By Perdia Education
Public skepticism toward traditional online program managers did not arise without cause. The 2024 Chapter 11 restructuring of 2U, along with public criticism of other OPM providers, has raised important questions about financial stability, transparency, institutional control, student recruitment, and the role of private companies in higher education. [1]
Faculty members, policymakers, students, trustees, and consumer advocates have every right to ask who controls an academic program, who communicates with prospective students, how an outside provider is paid, how student data is protected, and whether the institution remains accountable for the student experience.
Perdia Education welcomes those questions. What we reject is the assumption that every third-party education servicer is the same, or that every agreement funded through a share of tuition automatically represents the traditional OPM model.
Scrutiny is necessary. Category errors are not. |
Online program manager is an industry term, not a distinct federal regulatory status. The U.S. Government Accountability Office has noted that the Department of Education does not maintain a single controlling definition of an OPM. In practice, the label has been applied to companies with very different responsibilities, ranging from marketing and technology support to organizations that design courses, manage faculty relationships, influence pricing, and operate substantial parts of an institution’s online division. [2]
Federal rules take a more functional approach. They define a Third-Party Servicer by the services it performs under contract for an eligible institution in connection with the institution’s participation in Title IV programs. That framework focuses on written responsibilities, institutional oversight, regulatory compliance, reporting, audits, records, security, and accountability. It does not assume that every outside provider has been given control of a university’s academic mission. [3]
Perdia Education operates as a Third-Party Servicer under the Title IV regulatory framework and has been assigned TPS ID #77001825. The Department of Education does not list, endorse, or approve third-party servicers. The ID reflects Perdia’s reporting, annual audits, and oversight status within the applicable framework; it is not a government endorsement or approval of Perdia’s services. [4, 5]
That distinction matters. Perdia does not rely on a government label as a marketing credential. We rely on the substance of our contracts, the limits on our role, our compliance obligations, and the results we are accountable for delivering.
Perdia does not develop curricula, build courses, employ faculty, teach classes, assign grades, set academic standards, award credentials, or provide an institution’s learning management system. We do not determine what students must learn, who is qualified to teach, how academic performance is evaluated, or whether a degree should be awarded. Those responsibilities belong to the college or university and must remain there.
Our agreements are nonexclusive. Partner institutions remain free to conduct their own marketing and enrollment activities and to work with other providers. Perdia does not ask an institution to surrender control of its online programs, discontinue its internal operations, or hand over its academic identity. Our purpose is to create additional incremental enrollments that complement, rather than replace, the institution’s existing strategy. [6]
The institution retains authority over admissions standards, final admission and program-enrollment decisions, tuition, financial aid awards, curriculum, faculty, academic policies, and the awarding of credentials. Perdia may help a prospective student understand requirements, complete an application, obtain transcripts, assemble documents, and navigate administrative steps. That support does not transfer the institution’s decision-making authority to Perdia.
There is a meaningful difference between helping a student navigate an institutional process and controlling the outcome of that process.
Enrollment growth requires far more than buying digital advertisements or sending prospective students a sequence of emails. It requires market research, technology, trained personnel, disciplined communication, application support, document collection, systems integration, reengagement of previously interested students, registration support, and continued attention to the barriers that cause adult learners to stop before enrollment or leave before graduation.
Perdia invests in this operational infrastructure on behalf of its partners. We fund marketing and outreach, configure the Emma enrollment management platform for the institution, build program-specific communication pathways, integrate with institutional systems, employ and train enrollment personnel, assist with application completion, collect required documentation, and help students obtain official transcripts. After admission, services may include administrative support related to financial aid documentation, registration, institutional holds, continued communication, and persistence. The institution continues to control and process Title IV funds. [6]
Emma is not a substitute for an institution’s academic systems or faculty. It is an enrollment and student-experience platform that helps people complete complicated administrative processes through clear, manageable steps. Its purpose is to reduce avoidable friction, missed communications, incomplete applications, and unresolved administrative issues that prevent otherwise qualified students from progressing. Institutions can leverage Emma as a standalone operational system for their own internal use, if desired.
Perdia also evaluates institutional processes and provides research and strategic guidance so that the university gains more than a temporary flow of inquiries. The long-term objective is to strengthen the institution’s enrollment capabilities, workflows, use of data, and ability to serve online students effectively.
That is enrollment management. It is not academic program management.
