VA Student Financial Aid
Management Actions Needed to Reduce Overlap in Approving Education and Training Programs and to Assess State Approving Agencies Gao ID: GAO-07-384 March 8, 2007In fiscal year 2006, the Department of Veterans Affairs (VA) paid approximately $2.1 billion in education assistance benefits to more than 470,000 beneficiaries and about $19 million to state approving agencies (SAA) to assess whether schools and training programs offer education of sufficient quality for veterans to receive VA education assistance benefits when attending them. Qualified individuals--veterans, service persons, reservists, and certain spouses and dependents--receive benefits through a number of education assistance programs for the pursuit of various types of programs, such as a degree program, vocational program, apprenticeship, or on-the-job training. The Departments of Education (Education) and Labor (Labor) also assess education and training programs for various purposes, primarily for awarding student aid and providing apprenticeship assistance. In 2006, under Title IV of the Higher Education Act, Education provided nearly $77 billion in student aid in the form of both grants and loans. The Department of Education assesses and certifies postsecondary institutions for participation in Title IV programs through various oversight functions to ensure that these schools meet federal administrative and financial requirements and that they are accredited and licensed. Similarly, under the National Apprenticeship Act of 1937, the Department of Labor is authorized to formulate and promote the furtherance of labor standards to safeguard the welfare of apprentices. Given each agency's role, the potential of duplicative efforts among federal agencies has been a congressional concern. In 1995, GAO reported on this matter and concluded that there was a substantial amount of overlap between the efforts of SAAs and the other federal agencies. In light of continued congressional interest in this issue, we have now answered the following questions: (1) What changes have occurred in state approving agencies' duties and functions since 1995? (2) To what extent does the SAA approval process overlap with efforts by the Departments of Education and Labor? (3) What, if any, additional value do the SAA approval activities bring to VA education benefit programs?
Since 1995, legislative changes effective in 2001 created additional responsibilities for SAAs, including promoting the development of apprenticeship and on-the-job training programs, providing outreach services, and approving tests for occupational licensing. From fiscal years 2003 to 2006, SAA funding increased from $13 million to $19 million to expand services and support the additional responsibilities. However, funding is scheduled to decrease beginning in fiscal year 2008. Many education and training programs approved by SAAs have also been approved by Education or Labor, and VA and SAAs have taken few steps to coordinate approval activities with these agencies. In addition, information is not available to determine the amount of resources spent on SAA duties and functions, including those that may overlap with other agencies and programs. SAAs reportedly add value to the approval process for education and training programs through (1) a focus on student services for veterans and on the integrity of VA benefits, (2) more frequent on-site monitoring of education and training programs than provided by Education or Labor, and (3) assessments and approval of a small number of programs that are not reviewed by other agencies. However, VA's lack of outcome-oriented performance measures for evaluating SAAs makes it difficult to assess the significance of these efforts. In conclusion, while VA spends $19 million (less than 1 percent of the total benefit amount) to fund SAA duties and functions, it does not track the amount it spends on specific SAA activities, especially those that may also be performed by other agencies. Without knowing the amount of resources spent on specific duties and functions, VA does not have all relevant information for making resource allocation decisions and cannot determine if it is spending its federal dollars efficiently and effectively. While we have identified some overlap in approval efforts across agencies, the full extent of the overlap between SAA duties and other agencies' oversight efforts is unknown. It is important that VA work with other federal agencies to determine how the scope of the approval process could be streamlined to reduce overlap and ensure that federal dollars are spent efficiently. Finally, it is difficult to assess the effectiveness of SAA activities, in part because VA does not have outcome measures in place to fully evaluate SAA performance. Evaluating the effectiveness of VA's approval process is vitally important in order to manage the program and improve program results.
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: Team: Phone:GAO-07-384, VA Student Financial Aid: Management Actions Needed to Reduce Overlap in Approving Education and Training Programs and to Assess State Approving Agencies
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Report to the Ranking Minority Member, Committee on Veterans' Affairs,
U.S. Senate:
United States Government Accountability Office:
GAO:
March 2007:
VA Student Financial Aid:
Management Actions Needed to Reduce Overlap in Approving Education and
Training Programs and to Assess State Approving Agencies:
GAO-07-384:
Contents:
Letter:
Appendix I: Briefing Slides:
Appendix II: Comments from the Department of Veterans Affairs:
Appendix III: GAO Contact and Staff Acknowledgments:
Abbreviations:
Education: Department of Education:
IHL: institution of higher learning:
Labor: Department of Labor:
NASAA: National Association of State Approving Agencies:
OJT: on-the-job training:
RPO: regional processing office:
SAA: state approving agency:
SAC: state apprenticeship council:
VA: Department of Veterans Affairs:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
March 8, 2007:
The Honorable Larry E. Craig:
Ranking Minority Member:
Committee on Veterans' Affairs:
United States Senate:
Dear Senator Craig:
In fiscal year 2006, the Department of Veterans Affairs (VA) paid
approximately $2.1 billion in education assistance benefits to more
than 470,000 beneficiaries and about $19 million to state approving
agencies (SAA) to assess whether schools and training programs offer
education of sufficient quality for veterans to receive VA education
assistance benefits when attending them. Qualified individuals--
veterans, service persons, reservists, and certain spouses and
dependents--receive benefits through a number of education assistance
programs for the pursuit of various types of programs, such as a degree
program, vocational program, apprenticeship, or on-the-job training. In
general, these programs must be approved by an SAA in order for
qualified individuals to receive VA education assistance benefits.
