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Judith Flink

Judith Flink, University of Illinois at Chicago, IL, Executive Director, University Student Financial Services

Mr. Chairman and Members of the Committee:  My name is Judith Flink.  I serve as Executive Director of University Student Financial Services for the three campuses of the University of Illinois.  I have worked in the University’s business office and been actively involved in higher education for over 30 years.  On behalf of myself, colleagues in the AAU Bursar organization, colleagues from other educational institutions around the country, and most importantly, on behalf of the veterans attending or seeking to attend our institutions, I thank you for this opportunity to testify. 

In 2008, Congress passed landmark legislation recognizing the contributions and needs of millions of Americans who served their country in our armed forces in Afghanistan, Iraq and elsewhere.  This legislation, the Post 9/11 GI Bill, makes possible educational dreams that not only express a special thanks to our veterans, but also contribute directly to the economic recovery and future of America.

America’s postsecondary institutions are proud to have supported the enactment of this bill and welcome the opportunity to serve veterans in our classrooms.  Today, universities across the country enroll thousands of veterans who receive support through federal GI benefits.  Part of my hope in being here is to promote changes to the program that will increase that number.

Unfortunately, as you are aware, implementation of the vitally important education benefits authorized by the bill has not been smooth.  Delays in getting the program up and running, followed by numerous subsequent flaws in the interface between the VA and educational institutions, have created hardship for veterans and institutions.  My colleagues and I recognize the enormity of implementing this program and creating the systems to manage it.  We sincerely applaud the VA for its excellent work in getting the program up and running under difficult circumstances.  Our desire is to strengthen our partnership with the VA in an effort to help the program run better. 

With that in mind, I focus my testimony on flaws in the system that if corrected will more effectively fulfill the promise of this program.  Included with my remarks is a list of concerns compiled by the University of Illinois and 16 peer institutions.  While the list is not exhaustive, it identifies major concerns that render access to educational benefits under this program difficult for veterans and expensive for the federal government.   Some of these concerns result from legislative provisions, and many are the result of VA policy and procedures.

The majority of our remaining concerns are administrative in nature.  VA policies and procedures often fail to accommodate the education community’s existing systems and procedures, thereby creating needless delay and hardship for veterans.  I will not belabor the Committee with all the concerns on our attached list.  Allow me to highlight just three of them.    

Perhaps our greatest concern as university business officers is the VA’s refund policy which requires institutions to refund tuition overpayments to students who must then refund them back to the VA.  This policy mirrors that of the original GI Bill wherein all benefits (including tuition) were paid directly to the students who were then responsible for paying their tuition bills to the school and for refunding any overpayments back to the VA.  But under the Post 9/11 GI Bill, tuition benefits are paid to the school not the student.  Therefore, the requirement to refund overpayments to students instead of directly to the VA is not only inefficient, it also puts students at risk of losing future benefit eligibility under the program if they fail to understand or fulfill their responsibility to return those funds to the VA.  This risk is high. In all other financial aid programs, overpayments are refunded directly to the aid source bypassing the student.  Thus, students have come to expect that when they receive a refund from the school it is theirs to use for books and living expenses.   By the time they receive notification from the VA of the amount they must repay, the money may have been spent.  The VA will then suspend future benefit eligibility until payment is received which would delay or prevent the student from continuing their education.

A second major concern is the VA’s remittance of payment for students for whom the institution has certified a different amount, or for whom the institution has not even completed a Certificate of Eligibility. No explanation is provided with these payments. Therefore, the institution must contact the VA for an explanation of the discrepancy before releasing payment to the student.  When the institution calls, the VA’s phone lines have long delays with hold times up to 40 minutes. Sometimes calls are dropped altogether due to the high volume and the institution must dial again.  For months, the VA’s phone lines were closed on Thursdays and Fridays.  These delays and their resultant hardship to the Veteran could be eliminated if the VA included an adequate explanation to the school with each payment.

Our third concern is a lack of universal published guidance.  The VA will provide guidance through Policy Advisories but often as a response to a specific question posed by an institution.  The Advisories may not be disseminated to all participating schools creating a lack of consistent, uniform policy among institutions.  This lack of guidance results in confusion and conflicting administration between institutions and creates frustration on the part of veterans.  The creation of a single source of readily accessible Post-9/11 GI Bill administrative manual would eliminate the majority of this frustration and burden. 

While I’ve only mentioned three of our concerns, the attached list is more comprehensive.  We are confident, however, that many of them can be successfully resolved through open dialogue between schools and the VA. Our recent attempts to initiate this dialogue met with disappointing results.   We received a written response from the VA, for which we are grateful, but were not given the opportunity to discuss the matter in more detail or open a meaningful dialogue.

