Mr. Michael Dakduk
Chairman Stutzman, Ranking Member Braley and members of the Subcommittee:
Thank you for inviting Student Veterans of America to address the Subcommittee on the President’s Executive Order 13607, “Establishing Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members.” Student Veterans of America (SVA) currently has over 450 Chapters at colleges and universities across the nation assisting veterans in their education experiences on a daily basis. This direct contact gives SVA a unique perspective on the needs and obstacles faced by our nation’s veterans as they return to their communities to enroll in educational opportunities and later, reintegrate into the civilian workforce. Our goal is to provide the resources and support for student veterans to thrive in post-secondary education and contribute to civilian society in meaningful ways. As you are likely aware, we recently conducted an annual review of all of our chapters, both for-profit and non-profit, and found that 26 for-profit schools were suspected of creating fake chapters in order to recruit student veterans. We subsequently revoked their memberships per our charter. That perspective provides the framework for our testimony this morning.
The issues addressed in Executive Order 13607 carry great significance for our nation’s veterans, service members, and families. It reflects highly on this Subcommittee and the Executive Branch that such attention is being paid to addressing and resolving the challenges faced by some veterans who are targeted by ‘bad actors’ in the education system. Without the vigilance and oversight of the Congress, and this Subcommittee in particular, we cannot hope to craft the policies that will protect those who serve, and have served, and ensure that we have an effective and functional G.I Bill. We strongly believe that the education and protection of our nation’s warriors is not a partisan issue, and we are heartened to see that under both parties this committee has always worked towards those ends.
Because SVA is so regularly and intimately involved with the obstacles and challenges of our nation’s student veterans, we believe we have an effective institutional lens to measure the success of today’s educational programs for veterans. Executive Order 13607 takes up a few very important unresolved issues that impact the lives and educational experiences of some veterans who enroll in programs that take may advantage of them as well as the taxpayer.
SVA is deeply invested in this matter. Educational institutions, for profit schools, private corporations, federal, and state governments must work together to protect those using the G.I Bill and tuition assistance. Without protections, fraud would run rampant and the benefit will not meet its objectives. We appreciate the initiative that President Obama has demonstrated in signing this order; it is a strong first step. However, we believe there are issues identified in the Executive Order that may require the force of law, and that can only be addressed by the Congress. Those issues are outlined below.
With respect to Section 1 of the Executive Order:
SVA agrees that there are institutions that have engaged in improper behavior with respect to their recruitment of veterans and service members. The vast majority of these are for-profit educational institutions. However, we also recognize that many of SVA’s members studying at technical and vocational training programs that run on a for-profit basis have been treated well, are happy with their experience, and go on to find meaningful employment. SVA is a strong supporter of online education and vocational training. We believe that policies and the law should target bad actors, whether they are for-profit or non-profit, without unduly burdening good actors in the industry. A set of “Principles of Excellence” is an appropriate step toward addressing this issue.
With respect to Section 2 of the Executive Order:
Section a: Choosing an educational institution is an expensive and life-altering decision. Many veterans are the first people in their families to attend college. Others have been without a high school guidance counselor for more than a decade. Complete information is essential for those using the G.I. Bill and Tuition Assistance to make sound decisions. By understanding the costs of these programs, their likely level of indebtedness, and probable outcomes, student veterans will be able to choose their educational programs more wisely. Better choices will lead to better outcomes and a more efficient use of taxpayer dollars. It serves no one to spend taxpayer dollars to produce students who are deeply in debt, have no marketable job skills, or transferable credits when they leave.
SVA also recognizes that schools may be burdened by the requirement to collect and provide this information. However, it is our position that this burden is far outweighed by the benefits of attracting those veterans who are eligible for education benefits, and remain convinced that schools would need to only provide slightly more information to the VA to paint an accurate picture. Veterans, service members, and military families not only bring large amounts of federal funding, but also bring rich diversity and spirit to any campus.Veterans bring a unique set of experiences with them that enrich the classroom and the dialogue on campus. Few college students have faced the challenges or overcome the hardships that military members and their families deal with every day.
We believe most schools want to make themselves attractive to this population for more than just financial gain. Therefore, we support the provision of information collection and believe schools have a responsibility to report required data and information on student veterans.
Taxpayer dollars must be directed to those educational institutions that can best provide for this constituency. Good schools have nothing to lose by demonstrating the merits of their programs and SVA has no concerns for either the burden to, or any loss of enrollment from, bad actors as a result of these policies.
