UNITED STATES 

OFFICE OF PERSONNEL MANAGEMENT 

WASHINGTON, DC 20415-1000

OFFICE OF THE DIRECTOR

May 13, 2004 

MEMORANDUM FOR DEPARTMENT AND AGENCY HEADS 

 

FROM: KAY COLES JAMES 

 DIRECTOR 

SUBJECT: Strengthening Oversight of the Use of Diploma Mill 

 Credentials in Federal Employment 

I have written to you on three occasions during the past year addressing the critical issues 

surrounding the use of credentials from so-called “diploma mills.” There is also keen 

Congressional interest in this issue, especially by the Senate Committee on Governmental 

Affairs, under the leadership of Chairman Susan Collins, which held a hearing on this subject on 

May 11 and 12. At her request and that of Congressman Tom Davis, Chairman of the House 

Committee on Governmental Reform, the General Accounting Office has recently completed an 

investigation of how these phony degrees are used in Federal employment. This investigation 

revealed that some agencies are paying for their employees to receive bogus degrees from 

diploma mills. I appreciate the strong leadership and assistance both Senator Collins and 

Representative Davis have provided on this issue. Their efforts highlight the fact that this issue 

is of central importance to the entire Government, and one that requires the cooperative vigilance 

of both the executive and legislative branches to maintain the integrity of the civil service. 

Diploma mills are non-traditional schools that are not accredited by accrediting institutions 

recognized by the Department of Education (DoED). They generally award degrees or 

certificates with little or no course work completed by the student. These institutions often 

award degrees based largely on an assessment of the student’s life experience or cash payments 

and may translate those experiences into fraudulent curriculum transcripts, giving a false 

impression of a structured curriculum. In addition, some organizations simply sell counterfeit 

degrees, which would also fall into this category. 

Our position is clear: there is no place in Federal employment for degrees or credentials from 

diploma mills. They may not be used to qualify for Federal jobs or salaries; you may not send 

employees to diploma mills for degree training or for any other form of education; you may not 

reimburse employees for tuition associated with these schools; you may not use your authority to 

repay student loans if the degree is from a diploma mill. 

The Office of Personnel Management (OPM) has completed a review of the applicable statutes, 

regulations, policy documents, public information and forms within its jurisdiction to determine 

how we can strengthen and clarify how agencies, employees and applicants can become better 

informed of the issues relating to diploma mills. The review included OPM policies related to 

paying for academic degrees directly or through tuition reimbursement, repayment of student 

loans, employee training, higher education required to meet position qualification requirements, 

and the use of advanced education in the applicant ranking process. Further, we reviewed all 
 forms and instructions where this issue might surface. Finally, OPM has reviewed the 

background investigation process as it relates to verification of education claims and the 

standards for adjudicating investigations when bogus degrees were identified. 

Four distinct categories of higher education were identified: 

1. Conventional/Accredited: Degree-granting schools that are accredited by accrediting 

institutions recognized by the Secretary of Education. 

2. Non-Accredited/Pending Accreditation: Schools that are not accredited by an 

accrediting institution recognized by DoED; but offer a curriculum for advanced 

learning similar to a conventional/accredited institution which enhance an 

individual’s knowledge, skills and abilities for a position; and are in the process of 

seeking accreditation from an organization recognized by DoED and have received 

“pre-accreditation” or “candidate for accreditation” status. 

These schools are not accredited by an accrediting institution recognized by DoED 

but are in the process of seeking accreditation from an organization recognized by 

DoED and have received “pre-accreditation” or “candidate for accreditation” status. 

Based on information from the Office of the Assistant Secretary for Postsecondary 

Education, DoED, reaching this step in the accreditation process requires substantial 

review and a rigorous test, and that most schools reaching this position are accredited. 

Such schools must establish that their resources, facilities, financial conditions, 

faculty, and courses of study are rigorous and legitimate. 

3. Non-Accredited/Other: Schools that generally have a traditional curriculum but 

have chosen not to seek accreditation and thus do not qualify under criteria 1 or 2. In 

addition, foreign institutions that offer courses of study comparable to institutions 

accredited by organizations recognized by DoED fall in this group. These institutions 

may be accredited by appropriate organizations in their home country, but not by 

organizations recognized by DoED. 

OPM does not have the statutory authority, mission or capability of evaluating the 

quality of these programs. Without a fair and objective process to determine if the 

programs offered by these schools are equivalent to those that are fully accredited, or 

have received “pre-accreditation” or “candidate for accreditation” status, the human 

resources staff of the Executive Branch agencies cannot evaluate this education and 

determine whether it is qualifying for Federal employment purposes. Because we 

cannot evaluate these programs, at this time we are not in a position to determine 

whether training or education from “Non-Accredited/Other” schools meets the 

requirements set forth in law, regulation or policy for many of the activities described 

in this memorandum. 

4. Non-Qualifying: Non-traditional schools that are not accredited by accrediting 

institutions recognized by the Secretary of Education and that may award degrees or 

certificates with little or no course work completed by the student. These institutions 
often award degrees based largely on an assessment of the student’s life experience or 

cash payments and may translate those experiences into fraudulent curriculum 

transcripts, giving a false impression of a structured curriculum. Education is 

considered Non-Qualifying if it is determined that it is not equivalent in content to 

Conventional/Accredited higher education programs. This group includes diploma 

mills and organizations that simply sell counterfeit degrees, which would also fall 

into this category. 