My peers and I respectfully ask your assistance to open this dialogue.  We believe regularly scheduled meetings between the VA and a working group from the education community will enable both parties to collaborate on proposed program changes and regulations prior to implementation.  We would like to be considered as both a resource and partner for the VA and Congress in our mutual endeavor to improve delivery of Post 9/11 GI Bill tuition benefits to our veterans. 

Thank you again for the opportunity to speak with you.  I hope my testimony can be a spring board for productive dialogue between all parties who share your commitment to strengthening and improving services to our veteran community.   I would be pleased to respond to any questions members of the committee might have.





1. Western Illinois University

Veteran withdrew before class after Post-9/11 benefits had been paid; WIU refunded benefits to VA via check in Dec 2009; VA cashed the check in Feb 2010 but didn’t process it to the veteran’s account until Aug 2010.

2. University of Illinois

Veteran received ROTC scholarship after Post-9/11 benefits had been paid; UI refunded benefits to VA via ACH in early March 2010 according to VA’s ACH return policy; VA still has not processed the refund and was still requesting payment from the veteran in late Aug 2010.

3.University of Illinois 

Per veteran’s request, UI refunded Post 9/11 benefits to VA via ACH in early March 2010 according to VA’s ACH return policy; VA did not process the refund until late July 2010; meanwhile VA reported veteran as delinquent to the credit bureaus, ruining his credit and causing Discover to cancel his credit card.

4. University of Illinois

UI received $8,305.60 Post-9/11 benefit payment from VA on January 19, 2010 then received another payment in the amount of $9,343.80 from VA on May 13, 2010 for the same veteran. 

5. Illinois State University 

ISU received payment from VA for a veteran’s books and supplies stipend (which should have been remitted directly to the veteran). 


Illinois State University

ISU certified a veteran’s Post-9/11 benefit eligibility at 70% but received payment from VA in March 2010 at 60%; ISU questioned VA’s eligibility calculation in March 2010 and was told by VA that 60% was correct; at veteran’s request, ISU questioned VA again in August 2010 and was told student eligibility is 70%.


George Washington University

GWU received Yellow Ribbon benefit payment from VA on behalf of a veteran for whom VA had calculated 100% eligibility; VA later discovered they had incorrectly accounted for the veteran’s ROTC years, and recalculated Yellow Ribbon eligibility at 80%.


George Washington University

GWU received Yellow Ribbon benefit payment from VA on behalf of a veteran for whom VA had calculated 100% eligibility; VA paid half the benefit by check, half by wire; VA later discovered veteran was only eligible for 90% Yellow Ribbon benefits.


George Washington University

GWU received a $7,000 overpayment of Post-9/11 benefits for a veteran on March 9, 2010; GWU called VA to ask what to do with the funds and was instructed to wait for VA to call back later; after hearing nothing from VA for 4 months, GWU credited the overpayment to the veteran’s account at GWU on July 13; a week later VA called and requested GWU to refund $7,954.92 to VA.


George Washington University

A GWU veteran was active duty at start of Fall 2009 but scheduled to go off active duty mid semester; veteran also wanted to participate in Yellow Ribbon; GWU contacted VA for instructions and was told to certify Yellow Ribbon eligibility after veteran went off active duty; VA paid veteran’s full tuition plus YR plus housing stipend; VA then created a debt for the housing stipend.


The Post 9/11 GI Bill was signed into law August 1, 2009. Certification and processing of VA Chapter 33 program benefits began immediately thereafter. The volume of applicants overwhelmed VA resources and the program got off to a rough start. Improvements have been made in VA’s process, but the program continues to present significant challenges to the education community.

Following is a list of VA Chapter 33 issues and suggestions submitted by administrators from educational institutions (hereinafter collectively referred to as Institution) around the country. The issues needlessly delay delivery of benefit payments to veterans and unduly burden Institutions. The suggestions offer potential solutions.