Under contracts with the VA, SAAs ensure that education and training
programs meet federal VA standards through a variety of approval
activities, such as evaluating course quality, assessing school
financial stability, and monitoring student progress.
The Departments of Education (Education) and Labor (Labor) also assess
education and training programs for various purposes, primarily for
awarding student aid and providing apprenticeship assistance. These
assessments are based, in part, on evaluations against standards set by
laws and regulations, such as those applicable to accrediting agencies.
In 2006, under Title IV of the Higher Education Act, Education provided
nearly $77 billion in student aid in the form of both grants and loans.
The Department of Education assesses and certifies postsecondary
institutions for participation in Title IV programs through various
oversight functions to ensure that these schools meet federal
administrative and financial requirements and that they are accredited
and licensed. Similarly, under the National Apprenticeship Act of 1937,
the Department of Labor is authorized to formulate and promote the
furtherance of labor standards to safeguard the welfare of apprentices.
To ensure programs comply with federal standards, Labor directly
registers and oversees apprenticeship programs in less than half of the
states and has given state apprenticeship agencies or councils in the
remaining states such authority over their own programs.
Given each agency's role, the potential of duplicative efforts among
federal agencies has been a congressional concern. In 1995, GAO
reported on this matter and concluded that there was a substantial
amount of overlap between the efforts of SAAs and the other federal
agencies.[Footnote 1] In light of continued congressional interest in
this issue, we have now answered the following questions: (1) What
changes have occurred in state approving agencies' duties and functions
since 1995? (2) To what extent does the SAA approval process overlap
with efforts by the Departments of Education and Labor? (3) What, if
any, additional value do the SAA approval activities bring to VA
education benefit programs?
To address all three questions, we reviewed legislation, regulations,
federal guidance, and other documents relevant to the approval
processes for education and training programs. We also interviewed
officials from each of the entities involved in the approval processes
of VA, Education and Labor. Specifically, we interviewed federal
officials from VA, Education, and Labor as well as officials
representing three SAAs, three institutions of higher learning (IHL),
and state apprenticeship councils in Connecticut, Maryland, and
Washington. We also interviewed officials from one IHL that operates in
multiple states and officials from the National Association of State
Approving Agencies (NASAA), an accrediting agency (Accrediting
Commission of Career Schools and Colleges of Technology), the
Connecticut state licensing agency, and three apprenticeship programs
(in Connecticut, Illinois, and Maryland). We selected Connecticut,
Washington, Illinois, and Maryland based on VA's recommendation of
knowledgeable SAA officials, to include both state and federally
monitored states for apprenticeship programs, and geographic diversity.
To identify the programs that were approved by the Departments of
Veterans Affairs, Education, and Labor, we compiled and analyzed data
on approved programs from each of the three agencies. To assess the
reliability of the data, we talked with knowledgeable officials in each
of the agencies, reviewed relevant documentation, and performed
electronic testing of files. We determined that the data we have
included in this briefing were sufficiently reliable for this purpose.
We conducted our work from October 2006 to January 2007 in accordance
with generally accepted government auditing standards.
On February 1, 2007, we briefed your office on the results of our
analysis. This report formally conveys information provided during that
briefing, which is contained in appendix I. In summary, we reported the
following findings:
* Since 1995, legislative changes effective in 2001 created additional
responsibilities for SAAs, including promoting the development of
apprenticeship and on-the-job training programs, providing outreach
services, and approving tests for occupational licensing.[Footnote 2]
From fiscal years 2003 to 2006, SAA funding increased from $13 million
to $19 million to expand services and support the additional
responsibilities. However, funding is scheduled to decrease beginning
in fiscal year 2008.
* Many education and training programs approved by SAAs have also been
approved by Education or Labor, and VA and SAAs have taken few steps to
coordinate approval activities with these agencies. In addition,
information is not available to determine the amount of resources spent
on SAA duties and functions, including those that may overlap with
other agencies and programs.