Some public criticism treats the phrase revenue sharing as proof that an arrangement is improper. It is not. A percentage-based fee describes how a service provider is paid. It does not, by itself, establish what services are being provided, who controls academic decisions, whether students are treated fairly, or whether the agreement complies with federal requirements.
Revenue sharing deserves careful examination, but it cannot substitute for that examination.
Many regional, private, community-based, and tuition-dependent institutions face significant financial pressure. Competition for students is intense, operating expenses remain high, and many institutions have limited unrestricted cash available for major investments in marketing, technology, enrollment personnel, and student support. Current higher education credit outlooks continue to identify enrollment, liquidity, tuition, expense, and financial-flexibility pressures across meaningful parts of the sector. [7]
Perdia offers a conventional fee-for-service arrangement as its first pricing option, allowing institutions to pay directly for marketing, technology, staffing, implementation, and enrollment support. However, many institutions either decline this option or are unable to fund it because it requires significant financial commitment before enrollment results are realized. Under this structure, the institution assumes the upfront costs and related implementation, staffing, technology, and marketing risks. Although this approach may be practical for well-resourced universities, it is often beyond the available budgets of institutions facing limited liquidity and competing priorities. In those cases, Perdia offers a performance-based tuition-sharing model that funds the same bundled services while reducing the institution’s initial financial burden and aligning Perdia’s compensation with the enrollment revenue generated.
Perdia’s bundled model addresses that problem by investing its own capital in marketing, technology, staffing, and enrollment operations. Under the model described in our institutional proposals, the partner does not pay separate setup, consulting, or administrative fees for the bundled services. Perdia’s compensation is funded from tuition generated after students enroll and begin coursework. [6]
This structure gives institutions access to capabilities they may not otherwise be able to finance and transfers a meaningful portion of the upfront financial risk from the institution to Perdia. Eliminating performance-funded models would not eliminate the cost of enrollment infrastructure. It would reserve that infrastructure only for institutions already able to finance it in advance.
This is not an argument that every revenue-sharing agreement is appropriate. Some contracts may be too broad, too restrictive, insufficiently transparent, or poorly governed. It is an argument that the method of payment must be evaluated together with the services, safeguards, decision rights, employee compensation practices, institutional economics, and student protections contained in the agreement.
The Higher Education Act and its implementing regulation prohibit an institution from paying a commission, bonus, or other incentive compensation based directly or indirectly on success in securing enrollments or financial aid to a person or entity engaged in covered recruitment, admissions, or financial aid activities. [8]
That prohibition is real, and Perdia does not treat it lightly.
Federal Student Aid guidance distinguishes prohibited tuition sharing, when compensation is calculated as a reward for enrollment success, from the use of tuition revenue as the source of compensation paid to an unrelated third party for a genuine variety of bundled services. The Department’s guidance also makes clear that individuals involved in recruitment may not be paid based on enrollment success. [9]
Perdia structures its model to operate within those constraints. The relationship is based on a substantive bundle of services, not recruitment alone. The institution retains independent authority over admissions and program enrollment. Individual employees engaged in student recruitment are not to be compensated according to the number of students they enroll. Contracts, job descriptions, compensation plans, communications, system access, and day-to-day practices must all reflect those boundaries.
Compliance is not established merely by calling an agreement bundled. It must be demonstrated through the actual division of responsibilities, employee compensation practices, institutional controls, documentation, audits, and operations. Perdia supports that level of accountability.
Perdia is an outside contracted entity, not an employee of a partner institution. For the covered functions it performs, however, Perdia acts on behalf of the institution and is subject to applicable Title IV requirements. The institution does not escape responsibility by using a servicer, and the servicer does not operate outside the compliance framework.
Federal rules require written contracts that describe the servicer’s functions and impose specific obligations. Depending on the functions performed, those obligations include compliance with applicable Title IV requirements, access to records, return of records and funds when services end, audit requirements, reporting, and joint and several liability with the institution for violations resulting from the servicer’s work. [10]
That is a material difference from a vendor that simply sells a list of leads and disappears. Perdia accepts that an institution must supervise the services performed on its behalf. We also accept that Perdia must be accountable for the functions it performs and for the protection of the student information required to perform them.
Proper third-party relationships are not designed to remove institutional responsibility. They are designed to define responsibility clearly, place it in a written agreement, preserve access to records and data, and create the controls needed to monitor performance and compliance.
Recent criticism of the OPM industry has focused heavily on situations in which prospective students may not understand that they are communicating with a third-party employee. That concern should be addressed directly.
