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Witness Testimony of Arthur F. Kirk, Jr., President, Saint Leo University, Saint Leo, FL, on behalf of National Association of Independent Colleges and Universities

I am testifying on behalf of Saint Leo University and the National Association of Independent Colleges and Universities (NAICU) regarding H.R. 2301, a bill to change the reimbursement procedures under the Post-9/11 Educational Assistance Program.

Saint Leo University has a long history of serving veteran students—enrolling  4,743 during the past academic year, 2,790 (59 percent) of whom were Post-9/11 veterans.  The NAICU membership includes over 1,000 institutions nationwide, representing the diversity of private, non-profit higher education in the United States. 

H.R. 2301 would reduce the need for the Department of Veterans’ Affairs (VA) to make adjustments to their payments for veterans.  However, clearly, it also would increase the need to make adjustments at the school level for other financial aid for veterans -- particularly Title IV student financial aid.  Program participation would become much more complicated, both for the veteran students and for the institutions they attend.  Issues related to billing and to the assignment of responsibility for payment will be less clear.  The bill will require reprogramming of the management information systems of most schools; however, the more likely solution will be more manual adjustments. Meeting these challenges would be particularly difficult for small colleges—which could limit the options of veterans who wish to attend them. 

There are some pluses to H.R. 2301.  Student accounts do stabilize after add/drop deadlines so, if passed, the bill would provide a truer picture in most cases.  Also, the VA would pay after the term, so debt collection letters to the student or the institution would decline significantly, and time spent researching the letters would be reduced.

On the down side, cash flow to institutions and veterans would be problematic for many.  More Title IV aid adjustments for veterans’ accounts are likely to be needed.  It will be hard to pay Title IV credit balances to students, since they won’t have a credit on their account.  Veterans would face difficulties registering in many colleges without payment in advance or, in places like Saint Leo, without the bill being settled for the previous term before the next term begins.  Many institutional information systems will not be able to accommodate these changes without, at least, some re-programming.  Greater confusion about who owes what (the veteran, the VA, and Title IV) also will ensue.  Such confusion increases the barriers to successful completion for our vets.

We believe that the problems that H.R. 2301 is intended to solve would be better addressed through greater efforts to work within the framework the institutions now use to deliver financial aid to their students.  For example, we believe that a two-step certification process Saint Leo is planning will reduce the need for billing adjustments by the VA without adversely affecting veterans.  An approach like ours, or others that may be devised by other colleges, would offer a better solution.  Saint Leo, NAICU, and many others in the higher education community stand ready to assist the subcommittee in identifying ways to serve our veteran students effectively and efficiently.  


Chairman Stutzman, Ranking Member Braley, and members of the Subcommittee, I appreciate having the opportunity to appear today to discuss pending legislation dealing with the Post-9/11 GI Bill.  I am Art Kirk, president of Saint Leo University.

Saint Leo University is an independent Catholic university founded in 1889.  The University offers over 40 undergraduate and graduate degree programs on its residential campus in Florida, and to adult students on 16 military bases in Florida, Virginia, South Carolina, Mississippi, Texas, and California; to students in all states and overseas, through our center for online learning; and on 10 Florida community college campuses. 

The University began offering full degree programs on military bases in 1973, and became the first college or university in the nation to grant the bachelor’s degree on an Air Force base.  We were an early adopter, in 1997, of online offerings for the military.  The University’s mission, to provide opportunities for people of good character regardless of their religion, compelled the University to respond to these needs.

Saint Leo University enrolled 4,743 veterans during the past academic year, 2,790 (59 percent) of whom were Chapter 33 or Post-9/11 veterans.  The University awarded 678 associate, bachelor’s, and graduate degrees to veterans.  The University also educated 5,026 active duty military and reservists during the course of the last academic year.  All told, this equals 37 percent of the students who took at least one course with us during the year.

Today I represent not just my university, one of the leaders in educating our veterans and active duty military.  I also represent the member institutions of the National Association of Independent Colleges and Universities.  With more than 1,000 members nationwide, NAICU reflects the diversity of private, nonprofit higher education in the United States.  Members include traditional liberal arts colleges, major research universities, church- and faith-related institutions like mine, historically black colleges and universities, women's colleges, performing and visual arts institutions, two-year colleges, and schools of law, medicine, engineering, business, and other professions.  NAICU is committed to celebrating and protecting this diversity of the nation's private colleges and universities.

The subcommittee is receiving testimony about a number of bills today.  The one that I will address is H.R. 2301, which would change the reimbursement procedures for veterans and colleges and universities under the Post-9/11 Educational Assistance Program.

This bill would reduce the need for the Department of Veterans’ Affairs (VA) to make adjustments to their payments for veterans.  However, clearly, it also would increase the need for adjustments at the school level for other financial aid for veterans -- particularly Title IV student financial aid.  Program participation would become much more complicated, both for the veteran students and for the institutions they attend.  Issues related to billing and to the assignment of responsibility for payment will be less clear.  The bill will require reprogramming of the management information systems of most schools; however, the more likely solution will be more manual adjustments.  I will address this concern more fully in a moment.