* SAAs reportedly add value to the approval process for education and
training programs through (1) a focus on student services for veterans
and on the integrity of VA benefits, (2) more frequent on-site
monitoring of education and training programs than provided by
Education or Labor, and (3) assessments and approval of a small number
of programs that are not reviewed by other agencies. However, VA's lack
of outcome-oriented performance measures for evaluating SAAs makes it
difficult to assess the significance of these efforts.
In conclusion, while VA spends $19 million (less than 1 percent of the
total benefit amount) to fund SAA duties and functions, it does not
track the amount it spends on specific SAA activities, especially those
that may also be performed by other agencies. Without knowing the
amount of resources spent on specific duties and functions, VA does not
have all relevant information for making resource allocation decisions
and cannot determine if it is spending its federal dollars efficiently
and effectively. In addition, VA, Education, and Labor have various
standards and processes in place, in part to ensure that federal funds
are being spent on quality education and training programs. While we
have identified some overlap in approval efforts across agencies, the
full extent of the overlap between SAA duties and other agencies'
oversight efforts is unknown. It is important that VA work with other
federal agencies to determine how the scope of the approval process
could be streamlined to reduce overlap and ensure that federal dollars
are spent efficiently. Finally, it is difficult to assess the
effectiveness of SAA activities, in part because VA does not have
outcome measures in place to fully evaluate SAA performance. Evaluating
the effectiveness of VA's approval process is vitally important in
order to manage the program and improve program results.
To help ensure that federal dollars are spent efficiently and
effectively, we are recommending that the Secretary of the Department
of Veterans Affairs take steps to monitor SAA spending and identify
whether any resources are spent on activities that duplicate the
efforts of other agencies. The extent of these actions should be in
proportion to the total resources of the program. Specifically:
* VA should require SAAs to track and report data on resources spent on
approval activities such as site visits, catalog review, and outreach
in a cost-efficient manner; and:
* VA should collaborate with other agencies to identify any duplicative
efforts and use the agency's administrative and regulatory authority to
streamline the approval process.
In addition, we are recommending that the Secretary establish outcome-
oriented performance measures to assess the effectiveness of SAA
efforts.
We provided a draft of this report to officials of the U.S. Department
of Veterans Affairs for review and comment. In addition, we provided a
draft of this report to officials of the U.S. Departments of Education
and Labor for their technical review. In written comments on a draft of
this report, VA agreed with our findings and recommendations and stated
that it will (1) establish a working group with the SAAs to create a
reporting system to track and report data for approval activities with
a goal of implementation in fiscal year 2008, (2) initiate contact with
appropriate officials at the Departments of Education and Labor to
identify any duplicative efforts, and (3) establish a working group
with the SAAs to develop outcome-oriented performance measures with a
goal of implementation in fiscal year 2008. While VA stated that it
will initiate contact with officials at Education and Labor to identify
duplicative efforts, it also noted that amending its administrative and
regulatory authority to streamline the approval process may be
difficult due to specific approval requirements of the law. We
acknowledge these challenges and continue to believe that collaboration
with other federal agencies could help VA reduce duplicative efforts.
In addition, VA may wish to examine and propose legislative changes
needed to further streamline its approval process.
Labor provided technical comments and we incorporated them into this
report where appropriate.
We are sending copies of this report to relevant congressional
committees and other interested parties and will make copies available
to others upon request. In addition, this report will be available at
no charge on GAO's Web site at 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 that made major contributions to this report are
listed in appendix III.
Sincerely,
Signed by:
George A. Scott:
Acting Director:
Education, Workforce, and Income Security Issues:
[End of section]
Appendix I: Briefing Slides:
VA Student Financial Aid: Management Actions Needed to Reduce Overlap
in Approving Education and Training Programs and to Assess State
Approving Agencies:
Briefing for Staff of Senator Larry Craig, Ranking Member Committee on
Veterans' Affairs United States Senate:
February 01 , 2007:
Objectives:
Since the 1940's, the Department of Veterans Affairs (VA) and its
predecessor agencies have contracted with state approving agencies
(SAAs) to assess whether schools and training programs offer education
of sufficient quality for veterans to receive VA education assistance
benefits. SAAs are created or designated by state governments but are
federally funded and responsible for enforcing federal law. Concerns
have been raised about whether SAA approval activities are duplicative
of efforts conducted under other federal programs.
Key questions:
What changes have occurred in State Approving Agencies' duties and
functions since 1995.
To what extent does the SAA approval process overlap with efforts by
the Departments of Education and Labor?
What, if any, additional value do the SAA approval activities bring to
veterans' education benefit programs?
Scope and Methodology:
To address our key questions, we:
Reviewed legislation, regulations, federal guidance, and other
documents relevant to the approval processes for education and training
programs.
Compiled and analyzed data on approved programs from the Departments of
Veterans Affairs, Education, and Labor (DOL).
