DOD Education Benefits
Increased Oversight of Tuition Assistance Program Is Needed Gao ID: GAO-11-300 March 1, 2011In fiscal year 2009, the Department of Defense's (DOD) Military Tuition Assistance (TA) Program provided $517 million in tuition assistance to approximately 377,000 service members. GAO was asked to report on (1) DOD's oversight of schools receiving TA funds, and (2) the extent to which DOD coordinates with accrediting agencies and the U.S. Department of Education (Education) in its oversight activities. GAO conducted site visits to selected military education centers and interviewed officials from DOD, its contractors, Education, accrediting agencies and their association, and postsecondary institutions.
DOD is taking steps to enhance its oversight of schools receiving TA funds, but areas for improvement remain. Specifically, DOD could benefit from a systematic risk-based oversight approach, increased accountability in its education quality review process, and a centralized system to track complaints. DOD does not systematically target its oversight efforts based on factors that may indicate an increased risk for problems, such as complaints against schools or the number of service members enrolled at a school. Instead, DOD's oversight policies and procedures vary by a school's level of program participation, and schools that operate on base are subject to the highest level of oversight. DOD plans to implement more uniform oversight policies and procedures, but they are not expected to take effect until 2012. In addition, the process DOD used to review the academic courses and services provided by schools and military education centers was narrow in scope and lacked accountability. The review was limited to schools offering traditional classroom instruction at installations and did not include distance education courses, which account for 71 percent of courses taken in fiscal year 2009. The contract for these quality reviews expired on December 31, 2010, and DOD plans to resume its reviews on October 1, 2011, when a new contractor is selected. DOD is developing an expanded quality review process and plans to select schools based, in part, on the amount of TA funds received. With regard to accountability, DOD's review process provided recommendations that could improve educational programming, but there is no DOD-wide process to ensure that these recommendations have been addressed. Furthermore, DOD lacks a system to track complaints about schools and their outcomes. As a result, it may be difficult for DOD and its services to accurately identify and address any servicewide problems and trends. DOD's limited coordination with accreditors and Education may hinder its oversight efforts. DOD verifies whether a school is accredited; however, it does not gather some key information from accreditors when conducting its oversight activities, such as whether schools are in jeopardy of losing their accreditation. Accreditors can place schools on warning or probation status for issues such as providing inaccurate information to the public and poor institutional governance. Schools can experience various problems within the 3- to 10-year accreditation renewal period, and these problems can negatively affect students, including service members. Additionally, DOD does not require schools to have new programs and other changes approved by accrediting agencies in order to receive TA funds. Currently, students enrolled in unapproved programs or locations are ineligible to receive federal student aid from Education, but can receive TA funds. DOD's coordination with Education has generally been limited to accreditation issues and Education's online resources about schools and financial aid. DOD does not utilize information from Education's school-monitoring activities to inform its oversight efforts. Education's findings from program reviews and financial audits of schools provide insights about schools' financial condition, level of compliance, and governance. Collectively, this information could provide DOD with information that can be used to better target schools for review or inform other oversight decisions. GAO recommends that DOD (1) improve accountability for recommendations made by third-party quality reviews, (2) develop a centralized process to track complaints against schools, (3) conduct a systemic review of its oversight processes, (4) take actions to ensure TA funds are used only for accreditor-approved courses and programs, and (5) require and verify state authorization for all schools.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: George A. Scott Team: Government Accountability Office: Education, Workforce, and Income Security Phone: (202) 512-5932GAO-11-300, DOD Education Benefits: Increased Oversight of Tuition Assistance Program Is Needed
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United States Government Accountability Office:
GAO:
Report to the Chairman, Subcommittee on Federal Financial Management,
Government Information, Federal Services, and International Security,
Committee on Homeland Security and Governmental Affairs, United States
Senate:
March 2011:
DOD Education Benefits:
Increased Oversight of Tuition Assistance Program Is Needed:
GAO-11-300:
GAO Highlights:
Highlights of GAO-11-300, a report to the Chairman, Subcommittee on
Federal Financial Management, Government Information, Federal
Services, and International Security, Committee on Homeland Security
and Governmental Affairs, United States Senate.
Why GAO Did This Study:
In fiscal year 2009, the Department of Defense‘s (DOD) Military
Tuition Assistance (TA) Program provided $517 million in tuition
assistance to approximately 377,000 service members. GAO was asked to
report on (1) DOD‘s oversight of schools receiving TA funds, and (2)
the extent to which DOD coordinates with accrediting agencies and the
U.S. Department of Education (Education) in its oversight activities.
GAO conducted site visits to selected military education centers and
interviewed officials from DOD, its contractors, Education,
accrediting agencies and their association, and postsecondary
institutions.
What GAO Found:
DOD is taking steps to enhance its oversight of schools receiving TA
funds, but areas for improvement remain. Specifically, DOD could
benefit from a systematic risk-based oversight approach, increased
accountability in its education quality review process, and a
centralized system to track complaints. DOD does not systematically
target its oversight efforts based on factors that may indicate an
increased risk for problems, such as complaints against schools or the
number of service members enrolled at a school. Instead, DOD‘s
oversight policies and procedures vary by a school‘s level of program
participation, and schools that operate on base are subject to the
highest level of oversight. DOD plans to implement more uniform
oversight policies and procedures, but they are not expected to take
effect until 2012. In addition, the process DOD used to review the
academic courses and services provided by schools and military
education centers was narrow in scope and lacked accountability. The
review was limited to schools offering traditional classroom
instruction at installations and did not include distance education
courses, which account for 71 percent of courses taken in fiscal year
2009. The contract for these quality reviews expired on December 31,
2010, and DOD plans to resume its reviews on October 1, 2011, when a
new contractor is selected. DOD is developing an expanded quality
review process and plans to select schools based, in part, on the
amount of TA funds received. With regard to accountability, DOD‘s
review process provided recommendations that could improve educational
programming, but there is no DOD-wide process to ensure that these
recommendations have been addressed. Furthermore, DOD lacks a system
to track complaints about schools and their outcomes. As a result, it
may be difficult for DOD and its services to accurately identify and
address any servicewide problems and trends.
DOD‘s limited coordination with accreditors and Education may hinder
its oversight efforts. DOD verifies whether a school is accredited;
however, it does not gather some key information from accreditors when
conducting its oversight activities, such as whether schools are in
jeopardy of losing their accreditation. Accreditors can place schools
on warning or probation status for issues such as providing inaccurate
information to the public and poor institutional governance. Schools
can experience various problems within the 3- to 10-year accreditation
renewal period, and these problems can negatively affect students,
including service members. Additionally, DOD does not require schools
to have new programs and other changes approved by accrediting
agencies in order to receive TA funds. Currently, students enrolled in
unapproved programs or locations are ineligible to receive federal
student aid from Education, but can receive TA funds. DOD‘s
coordination with Education has generally been limited to
accreditation issues and Education‘s online resources about schools
and financial aid. DOD does not utilize information from Education‘s
school-monitoring activities to inform its oversight efforts. Education‘
s findings from program reviews and financial audits of schools
provide insights about schools‘ financial condition, level of
compliance, and governance. Collectively, this information could
provide DOD with information that can be used to better target schools
for review or inform other oversight decisions.