Section b: Notification of eligibility for federal aid reduces the burden on already overburdened students. Reducing the long-term debt that a student must incur increases the likelihood of positive outcomes and makes money spent on those students more efficient. SVA supports this provision.
Section c: SVA strongly believes it is important to enact safeguards for Service members. The American public expects that the military and other federal agencies will protect our troops on the battlefield. It is only right to expect that these Service members and their families will be protected from fraud and abuse at home.
Section d: SVA also believes it is essential that federal dollars be spent on programs that are likely to lead to meaningful employment and good careers. Requiring accrediting agency approval ensures the integrity of new course offerings and protects both students and institutions. That being said, we also believe that some accrediting bodies are part of the problem, in that they do not provide strict or meaningful standards for schools to meet. We once again call on the Congress to require the Department of Education to clearly define accreditation standards on public websites, and especially to define the difference between “national” and “regional” accreditation. This is one of the greatest complaints we hear from our membership and continues to lead to great confusion. This Subcommittee would be well suited to hold a hearing on accreditation standards as they relate to student veteran enrollment, retention and the transfer credit nightmares that result from this simple yet misleading distinction
Sections e and f: Interruptions in education due to military service obligations are not uncommon. They are necessary and reasonable given the enormous responsibilities that Service members carry. However, these interruptions can be disastrous for the student veteran. Those affected can be left with wasted benefits, education plans that are completely derailed, and lifelong goals cast into uncertainty. The immediate loss to educational institutions is far less than the overall waste of taxpayer money resulting from policies that require forfeiture of tuition and fees payments. Additionally, it is in the interest of all educational institutions to provide good outcomes for their students. A refund-reenrollment policy that allows for service related absences helps to facilitate those outcomes by reducing uncertainty and protecting the student’s progress.
Therefore, SVA strongly supports this provision. We encourage Congress to consider enacting even stronger legislation, as appropriate, to protect the progress of students who are forced to curtail their education due to military Service obligations. In this regard, SVA stands ready to assist the Subcommittee in drafting such a Bill and monitoring its implementation.
Sections g and h: Student veterans and Service members are highly skilled and highly trained. However, they are not generally trained in the development of education plans. As a consequence, they require assistance to develop realistic goals. Having a good academic plan and regular academic advising and other counseling improves their chances of completing their programs and graduating with marketable credentials. We believe it is reasonable to require that schools take every measure to establish policies that facilitate the success of students receiving the G.I. Bill and tuition assistance. These simple measures will do a great deal to facilitate that success.
Most schools already provide some form of assistance and advising to all students. Those that do not ought to. If schools without these programs in place expect the extraordinary amounts of G.I. Bill funding to continue, they should do as their peers do and take steps to ensure the success of their students. The burdens of such provisions are unlikely to fall heavily on schools already invested in their students because they already have such policies in place.
With respect to section 3 of the Executive Order:
Sections a, b, and c: SVA believes the agencies that are listed in this section of the Executive Order are appropriate to execute it. We remain available to assist both the Congress and the Executive Branch with the development and implementation of these Principles of Excellence. Of all of the Veterans’ Service Organizations, SVA is most deeply affected by these principles and we are eager to ensure that they are crafted and implemented to the greatest advantage for student veterans, Service members, and military families.
We strongly believe that subsection c, which requires outcome measures, is essential for the long-term viability of the Post 9/11 GI Bill and other such benefits. The 1944 GI Bill is repeatedly cited for its economic impact and creating the middle class. This is only possible because we know how many returning Service members completed degrees when they returned home. How is it that we have this information about the 1940s and 50s, and not since 2001? SVA has been calling for uniform standards to track graduation and outcome rates since the Post 9/11 GI Bill was written, and we call on the Congress to join us. This is not only important for data on which schools are performing better than others, but also for the essential Congressional oversight that this Subcommittee is charged with conducting.
Though the Executive Order establishes protections for students using educational benefits, SVA recognizes that it is not possible for the Executive Branch to enact policies to the extent they are needed. Specifically, provisions requiring a refund-readmit policy are based on participation in the Yellow Ribbon Program. This gives schools the option to simply opt out of provisions they find burdensome. However, were such protections given the force of law, schools would have to openly decline all federal funding in order to opt out of these provisions.
For example, because existing law does not extend to protecting Service members whose education is interrupted, Congress should consider strengthening certain provisions of the Uniformed Services Employment and Reemployment Rights Act (USERRA). By amending USERRA to include a requirement for schools receiving federal funding to have a refund-readmit policy for the protection of students whose educations are interrupted, Congress will safeguard both taxpayer dollars and student success.