Interviewed federal officials from VA, Education, and DOL.
Interviewed officials representing 3 SAAs, 3 institutions of higher
learning (IHL), and state apprenticeship councils in Connecticut,
Maryland, and Washington. We also interviewed one IHL that operates in
multiple states.
Interviewed officials from the National Association of State Approving
Agencies (NASAA), an accrediting agency (Accrediting Commission of
Career Schools and Colleges of Technology), Connecticut state licensing
agency, and 3 apprenticeship programs (in Connecticut, Illinois,
Maryland).
Our work was performed from October 2006 to January 2007 in accordance
with generally accepted government auditing standards.
Summary of Findings:
Since 1995, legislative changes effective in 2001 created additional
responsibilities for SAAs, including promoting the development of
apprenticeship and on the job training programs, providing outreach
services, and approving tests for occupational licensing.
Many education and training programs approved by SAAs have also been
approved by Education or Labor and VA and SAAs have taken few steps to
coordinate approval activities with these agencies.
SAAs reportedly add value to the approval process for education and
training programs, but the lack of outcome-oriented performance
measures makes it difficult to assess the significance of their
efforts.
Background:
VA Funding for Educational Assistance Programs and SAAs:
In fiscal year 2006, VA provided over $2.1 billion in educational
assistance benefits to more than 470,000 beneficiaries.
In the same year, SAAs received $19 million to assess the quality of
schools and training programs for veterans.
Program*: Montgomery GI Bill (Chapter30);
Beneficiaries: 313,766;
Expenditures: $1,909,014,605.
Program*: Reserve Educational Assistance Program (Chapter 1607);
Beneficiaries: 23,747;
Expenditures: $151,397,610.
Program*: Educational Assistance for the Selected Reserve (Chapter
1606);
Beneficiaries: 65,145;
Expenditures: $48,716,031.
Program*: Dependents and Survivors Educational Assistance Program
(Chapter 35);
Beneficiaries: 74,532;
Expenditures: $38,787,332.
Program*: Veterans Educational Assistance Program (Chapter 32);
Beneficiaries: 575;
Expenditures: $59,113.
Total;
Beneficiaries: 477,765;
Expenditures: $2,147,974,691.
* No payments for the National Call to Service program were made in
fiscal year 2006.
Source: VA.
[End of table]
Background:
VA Educational Assistance Programs:
Benefits are designed to assist individuals in gaining access to
postsecondary education or training for a specific occupation. Benefits
can be used to pursue a degree program, vocational program,
apprenticeship and on-the-job training.
Qualified individuals include veterans, service persons, reservists,
and certain spouses and dependents.
Background: Veteran Enrollment by Program Type in Fiscal Year 2006:
[See PDF for image]
Source: GAO analysis of VA enrollment data.
[End of figure]
Background: Agencies Responsible for the Approval Process for Education
and Training Programs:
[See PDF for image]
Source: GAO Analysis.
[End of figure]
Background: VA's Approval Process: Purpose and Responsible Entities:
Purpose - To ensure education and training programs meet VA standards
for receipt of veteran education assistance benefits.
Entities, Roles and Responsibilities:
* VA national office oversees the 4 regional processing offices (RPOs)
and national contract with SAAs.
* RPOs administer the education assistance programs and process
benefits for veterans.
* SAAs review education and training programs to determine which
programs should be approved and ensure schools and training providers
are complying with VA standards.
- Duties and functions-SAAs have 6 core duties:1) Approval of programs,
2) Visits to facilities, 3) Technical assistance to individuals at
facilities, 4) Outreach, 5) Liaison with other service providers, and
6) Contract management.
- Structure - 60 SAAs exist in the 50 states, the District of Columbia,
and Puerto Rico. Eight states have two SAAs. SAAs are usually part of a
state's department of education (31 SAAs). In some states, SAAs are
organizationally located in other departments such as labor (9 SAAs) or
veterans' services (19 SAAs).*:
* The Washington, DC SAA office is overseen by VA.
Background: Education's Approval Process: Purpose and Responsible
Entities:
Purpose -To ensure schools meet federal Education standards to
participate in the student financial aid programs. As part of
Education's approval process, the state licensing agencies, accrediting
agencies, and certain offices within Education are responsible for
various approval activities.
Entities, Roles and Responsibilities:
* State licensing agencies grant legal authority to postsecondary
institutions to operate in the state in which they are located. Each of
the states has its own agency structure, and each state can choose its
own set of standards.
* Accrediting agencies develop evaluation criteria and conduct peer
evaluations to assess whether or not those criteria are met by
postsecondary institutions. Institutions and/or programs that meet an
agency's criteria are then "accredited" by that agency. As of November
2005, there are 60 recognized private accrediting agencies of regional
or national scope.
