VA Education Benefits
Actions Taken, but Outreach and Oversight Could Be Improved Gao ID: GAO-11-256 February 28, 2011The U.S. Department of Veterans Affairs (VA) provided $9 billion in education benefits to service-members and veterans in fiscal year 2010, mostly through the new Post-9/11 GI Bill. In providing education benefits, VA relies on State Approving Agencies (SAA) to approve schools; and on schools to report students' enrollment status. GAO was asked to determine: (1) what is known about the effectiveness of outreach to and support for individuals applying for VA education benefits, particularly those with disabilities; (2) the role of school officials and challenges they face in their role; and (3) how VA monitors and oversees states' and schools' implementation of these benefits. GAO reviewed VA reports and plans, conducted a nationally representative survey of school officials, interviewed VA and state officials in four states, and reviewed recent statutory changes to the Post-9/11 GI Bill.
VA has various activities to reach out to and support individuals who are eligible for education benefits. For example, VA reaches eligible servicemembers through military separation briefings and has sponsored national marketing campaigns for the new Post-9/11 GI Bill. General awareness of VA education benefits among servicemembers and veterans is high, according to program stakeholders. In fiscal year 2010, more than 700,000 individuals were served by these programs. However, stakeholders also identified some limitations with VA's outreach and support. For instance, veterans' service organizations and school officials stated that some servicemembers and veterans may have difficulty determining which of VA's various programs may be right for them. In addition, VA primarily targets its outreach and support for its education benefits to the general population of servicemembers and veterans, not necessarily those with disabilities, because eligibility is based on length of military service and not disability status. Finally, little is known about the effectiveness of VA's outreach and support because VA has not established performance measures for these activities. School certifying officials' core responsibilities--primarily certifying student enrollment to VA and reporting enrollment changes--have become more complex under the Post-9/11 GI Bill, and officials identified challenges such as obtaining timely, comprehensive policy guidance and training from VA. For example, school officials must determine the tuition and fees that the Post-9/11 GI Bill will cover, which varies based on the length of active-duty military service and other factors. In our survey, school officials reported performing roles beyond those specifically required by VA, such as helping students apply for benefits. Although the majority of school officials were generally satisfied with VA's implementation of the Post-9/11 GI Bill, they cited a range of challenges, such as the lack of a Post-9/11 GI Bill policy manual. In addition, although VA provides training through conferences and its Web site, many officials did not participate due to other job responsibilities, travel costs, and lack of awareness about training opportunities. VA lacks comprehensive information on the effectiveness of its oversight of SAAs and schools. VA monitors SAAs, in part, by reviewing reports on the number of approved schools and completed site visits, but this approach has limitations. For example, VA has not set minimum standards for SAAs' reviews of student files during their site visits to schools and, therefore, lacks assurance that data collected from these file reviews are valid and comparable. Also, VA has not completed its own required school audits in recent years. Most recently, VA suspended its audits during fiscal year 2010 in order to reassign compliance staff to help process a backlog of Post-9/11 GI Bill claims. Although VA has resumed its audits, there are indications that it may not be able to complete all required audits in fiscal year 2011. Moreover, VA does not compile and review findings from its own or other entities' audits of schools that would, going forward, allow it to identify trends and better target its oversight of schools. GAO recommends that VA establish outcome-oriented performance measures for outreach and support activities; improve communication with school officials; and undertake a systematic review of its oversight of SAAs and schools. VA concurred with four recommendations and concurred in principle with one recommendation aimed at strengthening oversight. VA noted a number of actions already taken in this area. GAO encourages VA to address all aspects of this recommendation moving forward.
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: Daniel Bertoni Team: Government Accountability Office: Education, Workforce, and Income Security Phone: (202) 512-5988GAO-11-256, VA Education Benefits: Actions Taken, but Outreach and Oversight Could Be Improved
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United States Government Accountability Office:
GAO:
Report to the Ranking Member, Subcommittee on Military Personnel,
Committee on Armed Services, House of Representatives:
February 2011:
VA Education Benefits:
Actions Taken, but Outreach and Oversight Could Be Improved:
GAO-11-256:
GAO Highlights:
Highlights of GAO-11-256, a report to the Ranking Member, Subcommittee
on Military Personnel, Committee on Armed Services, House of
Representatives.