What GAO Recommends:
GAO recommends that DOD (1) improve accountability for recommendations
made by third-party quality reviews, (2) develop a centralized process
to track complaints against schools, (3) conduct a systemic review of
its oversight processes, (4) take actions to ensure TA funds are used
only for accreditor-approved courses and programs, and (5) require and
verify state authorization for all schools. DOD agreed with our
recommendations. Also, DOD and Education provided technical comments
on the draft report. We incorporated each agency‘s comments as
appropriate.
View [hyperlink, http://www.gao.gov/products/GAO-11-300] or key
components. For more information, contact George Scott at (202) 512-
7215 or scottg@gao.gov.
[End of section]
Contents:
Letter:
Background:
DOD Takes Steps to Enhance Its Oversight of Schools Receiving TA
Program Funds, but Areas for Improvement Remain:
DOD's Limited Coordination with Accreditors and Education May Hinder
Its Efforts:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Selected Postsecondary Institutions GAO Interviewed at
Selected Education Centers:
Appendix III: Comments from the Department of Defense:
Appendix IV: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Education's Monitoring of Schools Participating in the Title
IV Program:
Figures:
Figure 1: Military Tuition Assistance Expenditures:
Figure 2: DOD Participation Requirements by School Level of Program
Involvement:
Abbreviations:
AASCU: American Association of State Colleges and Universities:
ACE: American Council on Education:
CCAF: Community College of the Air Force:
DOD: Department of Defense:
ESO: education services officer:
GPA: grade point average:
HEA: Higher Education Act of 1965, as amended:
ICE: Interactive Customer Evaluation:
MIVER: Military Installation Voluntary Education Review:
MOU: memorandum of understanding:
MVER: Military Voluntary Education Review:
SOC: Servicemembers Opportunity Colleges:
TA: Tuition Assistance:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
March 1, 2011:
The Honorable Tom Carper:
Chairman:
Subcommittee on Federal Financial Management, Government Information,
Federal Services, and International Security:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
Dear Chairman Carper:
In fiscal year 2009, the Department of Defense's (DOD) Military
Tuition Assistance (TA) Program provided $517 million in tuition
assistance to approximately 377,000 service members who elected to
pursue off-duty[Footnote 1] postsecondary education.[Footnote 2] DOD
offers these benefits to service members in order to help them fulfill
their academic goals and enhance their professional development. In
order to participate in the program, DOD requires that postsecondary
institutions must be accredited by an accrediting agency recognized by
the U.S. Department of Education (Education). These institutions have
played an important role in providing traditional classroom
instruction to service members on military installations, but the
majority of courses service members are taking are distance education
courses.[Footnote 3] This report examines (1) the Department of
Defense's process for overseeing postsecondary institutions that
receive tuition assistance funds, and (2) the extent to which DOD
coordinates with accrediting agencies and Education in its oversight
of institutions participating in the tuition assistance program.
To address these objectives, we reviewed and analyzed relevant federal
laws, regulations, and program documents and data, including program
participation and expenditure data from DOD and its military services
(Army, Air Force, Marine Corps, and Navy). We analyzed available data
from the military services on service member complaints regarding
schools receiving tuition assistance funds. We also interviewed
officials from DOD, its military services, and contractors---
Servicemembers Opportunity Colleges (SOC) and the American Council on
Education. We conducted site visits to education centers located at
military installations of the four services to gain a better
understanding of how the program is implemented. We interviewed
Education officials to determine the extent to which they coordinate
with DOD as part of DOD's efforts to oversee its TA program. We also
reviewed Education's monitoring and compliance data. Finally, we
interviewed representatives from an association of colleges and
universities and selected accrediting agencies in order to obtain
information about the extent to which they coordinate and provide
information to DOD and its military services for monitoring schools.
We conducted this performance audit from August 2010 to February 2011
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives. See appendix I
for more detailed information about our scope and methodology.
Background:
DOD has voluntary education programs in place to facilitate
educational opportunities for service members to pursue postsecondary
education during off-duty time.[Footnote 4] Program oversight for
voluntary education programs is the responsibility of the
Undersecretary of Defense for Personnel and Readiness.[Footnote 5] In
addition, the military services are responsible for establishing,
maintaining, operating, and implementing the programs at 350 education
centers on military installations worldwide.[Footnote 6] Education
centers are managed by an education services officer (ESO) and staff,
such as education guidance counselors.
Service members must meet certain requirements in order to participate
in the program. These requirements include consulting with a counselor
in order to develop an education goal and degree plan, maintaining a
2.0 grade point average (GPA) for undergraduate-level courses, and
maintaining a 3.0 GPA for graduate-level courses. In accordance with
DOD policy, tuition assistance covers up to $250 per credit hour, with
a maximum of $4,500 per year.[Footnote 7] In fiscal year 2009, the
military services' TA program expenditures were $517 million, as shown
in figure 1.
Figure 1: Military Tuition Assistance Expenditures:
[Refer to PDF for image: stacked line graph]
Fiscal year: 2000;
Air Force: $56.2 million;
Army: $48.5 million;
Navy: $35.8v;
Marine Corps: $16.7 million;
Total: $157 million.
Fiscal year: 2001;
Air Force: $64.1 million;
Army: $72.9 million;
Navy: $38 million;
Marine Corps: $17.4 million;
Total: $192 million.
Fiscal year: 2002;
Air Force: $67.2 million;
Army: $114.9 million;
Navy: $42.6 million;
Marine Corps: $18.5 million;
Total: $243 million.
Fiscal year: 2003;
Air Force: $122.9 million;
Army: $152.1 million;
Navy: $60.7 million;
Marine Corps: $35.1 million;
Total: $371 million.
Fiscal year: 2004;
Air Force: $140.6 million;
Army: $217.4 million;
Navy: $71.3 million;
Marine Corps: $37.7 million;
Total: $467 million.
Fiscal year: 2005;
Air Force: $139.4 million;
Army: $211.8 million;
Navy: $72.6 million;
Marine Corps: $37.6 million;
Total: $461 million.
Fiscal year: 2006;
Air Force: $149.4 million;
Army: $140.9 million;
Navy: $95.2 million;
Marine Corps: $45.5 million;
Total: $431 million.
Fiscal year: 2007;
Air Force: $164.9 million;
Army: $154.7 million;
Navy: $103.8 million;
Marine Corps: $41.6 million;
Total: $465 million.
Fiscal year: 2008;
Air Force: $175.1 million;
Army: $170.4 million;
Navy: $94.9 million;
Marine Corps: $33.8 million;
Total: $474 million.
Fiscal year: 2009;
Air Force: $178.8 million;
Army: $187.4 million;
Navy: $102.8 million;
Marine Corps: $48.2 million;
Total: $517 million.
Source: GAO analysis of DOD data.
