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The Military Officers Association of America

The Military Officers Association of America

CHAIRMAN STUTZMAN, RANKING MEMBER BRALEY, DISTINGUISHED MEMBERS OF THE SUBCOMMITTEE, the Military Officers Association of America (MOAA) representing 375,000 current, retired and former officers of the seven Uniformed Services and the surviving spouses of deceased members is pleased to submit testimony for the official record of this hearing.  

MOAA does not receive any grants or contracts from the federal government.


The purpose of this hearing is to examine the impact of Executive Order # 13607 on post-secondary educational institutions (schools) and veterans. 

President Obama issued the Executive Order -- Establishing Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses and Other Family Members – to ensure that military members, their eligible family members and veterans have the information they need to make informed decisions regarding government-provided military tuition assistance, ‘My Career Advancement Account’ (MyCAA) educational stipends and veterans’ educational benefits.  The intended outcome of the Executive Order is to develop principles of excellence to strengthen oversight, enforcement and accountability of these benefit programs.

MOAA and other service organizations closely collaborated earlier this year on a series of recommendations we called a “GI Bill of Rights” to accomplish some of the objectives set out in the Executive Order.  The GI Bill of Rights was submitted to the Administration for consideration in developing a coordinated, interagency approach to improving oversight and outcomes under military and tuition assistance programs. MOAA, therefore, supports the Executive Order as an important first step in the development and execution of an interagency plan to improve the oversight of generous educational resources provided for our nation’s warriors, their family members and veterans.

The thrust of the “GI Bill of Rights” is to ensure that all post-secondary schools – public, private and proprietary – meet the highest standards of transparency, quality and measurable outcomes.  In short, all schools should be able to demonstrate a reasonable return on the enormous investment in the future of our fighting women and men, their families and veterans.

The Need

The Post-9/11 GI Bill authorized under Chapter 33 of 38 U.S. Code is the most generous educational assistance program since the great World War II GI Bill.

The VA has made nearly 700,000 payments to colleges, universities and training programs on behalf of veterans, active duty service men and women and dependents who have received transferred benefits. 

But a year-long Senate investigation detailed troubling trends in GI Bill outcomes and oversight:

•         33% of new GI Bill payments went to For Profit colleges, which trained only 25% of enrolled veterans in 2009 – 2010, the first year under the new program

•         8 of the top 10 recipients of Chapter 33 funds were For Profit colleges

•         The government spends more than twice as much per veteran at For-Profit colleges compared to public not-for-profit colleges

•         Recruiting expenditures at certain For Profit schools far exceed student services for veterans, which in some cases do not exist

•         The Attorney General and multiple states have brought suit against certain For Profit schools for misrepresentation, recruiting abuses, inflated job placements and other deceptive practices.


In testimony before a joint House and Senate Veterans Affairs Committee hearing on March 22, MOAA presented the Committees the following recommendations for improving GI Bill oversight, transparency and outcomes:


•         Direct the Department of Veterans Affairs to work with the Department of Education to create an online “dashboard” so that prospective GI Bill users can more easily compare costs, credit and transfer policies, outcomes and graduation rates and related consumer-friendly information about colleges in all sectors.

•         Further expand the VA’s on-campus VetSuccess program beyond the 80 campus, $8.8 million program requested in the Administration’s budget request for FY 2013.

•         Amend the educational counseling provisions in Chapter 36, 38 U.S. Code to mandate such counseling via appropriate means, including modern technologies, and permit veterans to “opt out”.   It will be necessary to raise the $6 million cap in the counseling provision to meet the enormous demand of new GI Bill enrollments.

•         Establish a centralized complaint reporting and resolution process for veterans using GI Bill entitlement.

•         Require that all programs receiving funding under the GI Bill be “Title IV” eligible; in other words, all post-secondary programs would have to meet Dept. of Education standards for accreditation and other requirements.

•         Support legislation to account for all Federal educational assistance funding under the Title IV category.  Changing the so-called “90/10” rule would compel all colleges and universities to demonstrate that their product is valuable enough to attract private sector students to pay for the education offered.

•         Trademark the term “GI Bill” so that the Dept. of the VA can control the use of that term for GI Bill-related websites and deter other promotional media that present themselves as quasi-governmental sources of information on the GI Bill.

A number of these recommendations have been incorporated into the Executive Order.  Comment and perspective on the recommendations above that relate to the EO follow.  