* Office of Postsecondary Education evaluates and recognizes
accrediting agencies based on federal requirements to ensure these
agencies are reliable authorities as to the quality of education or
training provided by the institutions of higher education and the
higher education programs they accredit.
* Office Federal Student Aid determines the administrative and
financial capacity of schools to participate in student financial aid
programs, conducts ongoing monitoring of participant schools, and
ensures participant schools are accredited and licensed by the states.
10:
Background: Labor's Approval Process: Purpose and Responsible Entities:
Purpose - To establish and promote labor standards to safeguard the
welfare of apprentices.
Entities, Roles and Responsibilities:
* Department of Labor establishes standards and registers programs that
meet the standards. Labor directly registers and oversees programs in
23 states but has granted 27 states, the District of Columbia, and 3
territories authority to register and oversee their own programs,
conducted by State Apprenticeship Councils (SACs). Labor reviews the
activities of the SACs.
* SACs ensure that apprenticeship programs for their respective states
comply with federal labor standards, equal opportunity protections, and
any additional state standards.
Objective One: Changes in SAA duties and functions:
Legislative Changes Effective in 2001 Created Additional
Responsibilities for SAAs, Including Promoting the Development of
Apprenticeship and On the Job Training Programs, Providing Outreach
Services, and Approving Tests for Occupational Licensing:
In 2001, SAAs received additional responsibility for:
Actively promoting the development of apprenticeship and on the job
training programs.
Conducting more outreach activities to eligible persons and veterans to
increase awareness of VA education assistance.
Approving tests used for licensing and certification, such as tests to
become a licensed electrician. (For those tests that have been
approved, veterans can use VA benefits to pay for testing fees.)
From fiscal years 2003 to 2006, SAA funding increased from $13 million
to $19 million to expand services and support the additional
responsibilities. Funding will begin to decrease in fiscal year 2008.
Objective Two: Overlap in Approval Efforts:
Many Education and Training Programs Approved by SAAs Have Also Been
Approved by Education or Labor and VA Has Taken Few Steps to Coordinate
Approval Activities with These Agencies.
Many education and training programs approved by SAAs have also been
approved by Education and Labor.
Similar categories of approval standards, such as student achievement
and institutional capacity (e.g. fiscal stability), exist across
agencies, but the specific standards within each category vary and the
full extent of the overlap is unknown.
VA and SAAs have made limited efforts to coordinate approval activities
with other federal agencies.
Information is not available to determine the amount of resources spent
on SAA duties and functions, including those that may overlap with
other agencies:
Many Education and Training Programs Approved by SAAs Have Also Been
Approved by Education And Labor:
69% of all programs approved by SAAs are offered by institutions that
have been certified by Education.
78% of SAA approved programs in institutions of higher learning (e.g.
colleges and universities) have been certified by Education.
64% of SAA approved non-college degree programs are in institutions
that have been certified by Education.
Less than 2% of all programs approved by SAAs are apprenticeship
programs. VA and SAA officials reported that many of these programs
have also been approved by Labor.
Similar Categories of Standards Exist Across Agencies, but the Specific
Standards within Each Category Vary and the Full Extent of Overlap is
Unknown:
Similar categories of standards exist across agencies.[1]
Categories of approval standards: Student achievement;
SAA[2,3]: IHL/NCD: X;
SAA[2,3]: IHL/NCD non-accredited: X;
SAA[2,3]: Apprenticeship: X;
SAA[2,3]: On the job Training: X;
Education[4]: Education's certification: [Empty];
Education[4]: Federal Standards for Accrediting Agencies: X;
Education[4]: Connecticut state licensing agency: X;
Labor: Apprenticeship: X.
Categories of approval standards: Curricula, program objectives, and
faculty;
SAA[2,3]: IHL/NCD: X;
SAA[2,3]: IHL/NCD non-accredited: X;
SAA[2,3]: Apprenticeship: X;
SAA[2,3]: On the job Training: X;
Education[4]: Education's certification: X;
Education[4]: Federal Standards for Accrediting Agencies: X;
Education[4]: Connecticut state licensing agency: X;
Labor: Apprenticeship: X.
Categories of approval standards: Facilities, equipment, and supplies;
SAA[2,3]: IHL/NCD: X;
SAA[2,3]: IHL/NCD non-accredited: X;
SAA[2,3]: Apprenticeship: X;
SAA[2,3]: On the job Training: X;
Education[4]: Education's certification: [Empty];
Education[4]: Federal Standards for Accrediting Agencies: X;
Education[4]: Connecticut state licensing agency: X;
Labor: Apprenticeship: X.