[End of figure]
In order to receive TA funds, DOD requires postsecondary institutions
to be accredited by an agency recognized by Education. Accreditation
is a peer review evaluative process that compares a school against its
accrediting agency's established standards. The accrediting agency
conducts institutional reviews to assess the school in its entirety,
including its resources, admissions requirements, and services
offered, and the quality of its degree programs. The schools'
accreditation is then periodically reevaluated every 3 to 10 years,
depending on the accrediting agency. Schools may lose accreditation if
their accrediting agency determines that they no longer meet the
established standards.
Since 1972, SOC has enhanced educational opportunities for service
members. SOC, a consortium of approximately 1,900 colleges and
universities, is funded by DOD through a contract with the American
Association of State Colleges and Universities (AASCU). SOC functions
in cooperation with 15 higher-education associations, DOD, and active
and reserve components of the military services to expand and improve
voluntary postsecondary education opportunities for service members
worldwide. SOC criteria stipulate that school policies and practices
be fair, equitable, and effective in recognizing the special
conditions faced by military students, such as trouble completing
college degrees because of their frequent moves. Colleges and
universities within SOC must have policies that meet four SOC criteria
relating to transfer of credit, academic residency
requirement,[Footnote 8] credit for military training and experience,
and credit for nationally recognized testing programs. In addition,
they must also follow SOC's three principles: (1) service members
should share in the postsecondary educational opportunities available
to other citizens; (2) educational programs for service members should
rely primarily on programs, courses, and services provided by
appropriately accredited institutions and organizations; and (3)
institutions should maintain a necessary flexibility of programs and
procedures, such as recognition of learning gained in the military and
part-time student status.[Footnote 9]
Since 1991, DOD's Military Installation Voluntary Education Review
(MIVER) process has provided an independent third-party assessment of
the quality of postsecondary education programs offered to off-duty
service members at military installations around the world. DOD
contracted with the American Council on Education (ACE) to administer
the MIVER.[Footnote 10] The MIVER had two purposes: (1) to assess the
quality of selected on-installation voluntary education programs and
(2) to assist in the improvement of such education through appropriate
recommendations to institutions, installations, DOD, and the military
services. To assess the quality of education programs offered by
schools on installations and to ensure that these program are
comparable to those offered at a school's other campuses, MIVER
assessed schools' missions, education programs, program
administration, resources, and program evaluation. The MIVER also
examined the installations' mission statements and command support,
program management and leadership, student services, resources, and
the voluntary education program plans to determine the quality of
their education programs and services. A visiting team composed of
college and university professors selected by the contractor evaluated
the quality of educational services and support provided by the
installation's education center and servicing institutions. The MIVER
provided installations and schools with commendations for their areas
of strength, and recommendations for areas needing improvement. It
also provided the military services with observations on issues that
require the military services' attention. MIVERs were for the purpose
of quality assessment and enhancement only; these reviews were not
intended to replace institutional accreditation. The MIVER contract
with ACE expired on December 31, 2010, and DOD elected not to renew
the contract because it is expanding the scope of these reviews, but
DOD is currently in the process of obtaining a new contract for its
reviews. According to DOD, a contractor will be selected in 2011 and
the new third-party review process will commence on October 1, 2011.
On August 6, 2010, DOD published a proposed rule for its voluntary
education programs in the Federal Register for public comment.
[Footnote 11] Included in this rule, among other things, are
guidelines for establishing, maintaining, and operating voluntary
education programs, including instructor-led courses offered on and
off installations, distance education courses, and the establishment
of a DOD Voluntary Education Partnership Memorandum of Understanding
(MOU) between DOD and all educational institutions receiving TA funds.
DOD estimates that this new rule will become effective at the
beginning of 2012.
While Education does not have a role in overseeing DOD education
programs, it is responsible for the administration of the federal
student aid programs under Title IV and oversees over 6,000
postsecondary institutions receiving these funds.[Footnote 12]
Education determines which institutions of higher education are
eligible to participate in Title IV programs, which include the
following:[Footnote 13]
* Public institutions--institutions operated and funded by state or
local governments, which include state universities and community
colleges.
* Private nonprofit institutions--institutions owned and operated by
nonprofit organizations whose net earnings do not benefit any
shareholder or individual. These institutions are eligible for tax-
deductible contributions in accordance with the Internal Revenue Code
(26 U.S.C. § 501(c)(3)).
* For-profit institutions--institutions that are privately owned or
owned by a publicly traded company and whose net earnings can benefit
a shareholder or individual.
Education is also responsible for overseeing school compliance with
Title IV statutory and regulatory provisions and ensuring that only
eligible students receive federal student aid. As part of compliance
monitoring, Education employees conduct program reviews of schools.
The reviewers examine school records, interview institution staff and
students, and review relevant student information, among other things.
In addition to program and eligibility reviews conducted by Education
employees, independent auditors conduct annual compliance and
financial audits of schools, and Education's Office of the Inspector
General conducts its own audits and provides information and referrals
to Education.[Footnote 14] Education resolves program deficiencies
identified in both program reviews and audit reports and may impose
penalties or other sanctions on schools found in violation of Title IV
requirements.[Footnote 15]
DOD Takes Steps to Enhance Its Oversight of Schools Receiving TA
Program Funds, but Areas for Improvement Remain:
DOD's Oversight Policies and Procedures Vary by Schools' Level of
Program Involvement but Could Benefit from a Systematic Risk-Based
Approach:
DOD policies and procedures to oversee schools receiving TA funds vary
based on the school's level of involvement in the program. While DOD
monitors enrollment patterns and schools' funding levels, and
addresses complaints about postsecondary schools on a case-by-case
basis, its oversight activities do not include a systematic approach
that considers these factors when targeting schools for review.
[Footnote 16] At a minimum, all postsecondary schools receiving TA
funds are required to be accredited by an agency recognized by the
Department of Education to ensure the quality of education programs
being offered to its service members. Schools that are members of the
SOC consortium or offer classes on an installation are subject to
additional DOD oversight, as shown in figure 2.
Figure 2: DOD Participation Requirements by School Level of Program
Involvement:
[Refer to PDF for image: illustration]
Level of oversight: progresses from Low to High:
All school participants:
* Must be accredited by an agency recognized by the Department of
Education.
Schools that belong to Servicemembers Opportunity Colleges (SOC)[A]:
* Sign a SOC agreement;
* Subject to an accreditation check every 2 years;
* Undergo verification of their loan default rates.
Schools with signed memorandums of understanding (MOU) with
installations:
* Must be members of SOC;
* Must be chartered or licensed by a state government;
* Must abide by MOU agreement with base commander that governs
solicitation policies, reporting requirements on academic offerings
and student academic status, and other terms of operations on the base;
* Were subject to Military Installation Voluntary Education Review
(MIVER)[B].
Source: GAO analysis of program policies and testimonial evidence from
DOD and SOC officials.
[End of figure]
Schools that elect to become members of the SOC consortium must comply
with SOC principles and criteria, which promote institutional
flexibility with regard to transfer of credits, the development of
programs and procedures appropriate to the needs of service members,
and safeguarding the quality of educational programs offered to
service members. SOC also reviews member schools' student loan default
rates and verifies their accreditation status every 2 years, according
to a SOC official.[Footnote 17] In addition, SOC considers recruitment
practices such as high-pressure promotional activities and "limited
time only" enrollment discounts inappropriate activities for its
member institutions to engage in. According to a SOC official, SOC
will submit a formal complaint to the school's accreditor when it
becomes aware of serious violations of prohibited marketing practices.