Why GAO Did This Study:
The U.S. Department of Veterans Affairs (VA) provided $9 billion in
education benefits to service-members and veterans in fiscal year
2010, mostly through the new Post-9/11 GI Bill. In providing education
benefits, VA relies on State Approving Agencies (SAA) to approve
schools; and on schools to report students‘ enrollment status. GAO was
asked to determine: (1) what is known about the effectiveness of
outreach to and support for individuals applying for VA education
benefits, particularly those with disabilities; (2) the role of school
officials and challenges they face in their role; and (3) how VA
monitors and oversees states‘ and schools‘ implementation of these
benefits. GAO reviewed VA reports and plans, conducted a nationally
representative survey of school officials, interviewed VA and state
officials in four states, and reviewed recent statutory changes to the
Post-9/11 GI Bill.
What GAO Found:
VA has various activities to reach out to and support individuals who
are eligible for education benefits. For example, VA reaches eligible
servicemembers through military separation briefings and has sponsored
national marketing campaigns for the new Post-9/11 GI Bill. General
awareness of VA education benefits among servicemembers and veterans
is high, according to program stakeholders. In fiscal year 2010, more
than 700,000 individuals were served by these programs. However,
stakeholders also identified some limitations with VA‘s outreach and
support. For instance, veterans‘ service organizations and school
officials stated that some servicemembers and veterans may have
difficulty determining which of VA‘s various programs may be right for
them. In addition, VA primarily targets its outreach and support for
its education benefits to the general population of servicemembers and
veterans, not necessarily those with disabilities, because eligibility
is based on length of military service and not disability status.
Finally, little is known about the effectiveness of VA‘s outreach and
support because VA has not established performance measures for these
activities.
School certifying officials‘ core responsibilities”-primarily
certifying student enrollment to VA and reporting enrollment changes”-
have become more complex under the Post-9/11 GI Bill, and officials
identified challenges such as obtaining timely, comprehensive policy
guidance and training from VA. For example, school officials must
determine the tuition and fees that the Post-9/11 GI Bill will cover,
which varies based on the length of active-duty military service and
other factors. In our survey, school officials reported performing
roles beyond those specifically required by VA, such as helping
students apply for benefits. Although the majority of school officials
were generally satisfied with VA‘s implementation of the Post-9/11 GI
Bill, they cited a range of challenges, such as the lack of a Post-
9/11 GI Bill policy manual. In addition, although VA provides training
through conferences and its Web site, many officials did not
participate due to other job responsibilities, travel costs, and lack
of awareness about training opportunities.
VA lacks comprehensive information on the effectiveness of its
oversight of SAAs and schools. VA monitors SAAs, in part, by reviewing
reports on the number of approved schools and completed site visits,
but this approach has limitations. For example, VA has not set minimum
standards for SAAs‘ reviews of student files during their site visits
to schools and, therefore, lacks assurance that data collected from
these file reviews are valid and comparable. Also, VA has not
completed its own required school audits in recent years. Most
recently, VA suspended its audits during fiscal year 2010 in order to
reassign compliance staff to help process a backlog of Post-9/11 GI
Bill claims. Although VA has resumed its audits, there are indications
that it may not be able to complete all required audits in fiscal year
2011. Moreover, VA does not compile and review findings from its own
or other entities‘ audits of schools that would, going forward, allow
it to identify trends and better target its oversight of schools.
What GAO Recommends:
GAO recommends that VA establish outcome-oriented performance measures
for outreach and support activities; improve communication with school
officials; and undertake a systematic review of its oversight of SAAs
and schools. VA concurred with four recommendations and concurred in
principle with one recommendation aimed at strengthening oversight. VA
noted a number of actions already taken in this area. GAO encourages
VA to address all aspects of this recommendation moving forward.
