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Submission For The Record of Mr. Ronald F. Chamrin, American Legion, Assistant Director, Economic Commission

Chair Herseth Sandlin and members of the Subcommittee, The American Legion appreciates this opportunity to share its views on State Approving Agencies (SAA) and the impact they have regarding the veterans’ education benefits. 

STATE APPROVING AGENCIES

The American Legion is deeply concerned with the timely manner that veterans, especially returning wartime veterans, receive their education benefits.  Annually, approximately 300,000 service members (90,000 of them belonging to the National Guard and Reserve) return to the civilian sector and use their earned education benefits from the Department of Veterans Affairs (VA). 

Any delay in receipt of education benefits or approval of courses taken at institutions of higher learning can adversely affect a veteran’s life.  There are time restrictions on most veterans’ education benefits, significantly, the National Guard and Reserve in which they must remain in the Selected Reserve to use their earned benefits. 

The American Legion believes that every effort should be made to ensure that the Montgomery GI Bill (MGIB) and related veterans’ education benefits are delivered without problems or delays.  Furthermore, veterans are unique in that they volunteer for military service; therefore, these educational benefits are earned as the thanks of a grateful nation. The American Legion believes it is a national obligation to provide timely oversight of veterans’ education programs to assure they are administered in a timely, efficient, and accurate manner. 

A recent Government Accountability Office (GAO) Report entitled “VA Student Financial Aid; Management Actions Needed to Reduce Overlap in Approving Education and Training Programs and to Assess State Approving Agencies” (GAO-07-384) focuses on the need to “ensure that Federal dollars are spent efficiently and effectively.”   

GAO recommends that VA should require SAA to track and report data on resources spent on approval activities, such as site visits, catalog review, and outreach in a cost-efficient manner.  The American Legion agrees. Additionally, GAO recommended that VA establish outcome-oriented performance measures to assess the effectiveness of SAA efforts.  The American Legion fully agrees.  In response, VA Deputy Secretary Mansfield plans to establish a working group with SAA to create a reporting system for approval activities and develop outcome-oriented measures with a goal of implementation in the FY 2008 budget cycle.

Finally, GAO recommended that VA should collaborate with other agencies to identify any duplicate efforts and use the agency’s administrative and regulatory authority to streamline the approval process.  The American Legion agrees.  VA Deputy Secretary Mansfield responded that VA will initiate contact with appropriate officials at the Departments of Education and Labor to help identify any duplicate efforts.

SEC. 301 of PL 107-330 created increases in the aggregate annual amount available for state approving agencies for administrative expenses from FY 2003- FY 2007 to the current funding level of $19 million.  The American Legion fully supports reauthorization of SAA funding. 

The American Legion opposes the President’s budget request for SAA funding at just $13 million for FY 2008.  The American Legion believes this is totally inadequate, especially for a nation at war, and strongly recommends keeping SAA funding at $19 million in FY 2008 to assure current staffing and activities.

SERVICES TO VETERANS

State Approving Agencies have the function of ensuring that qualified educational institutions and vocational training  establishments (offering apprenticeship and other on-the-job training) meet and maintain acceptable approval standards for enrollment of eligible VA educational beneficiaries.  State Approving Agencies currently provide qualified personnel with extensive knowledge in education administration and a full understanding of the laws and regulations that govern VA education benefits.

Receiving earned educational benefits under the Montgomery GI Bill usually takes 30 days. For veterans previously enrolled, current law authorizes VA to backdate the approval for up to one year, depending on the start date of the veteran's training. This usually covers most delays in the approval process.

After receipt of the veteran’s original visit and submission of the approval package,  SAA will request annual updates of the approval package. This is required when the school publishes a new catalog. Also, for veterans enrolled for the fiscal year (October-September), SAA will conduct an annual supervisory visit to the learning facility to check veterans’ records. The approval to train an eligible veteran is strictly voluntary on the part of the training facility and can be withdrawn upon the participating veteran’s request at any time.

State Approving Agencies operate under contract with VA. As such, SAA have their foundations in Federal law, Title 38, United States Code (USC). SAA operate as part of the government of the State and maintain the State's authority to approve or disapprove veterans' education and training programs. They also serve to prevent abuses and promote equality in veterans' education by evaluating and monitoring education and training programs.

The Code of Federal Regulations [38 CFR 21.4151(b)] summarizes SAA responsibilities:

  • to inspect and supervise schools and training establishments within the State,
  • to determine those programs of education and training which may be approved for veterans and other eligible students,
  • to determine whether a school or training establishment at all times complies with established standards relating to the approved programs, and
  • to render services and obtain information necessary for VA to approve or disapprove programs offered by any agency or instrumentality of the Federal government within the State.
  • The USC further requires SAA to cooperate with VA and pay particular attention:
  • to enforcing approval standards,
  • to enforcing enrollment restrictions, and
  • to identifying fraudulent and other criminal activities by persons connected with educational institutions and training establishments where veterans are enrolled.

