Chairwoman Herseth Sandlin, ranking member Boozman and Members of the Subcommittee. NAVPA appreciates the opportunity to comment on proposed legislation as well as to highlight issues of interest and concern to it members and the population we serve.

While H.R. 3579, To amend title 38, United States Code, to provide for an increase in the amount of reporting fees payable to education institutions that enroll veterans receiving education assistance from the Department of Veterans Affairs, and for other proposes, was removed from the legislative hearing , we would like to go on record as supporting this bill.

School reporting fees have not changed since the inception over 30 years ago; however, several programs have been added on to the school Veterans’ Program Administrators’ responsibility at the institution and some, such as Vocational Rehabilitation, Chapter 31, have never been included.  Now, a new and even more complex education program has been added, Chapter 33, PL 110-252. While the reporting, reconciliation and overall cost of administering all programs has increased and the burden on the educational institution is not business as usual; the added work effort has not been calculated.  Also, the use of these fees should be designated to support the Office of Veterans’ Affairs/Services and for professional development of the school VA Certification Officials and other Veterans’ Program Administrators. We further propose that at minimum, recipients of this reporting fee must match these funds to support veterans’ services.

NAVPA supports H.R, 950, To amend Chapter 33 of title 38, United States Code, to increase education assistance for certain veterans pursuing a program of education offered through distance learning. The intention of the Post-9/11 GI bill is to pay the basic housing allowance for veterans while pursuing a program of study at an institution of higher learning and many veterans are not able to travel to an IHL for various reasons choosing to continue their education via distance learning.    Many students take classes online or at branch campuses of a school while serving on active duty.  Once released, they find gainful employment and continue their education to be competitive in the civilian workforce.  Also, in many cases active duty members are released due to a disability.  In these cases, the students’ only choice may be to complete their program of study through distance learning. 

All modalities are approved by the State Approving Agencies for Veteran Training and recognized by accrediting bodies.  This group of veterans should not be penalized for being responsible, disciplined adult learners, for putting their family first or whatever reason for choosing this credible 21st century mode of study.  Thousands of veterans and active duty students are enrolled in courses defined by law and approved as distance learning – a mode of study that is approved for veterans training for all other GI Bill programs, and that has become a trend in both private and public education today – distance learning, blended, hybrid, etc. We should not inhibit the ability of our veterans to participate in their educational plans by restricting the method by which they receive their course of study.

NAVPA Supports H.R. 3484 to extend the authority for certain qualifying work-study activities for purposes of the educational assistance programs of the Department of Veterans Affairs; H.R. 3813 to provide for the approval of certain program of education for purposes of the Post-9/11 Educational Assistance Program which would include programs of education offered by an institution offering instruction that does not lead to an associate or higher degree; H.R. 3948 to provide for entitlement under the Post-9/11 Education assistance program to payment for test preparatory courses and for other purposes and H.R. 4079 to temporarily remove the requirement for employers to increase wages for veterans enrolled on On-the-job training programs.

PL 110-252 limits training opportunities, excluding On the Job Training, Apprenticeships and other training opportunities.  Such limitations will prove to be a disservice to our veterans when they find that numerous career goals cannot be realized; and to our nation when we realize that the return on investment is not as great as it was with previous education programs.  Many veterans are not interested in attending college, but have the skills necessary to master a trade. Our country certainly needs tradesmen and women like electricians, plumbers, carpenters and truck drivers to bring goods and services to the communities across this nation. We recommend that benefits be made available for certain skill attainment, trades and continuing education consistent with the concept of life-long learning and to provide the same flexibility currently in the Montgomery GI Bill chapters.

We advocate administrative like changes to Veterans’ Education Programs that would:

Expand the student work study program - This program needs to be expanded to allow students to work in academic or administrative departments at the institution in which they are pursuing a degree.  This will enable students to work in a number of jobs within the college or university and gain valuable civilian work experience.