  • VA refund policy is highly labor-intensive because:
  • VA under- and over-payments with no attached explanation result in long processing delays as Institution attempts to contact VA for details.
  • VA policy is inconsistent – some overpayments must be refunded to VA, others to the student; some refunds must be electronic, some by paper check.
  • VA policy of refunding to the student is contrary to all other forms of student financial assistance that require Institutions to refund to the aid source;
  • The policy of refunding to the student results in inaccurate IRS Form 1098-T reporting. For example, if VA remits $10,000 Chapter 33 tuition benefits to Institution then the student drops classes resulting in a $4,000 tuition reduction and Institution refunds that $4,000 to the student instead of VA, the Institution will report $10,000 in Box 5 of the student’s Form 1098-T, not the $6,000.
  •  Inadequate explanation of VA payments:
  • VA payments do not match the amount certified by Institution on the Certificate of Eligibility.
  • VA remits payments for students for whom Institution has not completed a Certificate of Eligibility.
  • VA remits duplicate payments for some students.
  • VA pays out-of-state tuition after Institution has charged and certified in-state tuition.
  • VA payments lack adequate identifying information – enrollment term, number of credit hours, percentage of eligibility, etc. For example, if Institution certifies $5,000 and VA remits only $3,200, Institution is given no explanation why.
  • VA policy of remitting individual instead of collective payments is highly labor-intensive.
  • Delayed VA payments result in additional labor-intensive Institution activities:
  • Institutions process emergency loans for delayed housing payments;
  • Institutions place provisional credits on student accounts in order to prevent late payment charges or cancellation of enrollment for non-payment;
  • Institution must conduct a manual reconciliation upon receipt of VA payments which are almost invariably different than the anticipated provisional credits;
  • Institution holds payments received for a previous enrollment term until VA confirms the student’s eligibility for the current or subsequent enrollment term in order to verify accuracy;
  • Institution must process multiple Certificates of Eligibility for students whose active duty and/or enrollment status changed prior to receipt of VA payment;
  • Lump sum payments for multiple terms are difficult to differentiate by term.
  • VA refund policy is highly labor-intensive because:
  • VA under- and over-payments with no attached explanation result in long processing delays as Institution attempts to contact VA for details.
  • VA policy is inconsistent – some overpayments must be refunded to VA, others to the student; some refunds must be electronic, some by paper check.
  • VA policy of refunding to the student is contrary to all other forms of student financial assistance that require Institutions to refund to the aid source;
  • The policy of refunding to the student results in inaccurate IRS Form 1098-T reporting. For example, if VA remits $10,000 Chapter 33 tuition benefits to Institution then the student drops classes resulting in a $4,000 tuition reduction and Institution refunds that $4,000 to the student instead of VA, the Institution will report $10,000 in Box 5 of the student’s Form 1098-T, not the $6,000.
  • VA return policy creates needless delays and administrative burden because:
  • Institution must return full payment if any variation in assessment has occurred subsequent to certification, even if that variation is a minor reduction in fees.
  • Institution must submit an amended certification after returning payment which removes it from VA’s automated process by requiring VA Claims Adjustor review.
  • VA Claims Adjustor must then submit a new payment request to the U.S. Treasury Department who waits to process the payment in batch.
  • VA has published no clear guidance regarding which benefits will be delayed in the event of an unreimbursed overpayment–tuition/fee payment to Institution, or living/book payment to student?
  •  VA has published no clear deadlines for retroactive applications (benefits for prior enrollment terms).
  • VA has published no clear guidance for Chapter 33 benefit eligibility for students who receive other forms of tuition assistance, e.g. Active Military tuition sponsorship, federal or state tuition assistance, Institutional tuition waivers, private tuition specific scholarships or sponsorships, etc.
  • VA has published no clear guidance for Chapter 33 benefit eligibility for students who are discharged from active duty during the enrollment period.
  • VA has not required or adequately accounted for DD214 (active duty discharge) data when determining Chapter 33 benefit eligibility.
  • VA has published no clear guidance on Chapter 33 benefit eligibility for waivable student health insurance.
  • Some VA payments appear on multiple cycle rosters giving the false impression that duplicate payments have been received.
  • Some VA deposits contain enrollment dates that do not match Institution’s.
  • Veterans and Institution have no mechanism for determining the status of a veteran’s application (22-1999) and whether the veteran will qualify for Chapter 33 benefits, so veterans who need the benefits in order to attend class cannot register.
  • VA restrictions on distance education unfairly deny housing stipends to these students.
  • VA does not notify Institution when student changes benefit Chapter.
  • Yellow ribbon payments have been particularly difficult; although they are included on the original certification, the yellow ribbon eligibility is segregated and payments for yellow ribbon claims have not been forthcoming.
  • VA customer service is inadequate:
  • Institution cannot contact VA’s Buffalo regional office directly even though they originate the payments; Institution has to use either the online inquiry system or call the national 888 number.
  • VA’s national 888 number results in long delays from hold times as long as 40 minutes or dropped calls; now the 888 number is closed Thursdays and Fridays to enable VA to “catch up”.
  • VA representatives often give conflicting information and when pressed either refer Institution to VA’s regional office in Buffalo (which Institution cannot contact), or instruct Institution not to question VA’s payments (even though Institution has found many errors and is supposed to be VA’s “partner”).
  • VA’s online system sometimes reports inquiries “closed” without providing an adequate explanation of the resolution.
  • VA Education Liaison Representatives (ELRs) are frequently unavailable due to “special assignment”.