As a part of the State government, SAA are also responsible for enforcing standards set by the various branches and licensing agencies of the State.

For eligible veterans to receive their Montgomery GI Bill education benefits, they must be matriculated in a SAA approved program, and attend training during a period of time (semester, term, etc.) under which the training has been approved.  It is the responsibility of the institution to maintain current approvals.  SAA assist institutions with maintaining updated program information and approval.  Institutions are required to send SAA four copies of the catalog every time a new edition is published, or at least once every three years.  Institutions are also expected to keep the SAA informed on a change of ownership, change in policy, new programs, program changes, and current or projected term dates.

VETERANS' HIGHER EDUCATION ADVOCACY

For such an important benefit, the ratio of support to overall benefit SAA provides to America’s veterans is quite astonishing.  In this current era of high speed Internet and electronic data sharing, the temptation to believe the need for staff is dwindling, especially as advanced technology is increasing. However, The American Legion believes that personal interaction is imperative and cannot be replaced.

The American Legion believes on-site visits to institutions of higher learning and vocational training facilities, interface with school officials, and one-on-one personal interaction with veterans is irreplaceable.

SAA act as monitors or “watchdogs” to higher education academia in that by SAA very presence helps to assure that veterans are being afforded the same opportunities compared to the larger non-veteran student population. Our country’s history has not always been kind and welcoming to recently separated veterans into the classroom. Through the tireless efforts of veterans’ advocates and other interest groups, such as SAA, higher education has gained valuable insight and now seems to welcome veterans into their culture.  SAA continue to be visible instruments of veterans’ advocacy and any diminishing of their presence would adversely affect currently enrolled veterans, as well as future generations of veterans.

The American Legion recognizes the importance to assure that veterans’ education programs are beneficial to veterans and not just universities, colleges, and vocational training facilities.  Administrators and other educational officials are constantly striving to morph, advance, expand, and explore new avenues of research and education, but must never forget the veterans’ portion of their student population.  SAA oversee and inform universities, on-the-job-training and apprenticeship programs when their courses do not meet the required standards for entitlement to veterans’ education benefits.

Interpersonal relationships between SAA staff and veterans ensure that an individual enters a program that will lead to productive educational and/or developmental goals.  Also, notification of changes in veterans’ benefits, in addition to technical assistance for education, is relayed from SAA officials to veterans.  Students are usually so engrossed in collegiate activities that they are too busy to know events outside of scholastic life.  Acting as veterans’ counselors, SAA fill an important role in the lives of veterans utilizing their earned educational benefits.

INCREASE IN USE OF VETERANS’ EDUCATION BENEFITS

Starting in 2001, the total use of education benefits by veterans continues to increase.  The following graphs reflect the changes from 2001-2006.  Chart 1 shows the increasing trend in usage of all VA education benefits programs.  Chart 2 shows the increasing trend of the MGIB.

Line Graph showing the total participants trained in all VA Education Programs

Line graph showing the MGIB (AD/SR/REAP) Number of Participants

In FY 2006, approximately 470,000 individuals received education benefits.  This equates to approximately 3 million courses taken by veterans.  Such an astronomical number for such a minute unit of measurement emphasizes the importance of timely and accurate oversight of VA’s education benefits.

The National Association of State Approving Agencies (NASAA) states that there are currently 200,000 approved programs.  These programs are evaluated on a rotational basis, with new, old, and failed programs contributing to their tally.

With the current increasing rate of eligible veterans and the increasing quantity of discharged veterans, the need for assistance and implementation of all elements of veterans’ benefits will continue to rise.  At the very least, maintaining the current level of SAA programs and staff will provide a baseline for oversight of VA’s education programs. 

CONCLUSION

Historically, The American Legion has encouraged the development of essential benefits to help attract and retain service members into the Armed Services, as well as to assist them in making the best possible transition back to the civilian community.  The Servicemen’s Readjustment Act of 1944, the “GI Bill of Rights” is an historic piece of social legislation, authored by The American Legion, that enabled millions of veterans to purchase their first homes, to attend college, obtain vocational training, receive quality health care and start private businesses.

The role from SAA is especially critical in providing wise counsel, moral support and technical expertise in the seamless transition from honorable military service to classroom academics.  In a time of war, every effort to promote and facilitate the use of veterans’ education benefits must be a national priority.

The American Legion believes that honorable military service, combined with improved education and vocational training opportunities, enhances an individual, increases diversity, and betters society as a whole.  The education pillar is continuous and ever evolving.  Diminishment in support for education and ability to gain knowledge for veterans will harm the nation as a whole, decrease the ability to recruit new service members, and unfairly subject veterans to barriers of benefits that they have earned.

State Approving Agencies are instrumental in the education process. The American Legion fully supports all efforts to maintain and enhance veterans’ education benefits and recommends that State Approving Agencies remain funded at $19 million in FY 2008.

The American Legion appreciates the opportunity to present this statement for the record.