View [hyperlink, http://www.gao.gov/products/GAO-11-256] or key
components. For more information, contact Daniel Bertoni at (202) 512-
7215 or bertonid@gao.gov.
[End of section]
Contents:
Letter:
Background:
VA Maintains Outreach and Support Activities but Does Not Assess Their
Effectiveness:
School Certifying Officials' Roles Have Become More Complex and
Challenging:
VA Lacks Comprehensive Information on the Effectiveness of Its
Oversight of States and Schools:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Overview of Post-9/11 Veterans Educational Assistance
Improvements Act of 2010:
Appendix III: Comparison of VA Education Benefit Programs:
Appendix IV: Comments from the U.S. Department of Veterans Affairs:
Appendix V: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Percentage of Maximum Post-9/11 GI Bill Benefits Based on
Length of Active-Duty Service:
Table 2: VA Activities to Reach and Support Servicemembers and
Veterans Applying for Education Benefits:
Table 3: School Certifying Officials' Required Responsibilities before
and after the Post-9/11 GI Bill:
Table 4: VA Oversight Activities for SAAs:
Table 5: Comparison of SAA Site Visits and VA Audits of Schools:
Table 6: Summary of the Number of SAA Supervisory Visit and VA
Compliance Survey Reports at Selected Schools in Four States:
Figures:
Figure 1: Types of Payments under the Post-9/11 GI Bill in Comparison
to VA's Other Education Benefit Programs:
Figure 2: Responsibilities of VA, SAAs, and Schools in Administering
Education Benefits:
Figure 3: Aspects of the Post-9/11 GI Bill Where Servicemembers and
Veterans Have a Moderate to Very Great Need for More Information,
according to School Certifying Officials:
Figure 4: VA's Education Call Center Monthly Performance Data, August
2009 - September 2010:
Figure 5: VA's Performance Goals, Objectives, and Measures Related to
Outreach to and Support for Individuals Applying for Education
Benefits:
Figure 6: School Certifying Officials' Reported Responsibilities for
VA Education Benefit Programs:
Figure 7: School Certifying Officials' Reported Challenges in
Fulfilling Responsibilities for the Post-9/11 GI Bill Program:
Figure 8: Aspects of the Post-9/11 GI Bill Where School Certifying
Officials Reported That More Information Would Be Helpful:
Figure 9: Percentage of Planned VA Audits Conducted, by State, in
Fiscal Year 2009:
Abbreviations:
DTAP: Disabled Transition Assistance Program:
Education: U.S. Department of Education:
MGIB-AD: Montgomery GI Bill-Active Duty:
MGIB-SR: Montgomery GI Bill-Selected Reserve:
NCES: National Center for Education Statistics:
Post-9/11 GI Bill: Post-9/11 Veterans Educational Assistance Act of
2008:
REAP: Reserve Educational Assistance Program:
SAA: State Approving Agency:
TAP: Transition Assistance Program:
VA: U.S. Department of Veterans Affairs:
VR&E: Vocational Rehabilitation and Employment:
WEAMS: Web Enabled Approval Management System:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
February 28, 2011:
The Honorable Susan A. Davis:
Ranking Member:
Subcommittee on Military Personnel:
Committee on Armed Services:
House of Representatives:
Dear Ms. Davis:
The U.S. Department of Veterans Affairs (VA) provided more than $9
billion in education benefits to help more than 700,000 servicemembers
and veterans pursue higher education or training in fiscal year 2010.