  • Open a dialogue between VA and Institutions that enables both parties to understand prior to implementation the system and process implications of VA proposed new changes and regulations.
  • Establish a partnership between VA and U.S. Department of Education (ED) to share resources and expedite delivery of VA benefits.
  • Revisit the education law passed by Congress last year that removes VA benefits from consideration when determining student eligibility for Title IV funds. Federal need based financial assistance must by definition be determined on need, and need is mitigated by federal assistance from another federal agency.
  • Create an on-line portal similar to the WAVE portal for Chapter 30 benefits that would enable veterans and Institution to determine the veteran’s Chapter 33 application status and eligibility for benefits.
  • Veterans need an effective source of accurate information about their individual benefit eligibility before they apply for and accept admission to an Institution in order to know whether they can afford to attend.
  • Institutions who are asked to carry the financial risk for veterans by holding them harmless while awaiting payment from VA need an effective source of accurate information about their application and benefit status.
  • Simply, streamline, standardize, and improve communication regarding VA overpayment policy:
  • Allow Institution to refund/return only the overpayment amount rather than the full payment followed by an amended certification.
  • Allow Institution to batch overpayment refunds/returns rather than remitting them individually.
  • Standardize VA overpayment policy to mirror ED and other financial aid policies that return overpayments to the aid source not student.
  • Improve communication regarding status of student refund/return.
  • Provide adequate and accurate explanations to Institution for VA payments that differ from Institution certified amounts; then remit batch/collective payments to Institution instead of multiple individual payments.
  • Allow individuals other than the single certifying official at Institution to initiate/maintain contact with VA; for example, individuals who research billing issues should be able to speak directly with VA payment coordinators to resolve discrepancies.
  • VA responsiveness to researching mismatched payments has improved, now originating issues need to be addressed.
  • Replace the per-credit hour cap with a single dollar amount cap for each state. This would eliminate the need to calculate benefits individually for each student based on enrolled credit hours.
  • Revisit VA restrictions on distance education to allow veterans Chapter 33 housing stipends while enrolled solely through distance education courses. 
  • Clarify VA policy on overseas study and expand Chapter 33 benefit eligibility to include courses taken abroad that count toward the student’s degree. 
  • Allow veterans to revert to a more advantageous program if they discover Chapter 33 is not in their best interest.
  • The irrevocable nature of Chapter 33 benefit election coupled with the lack of clear situation-specific information to effectively guide their decision has created hardships for many veterans.
  • Remove the Chapter 30 to Chapter 33 conversion penalty which limits combined use of the two programs to 36 months unless Chapter 30 is exhausted.
  • Simplify Chapter 33 eligibility rules and allow all active service to count; eliminate the requirement to verify the purpose and authorizing U.S. Code for each active duty period.
  • Expand Chapter 33 timelines to allow Institution to complete Certificates of Eligibility far enough in advance to enable VA to process claims by the start of the term and continue uninterrupted between terms. 
  • The Higher Education Opportunity Act’s Readmission Requirements for Service Members states that returning service members may not be charged tuition and fees in excess of the rate charged during the term in which they left school for military service unless they have veteran or military education benefits.  Is it reasonable to base charges on benefit eligibility? 
  • Improve VA delivery of policy notifications to Institution Certifying Officials (COs). Recent VA policy updates submitted to COs via mass e-mail with a link to VA’s Web Automated Reference Material System (WARMS) were missed because many COs could not access the link to WARMS. All time sensitive information should be included in the actual email text. 
  • Forward to Institution a monthly report (or copy of Certificate of Eligibility) listing each applicant and percentage of Chapter 33 benefit eligibility for that Institution.
  • Forward to Institution a monthly (or quarterly) report listing students who owe an overpayment to VA, and when the overpayment has been paid.
  • Remove the detailed examination of each course’s applicability to a degree program, attendance, retakes, and need for remediation. Why does the VA track this level of detail when U.S. Department of Education does not? 
  • Remove the tracking of each course by start and stop date; allow Institutions with regular terms of enrollment to use the same criteria as Title IV for full time enrollment. 
  • Remove the requirement for State Approving Agencies to approve each program of education at an accredited Institution. If the Institution meets accreditation standards, shouldn’t that be sufficient for education benefits?

Contributing Institutions:

  • Margaret Baechtold and Susan Cote, Indiana University
  • Sandie Rosko, University of Washington
  • Laurie Schlenke, Michigan State University
  • Jean Thomson, University of Colorado, Boulder
  • Bob Lech, University of Pittsburgh
  • Beth Barrett, Harvard University
  • Roseann Sieminski, Pennsylvania State University
  • James Middlemas, University of Michigan
  • Marty Miller, University of Iowa
  • Christina Westendorf, Illinois State University
  • Cathie Easter, University of Wisconsin
  • Bradley Stene, Northwestern University
  • Marsha Lovell, UCLA
  • Cathy Foland, Southern Illinois University Edwardsville
  • Paul Toler, University of Missouri Columbia
  • John Higgins, Purdue University
  • Judith Flink, University of Illinois