A university-branded enrollment experience can be appropriate because the student is applying to the university, not to Perdia. The university owns the academic program, admits the student, delivers the education, and awards the credential. But university branding should never be used to create confusion about the role or employer of a contracted service provider.
Perdia is committed to communications that accurately explain its role as an enrollment services provider working on behalf of a partner institution. Perdia personnel should not imply that they are faculty members, independent academic counselors, or direct employees of the institution when they are not. Titles, email signatures, scripts, websites, advertising, and student communications should accurately reflect the relationship. Department guidance has warned that inaccurate representations about a third-party employee’s employer or role can create substantial misrepresentation risk. [11]
Transparency does not weaken an institutional partnership. It strengthens student trust and protects both parties.
Rather than condemning every third-party relationship under one label, higher education should evaluate each agreement according to the questions that actually matter.
Who controls curriculum, faculty, academic standards, admission, tuition, financial aid, and the awarding of credentials? Is the agreement exclusive, or does the institution remain free to pursue other strategies? Does the provider receive payment for a legitimate bundle of services, or simply for producing enrollments? Are individual recruiters insulated from enrollment-based commissions? Are students told who is communicating with them? Can the institution access and recover its data and records? Are responsibilities documented, monitored, and auditable? Does the arrangement build institutional capacity, or create dependence?
Perdia’s model is designed to answer those questions in favor of institutional control.
We do not ask a university to outsource its mission. We ask to be held accountable for a defined set of enrollment, technology, marketing, and student-support services. We invest capital that many institutions cannot reasonably commit in advance. We work within the institution’s standards and systems. We support students through administrative processes while the institution retains the authority that belongs to it. We operate through nonexclusive agreements, and we are compensated for the complete bundle of services we provide.
Faculty members deserve assurance that academic governance will remain with the institution. Students deserve accurate information, responsive service, and a clear understanding of who is assisting them. Trustees and institutional leaders deserve transparent economics and measurable performance. Regulators deserve documented compliance. Perdia’s model is built to serve all four interests.
Higher education should continue to scrutinize third-party providers. Perdia welcomes that scrutiny because strong oversight rewards responsible partners and exposes irresponsible ones.
But scrutiny must be based on facts, functions, contracts, and conduct, not on a broad label or the payment method alone.
Perdia does not manage online academic programs. We help institutions find, enroll, and support the students those programs were created to serve. We do so while preserving academic ownership, institutional authority, regulatory accountability, transparency, and financial flexibility.
That is not the traditional OPM model. It is an accountable enrollment management partnership built to protect and strengthen higher education
The references below support the regulatory and industry context discussed in this opinion editorial. Internal descriptions of Perdia’s services are based on the company’s current proposal materials.
[1] 2U, Inc., Form 8-K reporting commencement of Chapter 11 cases, July 25, 2024. Source
[2] U.S. Government Accountability Office, Higher Education: Education Needs to Strengthen Its Approach to Monitoring Colleges’ Arrangements with Online Program Managers, GAO-22-104463, April 2022. Source
[3] 34 C.F.R. section 668.2, definition of Third-Party Servicer. Source
[4] Federal Student Aid, Third-Party Servicers, Title IV Program Eligibility. The inquiry process collects and validates information for oversight. Source
[5] Federal Student Aid, Third Party Servicer Frequently Asked Questions, D&E-Q6. This archived resource contains the Department’s express statement that it does not list, endorse, or approve third-party servicers. Source
[6] Perdia Education, Enrollment Services Proposal, September 9, 2025. Internal company document describing nonexclusive enrollment services, Emma, institutional responsibilities, and the bundled compensation model.
[7] S&P Global Ratings, U.S. Not-For-Profit Higher Education 2026 Outlook: Lower Expectations for Higher Education. Source
[8] 34 C.F.R. section 668.14(b)(22), incentive compensation prohibition. Source
[9] Federal Student Aid Handbook, 2025-2026, Volume 2, Chapter 3, Title IV Administrative and Related Requirements, including the tables addressing bundled services and tuition as a source of compensation. Source
[10] 34 C.F.R. section 668.25, contracts between an institution and a third-party servicer. Source
[11] U.S. Department of Education, Notice of Interpretation Regarding Misrepresentations by Third-Party Service Providers Engaged by an Institution of Higher Education, January 16, 2025. Source
Editorial note: This document is an opinion editorial, not legal advice. Perdia and each partner institution should have qualified counsel review applicable agreements, employee compensation practices, disclosures, and operating procedures for compliance with current law and guidance before publication or implementation.