Categories of approval standards: Institutional objectives, capacity,
and administration;
SAA[2,3]: IHL/NCD: X;
SAA[2,3]: IHL/NCD non-accredited: X;
SAA[2,3]: Apprenticeship: [Empty];
SAA[2,3]: On the job Training: [Empty];
Education[4]: Education's certification: X;
Education[4]: Federal Standards for Accrediting Agencies: X;
Education[4]: Connecticut state licensing agency: X;
Labor: Apprenticeship: X.
Categories of approval standards: Student support services;
SAA[2,3]: IHL/NCD: [Empty];
SAA[2,3]: IHL/NCD non-accredited: [Empty];
SAA[2,3]: Apprenticeship: [Empty];
SAA[2,3]: On the job Training: [Empty];
Education[4]: Education's certification: [Empty];
Education[4]: Federal Standards for Accrediting Agencies: X;
Education[4]: Connecticut state licensing agency: X;
Labor: Apprenticeship: [Empty].
Categories of approval standards: Recruiting and admissions practices;
SAA[2,3]: IHL/NCD: X;
SAA[2,3]: IHL/NCD non-accredited: X;
SAA[2,3]: Apprenticeship: [Empty];
SAA[2,3]: On the job Training: [Empty];
Education[4]: Education's certification: X;
Education[4]: Federal Standards for Accrediting Agencies: X;
Education[4]: Connecticut state licensing agency: X;
Labor: Apprenticeship: X.
Categories of approval standards: Record of student complaints;
SAA[2,3]: IHL/NCD: [Empty];
SAA[2,3]: IHL/NCD non-accredited: [Empty];
SAA[2,3]: Apprenticeship: [Empty];
SAA[2,3]: On the job Training: [Empty];
Education[4]: Education's certification: [Empty];
Education[4]: Federal Standards for Accrediting Agencies: X;
Education[4]: Connecticut state licensing agency: [Empty];
Labor: Apprenticeship: X.
Categories of approval standards: Process related requirements (e.g.
application requirements);
SAA[2,3]: IHL/NCD: X;
SAA[2,3]: IHL/NCD non-accredited: X;
SAA[2,3]: Apprenticeship: X;
SAA[2,3]: On the job Training: X;
Education[4]: Education's certification: X;
Education[4]: Federal Standards for Accrediting Agencies: [Empty];
Education[4]: Connecticut state licensing agency: X;
Labor: Apprenticeship: X.
Source: GAO analysis of VA, Education, and Labor Standards:
Note: GAO constructed these categories to encompass the numerous and
broad range of standards used by agencies.
[1] SAA has different sets of standards for each program type (e.g. IHL
and NCD). Education's approval process involves different sets of
standards used by different entities, such as accrediting agencies.
Labor has one set of standards that is applicable to apprenticeship
programs.
[2] By statute, courses must meet certain criteria. These relate to:
(1) record-keeping of student progress; (2) record-keeping of students'
previous education; (3) quality, content and length of courses; (4)
qualifications of administrators and instructors; and (5) equipment,
space, and instructional materials. We categorized the first two
criteria as student achievement, criteria (3) and (4) as Curricula,
Program Objectives and Faculty, and criterion (5) as Institutional
objectives, capacity, and administration.
[3] SAA approval requirements for non-accredited courses encompass a
number of additional criteria, such as having a tuition refund policy
and enrollment limitations.
[4] Connecticut's standards may not be representative of standards
across the country.
[End of table]
Similar Categories of Standards Exist Across Agencies, but the Specific
Standards within Each Category Vary and the Full Extent of Overlap is
Unknown:
Specific standards within each category vary across agencies.
For example, while VA and Education's approval standards have
requirements for student achievement, the New England Association of
Schools and Colleges, an accrediting agency, requires that students
demonstrate competence in various areas such as writing and logical
thinking and VA does not have this requirement.
Also under student achievement, VA requires schools to give appropriate
credit for prior learning while Education does not have such a
requirement.
Similar Categories of Standards Exist Across Agencies, but the Specific
Standards within Each Category Vary and the Full Extent of Overlap is
Unknown:
While agencies have the same standards in some instances, the
interpretation and application of these standards may differ. For
examples:
VA, accrediting agencies, and Labor require that facilities have
adequate space, equipment and instructor personnel to provide quality
training, but the definition of adequacy differs in the level of
specificity.
VA and accrediting agencies require that schools have policies related
to student achievement such as minimum satisfactory grades, but the
requirement differs in the level of specificity.
VA and SAAs Have Made Limited Efforts to Coordinate Approval Activities
with Education and Labor:
VA reported that while it has coordinated with Education and Labor on
issues related to student financial aid and apprentices' skill
requirements, it believes increased coordination is needed for approval
activities in order to determine the extent of duplicative efforts.
Most of the SAA officials we spoke with reported that they have
coordinated with SACs to register apprenticeship programs in their
states.
Labor reported that it coordinated with VA's national office in several
instances including providing a list of registered apprenticeship
programs.