Schools offering classes on an installation are subject to additional
oversight measures. Aside from accreditation and mandatory membership
of SOC institutions that provide academic courses on military
installations,[Footnote 18] schools are subject to additional
oversight measures including state licensure, MIVER quality reviews,
and the terms and conditions of an individualized MOU with the
installation commander.[Footnote 19] The MOU governs the school's
operations on an installation; for example, it can cover reporting
requirements on course offerings and the maintenance of student data
such as course grades and degrees completed. Education center
officials at two installations we visited reported that they stay in
constant contact with on-installation schools and review relevant
information such as school term schedules and class rosters to ensure
that schools comply with their MOUs. If a school does not comply with
the MOU requirements, the installation commander can require the
school to leave the installation, according to education center
officials at two of the installations we visited. In general, DOD and
its military services' oversight of schools is based on a school's
level of program participation rather than a risk-based approach.
To address the varying levels of oversight and create a more uniform
set of program oversight policies, DOD has developed a new standard
MOU for all schools receiving TA funds. Under the new MOU, all schools
will be required to, among other things, abide by SOC principles and
criteria and provide an evaluated educational plan to service members.
DOD estimates that this new rule will be implemented at the beginning
of 2012.
DOD's Education Quality Review Process Was Narrow in Scope and Needed
Increased Accountability:
The MIVER was limited to institutions that offer face-to-face courses
at military installations. While distance learning courses accounted
for 71 percent of courses paid for with TA funds in fiscal year 2009,
DOD did not have a review process in place to assess the quality of
these institutions. In addition, quality reviews were not conducted at
all installations. According to DOD officials, since the MIVER process
was first initiated, in 1991, all Marine Corps installations were
visited, while only a portion of installations of the other military
services were reviewed (86 percent of Navy installations, 56 percent
of Army installations, and 30 percent of Air Force installations).
[Footnote 20] Under the expanded review process that is being
developed, all institutions receiving TA funds will be subject to a
new third-party review process--a Military Voluntary Education Review
(MVER)--regardless of whether the school delivers courses face to face
or by distance education. In addition, DOD officials said that schools
will be selected for the MVER process based on the amount of TA funds
they receive.
DOD has relied on MIVER to evaluate the quality of the education
services being provided to its service members at installations;
however, three of the four services lacked a process to follow up on
and respond to the findings of the MIVER process. During the MIVER
process, reviewers developed a report listing their recommendations,
commendations, and observations of the educational services provided
by the installation it was reviewing and the institutions offering
courses at that installation. MIVER final reports were distributed to
the institutions and installations that were reviewed as well as DOD
officials and its military services. The Army was the only military
service that required installations that received a MIVER visit to
submit a follow-up report indicating actions taken in response to the
MIVER review. The Air Force recognizes the importance of having such a
process and was considering adopting a policy that would implement a
formal process of tracking and following up on items mentioned in
MIVER reports. The Navy and Marine Corps reported that they did not
have a formal process requiring their installations to track the
outcome of MIVER recommendations, commendations, and observations.
[Footnote 21] These military services also reported that they review
and maintain copies of all MIVER reports. One DOD official reported
that MIVER reports were helpful in identifying the strengths,
weaknesses, and areas for improvement in DOD educational programming.
[Footnote 22] Additionally, according to ESOs we interviewed, some
MIVER recommendations were implemented with successful results. For
example, an ESO told us that some of the Navy installations
implemented a MIVER recommendation to strengthen their coordination
with nearby schools. Given that there was no DOD-wide requirement to
track the outcomes of MIVER recommendations and some of the military
services did not require schools and installations to formally respond
to MIVER findings, it is unclear to what extent recommendations that
could improve the quality of education services offered at schools and
installations were addressed. There is currently no such requirement
in place for its new third-party process, according to DOD officials.
DOD Has Several Ways to Receive Reports of Problems but Needs a
Centralized System to Track Complaints:
While DOD has several mechanisms for service members to report
problems associated with their TA funding, it lacks a centralized
system to track these complaints and how they are resolved. If service
members have a complaint or issue regarding a school, they can speak
with a counselor at their installation's education center, contact a
representative from SOC, use the call center service,[Footnote 23] or
use the Interactive Customer Evaluation (ICE).[Footnote 24] According
to DOD officials, DOD's practice is to have ESOs and education center
staff resolve complaints at the installation level and to only elevate
issues that warrant greater attention at the military service level.
However, DOD and its military services do not have a formal process or
guidance in place for when ESOs should elevate a complaint to their
military service chief or DOD.
DOD reported that most of the complaints it receives are
administrative in nature, but a few complaints involve improper or
questionable marketing practices. ESOs we spoke with reported that the
most frequent complaints they receive from all sources tend to be
administrative, such as billing issues. These complaints are often
handled directly by counseling staff at the education offices and are
generally resolved immediately at the installation level, according to
DOD officials. ESOs told us that they also receive complaints about
improper or questionable marketing practices by schools receiving TA
funds. ESOs and their staff mentioned cases where school
representatives have conducted marketing activities at installations
without the installation commander's or ESO's permission. Although the
ESOs do not maintain an official record of all complaints, ESOs we
spoke with recalled that most of the instances of a school engaging in
improper or questionable marketing practices have involved for-profit
schools. They provided us with documentation of a few examples of
these complaints. In one case, a for-profit school was found to be
charging higher tuition rates to service members than civilians and
offering service members $100 gas cards upon course completion. The
ESO at the installation where this incident occurred told us that this
issue was resolved by speaking with school officials and an
accrediting agency. An official also told us that another for-profit
school representative continually called and e-mailed a service member
during day and evening hours after he elected not to attend that
institution.
SOC also helps DOD and its military services in resolving complaints.
SOC produces and disseminates quarterly reports to the voluntary
education service chiefs of each of the military services to inform
them of the issues that SOC has addressed on behalf of DOD and its
military services. SOC addresses various administrative matters such
as answering questions from schools and service members about the TA
program. A SOC official told us that SOC also resolves complaints
involving aggressive marketing, claims of unfair grading, and issues
relating to deployment and transfer of credit between institutions.
For example, SOC intervened on a student's behalf and successfully
secured transfer of credits when a school failed to honor its
agreement with the service member to do so upon course completion.
Education center staff elevate issues that cannot be handled locally
to the military service chief level, but DOD does not have specific
guidance explaining when to do so. When a school distributed flyers
and e-mails at an installation to advertise courses it planned to
offer on-installation without an MOU and misrepresenting the number of
credits service members would receive from taking the school's
courses, DOD officials and SOC were notified of these activities. In
response to these issues, DOD shared its concerns and copies of the
school's marketing materials with Education. Additionally, SOC filed a
complaint with the school's accrediting agency. Education planned to
review the school' marketing materials, and the accreditor plans to
hold a meeting to determine the appropriate actions to address SOC's
complaint, according to DOD officials. DOD's Interservice Voluntary
Education Working Group serves as a forum for service officials to
share information, including complaints they might be made aware of,
with DOD headquarters officials. The group, with representation from
each military service, meets quarterly to discuss various DOD
voluntary education-related issues and share information among the
four military services. Despite such examples of complaints being
referred up the chain of command, one military service official said
that it is difficult to establish policy on how to handle every
complaint or issue that may arise. Without polices and a centralized
system to track complaints and their outcomes, DOD may not have
adequate information to assess trends across its military services or
determine whether complaints have been adequately addressed.