[Footnote 1] A significant portion of those funds were distributed
through the Post-9/11 Veterans Educational Assistance Act of 2008
(Post-9/11 GI Bill),[Footnote 2] which began offering benefits in
August 2009 and increased education benefits for many individuals who
served on active duty after September 10, 2001. The Post-9/11 GI Bill
program added complexity to VA's education claims process because the
benefits are highly individualized and based on factors such as length
of service and the location of the school a servicemember or veteran
is attending. The claims process also requires accurate and timely
information from state agencies, known as State Approving Agencies
(SAA), and institutions of higher learning (schools).[Footnote 3] In
the first semester that Post-9/11 GI Bill benefits were available,
servicemembers and veterans filed hundreds of thousands of claims, and
VA faced challenges processing these and its other education claims in
a timely manner. In December 2009, for example, VA reported it took an
average of 60 days to process an education claim, compared to its
target of 24 days.
VA currently has four active education benefit programs for
servicemembers and veterans, and individuals may be eligible for more
than one of these programs.[Footnote 4] Some have raised questions
about whether individuals fully understand the range of benefit
options and whether they need assistance in determining the program
that best fits their needs. Moreover, servicemembers and veterans with
disabilities, such as those with post-traumatic stress disorder and
traumatic brain injury, may have greater difficulty understanding and
applying for VA education benefits. Individuals with disabilities also
can receive education benefits under VA's Vocational Rehabilitation
and Employment (VR&E) program.[Footnote 5] However, if they elect to
receive Post-9/11 GI Bill benefits, they are ineligible for the case
management, individualized counseling support, and other benefits that
the VR&E program offers.
To obtain information on VA's implementation of these education
benefit programs, you asked us to examine (1) what is known about the
effectiveness of VA's outreach to and support for individuals applying
for education benefits, particularly for servicemembers and veterans
with disabilities, such as post-traumatic stress disorder and
traumatic brain injury; (2) the role of school officials and the
challenges they face in fulfilling their responsibilities for VA's
education benefit programs; and (3) how VA monitors and oversees
states' and schools' implementation of its education benefit programs.
While our scope included VA's four active education benefit programs,
we had a particular focus on the Post-9/11 GI Bill, as it is the
newest and most complex.
To address these objectives, we reviewed relevant federal laws,
regulations, and other agency documents and conducted interviews with
VA officials and key program stakeholders, including veterans service
organizations and national organizations representing SAAs and school
officials. For our first objective, we assessed VA's performance
objectives and measures related to outreach and support for
servicemembers and veterans against requirements of the Government
Performance and Results Act of 1993,[Footnote 6] and key attributes
for performance measures we developed in prior work.[Footnote 7] We
also conducted two discussion groups with VA education beneficiaries
enrolled in schools in Oklahoma and Virginia.[Footnote 8] For our
second objective, we conducted a nationally representative web-based
survey of school certifying officials--school employees who are
responsible for verifying student enrollment for VA--in the 50 states
and the District of Columbia. We drew a simple random sample of 273
certifying officials from VA's public Web Enabled Approval Management
System (WEAMS) database of 6,403 active facilities,[Footnote 9] as of
August 2010. We received a response rate of 71 percent.[Footnote 10]
We assessed VA's coordination with these officials using government
internal control standards for coordinating with external parties that
have a significant impact on agency goals. For our third objective, we
reviewed VA reports and data that offered a national perspective on
VA's monitoring and oversight of SAAs and schools. We also examined
VA's oversight activities in four states: California, Georgia,
Kentucky, and Massachusetts. We selected these states--one in each of
VA's four regions for processing education benefits--for reasons such
as variation in the number of schools and students within a state that
have been approved to participate in VA education benefit programs and
program expenditures. In these states, we interviewed relevant VA and
state officials and reviewed the most recent audit and site visit
reports from VA and SAAs for randomly selected schools.[Footnote 11]
We compared VA's policies and procedures to government internal
control standards.[Footnote 12] We assessed the reliability of VA's
data on its toll-free hotline performance measures and active
facilities by reviewing existing information about the data and the
systems that produced them and interviewing knowledgeable agency
officials. We determined that the data on performance measures were
sufficiently reliable for the purposes of this report. We determined
that the data on active facilities were not sufficiently reliable for
our purposes, primarily due to missing data on school certifying
officials, and we conducted additional work--including performing
Internet searches and making telephone calls to schools to gather
contact information for school certifying officials--to overcome this
limitation. See appendix I for a more detailed description of our
objectives, scope, and methodology.
