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Witness Testimony of Ms. Margaret Baechtold, Director, Veterans Support Services Indiana University – Bloomington, IN On Behalf of National Association of Veteran Program Administrators (NAVPA)

Chairman Stutzman, Ranking Member Filner, and Members of the Subcommittee,

Thank you for the opportunity to testify today on behalf of the National Association of Veterans Program Administrators (NAVPA) regarding Executive Order 13607.  My name is Margaret Baechtold.  For over five years I have served as the Director of Veterans Support Services at Indiana University, a major public four-year institution of higher education where we believe in Honoring Service, Supporting Education, and Serving Veterans.  A veteran myself, I retired from the United States Air Force as a lieutenant colonel after 20 years of service.  I also currently serve as the Legislative Director for NAVPA.   NAVPA’s membership is comprised of educational institutions from all sectors with an organizational commitment to advocating for what is in the best interests of student veterans at our institutions.  Our expertise lies in the administration of veterans programs at colleges, universities, and other education providers and most of our members serve as school certifying officials for VA education benefits.  Our organization represents close to 400 educational institutions nation-wide and our leadership is comprised of non-paid staff members.  We voluntarily serve NAVPA in an effort to better serve the veterans on our campuses.

As a voluntary organization, NAVPA does not police its membership regarding the issues raised by this Executive Order.  Our primary mission is to provide training and professional development to member institutions, collect and disseminate best practices surrounding support for student veterans and military members, and advocate on behalf of students and our institutions.  As an organization, we believe strongly that all educational institutions should be forthright and open with all students, particularly with regards to veterans’ and military service members’ unique needs and circumstances.

Like so many other organizations, NAVPA has been dismayed at news reports of unscrupulous organizations’ treatment of unsuspecting veterans and we strongly condemn the abuses to which veterans have been subjected at the hands of some institutions.  While we believe there are no doubt costs and burdens involved in implementing Executive Order 13607 at our institutions, we cannot object to an initiative that seeks to ensure that veterans are appropriately recruited, advised, and supported while in school.  NAVPA is pleased that the President has taken such a direct interest in the education needs of our nation’s veterans. 

(Section 2 - Financial Advising) We recognize that a requirement to provide specific and personalized financial advising will be challenging to implement, and increases the administrative burden on schools.  This advice can only be provided if the institution has full access to all of the eligibility information required to determine possible aid alternatives.  NAVPA has long advocated for direct access to student information from the VA and will continue to do so.  At present, eligibility information is generally not provided directly to institutions, and it is incumbent upon students to furnish such information.  As students do not always self-identify as military service members or veterans prior to enrollment, comprehensive information about student benefit eligibility is exceptionally challenging to obtain.

The timing of institutional and agency business practices will also make implementation of financial advising requirements difficult.  Some specific services that may be mandated pursuant to the Executive Order require information about student benefit eligibility from both the VA and the DOD at a very early stage (prior to enrollment).  However, students cannot even apply for certain federal benefits or assistance, such as Army Tuition Assistance, until after they have already enrolled in classes.  Schools cannot effectively predict in advance when and how much funding might be provided by military tuition assistance – or even Veterans Affairs education benefits – prior to enrollment, application to those agencies either for general eligibility or for the specific term of enrollment, and benefit or award authorization. 

Furthermore, it will be particularly difficult to provide individualized financial counseling prior to enrollment when many benefits are based on actual enrollment levels, actual institutional charges, and the receipt of other financial awards.  Many federal, state, private, and campus-based financial awards are determined by a student’s unmet financial need, and must be adjusted when a student receives other funding. The Post-9/11 GI Bill is one example of a program that pays a net-cost, which must be adjusted when other tuition-restricted awards are processed. 

NAVPA supports efforts to improve the information flow to prospective students, which will help veterans make better-informed decisions about how to use their benefits, but we also recognize the challenges involved with implementing the services required by this Executive Order. We hope and expect that as policies are developed, we might contribute to the conversation about how best to provide the information needed by prospective student veterans and their families regarding funding options for their education.

(Section 3 - Data Reporting) We particularly appreciate the Administration’s efforts to rely on existing data and reporting mechanisms to mitigate the potential increase in workload on the part of schools.  One estimate from a four-year public institution predicts the initial time commitment to build a report structure in compliance with the broad goals of this Executive Order would be 100-150 man-hours. The type of aggregate data reporting required would likely not come via our members, the School Certifying Officials, but rather from school Institutional Reporting offices that now collect, analyze and report data for other federal requirements such as those from the Department of Education.  Collective information is not something that certifying officials have the authority to access or release on behalf of their institutions.

(Section 3c - Success Metrics) All schools are interested in assessing the success of all their students.  The most important factor will be to define success appropriately for each academic environment and develop data collection methods that are robust, accurate, and meaningful.  We hope and expect that educational institutions and the organizations that represent them including NAVPA will be involved in the process of developing these desired outcomes and metrics.

(Section 3d - Information Sharing) We support efforts to provide or improve resources for comparative data for students about prospective schools.  Links between the VA’s eBenefits portal and information collected and available through the Department of Education could serve to streamline veteran’s access to comparative data regarding their education options.  We also encourage continued efforts to provide schools access to data about individual student’s benefit eligibility so we can accomplish the tasks asked of us by both this Executive Order and current regulations.  While we understand that these improvements will require resources to complete, we feel these are worthwhile investments.  We do have concerns should the appropriate resources not be provided to the entities responsible for implementation.

(Section 4 - Oversight)  As I stated previously, NAVPA fully supports efforts to ensure veterans are appropriately recruited, advised, and supported while in school.  Requiring disclosure by schools should not be a substitute for solid oversight, however.  The agencies administering these programs at all levels are in need of further oversight resources to provide training and enforce the provisions of this Executive Order as well as the currently existing regulations.  The VA needs assistance with compliance tasks now that the Post 9/11 GI Bill has become so complex.  Diverting State Approving Agency resources to that role has proven problematic and leaves no one to fulfill the SAA’s historic role of providing training and supervision to institutions regarding education issues beyond the payment of education benefits. There are varying roles within the oversight arena and tasks should be distributed to the agencies best suited and situated to accomplish them

(Section 4 a -- Complaint System) We have no reservations about a structured and centralized complaint system.  We too want to see every institution provide superb education and support for veterans.  This is another area that will require appropriate resourcing to ensure the agencies such as State Approving Agencies tasked with implementing this system can manage this along with all other current tasks.

 Mr. Chairman, this concludes NAVPA’s statement.  As a veteran and on behalf of the members of NAVPA, I’d like to thank you and the member of the Subcommittee for your leadership on issues of critical importance to America’s veterans.  I appreciate this opportunity to share our views today.  I look forward to working with you and would be happy to answer any questions you may have.