Military Education Center Staff and School Representatives Identified
Areas Needing Improvement:
Education center staff and school representatives outlined several
areas that could improve program oversight--(1) requiring schools to
offer distance learning tutorials, and (2) developing a uniform
installation access policy for schools.
Require schools to offer a distance learning tutorial: Officials at
the military education centers we visited suggested that the
availability of a distance learning tutorial for all service members
accessing online courses is important to ensure that service members
successfully complete these courses. Because of the mobile nature of a
service member's life, online education offerings provide an
opportunity for service members to access and complete postsecondary
courses. However, counseling staff and school representatives we
interviewed at one installation reported that some service members
have had difficulty using the course software to access discussion
boards and/or submit assignments because they had not previously taken
an Internet-based course. Officials from one of the institutions we
spoke with told us that they offer online tutorials and technical
support for their distance learning courses, and participation in the
online tutorial is strongly encouraged.
Uniform installation access policy for schools: School representatives
we met with suggested that DOD establish a uniform installation access
policy for all schools participating in the TA program. Installation
access policies are determined at the installation level by the ESO
and installation commander, and these policies tended to vary with
installations we visited. In addition to schools that offer courses on
an installation and have a signed MOU, some schools are granted access
to the installation by the ESO as visiting schools. These schools do
not offer courses on an installation but instead offer periodic office
hours and academic support for the students they serve at that
installation. At one installation we visited, the ESO grants access to
only a few visiting schools and requires that they all sign an MOU
outlining the terms of their operations on an installation. However,
at another installation we visited, the ESO allows any school that
currently serves students on an installation to hold office hours with
the education center's approval. A few school representatives
expressed concerns about their limited or lack of installation access
to support their students.
DOD's Limited Coordination with Accreditors and Education May Hinder
Its Efforts:
DOD Coordinates with Accrediting Agencies but Does Not Use Information
about Schools That Have Been Sanctioned or Have Unapproved Changes:
While DOD coordinates with accrediting agencies, it does not use
accrediting agencies' monitoring results or consider schools'
unapproved substantive changes as it carries out its oversight. DOD
officials told us they communicate with accrediting agencies through
SOC to verify accreditation, and report complaints or problems with
schools. SOC, on the behalf of DOD, contacts accrediting agencies
biannually to verify the accreditation status of its member
institutions, according to a SOC official.[Footnote 25] DOD and its
military services officials reported that they also contact
accrediting agencies directly or through SOC when they cannot resolve
complaints against schools. For example, one military service worked
with SOC to file a complaint against a school when it found that a
school was falsely marketing its courses to its service members.
According to DOD, this complaint led to an investigation into the
matter by the school's accrediting agency. DOD also reported that it
holds annual meetings with accrediting agencies to discuss DOD
policies and procedures and the delivery of educational programs to
its military services.
DOD's oversight process does not take into account accrediting
agencies' monitoring results of schools that could negatively affect
students and service members. Schools can be sanctioned by accrediting
agencies when they fail to meet established accrediting standards,
such as providing sound institutional governance, providing accurate
information to the public, and offering effective educational
programs. For example, on the basis of an accrediting agency's
monitoring results that were publicly available, a school was warned
it could be at risk of losing its accreditation in part because it
lacked evidence of a sustainable assessment process to evaluate
student learning. The school was required to submit a report to the
accrediting agency providing evidence of its process and that the
results were being used to improve teaching, learning, and
institutional effectiveness. According to accrediting agency
officials, schools are given multiple opportunities to correct
deficiencies before having accreditation revoked and can be sanctioned
for up to 2 years.[Footnote 26]
DOD does not currently require schools to have their substantive
changes approved by their accrediting agency in order to receive TA
funds. Schools may introduce new courses or programs significantly
different from current offerings, and such changes may be considered
substantive and outside the scope of an institution's accreditation.
Unlike DOD, Education requires a school to obtain its accrediting
agency's approval on any substantive change and report this
information to Education for approval before it can disburse Title IV
funds to students enrolled in new courses or programs considered to be
substantive changes.[Footnote 27] Education requires accrediting
agencies to have substantive change policies in place to ensure that
any substantive change to an institution's educational mission or
programs does not adversely affect its capacity to continue to meet
its accrediting agency's standards. DOD recently proposed that tuition
assistance funds should be available for service members participating
in accredited undergraduate or graduate education programs and that
approved courses are those that are part of an identified course of
study leading to a postsecondary certificate or degree.[Footnote 28]
According to Education, schools seeking Title IV funds generally wait
for approval before enrolling students in such new courses and
programs, but can collect other federal education assistance and out-
of-pocket funds during that time. Students enrolled in unapproved
courses or programs have less assurance that they are receiving a
quality education, according to Education officials. On the basis of
Education's fiscal year 2009 Program Compliance Annual Report, we
determined that there were over 1,200 substantial changes processed in
fiscal year 2009.
DOD Could Better Leverage Compliance Information from Education to
Improve Its Oversight of Schools:
DOD coordinates with Education to some extent but does not utilize
Education's compliance data to oversee schools receiving TA funds. The
extent of DOD's coordination with Education has generally been limited
to accreditation status. According to DOD officials, DOD regularly
searches Education's Web site to verify schools' accreditation status,
and utilizes Education's resources for counseling students on federal
student aid. In addition, DOD reported that it invited Education
officials to attend its Interservice Voluntary Education Working Group
meeting in September 2010 to discuss future changes to the
accreditation process. However, DOD does not utilize information from
Education's monitoring reviews to inform its oversight efforts. This
information can alert DOD to problems at schools that may affect the
quality of education provided to students, including service members.
Education determines schools' initial eligibility to participate in
federal student aid programs through eligibility reviews and
continuing eligibility through program reviews, compliance audits, and
financial audits. The results of these oversight measures provide
additional insight into a school's financial stability, quality of
education, and compliance with regulations that provide consumer
protections for students and the federal investment. See table 1 for a
summary of these oversight activities.
Table 1: Education's Monitoring of Schools Participating in the Title
IV Program:
Focus of oversight: Financial health[A];
Types of school monitored: Private nonprofit and for-profit;
Activity: Financial responsibility: Education determines schools'
financial responsibility by assessing its cash reserves and the
school's history of meeting its past financial obligations. In 2008
and 2009, at least 249 schools failed the financial stability test,
and Education placed some of these schools on heightened monitoring.
Focus of oversight: Related to quality of education;
Types of school monitored: All schools;
Activity: Student loan cohort default rate: According to Education
officials, Education uses student loan cohort default rates implicitly
as a proxy for education quality. A large number of students in
default may indicate that a school may be poorly preparing students
for employment. Schools with default rates above certain thresholds
lose eligibility to participate in Title IV programs.