Section d: SVA supports the improvement of the eBenefits portal operated by the Department of Veterans Affairs. We know from experience that the easier it is to compare opportunities, the more likely it is that students will make good decisions. All institutions should be transparent, and they should include tools for comparison and evaluation that help student veterans make better decisions. Successful programs will win out over unsuccessful programs, as they should in a free market.
With respect to Section 4 of the Executive Order:
Sections a, b, c, and d: SVA strongly supports the establishment of a unified system for accepting complaints by those using educational benefits. While State Approving Agencies (SAA) already have provisions in place for complaints, these systems are often difficult to access and they lack uniform standards for conduct. We also know from experience that SAAs will refer most complaints back to the VA anyway. By establishing a more formal complaint process, VA can clarify roles and responsibilities for each Federal agency involved. It is only logical that a Federal agency be involved in the enforcement and protection of a Federal benefit like the GI Bill or Tuition Assistance.
Such a system should be developed in cooperation with SAAs and include clear mechanisms for enforcement and resolution of complaints. SVA does not believe it is proper for the VA to dictate to SAAs how to operate their complaint systems, but rather feels that it is in everyone’s best interests to create uniformity and clarity in the system that already exists.
SVA believes that Congress can strengthen this system by mandating a cooperative process between the VA and SAAs to establish a national system for the acceptance and resolution of complaints by students receiving educational benefits. It is essential that there be a workable, reliable and credible mechanism by which students can seek resolution to complaints regarding their institution or benefits. Lacking such a resource, many veterans and Service members simply choose to curtail their education. This wastes not only the valuable potential of those students, but also the taxpayer monies spent prior to curtailment. It is far better to provide an outlet for complaints, and a mechanism for their resolution, than to accept the loss to the nation, both tangible and intangible, that results from students dropping out.
Section e: SVA knows it is entirely reasonable and necessary for the Department of Defense to restrict access to military bases. In this regard, SVA can be an important resource because our Chapters and members are available to assist the Department, the military services, or individual base commanders with institutions requesting access to military bases. SVA does not support a blanket prohibition of educational institutions from visiting military bases. On the contrary, we support strengthening and unifying a vetting and compliance process for any institution requesting access to military facilities.
Section f: SVA strongly supports the trademarking of the term, “GI Bill” and any other related terms to prevent deceptive marketing practices. We believe it is important for Congress to support a trademark process because these terms need to be protected to ensure their integrity regardless of who is responsible for their protection.
While it is not specifically addressed in this Executive Order or in today’s Subcommittee Hearing, SVA would like to take this opportunity to call for an amendment to the so called, “90/10 rule.” SVA supports the various bi-partisan and bi-cameral Bills pending that would effect such a change. Common sense dictates that schools that are required to receive no more than 90% of their income from the federal government should not be able to skirt this rule by accepting the overage in veterans’ benefits. Requiring competition for 10% of revenue is a reasonable mechanism for ensuring this and strengthens the free-market in education.
Quite frankly, any business that complains about having to compete for 10% of their customers should not be in business. We strongly challenge the sentiment that a change to 90/10 or the requirements contained in this Executive Order somehow inhibits a school’s ability to compete. Any school that claims they would have to raise prices on student veterans in order to accommodate the change is free to do so. SVA is confident that student veterans will vote with their feet, especially considering the astronomical profits that these schools return to their shareholders on Wall Street while still charging the taxpayer full price. A mere fraction of what most for-profits spend on marketing and recruiting should more than cover any imposed cost with being honest brokers of this money.
In conclusion, SVA believes the provisions of the Executive Order requiring transparency, accountability, and preventing fraud, waste, and abuse are reasonable to ensure better educational opportunities for veterans and fair competition for educational institutions. It is all together proper for the federal government to mandate that educational institutions provide information to veterans about their programs regardless of where they attend classes. The Executive Order, strengthened by legislation SVA has recommended, will make it more likely that institutions providing good value and service will win out, just as they should in a free market.
Student Veterans of America is grateful for the opportunity to provide this testimony. We thank the Chairman and the Subcommittee members for their time, attention, and devotion to the cause of higher education. We look forward to continuing to work with this Subcommittee and the Congress in the future to ensure the success of all generations of veterans through education.
Thank you for allowing Student Veterans of America to participate in this important Hearing.