Not tie the certification of tuition and fees to the living stipend - The living stipend/housing allowance under the Post 9/11 GI Bill should not be tied to the certification of tuition and fees.  The Post-9/11 GI Bill requires that schools certify one term/semester at a time in order that actual tuition and fees be reported, rather than estimated.  Understanding this requirement, it will be necessary for the VA to develop another certification of “Anticipated Enrollment” in order that the living stipend/housing allowance will be paid without interruptions.  Allow schools and training institutions to certify students “intent” to enroll for the full academic year to establish eligibility for the living stipend.  Allow the VA to pay and continue paying the living stipend until a report (VA Form 22-1999b) is submitted by the education/training institution which would stop or otherwise adjust this monthly payment.  Further, we recommend that tuition and fees are reported/certified after the end of the schools’ published drop/add period.  This would result in a substantial reduction in the number of reports made by school officials and the number of adjustments made by the VA. 

Payment of tuition and fees must be made to the school in a timely manner.  The VA defines timely as 30 days from the occurrence.  Education institutions will work with the men and women who serve our country and appreciate the VBA’s position, but there should not be an expectation that they will carry account balances indefinitely or that they will continue to defer payments without verification of entitlement (Certificate of Eligibility).   

The majority of educational institutions are deferring tuition and fees (in the amount due from the VA) for students who are, or appear to be eligible for the Post-9/11 GI Bill.  However, these students came to college campuses with the understanding, a promise if you will that they would receive a monthly living allowance to supplement or in some cases cover living expenses.  The current system of certification (one term at a time) will delay monthly payments further if there is not a means to separate the certification of “Anticipated Enrollment Status” from the certification of tuition and fees.   

Allow for an electronic means of accessing education benefit information from Department of Veterans Affairs - NAVPA recommends that the Department of Veterans Affairs develop an Education Web Portal for easy and accurate access to VA Records pertaining to Veterans’ Education Benefits. Veteran students do not have an electronic means of accessing meaningful and useful information from the Department of Veterans’ Affairs on their education benefits, usage and remaining entitlement from their VA records.  Educational institutions are overwhelmed with the volume of calls, misinformation from the VA Call Center and limited ability to assist students in determining the status of their claims or even eligibility.  Above all, eligible individuals/students should have access to their VA records.  All information relative to their VA education benefits, eligibility, applications, enrollment certifications and payments should be made available to them through this portal. Information should include at minimum information sent to the veteran via the US mails at the beginning and throughout each academic year as contained in the ‘Award letter and now the Certificate of Eligibility under the Post-9/11 GI Bill.  

Designated school officials would have secure access to the portal for veteran students so they may provide counseling and assistance when necessary.  VA-ONCE and WAVE have partially covered these issues; however, all information is still not available.  Veterans should be able to view all pending issues to include receipt of documentation and current status, reasons for any delays in processing should also be addressed on this WEB portal.

We believe the implementation of a secure web portal will enhance service to veterans, bring efficiencies to the DVA with a corresponding reduction in telephone service personnel.  The efficiencies in personnel utilizations realized would benefit processing time.  This concept is needed now more than ever with the extreme delays in processing claims and the complexities of the Post-9/11 GI Bill.

In closing NAVPA request that the rules, policies and procedures governing the administration of the Post-9/11 GI Bill be made consistent, nationwide.  Due to the complexities of this program schools are currently working with limited to non-existent information.  Often what little they have was received through informal channels outside their state and RPO areas of responsibility.  It is critical that VA create policies consistent with the published final rules, document them thoroughly, and distribute them consistently at all levels from VA Central Office through RPOs and ELRs down to the institutions that must implement them. Only then can every veteran be assured of receiving the same benefit consideration no matter what school, state, or RPO is responsible for the processing of their claim.

Again, thank you for the opportunity to support meaningful legislation and to make recommendations for improvements in the administration of the GI Bills. I would be pleased to answer any questions you may have.

Respectfully submitted for the record.