Education reported that it does not have formalized coordination with
VA but has had some contacts to inform VA of its concerns regarding
specific institutions.
Information Is Not Available to Determine the Amount of Resources Spent
on SAA Duties and Functions, Including Those That May Overlap with
Other Agencies:
VA does not require SAAs to collect information on the amount of
resources they spend on specific approval activities.
The SAA officials we spoke with said that their most time consuming
activity is conducting inspection and supervisory visits of schools and
training facilities.
Lack of data on resource allocation prevented us from determining what
portion of funds spent by SAAs were for approval activities that may
overlap with other agencies.
Objective Three: Value of SAA Services:
SAAs Reportedly Add Value to the Approval Process for Education and
Training Programs, but the Lack of Outcome-oriented Performance
Measures Makes it Difficult to Assess the Significance of Their
Efforts:
SAA and other officials reported that SAA activities add value because
they provide enhanced services to veterans and ensure program
integrity.
VA uses output measures rather than outcome-oriented performance
measures to evaluate SAA performance and progress.
SAA and other officials reported that SAA Activities Add Value Because
They Provide Services to Veterans and Ensure Program Integrity:
SAA and Other Officials Reported SAAs' added value includes:
A focus on student services for veterans and on VA benefits;
More frequent on-site monitoring of education and training programs
than Education and Labor; and:
Assessments and approval of a small number of programs that are not
reviewed by other agencies.
The SAA Approval Activities Focus on Student Services for Veterans and
on VA Benefits:
SAA approval activities:
Ensure that veterans are taking courses consistent with occupational
goals and program requirements.
Ensure that schools and training programs have evaluated prior learning
and work experience and grant credit as appropriate.
Ensure that school or program officials know how to complete paperwork
and comply with policies required by VA educational assistance through
technical assistance.
States, schools, and apprenticeship officials we spoke with reported
that without SAAs, the quality of education for veterans would not
change; however, their receipt of benefits could be delayed and the
time required to complete their education and training programs could
increase.
SAAs Generally Conduct More Frequent On-Site Monitoring of Education
and Training Programs Than Education and Labor:
Oversight of veterans assistance is generally more frequent than
oversight by Education and Labor, which may prevent fraud, waste, and
abuse.
Some officials reported that SAAs' frequent visits were beneficial
because they ensure schools properly certify veterans for benefits,
ensuring that benefits are distributed accurately and quickly.
Officials from one school reported that SAAs' visits were unnecessary
because many schools are sufficiently monitored by their accreditors
and Education.
Table:
Entity: SAA;
Frequency of site visits to each school: 1-3 years.
Entity: VA's RPO;
Frequency of site visits to each school: 3 years.
Entity: Education;
Frequency of site visits to each school: Only schools that have
performance issues are visited[1].
Entity: Accrediting agencies;
Frequency of site visits to each school: 2-10 years[2].
Entity: Labor;
Frequency of site visits to each school: 1-3+ years[3].
Source: GAO analysis.
[1] Education also performs ongoing monitoring by reviewing schools'
annual compliance audits and financial statements.
[2] Accrediting agencies' frequencies vary depending on whether the
agency is a national or regional agency.
[3] Labor -See Registered Apprenticeship Programs: Labor Can Better Use
Data to target Oversight, GAO-05-886 (Washington D.C: August 29,2005).
[End of table]
SAAs Approve a Small Number of Programs that Are Not Reviewed by Other
Agencies:
SAAs approve a small number of programs that are not reviewed by other
agencies:
Programs, such as cosmetology and massage training, offered by
unaccredited schools:
On-the-job-training programs:
Apprenticeship programs not approved by Labor:
VA Uses Output Measures Rather Than Outcome Measures to Evaluate SAA
Performance and Progress:
Although VA does have some output measures in place, such as the number
of supervisory visits SAAs conduct, it does not have outcome-oriented
performance measures to evaluate the overall effectiveness and progress
of SAAs.
Table:
Examples of Existing VA Output Measures: Percentage of visits to
facilities for supervisory and inspection purposes completed within VA
specified timeframes;
Examples of Potential Outcome Measures: Amount of benefit adjustments
resulting from SAA's review of school certification transactions.
Examples of Existing VA Output Measures: Number of times technical
assistance provided to interested parties such as individuals and
schools;
Examples of Potential Outcome Measures: Error rate of certification
transactions identified by SAA's.
Examples of Existing VA Output Measures: Number of approved facilities
with approved programs;
Examples of Potential Outcome Measures: Completion rates of
beneficiaries.
Source: GAO analysis.
[End of table]
Conclusions:
While VA spends $19 million (less than 1 % of total benefit amount) to
fund SAA duties and functions, it does not track the amount it spends
on specific SAA activities, especially those that may be performed by
other agencies. Without knowing the amount of resources spent on
specific duties and functions, VA does not have all relevant
information for making resource allocation decisions and cannot
determine if it is spending its federal dollars efficiently and
effectively.