Focus of oversight: Related to quality of education;
Types of school monitored: For-profit only;
Activity: 90/10 rule: In order to participate in Title IV programs,
for-profit schools cannot receive more than 90 percent of their
revenue from title IV funds.[B] Between 2003 and 2008, 7 schools lost
eligibility for federal student aid because of noncompliance with the
90/10 rule.
Focus of oversight: Consumer protection related to schools' recruiting
practices;
Types of school monitored: All schools;
Activity: Incentive compensation: Schools participating in Title IV
programs are prohibited from compensating recruiters based directly or
indirectly on their success in enrolling students or securing
financial aid for them. Between 1998 and 2009, Education substantiated
incentive compensation violations at 32 schools.[C].
Focus of oversight: Consumer protection related to schools' recruiting
practices;
Types of school monitored: All schools;
Activity: Misrepresentation: Institutions participating in Title IV
programs may not engage in substantial misrepresentation of the nature
of the institution's educational program, its financial charges, or
the employability of its graduates. According to Education's
compliance data, Education found at least 16 misrepresentation
violations between 2004 and 2009 through compliance audits and closed
program reviews.
Source: GAO analysis of laws and regulations, as well as testimonial
evidence and program documents from Education.
[A] Education considers a public institution financially responsible
if it demonstrates legal designation as a public institution and has
not violated past performance requirements.
[B] DOD tuition assistance funds are counted toward meeting a
proprietary institution's minimum of 10 percent non-Title IV funds. A
school's revenue percentage must be calculated in accordance with 34
C.F.R § 668.28.
[C] GAO, Higher Education: Information on Incentive Compensation
Violations Substantiated by the U.S. Department of Education, GAO-10-
370R (Washington, D.C. February 23, 2010).
[End of table]
The results of these oversight measures can provide DOD and its
military services with additional insight into a school's ability to
provide a quality education and services to students. Schools that are
financially unstable or fail to comply with student loan default rate
and 90/10 requirements may be unable to fulfill their promises to
provide students with quality program offerings, according to
Education. While DOD monitors default rates through SOC, it does not
formally monitor 90/10 information. Military education center staff we
spoke with at two military installations indicated that ensuring the
consumer protection of service members amidst sometimes deceptive
recruiting practices of some schools can be a challenge. Education's
monitoring results in these areas could provide relevant information
to help DOD and its military services to better target their oversight
and provide additional consumer protection for service members.
Education has recently developed additional provisions to better
address oversight in distance education. Education has developed a
review process and guidance for its staff to assess the integrity of
distance learning programs, such as whether schools have a process to
verify student attendance. DOD has proposed that distance education
schools be subject to MVER reviews, but currently does not generally
evaluate these courses.[Footnote 29] DOD may be able to leverage
information from Education's ongoing efforts in this area.
In part because of inconsistencies in states' authorization
requirements for schools, Education recently clarified what is
required for institutions of higher education to be considered legally
authorized by a state. Under new regulations that will generally take
effect in July 2011, states must, among other things, have a process
to review and address complaints about institutions authorized by the
state. In addition the new regulations require that if an institution
is offering postsecondary education through distance or correspondence
education in a state in which it is not physically located, the
institution must meet any state requirements for it to be legally
offering distance or correspondence education in that state.[Footnote
30] Unlike Education, DOD does not verify that all schools receiving
TA funds have state authorization; it only verifies state
authorization for on-installation schools. Since DOD reported that it
has not had the opportunity to fully review Education's new rule
regarding state authorization, it is unclear whether it will follow
those requirements.
Education has partnerships with a number of other federal agencies,
including the Department of Justice and the Federal Trade Commission.
Education partners with these two agencies to share information on
complaints and college scholarship and financial aid fraud.
Additionally, Education has a Federal Agency Advisory Working Group to
facilitate its coordination with other federal agencies and told us
that it is willing to share information and provide guidance to DOD in
real time.
Conclusions:
In fiscal year 2009, nearly 377,000 service members relied on TA funds
to help further their academic and professional goals. Schools that
offer distance learning courses play an ever increasing role in
helping students achieve these goals. The amount of TA funding going
toward distance learning programs creates new oversight challenges for
DOD and its military services, especially since DOD oversight has
primarily focused on schools offering traditional classroom
instruction on military installations.
Increased oversight is needed to remedy gaps in the accountability of
the quality review process and the process to address complaints
against schools. Although DOD has plans to improve its oversight of
schools receiving TA funds, without accountability measures for its
quality review process, DOD cannot be certain its efforts to safeguard
TA funds will be effective. In addition, while DOD is aware of some
concerns regarding schools' improper recruiting practices, without a
centralized process to track complaints against schools and their
resolution, DOD lacks the ability to accurately determine trends in
areas requiring oversight and whether concerns have been adequately
addressed.
DOD could further enhance its oversight efforts by leveraging
resources and information that accrediting agencies and Education
already collect. For example, the additional consumer protections
provided by Education's regulations on schools' substantive changes
could provide DOD with additional assurance that TA funds are going
toward courses and programs that have been properly vetted by the
schools' accreditors. Without leveraging these additional oversight
tools, DOD and its military services may lack key information that
could help strengthen and inform future program oversight. Targeted
improvements in these areas may help DOD and its military services to
better ensure that TA funds are being properly utilized and services
members are receiving quality education.
Recommendations for Executive Action:
We recommend that the Secretary of Defense direct the Undersecretary
of Defense for Personnel and Readiness to take the following 5 actions
to improve its oversight of schools receiving TA funds:
1. To improve the accountability of DOD, its military services, their
installations, and participating postsecondary schools in developing
its new third-party review process,
* require all schools, installations, and the military services to
formally respond in writing to related recommendations pertaining to
them, and:
* develop a process to track and document the status of all
recommendations for improvement.
2. Evaluate ways to develop a centralized process to record and track
the status and outcomes of complaints. This should be done in a way
that balances the need for a comprehensive tracking system with, to
the extent possible, minimizing the reporting burden placed on
education center staff at military installations.
3. Undertake a systematic review of its oversight of schools receiving
TA program funds. In doing so, the Undersecretary of Defense for
Personnel and Readiness should consider the following:
* developing a more systematic risk-based approach to oversight by
utilizing information from accrediting agencies and Education to
better target schools,
* modifying its proposed standard MOU to include an explicit
prohibition against school conduct that may adversely affect service
members, such as misrepresentation, and:
* reviewing Education's recently promulgated requirements for state
authorization of schools and coordinate with Education to determine
the extent to which these requirements are useful for overseeing
schools receiving TA funds.
4. Prohibit TA funds from being used to pay for courses and programs
that are not included within the scope of an institution's
accreditation. This could include leveraging Education's knowledge and
expertise to determine the extent to which other substantive changes
listed in Education's regulations are applicable to the military
education programs.
5. Require and verify that all schools receiving TA funds are
authorized by their state.
Agency Comments:
We provided a draft of this report to DOD and Education. DOD's written
comments are reproduced in appendix III. DOD agreed with our
recommendations and noted steps it would take to address them.
Additionally, DOD and Education provided technical comments on the
draft. We incorporated each agency's comments as appropriate.
