On page 83 of the recent proposed rulemaking from the department of Education you will find:

Several negotiators were concerned about the impact of the proposed language on an institution’s Internet-based activities.  Negotiators asserted that the HEA permits advertising and marketing activities by a third party, as long as payment to the third party is based on those who “click” and is not based on the number of individuals who enroll.  The Department agrees and does not believe that the proposed regulatory language would prohibit such click-through payments.

Please explain to me how CPC makes more sense than cpl, other than with non-internet (call center) leads.  Anyone who can manage an efficient CPL program can just as easily manage a successful CPC program.  Still don’t see why internet driven CPL is being called into question especially for the lead provider who have zero interaction with the prospect who sought out, then filled out the lead form for the school.

To access the complete 500+ page doc Click: 

http://www.ed.gov/news/student-aid-rules-protect-borrowers-and-taxpayers

then click on the link in box on right: notice of proposed rulemaking.