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Witness Testimony of James Bombard, National Association of State Approving Agencies, Legislative Director, and Chief, New York Bureau of Veterans Education

Introduction

Madam Chairwoman and Members of the Subcommittee, I am pleased to appear before you today on behalf of the National Association of State Approving Agencies (NASAA) to provide input, support, and to discuss the provisions of the following bills:  H.R. 3813, H.R. 4079, H.R. 3948, H.R. 3579, H.R. 3484, and H.R. 4203.  The other bills listed in the invitation letter (H.R. 3257, H.R. 3976, H.R. 4359, and H.R. 4469) are not within the purview of education benefits so I will not be commenting on them.  We are supportive of them in principle.

State Approving Agencies have been an integral part of the administration of the various GI Bills since shortly after the inception of the original GI Bill in June of 1944.  It has been our distinct pleasure and honor to have the opportunity to contribute to the success of these programs.  In short, State Approving Agencies are “the face of the GI Bill at the state level.” 

H.R. 3813

This bill would expand the Post-9/11 GI Bill to include approved programs offered at noncollege degree educational institutions.  The Post-9/11 GI Bill does not provide increased benefits for all eligible veterans/individuals because it limits the type of educational institutions they can choose to use their earned benefits.  Students attending nondegree granting postsecondary educational institutions (public vocational-technical, some career schools, certain nursing schools, and other approved educational institutions) are not eligible for increased benefits under the Post-9/11 GI Bill.

On return to civilian life, many service members are interested in hitting the ground running.  Short-term certificate and diploma programs can be a critical part of a successful transition.  But if they are not offered at a degree granting institution, then programs such as truck driving, some police and firefighting academies, aviation maintenance, cosmetologist, barber, HVAC, construction trades, allied medical programs such as medical assisting, EMT, etc., are not available for pursuit under the new GI Bill.  Nondegree institutions have been included in other GI Bills so why should Chapter 33 be different?  After a veteran has bravely served their country, they should be allowed to pursue their next career at the institution of their choice.  Since all institutions/programs must be approved by the State Approving Agency, there is a detailed review by a government agency to ensure all state and federal requirements are met.   State Approving Agency staff have had many examples of individuals who do not understand why they cannot use their earned benefits.  In fact, on February 3, 2010, during a routine supervisory visit to a cosmetology school in Pennsylvania, William Stephens (NASAA President) had to explain this “short fall” in benefits to both a Pennsylvania National Guard member (with over 36 months of active duty) and the father of a National Guard member who had transferred his benefits to his daughter so she could obtain her cosmetology education and license.  Both thought they could use their earned Chapter 33 benefits at this institution and now have a potential large shortfall in their benefits.  They were both understandably frustrated.  They had earned the benefits and should be able to use them (or give them to their dependents) at the approved institution of their choice.

H.R. 4079

This bill would remove the requirement for employers to increase wages for veterans enrolled in on-the-job training programs.  It is necessary due to the difficult economic times.  This would be a temporary waiver (5 years) of the mandatory wage increase for private sector employers to participate in the VA on-the-job training program.  It will allow veterans to utilize their GI Bill as they pursue job training and careers consistent with the promise of the GI Bill. 

Difficult economic times that contribute to wage freezes or wage reductions in the private sector impacts veterans seeking OJT benefits from the approval perspective as wage increases are required in the private sector only.  The quality of a training program is not predicated on wage increases. 

A national survey completed by the National Association of State Approving Agencies (NASAA) found that 22 of 30 states that are active in the on-the-job training program have identified lost approval opportunities due to the wage increase requirement. 

As an example, in Missouri, it is estimated more than 20 employers have not qualified for approval due to the wage increase requirement since mid FY 2009.  Some of these companies are nationally known while others represent the small business sector.  The impact of the GI Bill through the on-the-job training program is enormous. 

The product created by passage of H.R. 4079 is a level playing field for veterans opting for on-the-job training.  The wage increase requirement for public sector employers was removed several years ago (based on the same rationale) as state, county, and municipal budgets flat lined.

Employers, both private and public, are not allowed to pay less in wages to eligible veterans/reservists/dependents than other similarly qualified trainees.  This is a regulatory requirement and is monitored by State Approving Agencies.  The passage of this bill will allow eligible veterans/individuals to use their earned benefits during these difficult economic times at programs that are approved and monitored by State Approving Agencies.

H.R. 3948

This bill would include the payment of Chapter 33 benefits for test preparatory courses for a test that is required or used for admission to an educational institution.  Currently Chapter 33 eligible individuals can use their benefits for one licensure or certification test reimbursement.  This bill will expand the opportunities and permit eligible individuals to use their earned benefits in obtaining admission to educational institutions.  We support this bill and recommend that additional consideration be given to expanding the number of test preparatory courses and the number of tests for licensure or certification for which veterans can use their earned benefits.

H.R. 3579

This bill would increase the reporting fees paid to institutions for their role in administering the GI Bill.  The current fee structure ($7.00 for regular enrollments and $11.00 for advance pay enrollments) has been in force for over 30 years.  It is time for an increase.  Certifying Officials at the various institutions are a "key" player to the success of the GI Bills.  They are the “front line” and have the most contact/interaction with veterans/reservists/dependents.  As a side note, some Certifying Officials are able to use these funds for travel to training sessions sponsored by State Approving Agencies and/or Department of Veterans Affairs.  It is time to increase their reporting fee. 

H.R. 3484

This bill would extend the authority for veterans to use the work study program while assisting with the preparation and processing of papers and other documents at educational institutions or facilities of the VA and working in support of certain other veteran related activities at the federal and state level, such as outreach activities conducted by the VA and State Approving Agencies.  Many veterans find it necessary to supplement their benefits by working.  The work study program has been very successful and not only provides eligible veterans a method to increase their income while in school but also provided a substantial amount of workers for Department of Veterans Affairs, State Approving Agencies, and educational institutions.  An extension of these other activities is a “win-win” situation. 

H.R. 4203

This bill would ensure veterans have the opportunity to use direct deposit of their benefits.  This approach to the payment of benefits not only provides a secure and fast method for the veteran/individual to receive his/her benefits, it also is more efficient for the Department of Veterans Affairs, thus, saving staff time. 

Closing

We encourage the leadership and members of this Committee to take a firm and aggressive stand in promoting the enactment of the bills discussed above.  We would also like to respectfully request your support for another bill, H.R. 4571, which was just introduced by Representative Sestak from Pennsylvania.  This bill would increase State Approving Agency funding.  As we have discussed before, funding for SAAs has remained at $19 million for the past 5 years and with the increased workload associated with the Post-9/11 GI Bill and increased operating costs, many State Approving Agencies are in crisis.  Some are finding it necessary to decrease staff for this current fiscal year.  Now is not the time to decrease the service for those who have served (or are currently serving) our country.  We have provided written documentation on the rationale to increase SAA funding.   We are available to provide additional detail on our request and look forward to working with the Subcommittee on H.R. 4571 or similar legislation which the Committee may consider.

Thank you Madam Chairwoman and members of the Subcommittee for the opportunity to address you today.  We would be pleased to respond to any questions that you have.