We are sending copies of this report to relevant congressional
committees, the Secretary of Defense, the Secretary of Education, and
other interested parties. In addition, this report will be available
at no charge on GAO's Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to
this report are listed in appendix IV.
Sincerely yours,
Signed by:
George A. Scott:
Director, Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Scope and Methodology:
To address our objectives, we reviewed and analyzed relevant federal
laws, regulations, and program documents and data, including program
participation and expenditure data from the Department of Defense
(DOD) and its military services. We also reviewed the Department of
Education's (Education) monitoring results to report on cases where
schools were not in compliance with Title IV requirements.
We interviewed officials from DOD, its military services, and
contractors--Servicemembers Opportunity Colleges (SOC) and the
American Council on Education. We conducted site visits to education
centers located at military installations of the four military
services to gain a better understanding of how the program is
implemented. We selected these sites based on whether the sites had a
mix of public, private nonprofit, and for-profit schools offering
classes or held office hours at the installations. We visited one
installation per military service--Joint Base Andrews, Fort Carson,
Marine Corps Base Quantico, and Naval Station Norfolk. During our site
visits, we toured the education facilities and interviewed education
center staff and representatives from 16 schools across the four
installations that we visited. (See appendix II.)
We interviewed Department of Education officials to determine the
extent to which they coordinate with DOD as part of DOD's efforts to
oversee its Military Tuition Assistance (TA) program. Finally, we
interviewed representatives from an association of colleges and
universities (Council for Higher Education Accreditation) and selected
accrediting agencies (the Distance Education and Training Council and
the Higher Learning Commission) in order to obtain information about
the extent to which they coordinate and provide information to DOD and
its military services for monitoring schools. Overall, we assessed the
reliability of these data by reviewing existing information about the
data and the system that produced them and interviewing agency
officials knowledgeable about the data. We determined the data to be
sufficiently reliable for the purposes of this report.
We conducted this performance audit from August 2010 to February 2011
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Selected Postsecondary Institutions GAO Interviewed at
Selected Education Centers:
For-profit:
1. American Military University:
2. Ashford University:
3. DeVry University:
4. ECPI College of Technology:
5. Strayer University:
6. University of Phoenix:
Private nonprofit:
7. Embry Riddle Aeronautical University:
8. Park University:
9. Webster University:
Public:
10. Colorado State University-Pueblo:
11. Pikes Peak Community College:
12. Northern Virginia Community College:
13. Tidewater Community College:
14. Troy University:
15. University of Colorado at Colorado Springs:
16. University of Maryland University College:
[End of section]
Appendix III: Comments from the Department of Defense:
Office Of The Under Secretary Of Defense:
Personnel and Readiness:
41130 Defense Pentagon:
Washington, DC, 20301-4000:
February 22, 2011:
Ms. Janet St. Laurent:
Managing Director, Defense Capabilities and Management:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Ms. St. Laurent:
This is the Department of Defense (DoD) response to the GAO Draft
Report, GAO-11-300, "DOD Education Benefits: Increased Oversight of
Tuition Assistance Program is Needed," dated February 3, 2011(GAO CODE
131025).
In the enclosure we provide the DoD responses to the GAO
recommendations. We concur with all recommendations.
Signed by:
Robert L. Gordon III:
Deputy Assistant Secretary of Defense (Military Community and Family
Policy):
Enclosure: As stated:
[End of letter]
GAO Draft Report Dated February 3, 2011:
GA0-11-300 (GAO Code 131025):
"DOD Education Benefits: Increased Oversight of Tuition Assistance
Program is Needed"
Department Of Defense Comments To The GAO Recommendations:
Recommendation 1: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness to
take the following actions to improve the accountability of the DOD,
its Military Services, their installations, and participating
postsecondary schools in developing its new third party review process:
* require all schools, installations, and the Military Services to
formally respond in writing to related recommendations pertaining to
them;
* develop a process to track and document the status of all
recommendations for improvement.
DoD Response: Concur. The new third party review process will require
all schools, installations and the Services to formally respond in
writing to recommendations and show actions taken for improvement. OSD
will track to ensure compliance and monitor all corrective actions to
ensure there is continuous quality improvement. (Estimated completion
date is Oct. 11)
Recommendation 2: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness to
evaluate ways to develop a centralized process to record and track the
status and outcomes of complaints. This should be done in a way that
balances the need for a comprehensive tracking system with, to the
extent possible, minimizing the reporting burden placed on Education
Center staff at military installations.
DoD Response: Concur. Currently, DoD is developing an automated
tracking system to document all concerns and complaints. The system
will track the complaint, status and record resolutions. The system
will allow students, DoD personnel and schools to submit complaints
and will be located on DoD Voluntary Education Partnership MOU web
page: www.dodmou.com or as a link under the DoD Voluntary Education
Web site at www.volcd.dodcd.mil . (Estimated completion date is June
11).
Note: The Army has already established a process to record/track
complaints through the GoArmyEd's Customer Relationship Management
(CRM) resource available to all Soldiers who use Federal tuition
assistance. Soldiers can create a CRM case either on-line (in
GoArmyEd) or use toll-free phone numbers to the GoArmyEd's helpdesk.
Once a CRM case is resolved/closed, the Soldier may use the available
"Customer Satisfaction Survey" to rate the course and/or provide
candid comments concerning the level of service provided to resolve
their case.
Recommendation 3: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness take
the following actions to undertake a systematic review of its
oversight of schools receiving Tuition Assistance (TA) program funds.
In doing so, the Undersecretary of Defense for Personnel and Readiness
should consider the following:
* developing a more systematic risk based approach to oversight by
utilizing information from accrediting agencies and Education to
better target schools;
* modifying its new standard MOU to include an explicit prohibition
against school conduct that may adversely affect service members, such
as misrepresentation;
* reviewing Education's recently promulgated requirements for state
authorization of schools and coordinate with Education to determine
the extent to which these requirements arc useful for overseeing
schools receiving TA funds.
DoD Response: Concur. DoD has contacted the Department of Education
and is developing a partnership sharing agreement to utilize
information from Education's 1) requirements reports from accrediting
agencies, 2) school monitoring reviews, and 3) requirements for state
authorization of schools. This information will be used to assist is
targeting its review process. In addition, DoD will revise directives
to more explicitly address adverse conduct by a school that may
negatively impact Service members. (Estimated completion date is
August 11)
Recommendation 4: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness to
take the following action to prohibit TA funds from being used to pay
for courses and programs that arc not included within the scope of an
institution's accreditation. This could include leveraging Education's
knowledge and expertise to determine the extent to which other
substantive changes listed in Education's regulations are applicable
to the military education programs.
DoD Response: Concur. DoD has contacted the Department of EdUcation
and is developing a partnership sharing agreement to utilize
information from Education's requirements reports from accrediting
agencies to include substantive change reports. As part of this, we
will be determining which of Education's regulations are applicable to
DoD Voluntary Education programs and apply to the military tuition
assistant program policies. (Estimated completion date is August 11)
Recommendation 5: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness take
action to require and verify that all schools receiving TA funds are
authorized by their state.
