On 10/6/16, 3:11 PM, "Jennifer Azzarano" wrote: Good Afternoon Ms. Waldman, Let us again begin responding to your questions by noting that you have clearly made some judgments, without facts, and gone on to draw conclusions based on your own, unprofessional assessments and not anything issued or outlined by any authority. Questions: 1. Do you think that the incentive might influence how reviewers write their reviews? Or somehow create bias? a. You are the one calling it an incentive, and the answer is, no. A thumb drive was provided no matter how a reviewer responded. 2. None of the students disclosed that they received a gift. Why did the agency not ensure this disclosure? In its guides, the FTC has made clear that “marketers” need to disclose any material connections they may have with “endorsers,” so that other consumers are aware of any incentives that led to reviews. 3. Google has also said that any incentivized review is not allowed, from their guidelines: “Conflict of interest: Reviews are most valuable when they are honest and unbiased. If you own or work at a place, please don’t review your own business or employer. Don’t offer or accept money, products, or services to write reviews for a business or to write negative reviews about a competitor. If you're a business owner, don't set up review stations or kiosks at your place of business just to ask for reviews written at your place of business.” Are you concerned that your giveaway may violate google’s own guidelines? a. To Questions No. 3 & 4: Because you are taking it upon yourself, and no independent authority, to interpret policies and federal regulations, it is important to note that Tuition Aid Grant (TAG) is not a product but rather a need-based funding program from the State – funding that is not repaid. HESAA does not gain any pecuniary benefit from more or less TAG recipients. This effort was built into our early Free Application for Federal Student Aid (FAFSA) availability campaign because this reminder is one of the many ways we are supporting TAG students in the renewal process. 4. Did the agency invite all students to the giveaway? Or only those that have received TAG grants? If only TAG students, why not invite the borrowers of NJCLASS loans or other programs to the giveaway? a. Please be aware that the student reviews that you asked about were a small part of a much larger, ongoing effort to build awareness of the early availability of the FAFSA. This specific portion of the awareness campaign was an outreach to TAG students who have previously benefited from TAG, which is New Jersey's premier need-based grant program. b. As stated twice in the request for reviews, our goal is to gain feedback on our customer service efforts. Everyone who responded with their experience received a flash drive along with a reminder to file their FAFSA. c. As for NJCLASS, please understand that those students do not have to adhere to State grant FAFSA deadlines and TAG students do. Therefore, the NJCLASS borrowers were not contacted through this early FAFSA availability awareness campaign. It is important to us that our responses are not taken out of context and I am happy to clarify any other aspects of HESAA’s efforts to promote the completion of the FAFSA. I welcome any additional questions that you or your editor may have. However, should you write another piece using only bits and pieces of our responses, as you have in the past, we will provide our full responses to all other media organizations and anyone else who may be prompted to contact us as a result of what you publish. Jennifer Azzarano Director of Communications From: ​Annie Waldman Date: ​Tuesday, October 4, 2016 at 3:41 PM To: ​"Marcia_Karrow@hesaa.org" , Gabrielle Charette , "amaglione@hesaa.org" Subject: ​Re: ProPublica Inquiry - Gift Giveaway + Reviews Hi Ms. Karrow, Ms. Charette and Mr. Maglione, About three weeks ago, HESAA started to receive dozens of five-star reviews on Google. Students have informed me that they were recently asked to write these reviews in exchange for flash drives. According to students, they received an email informing them about the giveaway, which offers free flash drives in exchange for reviews that show the benefits of HESAA. They were not told that they had to disclose the incentives they received for the review. Such reviews (those that were incentivized yet have no disclosure) go against Google guidelines​ and may also go against f​ ederal regs​ related to “truth-in-advertising”. The FTC has made it clear in their endorsement​ ​guide​ that when incentives are involved for online reviews, the incentives must be disclosed. Questions: 1. Do you think that the incentive might influence how reviewers write their reviews? Or somehow create bias? 2. None of the students disclosed that they received a gift. Why did the agency not ensure this disclosure? In its guides, the FTC has made clear that “marketers” need to disclose any material connections they may have with “endorsers,” so that other consumers are aware of any incentives that led to reviews. 3. Google has also said that any incentivized review is not allowed, from their guidelines: “​Conflict of interest: Reviews are most valuable when they are honest and unbiased. If you own or work at a place, please don’t review your own business or employer. Don’t offer or accept money, products, or services to write reviews for a business or to write negative reviews about a competitor. If you're a business owner, don't set up review stations or kiosks at your place of business just to ask for reviews written at your place of business.” Are you concerned that your giveaway may violate google’s own guidelines? 4. Did the agency invite all students to the giveaway? Or only those that have received TAG grants? If only TAG students, why not invite the borrowers of NJCLASS loans or other programs to the giveaway? Our deadline is 3pm tomorrow Wednesday, October 5, so if you could get back to us by then, we would appreciate it. Best, Annie Waldman -Annie Waldman ​ Reporter ​ProPublica d: 917-512-0244 c: 347-549-0332 annie.waldman@propublica.org @AnnieWaldman