; College is Possible - Legitimate Learning; Thomas, n.d.; American College Advisory Service).

• Classrooms are often pictured but do not exist (Porter, 1972:31; American College Advisory Service).

• Advertisements are exaggerated by drastically enlarging bona fide curriculum offerings (Porter: 1972:31, Dejnozka & Kapel in Patrick O'Neill, 1991; McQuaid in Patrick O'Neill, 1991; Spille & Stewart 1988) whilst advertisements appear in legitimate and prestigious magazines (Levicoff, 1992; Askins, 1996:11; Kenyon 1999).

• Transcripts can be 'attested' by an official state or federal government (Spille & Stewart 1988).

• Credits for 'life experience' may comprise all, or most, of their requirements and are given for almost everything imaginable (Fraudulent Credentials 1985; Tufts in Patrick O'Neill, 1991; Arnstein, 1982; Snyder 1974; Spille & Stewart 1988; Kenyon 1999; Lord 1998; Better Business Bureau of Hawaii in Omandam 1997).

• Dissertations are 'a shallow analysis or descriptions of various aspects of a persons job or current life situation', and are not defended (Spille & Stuart, 1988:30) Sometimes an autobiography is sufficient work (Arnstein 1982) whilst quantity, rather than quality is emphasised (Spille & Stuart 1988:32).

• Narrative in the catalogue and promotional material is filled with errors in spelling, grammar and syntax, whilst the overuse of Latin and extravagant, pretentious words aims to impress the prospective student (Levicoff, 1992 ;Spille & Stewart 1988; Salkever, 1999; College is Possible - Legitimate Learning; American College Advisory Service; Lord 1998; Better Business Bureau of Hawaii in Omandam 1997 ). Some call themselves 'pioneers in international education' or 'leaders in distance education' (Guernsey, 1997).

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• Tuition is charged on a 'per degree' or 'flat fee' basis as opposed to normal per semester, per subject process (Spille & Stuart 1988; Salkever 1999; College is Possible - Legitimate Learning; American College Advisory Service; Lord 1998; Better Business Bureau of Hawaii in Omandam 1997).

• The school has an 'online catalogue' but no printed catalogue. (Levicoff 1992) • The schools website gives no physical address or phone number (Levicoff 1992) • Degrees can be obtained in a relatively short period of time (Dejnozka & Kapel in

Patrick O'Neill, 1991; Salkever 1999; Snyder 1974; Spille & Stewart 1988; College is Possible - Legitimate Learning; Kenyon 1999; American College Advisory Service; Lord 1998;Better Business Bureau of Hawaii in Omandam 1997).

• Photographs of diplomas appear in catalogues; whilst sample copies are used in promotional mailings and documents can be backdated (Levicoff, 1992; Spille & Stewart 1988; College is Possible - Legitimate Learning; American College Advisory Service). Certificates of incorporation and 'good standing' are also promoted to push legitimacy.

• Faculty listed in promotional material are either non-existent, or are from legitimate organisations and do not know they are listed. An emphasis is made on degree identification for individuals. For example John Doe, Chancellor, PhD, EdD, BSEd, MAR, DD, LHD, LLD (Levicoff, 1992; Spille & Stewart, 1988:30; McQuaid in Patrick O'Neill, 1991; American College Advisory Service; Lord 1998; Better Business Bureau of Hawaii in Omandam 1997).

As previously mentioned, the above list is by no means exhaustive; however, within the scope of this paper, it provides a useful checklist of the main characteristics of so-called degree/ diploma mills. Perhaps the single most important factor explaining the increase of degree/ diploma mill activity has been the advent of the Internet. This revolutionary communication tool may permit any individual to perform the following steps for fewer than three thousand dollars:

1. Incorporate a business name in an offshore tax haven, e.g. British Virgin Islands, called ‘The University of Australia Pty Ltd’ and, through its own articles of incorporation, empower the university to confer degrees from Bachelor to PhD

2. Register domain names – one for the university e.g. http://www.university-of-australia-edu.org.au and one for an accrediting agency e.g. http://www.austassocofuniversities.org.au

3. Create two websites, one for the university and one for the accrediting agency that accredits The University of Australia. The publishing power of software allows the ‘Chancellor’ to create the sites and maintain them with minimal cost.