We conducted this performance audit from February 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.
Background:
On June 30, 2008, the Post-9/11 Veterans Educational Assistance Act of
2008, which established the new Post-9/11 GI Bill program, was signed
by the President. The Post-9/11 GI Bill program adopted a new way for
VA to deliver education benefits. Whereas VA's other education benefit
programs provide a single, standard monthly payment directly to
students enrolled in school, the Post-9/11 GI Bill requires VA to send
multiple payments to both students and schools (see figure 1).
Figure 1: Types of Payments under the Post-9/11 GI Bill in Comparison
to VA's Other Education Benefit Programs:
[Refer to PDF for image: illustration]
Post-9/11 GI Bill Program: to VA Education Beneficiaries;
* Monthly housing allowance;
* Books and supplies stipend (up to $1,000 a year):
* Rural relocation payment[A]
Post-9/11 GI Bill Program: to schools;
* Tuition and fees:
* Yellow Ribbon payment[B].
Other VA Education Benefit Programs (e.g., Montgomery GI Bill, Reserve
Educational Assistance Program): to VA Education Beneficiaries;
* Monthly stipend (i.e., one payment for subsistence, tuition and
fees, supplies, books, and equipment).
Source: GAO analysis of VA documents.
[A] VA provides a rural relocation payment to individuals who reside
in a rural county and must relocate a distance of at least 500 miles,
or an individual who must travel by air to attend school. 38 U.S.C. §
3318. These individuals are entitled to a single payment of up to $500.
[B] Through the Yellow Ribbon G.I. Education Enhancement Program,
which is part of the Post-9/11 GI Bill, schools enter into agreements
with VA to pay a portion of the tuition and fees that exceed an
individual's Post-9/11 GI Bill benefit. 38 U.S.C. § 3317. VA matches
the schools' contribution. In order to be eligible for the Yellow
Ribbon program, individuals must be eligible for the maximum Post-9/11
GI Bill benefit. That is, after September 10, 2001, they generally
must have 36 months of active-duty service or 30 continuous days of
active-duty service and discharged from active duty for a service-
connected disability. 38 U.S.C. §§ 3311(b)(1) and (2), 3313(c)(1), and
3317(a).
[End of figure]
Post-9/11 GI Bill benefits are based, in part, on an individual's
length of active-duty service.[Footnote 13] In order to be eligible
for the Post-9/11 GI Bill, individuals generally must have served at
least 90 days on active duty after September 10, 2001. However, in
order to be eligible for the maximum benefits payable, individuals
must have at least 36 months of aggregate active-duty service (see
table 1). Those with less than 36 months of service receive a
percentage of the maximum benefit payable. For example, if a veteran
had 25 months of active-duty service, he or she would be eligible for
80 percent of the maximum allowable tuition and fee, housing, and book
payments. In addition, in order to be eligible for the housing
allowance, individuals must be enrolled in school more than half-time
and taking at least one course on campus.[Footnote 14] Active-duty
servicemembers are not eligible for the housing allowance or the books
and supplies stipend.[Footnote 15]
Table 1: Percentage of Maximum Post-9/11 GI Bill Benefits Based on
Length of Active-Duty Service:
Length of aggregate active-duty service after September 10, 2001: At
least 36 months or at least 30 continuous days on active duty and
discharged with service-connected disability;
Percentage of maximum benefit payable: 100%.
Length of aggregate active-duty service after September 10, 2001: At
least 30 but less than 36 months;
Percentage of maximum benefit payable: 90%.
Length of aggregate active-duty service after September 10, 2001: At
least 24 but less than 30 months;
Percentage of maximum benefit payable: 80%.
Length of aggregate active-duty service after September 10, 2001: At
least 18 but less than 24 months;
Percentage of maximum benefit payable: 70%.