VA, Education, and Labor have various standards and processes in place,
in part to ensure that federal funds are being spent on quality
education and training programs. While we have identified some overlap
in approval efforts across agencies, the full extent of the overlap
between SAA duties and other agencies' oversight efforts is unknown. It
is important that VA work with other federal agencies to determine how
the scope of the approval process could be streamlined, such as to
determine the extent to which SAAs could rely on recognized
accreditors' assessments of institutions' policies on student
achievement to reduce overlap and ensure that federal dollars are spent
efficiently.
It is difficult to assess the effectiveness of SAA activities, in part
because VA does not have outcome measures in place to fully evaluate
SAA performance, such as the outcomes of site visits. Under the
Government Performance Results Act, federal agencies must report on
their results in achieving their agency program goals. Outcome-oriented
performance measures are should be used to assess program activity.
Evaluating the effectiveness of VA's approval process is vitally
important in order to manage the program and improve program results.
Recommendations for Executive Action:
To help ensure that federal dollars are spent efficiently and
effectively, we are recommending that the Secretary of the Department
of Veterans Affairs take steps to monitor its spending and identify
whether any of its resources are spent on activities that duplicate the
efforts of other agencies. The extent of these actions should be in
proportion to the total resources of the program. Specifically:
VA should require SAAs to track and report data on resources spent on
approval activities such as site visits, catalog review, and outreach
in a cost-efficient manner.
VA should collaborate with other agencies to identify any duplicative
efforts and use the agency's administrative and regulatory authority to
streamline the approval process.
In addition, we are recommending that the Secretary establish outcome-
oriented performance measures to assess the effectiveness of SAA
efforts.
[End of section]
Appendix II: Comments from the Department of Veterans Affairs:
The Deputy Secretary Of Veterans Affairs:
Washington:
February 27, 2007:
Mr. George Scott:
Acting Director:
Education, Workforce, and Income Security Issues:
U. S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Scott:
The Department of Veterans Affairs (VA) has reviewed the Government
Accountability Office's (GAO) draft report, VA Student Financial Aid:
Management Actions Needed to Reduce Overlap in Approving Education and
Training Programs and to Assess State Approving Agencies (GAO-07-384).
VA agrees with your findings and concurs with your recommendations. The
enclosure details VA's actions to implement Government Accountability
Office's recommendations.
I appreciate the opportunity to comment on your draft report.
Sincerely Yours,
Signed by:
Gordon H. Mansfield:
Enclosure:
Department of Veterans Affairs (VA) Comments to the Government
Accountability Office (GAO) Draft Report, VA Student Financial Aid:
Management Actions Needed to Reduce Overlap in Approving Education and
Training Programs and to Assess State Approving Agencies (GAO-07-384):
To ensure that federal dollars are spent efficiently and effectively,
GAO recommends that the Secretary of the Department of Veterans Affairs
take steps to monitor its spending and identify whether any of its
resources are spent on activities that duplicate the efforts of other
agencies. The extent of these actions should be in proportion to the
total resources of the program. Specifically:
* VA should require SAAs to track and report data on resources spent on
approval activities, such as site visits, catalog review, and outreach
in a cost-efficient manner.
Concur - VA will establish a working group with the SAAs to create a
reporting system for approval activities with a goal of implementation
in the FY08 budget cycle.
* VA should collaborate with other agencies to identify any duplicate
efforts and use the agency's administrative and regulatory authority to
streamline the approval process.
Concur - VA will initiate contact with appropriate officials at the
Department of Education and Labor to identify any duplicative efforts.
However, amending the agency's administrative and regulatory authority
to streamline the approval process may be difficult due to the specific
approval requirements of the law.
* VA should establish outcome-oriented performance Measures to assess
the effectiveness of SAA efforts.
Concur - VA will establish a working group with the SAAs to develop
outcome-oriented measures with a goal of implementation in the FY08
budget cycle.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
George A. Scott (202) 512-7215 or scottg@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Heather McCallum Hahn,
Assistant Director, Tranchau T. Nguyen, Jacqueline Harpp, Cheri
Harrington, Richard Burkard, Susannah Compton, John Mingus, and Jim
Rebbe made key contributions to this report.
FOOTNOTES
[1] GAO, VA Student Financial Aid: Opportunity to Reduce Overlap in
Approving Education and Training Programs, GAO/HEHS-96-22 (Washington,
D.C.: Oct. 30, 1995).
[2] Veterans Benefits and Health Care Improvement Act of 2000, Pub. L.
No. 106-419 (2000); and Veterans Education and Benefits Expansion Act
of 2001, Pub. L. No. 107-103 (2001).
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