4. Print a range of glossy brochures, featuring pictures of Australian universities, landmarks etc. Print application forms, referee forms and policies/ terms and conditions

5. Open a PO Box and an answering service, in Australia, to accept all calls and correspondence

6. Advertise heavily online over the Internet via free websites, and Australian sites where advertisements are listed for free.

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The anonymity and far reaching capabilities of this tool has made it increasingly difficult to trace and monitor activity, and/ or to warn prospective students of the problems of pursuing a degree/ diploma mill course. The following section will profile such problems. Degree/ diploma mills – new challenges on the Internet

Bear & Bear (1999) suggest that with the advent of new technology such as laser printers, computers (and the Internet), diploma mills have multiplied. Mayfield (2000) advocates that the Internet has spawned a new generation of cyber-degree mills, which has 'rekindled the old fashioned diploma mill'. Ironically, Koepell (1998) & Kenyon (1999) found degree/ diploma mills to be some of the first institutions to set up business on the Internet, well before other types of business activity. Guernsey (1997) suggests that the Internet has given new life to the degree mill business, whilst Salkever (1999:2) claims it has proven to be '…a perfect vehicle for degree programs that carry little weight in the job market'. Unfortunately, due to the Internet and ease of publishing, 'no one really knows how many diploma mills exist because new ones keep popping up and others re-name themselves or open branches in new locations (Rowh 1997:1). Cunningham et al (2000:143) acknowledge, 'that the US has been plagued for many years by fraudulent operators in education delivery’, and that the advent of the Internet has provided a new avenue for some of these 'diploma mills'', suggesting that it is almost inevitable that their operations will bridge over into Australia. Citing the Australasian Institute case (http://www.tai.edu.au) and other providers' loose use of the term 'university', they showed concern that this problem was increasing. Certainly forecasted figures on higher education and online delivery fuel these concerns. The United States Internet Council (2000) forecasted spending on higher education Internet related technologies would rise by 5 billion dollars in 2003, up from 3.1 billion in 1998, citing increased competition for students, the changing needs of these students and the shifting missions of educational institutions. Presently 72% of colleges offer some form of online distance education, up from 48% in 1998, whilst forecasts for revenue from online education will rise to 2 billion dollars in 2003, up from 350 million at present. Of more concern though, is the admission that the number of online colleges offering accredited degrees is very low. From another Australian perspective, Swannell (1999), Vice-Chancellor of the University of Southern Queensland has expressed concern over the new Internet paradigm, suggesting that existing universities and other higher education providers have a responsibility to assist only quality providers of Internet-delivered education. However, as Salkever (1999:2) highlights, the Internet increases the ability of degree mills to cross borders and, 'reach millions of potential students quickly and easily' whilst 'with so many colleges in operation, fake ones can lose themselves in the crowd with relative ease' (Rowh, 1997:2).

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Geber (1999) concurs with Rowh, citing the ease of creating authentic-looking web pages; degree/ diploma mills can 'gull the unwary into assuming that the college portrayed is genuine and accredited'. The anonymity of the Internet makes it virtually impossible to find those that run fake virtual universities (Mayfield 2000). Of the most notable degree mills to ever exist and thrive was Columbia State University. On July 6, 1998, a US Federal Bureau of Investigation finally raided the principal office of its operations in California. The owner, Ronald Pellar, was sentenced to 67 months in federal prison, for fraud, but managed to escape and is a federal fugitive apparently in Mexico. Evidence presented in the case found that deposits to the university’s account in one year alone totaled more than US$16 million. How did such an elaborate façade manage to generate so much revenue? It used the qualities that many established universities possess, and unfortunately, degrees mills imitate. For instance, the "campus" photo on the front page of the prospectus was that of Lyndhurst, a magnificent home in New York whilst it advertised heavily in magazines and newspapers such as Time, The Economist, and USA Today. With regard to accreditation, neither of the claimed accreditation agencies ever existed, whilst the president, Austen Henry Leyard, was a famous paleontologist who died over a century ago. Without doubt, as Mayfield (2000) espouses, diploma mills threaten legitimate distance-learning institutions, whose reputations and enrolments may suffer as they lose students to bogus schools. But what do these 'diploma' and 'degree mills' look like, and what do they offer? The following sections profile a few of the thousands that operate on the Internet. Examples of Internet diploma mills Perhaps one of the most disturbing examples of Internet sites promoting the Type 1 'briefcase' model are those organizations providing instant degrees, transcripts and associated paperwork for a fee. The following are examples of organizations providing this service:

http://www.kaiserince.com/replacementservice.htm http://www.counterfeitcafe.com http://www.geocities.com/davephilipau http://www.fakeresumes.com http://www.geocities.com/hakers1000/fakedegree.HTM http://www.fakedegrees.com http://www.photoidcards.com/moresamples.htm http://www.virtualdegree.com/ http://www.professionaldegrees.com http://www.phoneydiploma.com http://www.replicadegree.com http://www.fakediplomas.com/ http://www.diplomamakers.com/ http://www.counterfeitlibrary.com/ http://www.blacksprofessional.com/ http://www.diplomas2go.com http://www.blackmarket-press.com http://www.myspace.co.uk/degree/index1.htm http://www.prestigious-images.com/ http://www.bogusphd.com http://www.fake.to/cl/forums/ http://paperbrain.tripod.com/ http://www.idhookupz.com/ http://www.qualitydegrees.com/accessok.html http://www.replacementdiplomas.com alt.2600.fake-id http://www.degreebank.com/ http://www.virtualdegreesonline.com/ http://www.degree.freeserve.co.uk/index.html http://fake.to/cl/qual.asp http://www.buildinghopes.com/ http://www.webspawner.com/users/fake21/ http://www.cooldegree.com/ http://www.photoidcards.com http://www.fakephotoid.com/private/frontpage.html http://www.secretknowledge.com/index.htm http://www.boxfreeconcepts.com http://www.degreeconsulting.com/english.html http://www.webspawner.com/users/degree2 http://www.nashco.com/nashco/honorarydegree.html http://www.closedcollege.com http://newwritersguild.com/diplomas.html

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http://www.idtemplates.com http://www.globalidsite.com/index.html http://www.factorydirectoutlet.com http://members.tripod.com/~deed/

These organizations provide parchments from Bachelor to PhD level and circumnavigate the legal issue of selling degrees by promoting the fact that they are 'novelty' products and should not be used for educational or employment purposes. To demonstrate the ease of obtaining these degrees, Dr Bear purchased a fake Harvard Law degree from a 'lost diploma replacement service' in Grants Pass, Oregon. For $58.00 he obtained the degree and removed the peel off 'novelty item' sticker and placed it not so proudly alongside his legitimately earned PhD from Michigan State University. In Australia, the most notable Type 1 organisation was 'Blacks Professionals', which operated in Queensland until late 1999. Donaghy (1999) found this organisation was selling "extremely authentic" degrees from universities around the world, particularly established Australian universities, along with transcripts and associated paperwork. The AVCC voiced concern about this operation and made inquiries, upon which it promptly vanished from the Internet and set up a post office box in Spain. The problem of these fake credential services has been highlighted by reseach conducted in the area. ICC Commercial Crime Services (2000) profiled a six-month study undertaken by a New York corporate investigation firm. This report found over a quarter of 1,000 CVs analysed contained falsehoods, ranging to false claims supported by fake documents obtained off the Internet. Experian, a company in the UK found that lying in CVs about higher education qualifications accounted for 21 percent of false information, second only to lies about previous employment. Further studies have found that fake documentation has been a serious problem. Perhaps the most prolific and perfect exemplar of the Type 1 model purporting to be an actual university, is the following organization, which has used the below names over the past four years: University of San Moritz University of Palmers Green Harrington University http://www.harringtonuniv.org Brentwick University http://www.brentwickuniv.org University of Devonshire http://universityofdevonshire.org/ Shelbourne University http://henryheston.com/shelbourne/index.htm University of Wexford http://www.universityofwexford.org Ashford University http://www.ashforduniversity.org Thornewood University http://thornewooduniversity.org Parkwood University http://www.parkwooduniversity.org Glencullen University http://www.henryheston.com/glencullen.htm University of Ravenhurst http://64.55.192.251 Kingsfield University http://www.kingsfielduniversity.org Westbourne University http://www.westbourneuniversity.org This ‘university’ has used the following e-mail promotion which has circulated the globe and found its way into the PC inbox of thousands of individuals:

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------------------------------------------------- U N I V E R S I T Y D I P L O M A S! ! ! Obtain a prosperous future, money earning power, and the admiration of all. Diplomas from prestigious non-accredited universities based on your present knowledge and life experience. No required tests, classes, books, or interviews. Bachelors, masters, MBA, and doctorate (PhD) diplomas available in the field of your choice. No one is turned down. Confidentiality assured. CALL NOW to receive your diploma within days!!! 1 - 7 1 3 - 8 6 6 - XXXXX Call 24 hours a day, 7 days a week, including Sundays and holidays ------------------------------------------------ A myriad of articles have been published profiling the above organisation (Lloyd 2000; Mayfield 2000; Bresnahan 1999; Schulhof 1999; Keppeler 1998; Bruno & Chae 2000, Browne 2002; Singer 2002), all suggesting these universities do not exist, have no campus, facilities or faculties. Moreover, articles published have found that the organisation actually advises the consumer they are, indeed, a diploma mill as such bypassing consumer protection laws. In a recent attempt to legitimise the organisation, it appears the owners (who allegedly live in Jerusalem, with mail forwarded from the US to Cyprus) have developed the "European Council for Open & Distance Learning" http://www.ecdol.org and the Distance Learning Council of Europe http://www.dlce.org designed to provide a form of accreditation for the above universities. This accrediting organization is not recognized under GAAP, but lists other established universities on its websites such as the University of Bradford, Bristol and Cambridge in order to lend credibility. Examples of Internet degree mills Providing exemplars of the Type 2 model is perhaps, the most difficult challenge of this paper. As discussed previously, it is very complicated to define what actually constitutes a degree mill as many non-traditional programs (particularly totally online virtual universities) are legally established with incorporated business names, but do not however choose to seek any form of legitimate accreditation. Some are very

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sincere in their endeavors, whist the majority and designed to defraud. In addition, this type of institution requires the student to do some academic work, which may vary in depth and duration, depending on how it is operated. In an attempt to categorize these types of institutions, Bear & Bear (1999) list over eighteen pages of 'Other schools with Non residential Programs'. The following is a selection of these types of universities, which the author does not label Internet degree mills, but have been featured in the Australian media. The reader may visit, online and form their own conclusions:

• American Coastline University http://www.amercoastuniv.edu • Chancery International University http://www.chanceryiu.net • Golden State University http://www.goldenstateuniversity.edu • Greenwich University http://www.greenwich.edu.nf • International University of America http://www.merc-iua.ac • International University of Fundamental Studies http://www.iufs.edu • Kensington International University http://www.kensington.edu • Knightsbridge University http://www.knightsbridge-university.co.uk • St Clements University http://www.stclements.edu • St Regis University http://www.saintregisedu.org • Southern Pacific University http://www.spuni.edu • University of Asia http://www.uniasia -thailand.net • University of the Seven Rays http://www.sevenray.com • Warnborough University http://www.warnborough.edu • Washington International University http://www.wash.edu