Schools determined to be Non-Qualifying may or may not operate legally depending 

on State laws and their forming charter. In some instances, legal action has been 

taken to force these institutions out of operation and schools have been designated as 

“diploma mills.” 

Based on the four categories of higher education defined (Conventional/Accredited, NonAccredited/Pending Accreditation, Non-Accredited/Other, and Non-Qualifying), the 

applicability of each category to the following activities is explained below. 

Activity 

Consideration 

For 

Conventional

Accredited 

NonAccredited/ 

Pending 

Accreditation

NonAccredited/ 

Other 

NonQualifying 

(includes 

Diploma 

Mills) 

Student Loan 

Repayment Pay Yes No No No 

Academic Degree 

Training Program Training Yes No No No 

Tuition 

Reimbursement or 

Employee Training Training Yes Yes Yes No 

Position 

Qualification 

Requirements 

(including Student 

Educational 

Employment 

Programs (SEEP)) 

Qualification 

(Eligibility 

for SEEP) Yes 

Yes 

(No for 

SEEP) No No 

Student Loan Repayment 

Pursuant to 5 U.S.C. 4107 and 5379, OPM’s policy limits student loan repayment to colleges and 

universities that are accredited by nationally recognized bodies (i.e., Conventional/Accredited). 
Academic Degree Training Programs 

Pursuant to 5 U.S.C. 4107, OPM’s policy limits sending employees for degree training to 

colleges and universities that are accredited by nationally recognized bodies (i.e., 

Conventional/Accredited). 

Employee Training/Training Reimbursement 

Employee training is not specifically limited to Conventional/Accredited schools. 5 CFR 

410.601 states only that the agency head shall evaluate training to determine how well it meets 

short and long range program needs by occupations, organizations, or other appropriate groups. 

The agency head may conduct the evaluation in the manner and frequency he or she considers 

appropriate. Consequently, training may be obtained from Non-Accredited/Pending 

Accreditation and Non-Accredited/Other schools if the training content meets the agency 

program needs. An agency may reimburse employees for all or part of the costs of the training 

or education. (5 USC 4109 (a)(2)) 

Education To Meet Qualification Requirements

Under OPM’s Operating Manual, “Qualification Standards for General Schedule Positions,” 

Section 4, education from degree-granting schools that are accredited by accrediting institutions 

recognized by the Secretary of Education satisfies degree or education requirements. 

Degrees obtained from Non-Accredited/Pending Accreditation institutions may suffice if certain 

provisions are met. First, the school must fully meet the definition of Non-Accredited/Pending 

Accreditation. Employees or applicants can be required to provide written documentation of a 

school’s status before the agency makes a judgment as to whether education is qualifying. This 

ensures that the course work is equivalent to conventional higher education programs of U.S. 

institutions. 

OPM’s education policy also details the provisions for assessing credits given for life experience 

under Other Education. The college or university must identify the course work area(s) or 

course(s) for which credit was given, and there must be a direct link between credit given and the 

course objective or syllabus. Life experience credit for courses that are not identified in the 

school’s course catalog as part of the school’s curriculum is not acceptable, unless the college or 

university is giving credit for course work that is a prerequisite for more advanced courses 

included in its curriculum. 

OPM is revising and will issue changes to its handbooks, public information, and forms to clarify 

these issues. We are consulting with interested parties in this process. You will see changes in 

the following: 
POLICY GUIDANCE 

Delegated Examining Operations Handbook 

OPM Operating Manual, “Qualification Standards for General Schedule Positions” 

Training Policy Handbook (OPM web site) 

HR Flexibilities (OPM web site) 

Enterprise Human Resources Integration (EHRI) Initiative Training Data Elements 

INV-020 - Questions and Answers About Background Investigations 

OPM-CONTROLLED FORMS (Subject to publication and notice periods) 

 OF 612 - Optional Application for Federal Employment 

 OPM Form 1300 - Presidential Management Fellow Application 

Standard Forms (SF) 85/85P/86 - Questionnaire for Non-Sensitive/Public Trust/National 

Security Position 

OF 510 - Applying for a Federal Job 

IS-15 – Requesting OPM Personnel Investigations 

INV Form 43 - Investigation Request for Educational Registrar and Dean of Students 

Record Data 

ADVICE TO THE PUBLIC AND FEDERAL AGENCIES 

OPM.GOV 

USAJOBS - Resume and Vacancy Announcement Builder 

Resume Builder 

VACANCY ANNOUNCEMENT BUILDER

Educational and Training Provisions or Requirements Fact Sheet 

Your Department or Agency should ensure that it is following this guidance immediately. If you 

have any questions, please have your Chief Human Capital Officer contact the Human Capital 

Leadership and Merit System Accountability Division Deputy Associate Director assigned to 

your agency. OPM presented a half-day seminar on these issues on May 5 and 7. If there is 

sufficient interest, we will be happy to present additional seminars, in Washington, DC or, in 

coordination with you, at sites outside of Washington where sufficient attendance will be 

available. 

cc: Chief Human Capital Officers 

 Human Resources Directors 

 Personnel Security Directors