A particular concern is the impact of this change on small colleges, and on the veterans who choose to attend them.  While I would be quite pleased if every veteran looking for a college were to choose Saint Leo, I also believe deeply in the goal of the GI Bill to give veterans the widest choice possible of educational options. 

Over half of our nation’s private, non-profit colleges have fewer than 5,000 students, and a quarter have fewer than 2,000.  Many veterans choose to attend these smaller institutions.  While their veteran student population is just a fraction of that at Saint Leo, these small schools will struggle far more with the new procedures under this bill, and the consequent cash flow problems.  The typical semester is 15 weeks.  This bill would move payment from the beginning of the semester, when most student accounts are collected, to 30 days after the semester ends.  That’s 19 weeks in which to wait for payment.  Meanwhile, the institution will, of course, have had to pay faculty and staff salaries and other bills during that time.

This problem won’t necessarily be limited to small colleges.  The median endowment across all private, not-for-profit colleges is only about $18 million.  Indeed, while Saint Leo was not small 14 years ago, we did find that our cash flow was tight year-round at that time.  Delayed payment would have been a hardship for us.  Thankfully, we would now have the cash reserves to handle this.

Even if it is difficult to do so, private colleges may be able, by using cash reserves or lines of credit, to enroll students and defer collections as proposed.  However, public colleges and universities will face unique challenges if this bill is enacted.  Most public institutions must collect full tuition from their students, or from the students’ financial aid providers, at the beginning of the term.  Veterans will face barriers to enrolling at public universities and colleges, given that many will not be in a position to pay their tuition and fees up front, and then wait for their reimbursement months later.  

As I noted earlier, another concern for the many smaller colleges would be coping with changes in procedures.  Among others, these changes would involve such matters as manually voiding late payment fees and future registration blocks -- which trigger automatically when a student’s bill is not paid.

Saint Leo has several experts in the specialized services and administrative procedures essential to enrolling veterans.  We also have skilled staff members who train others in these procedures.  Small colleges or colleges with relatively small numbers of veterans are likely to lack these expert resources.

Saint Leo University already is implementing a two-step veteran’s certification process that, we believe, will resolve the problems this bill seeks to address.  Our Veterans Certifying Officers will enter the veteran as a student, but will certify zero tuition and fees in VAOnce -- the VA GI Bill database system -- at the semester’s start.  This allows the veteran to receive their housing and living stipend.  After the period for adding and dropping courses ends, we then will reenter the student in VAOnce, now adding the tuition and fee charges for all the courses in which the veteran is actually enrolled.

In summary there are some pluses to H.R. 2301:

  • Student accounts do stabilize after add/drop deadlines, so the bill would provide a truer picture in most cases.
  • The VA would pay after the term, so debt collection letters to the student or the institution would decline significantly.  Every one of these letters must be researched, and the time spent doing so would be reduced.

However, on the down side:

  • Cash flow to institutions and veterans would be problematic for many.
  • More Title IV aid adjustments for veterans’ accounts are likely to be needed.
  • It will be hard to pay Title IV credit balances to students, since they won’t have a credit on their account.
  • Veterans would face difficulties registering in many colleges without payment in advance or -- in places like Saint Leo -- without the bill for the previous term being settled before the next term begins.
  • Many college and university information systems will not be able to accommodate these changes without, at least, some re-programming.
  • Greater confusion about who owes what (the veteran, the VA, and Title IV) will ensue.  Schools won’t know what VA will pay, or what to bill the veteran.   Such confusion increases the barriers to successful completion for our vets.

We believe that the problems that H.R. 2301 is intended to solve would be better addressed through greater efforts to work within the framework the institutions now use to deliver financial aid to their students.  We believe, for example, that Saint Leo’s approach will have no adverse affects on the veterans, and will reduce the need for billing adjustments by the VA.  An approach like ours, or others that may be devised by other colleges, would offer a better solution. 

I’d also like to briefly mention the two other provisions of H.R. 2301:

  • Section 3 sets an effective date of August 1 of this year -- less than a month from now.  Making the proposed changes on such short notice would be highly disruptive for students, institutions, and the VA alike.  All of the procedural concerns outlined in my testimony would be magnified.
  • Section 4 specifies the means by which established charges per credit hour are to be determined.  It is our understanding that the provision is designed to avoid situations in which charges to a student taking only one course are significantly higher than the per-credit charge if the student were taking a full load.  However, since established charges per credit hour will no longer be used as the basis for determining the Chapter 33 tuition benefit, this provision will not have any effect that we can discern.  Rather, its most likely effect will be to create confusion about how it is to be interpreted.  For that reason, we would suggest that the language be dropped.

Saint Leo, NAICU, and many others in the higher education community stand ready to assist the subcommittee in identifying ways to serve our veteran students effectively and efficiently. 

Finally, on a related topic, allow me to take this opportunity to extend our appreciation to the members of this subcommittee, and to the full Veterans’ Affairs Committee, for your work in moving the "Restoring GI Bill Fairness Act of 2011" (H.R. 1383).  The bill provides an important "hold-harmless" for veterans who otherwise would see their Post-9/11 GI Bill tuition-and-fee benefits reduced August 1.  Enactment of this bill would assure that student veterans attending private institutions in several states will not face an unexpected increase in expenses while mid-way through their higher education programs.

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