Australia’s moves to eradicate the degree/ diploma mill problem

The former Federal Minister for Education, Dr David Kemp found, amongst other major weaknesses in the current accreditation/ quality assurance framework that there was 'a lack of coherence in policies and procedures for the accreditation of institutions and courses' (Kemp 1999:5). As such, The National Protocols for Higher Education Approval processes were developed, which, according to DETYA (2000), were endorsed by the Ministerial Council on Education, Employment, Training and Youth Affairs on the 31st March 2000. Seen to be an integral part of the new national quality assurance framework, the protocols were required to be written into of the mainland state and territory Higher Education Acts by the 30th June 2001. The protocols are designed to ensure two main outcomes:

1) to protect the title 'university' across all states and territories of Australia and ensure its use is commensurate with a nationally agreed definition;

2) establish uniform processes for the creation and ongoing accreditation/ quality assurance of universities in Australia and other providers seeking to offer higher education awards in Australia.

At the writing of this paper, Victoria appears to be the only state that has met the requirements, whilst New South Wales is close to having their new legislation passed.

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Since 2001, there have been over six overseas institutions delivering higher education courses into Australia without approval. This is of major concern to the community and urgent action is required to protect the reputation of Australia’s burgeoning higher education industry. The following section will provide strategies for various stakeholders to be proactive and ensure due process is followed. Summary and recommendations for the future

Australian educational providers Clearly, based on the preceding information, the Internet is clouded with a plethora of online deliverers and promotion of programs that are difficult to determine from legitmate university providers. The slow integration of the National Protocols is of a concern; in the interim, the following recommendations are made for established, recognized providers of higher education in Australia:

• Emphasize legitimate Australian accreditation – whilst this is a requirement under the ESOS Act for providers delivering to overseas students, it is important to provide as much information as possible. It is recommended that providers list e-mail addresses and links to the online CRICOS database, DEST and the state accrediting board that governs the providers registration and accreditation. Australian universities should place online links to copies of their enacting Acts of Parliament to re-assure the legitimacy of their programs to overseas students.

• Promote the Australian ‘.edu.au’ domain name – To obtain such a domain suffix is extremely difficult, and is a useful tool to differentiate credible Australian providers from other online providers. The world-wide, generic ‘.edu’ suffix is extremely easy to obtain, and many established degree mills posses such a domain. It is suggested that providers warn students of such online institutions and thorough check the bona fides of such providers.

• Fraudulent credentials are rife - Ensure your institution implements tight document verification procedures for parchments and transcripts of results. Use watermarks, embedded logos and original verification features on all paperwork issued by your organization.

• Insist that overseas student who seek advanced standing in an Australian institution, provide original copies of results and parchments which have been sent directly from the host provider.

Federal and state governments A recent Internet scam involving the online sale of inflated rugby and opera tickets drew the ire of federal law enforcement agencies around the world, determined to close these operations down. Why then, has there been such ignorance to the blatant sale of worthless degrees, which has the potential to ruin the academic futures of so many people? The Federal and State governments are implored to implement the following measures:

• The National Office of Overseas Skills Recognition (NOOSR) should make its Country Series available online, free of charge, to all Australian Universities and

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RTO’s. The availability of this invaluable resource would provide instant verification of bona fide institutions.

• The AVCC re-launch the degree verification service proposed by Degreeoftruth Pty Ltd (http://www.degreeoftruth.com.au) or similar model. The steep rise in credential fraud and availability of parchments from any university in the world via the Internet is of major concern to the Australian higher education community.

• Each state and territory seek to urgently address the integration of the National Protocols into their higher education Acts.

• DEST to create a centralised, online database, of unrecognised providers attempting to deliver programs into Australia without approval. This information source should also make links to student-orientated discussion sites such as Degreeinfo (http://www.degreeinfo.com) and other online resources providing information on degree mills and fraudulent online activity. The US State of Oregon’s Office of Degree Authorisation model is a perfect model to follow.

These are indeed new times – and there is an urgent need to take new approaches re-regulatory control to protect all stakeholders in the Australian higher education system. For Australia to be seen as a credible competitor in the global education market, it must be seen to be proactive in this area – not reactive, or suffer the same fate as many of our Asian partners are encountering. These recommendations are but a first step in ensuring we remain the wheat in a plethora of online chaff.

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