DoD Response: Concur. DoD has contacted the Department of Education
and is developing a partnership sharing agreement to utilize the
tracking and documentation of a school's state authorization. The
information will be used, prior to issuing tuition assistance funds,
to ensure schools are in compliance with Education's new requirement
for all schools to have state authorization to offer distance or
correspondence learning. (Estimated completion date to begin receiving
audit reports from the Department of Education is August 11; a
comprehensive tracking system will be developed by the Department of
Education but will require additional time)
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
George A. Scott, (202) 512-7215 or scottg@gao.gov:
Staff Acknowledgments:
In addition to the above contact, Tranchau (Kris) Nguyen (Assistant
Director), Raun Lazier (Analyst-in-Charge), James Bennett, Jessica
Botsford, Susannah Compton, Catherine Hurley, Edward (Ted) Leslie,
Katya Melkote, and Luann Moy made significant contributions to this
report.
[End of section]
Footnotes:
[1] DOD defines "off-duty time" as the time when service members are
not scheduled to perform official duties.
[2] TA funds may be used for educational activities such as (1)
completion of an associate's degree, bachelor's degree, or master's
degree; (2) for courses leading to technical, vocational, or
professional certificate or license; (3) building academic foreign
language skills when not part of a degree program; and (4) pursuing
prerequisite courses for academic skill development or preparation for
a degree program, according to the Joint Service Uniform Tuition
Assistance Policy.
[3] DOD defines "distance education" as the delivery of education or
training through electronically mediated instruction, including
satellite, video, audio graphic, computer, multimedia technology, and
other forms of learning at a distance, such as correspondence and
independent study.
[4] Voluntary education programs are authorized by 10 U.S.C. §§ 2005
and 2007.
[5] DOD Directive 1322.08E (May 3, 2010) and DOD Instruction 1322.25
(April 23, 2007).
[6] Education centers located on military installations are equipped
with office space, classrooms, laboratories, and other features to
conduct voluntary education programs and provide on-installation
classes.
[7] According to DOD, TA funds are paid directly to schools, and if
service members do not meet GPA requirements or complete their
courses, service members are responsible for paying back the money for
these courses.
[8] The term "academic residency requirement" pertains to the required
number of course credits students must take from their home
institution to be eligible for a degree.
[9] Servicemembers Opportunity Colleges, SOC Principals and Criteria
2011-2013.
[10] The most recent MIVER contract was a 4-year contract (January 1,
2007, to December 31, 2010) with a total value of $3,743,440.
[11] Voluntary Education Programs, 75 Fed. Reg. 47,504 (Aug. 6, 2010)
(to be codified at 32 C.F.R. pt. 68).
[12] Title IV of the Higher Education Act of 1965 (HEA), as amended,
authorizes financial assistance to help students and families pay for
postsecondary education through student grants and loans, such as Pell
Grants for low-income students, loans to parents and graduate
students, and Stafford loans.
[13] Under the HEA, institutions must meet certain requirements to
participate in Title IV student aid programs. In general, an
institution of higher education is required to (1) be authorized by
the state in which it is located to provide higher education, (2) be
deemed eligible and certified to participate by the Department of
Education, and (3) be accredited by an accrediting agency recognized
by the Secretary of Education. Although Education's regulations
provide that accrediting agencies may not accredit institutions that
lack state authorization, accreditation does not establish that an
institution is authorized by a state for purposes of the Title IV
program.
[14] Institutions that receive Title IV funds must submit an annual
audit to Education prepared by a certified independent auditor.
[15] As part of the resolution process, Education generally sends a
program review or audit determination letter to the school describing
the violations found and any corrective actions the school must take
to address the finding. In certain circumstances, Education may fine a
school or suspend, limit, or terminate a school's participation in
Title IV programs.
[16] According to the GAO's standards for internal control in the
federal government--GAO, Internal Control: Standards for Internal
Control in the Federal Government, [hyperlink,
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C.
November 1999)--to better achieve their missions and improve
accountability, federal agencies are required to employ certain
internal controls, including assessing the risk agencies face from
both external and internal sources. Applying the federal risk
assessment standard to the TA program suggests that DOD needs to
consider all significant interactions between its entity and other
parties, as well as internal factors at both the entitywide and
activity level. Risk identification methods may include qualitative
and quantitative ranking activities, and consideration of findings
from audits and other assessments.
[17] SOC follows Education's definition of loan default limits for its
membership eligibility. Generally, a school loses eligibility to
participate in Title IV programs when its cohort default rate exceeds
25 percent for 3 consecutive years or 40 percent in any one year. 34
C.F.R. § 668.187.
[18] The Air Force is the only service that does not require
membership of SOC for institutions located on its installations. This
is because the Air Force operates the Community College of the Air
Force (CCAF), which is a regionally accredited, 2-year college open to
Air Force enlisted on active duty, or enlisted in reserve or guard
services. As with the SOC program, credits toward a CCAF degree can be
accumulated through Air Force training and credit from examinations.
[19] All on-installation schools and installations are subject to a
MIVER review but may not be selected for one.
[20] Between 1994 and 2004, Air Force policy was to use MIVER at
overseas locations only. In 2005, the Air Force changed that policy
and began MIVER at stateside locations.
[21] The Marine Corps has a MIVER follow-up procedure, which involves
filing an action plan in response to MIVER findings and reviewing the
plan to determine if an additional MIVER site visit is necessary.
[22] The military services also had the option to request a MIVER
revisit. During a revisit, a MIVER team would return to the
installation to determine the extent to which the recommendations had
been implemented. The revisits usually occurred in cases where the
original MIVER visit resulted in many negative findings and
commensurate recommendations.
[23] The military services established call centers to handle issues
such as complaints related to the TA Program, according to DOD
officials.
[24] ICE is an online portal operated by DOD to collect feedback on
DOD products and services, including educational programming.
[25] According to a report by Education's Office of Inspector General,
an accrediting agency allowed a school to remain accredited even
though it had determined the school's credit hour policy was
"egregious and not in the best interest of the students."
[26] Accrediting agencies may also be challenged in their decisions to
revoke a school's accreditation, and legal proceedings may take a
number of years to be finalized.
[27] In order to be recognized by Education, accrediting agencies must
require an institution to obtain the agency's approval of a
substantive change, and have a definition of substantive change, which
includes such changes as any change in the established mission or
objectives of the institution; any change in the legal status, form of
control, or ownership of the institution; the addition of courses or
programs that represent a significant departure from the existing
offerings of educational programs, or method of delivery, from those
that were offered when the agency last evaluated the institution; or
the addition of programs of study at a degree or credential level
different from that which is included in the institution's current
accreditation or pre-accreditation.
[28] Voluntary Education Programs, 75 Fed. Reg. 47,508 (Aug. 6, 2010)
(to be codified at 32 C.F.R. pt. 68).
[29] A school on a military installation selected for a MIVER review
may be subject to questions MIVER has developed for distance education
providers, such as how to verify the identity of students enrolled in
online courses.
[30] 34 C.F.R. § 600.9(c), as added by final regulations published on
October 29, 2010, at 75 Fed. Reg. 66,832.
[End of section]
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