1.      Online “Dashboard.”  Section 2(a) and Section 3(c) of EO 13607. The Department of Education recently developed the “College Navigator” website to provide relevant information to prospective students, parents and others to support decision-making on college selection.  The EO essentially directs a further refinement of the online tool so that military students and veterans can more easily compare school costs, accreditation, graduation, drop-out rates, and other features.  College Navigator is a very useful first step in that direction.  MOAA stated at the March 22 joint hearing that an upgraded online tool or “dashboard” would be akin to an “online shopping tool like the Amazon website” to facilitate making informed choices about college.  (Section 2

2.      Complaint Resolution Process. Section 4 of the EO, Strengthening Enforcement and Compliance Measures.  Student veterans and returning warriors from the Iraq and Afghanistan conflicts strongly support the need for a closed-loop complaint resolution process.  Most of the interactions between the VA and schools concern enrollment certification, payment and recoupment actions – administrative activities, for the most part.  Student veterans, however, need a reliable channel of communication to report alleged improprieties in program quality, fraud, misrepresentation and related concerns to protect them, the government’s interest and the nation’s investment in their futures. 

      Section 4(b).  The State Approving Agencies (SAAs) may be the right vehicle for        this purpose.   But the recent change in the SAAs’ mission and reporting chain –           placing them under the VA Education Service and essentially making them     an        investigative   body – were done with no additional training resources or         guidance, as far as we know, on how they were to accomplish the new   mission.  We note that there were     no hearings held prior to changing the SAAs          mission.   In informal discussions       with SAAs it appears that some are still      operating as advisors to schools      and veterans while others are trying to         function as “IGs”.  MOAA believes there is a need for Congressional    hearings to examine how best to use the      SAAs   going   forward.

3.      Educational and Financial Advice.  Sections 2(g), (h).  The EO requires schools that receive Federal military and veterans educational benefits to provide an “educational plan” on how these students will fulfill graduation requirements.   The EO also expects schools to designate a point of contact for academic and financial advising, including access to disability counseling for service members, military family members and student veterans.

          MOAA believes that veteran support services, other than academic        counseling,     should be provided by the VA. Schools themselves that have a threshold    number of student veterans and military students should be     provided additional    resources as may be needed for purely academic advice and planning assistance. 

            Our understanding is that most if not all campus-based educational programs   already provide academic program assistance via faculty advisors and registrars      for all students.  And, a growing number of colleges and universities have             established     their own veteran centers on campus; e.g., Mississippi State             University and Florida State University.  Coupled with Student Veterans of      America chapters on campuses, MOAA believes tailored support services       for       student veterans and military family members can help foster successful    outcomes under GI Bill and military tuition assistance programs.

            In MOAA’s testimony on 22 March, the Association recommended expansion of       the VA’s VetSuccess program on campuses over and above the target of 80         campuses (from about 20 currently), as requested in the Administration’s budget   request for fiscal year 2013.  We believe the VetSuccess program can provide     value-added support primarily for non-educational VA-sponsored services for our      student veterans: enrollment in VA health care, behavioral counseling, referral to        Vets Centers and application for service-connected disabilities.

            The EO directs an Interagency approach to educational planning for military    students and veterans.  In that regard,     MOAA continues to recommend     mandating the educational counseling provisions in Chapter             36, 38 U.S. Code for             delivery by appropriate means, including modern technologies.  Veterans             should be permitted  to opt out.  The current $6 million statutory cap for        such counseling is inadequate      to the rising demand.  Schools         may need        additional resources to carry out the EO directive, but it is unlikely that        any      new funds would be provided in this environment.

4.      Trademark “GI Bill.”  Section 4(f) of the EO directs the Interagency to take all appropriate steps to ensure that websites and programs are not deceptively and fraudulently marketing educational services and benefits to program beneficiaries by trade marking the term “GI Bill” and other terms military or veterans-related terms.  Trade marking “GI Bill” would set in motion a process for purveyors of information about the new GI Bill and other military tuition assistance programs would be required to obtain a license or other release to use with the program.  MOAA strongly endorses this action.

Conclusion.  The underlying intent of Executive Order 13607 is to ensure that all schools meet the same standards of transparency regarding information about programs, costs, accreditation and other factors.  All schools – public, private and proprietary – should play by the same set of rules.   It is in our nation’s best interest to provide the military community, veterans,  educational and political leaders, and the general public reasonable assurance that the generous investment in the futures of those who have given so much will yield great dividends for them and the country. 

MOAA strongly supports the issuance of Executive Order 13607 and urges additional action to strengthen the support of military and student veterans in their pursuit of their educational goals.