Length of aggregate active-duty service after September 10, 2001: At
least 12 but less than 18 months;
Percentage of maximum benefit payable: 60%.
Length of aggregate active-duty service after September 10, 2001: At
least 6 but less than 12 months;
Percentage of maximum benefit payable: 50%.
Length of aggregate active-duty service after September 10, 2001: At
least 90 days but less than 6 months;
Percentage of maximum benefit payable: 40%.
Source: 38 U.S.C. §§ 3311 and 3313.
[End of table]
The Post-9/11 GI Bill covers up to the full cost of tuition and fees
for a program of education at any public school. However, these costs
cannot exceed the highest undergraduate tuition and fee rates charged
to in-state residents by public schools in each state.[Footnote 16]
The maximum tuition and fee rates, calculated separately for each
state by its SAA, vary widely. Among states, the highest tuition rate
for the 2010-2011 school year is $1,549 per credit hour in Texas,
while the lowest is $99 per credit hour in Wyoming. The highest fee
rate is $85,255[Footnote 17] per term in Utah, while the lowest is
$310 in Washington, D.C. Veterans attending private schools or
graduate programs may receive additional benefits to cover costs that
exceed this amount, through VA's Yellow Ribbon program.[Footnote 18]
Whereas the Post-9/11 GI Bill covers only education or training
programs offered by institutions of higher learning, servicemembers
and veterans can use VA's other education benefits to obtain education
or training offered through non-college degree, certificate, on-the-
job training, apprenticeship programs, flight, and other programs.
[Footnote 19]
In addition to the Post-9/11 GI Bill, VA has three other education
benefit programs for servicemembers and veterans (see appendix III for
a description of these programs):
* Montgomery GI Bill-Active Duty;[Footnote 20]
* Montgomery GI Bill-Selected Reserve;[Footnote 21] and:
* Reserve Educational Assistance Program.[Footnote 22]
Eligible individuals can receive up to 36 months of benefits under any
one of VA's education programs.[Footnote 23] However, one difference
between the programs is that individuals under the Post-9/11 GI Bill
have up to 15 years after they separate from the military to use the
benefit.[Footnote 24] VA's other education programs generally have a
10-year window to use benefits.[Footnote 25] The Post-9/11 GI Bill
also uniquely allows eligible servicemembers to transfer their
benefits to a spouse or dependents.[Footnote 26] In order to do so,
servicemembers generally must commit an additional 4 years of military
service.[Footnote 27] Post-9/11 GI Bill benefits cannot be transferred
to a dependent after separation from the military. Finally, in order
to receive benefits under the Post-9/11 GI Bill, eligible individuals
must make what is called an "irrevocable election" and relinquish
their entitlement to any other VA education benefits.
On January 4, 2011, the president signed the Post-9/11 Veterans
Educational Assistance Improvements Act of 2010, which revises the
Post-9/11 GI Bill program.[Footnote 28] For example, the law expands
the Post-9/11 GI Bill to cover non-degree granting programs,
apprenticeships or other on-the-job training programs, flight training
programs, and training by correspondence. The law also simplifies
tuition and fee benefits by eliminating the state maximum tuition and
fee rates and capping benefits at all private and foreign schools at
$17,500 per year. In addition, the law allows individuals enrolled
exclusively online to receive a portion of the housing allowance, but
also calculates the housing allowance for all beneficiaries based on
their rate of pursuit (that is, the percentage of a full-time course
load). Many of these provisions are scheduled to take effect in the
early fall of 2011. See appendix II for our overview of these changes.
Vocational Rehabilitation and Employment Benefits for Servicemembers
and Veterans with Disabilities:
Nearly 2 million servicemembers and veterans have served in military
operations in either Afghanistan or Iraq since 2001, and some of these
individuals may have disabilities incurred or aggravated due to their
military service. In particular, post-traumatic stress disorder and
traumatic brain injury are considered to be signature disabilities of
these recent conflicts. Post-traumatic stress disorder can develop
after military combat and exposure to the threat of death or serious
injury.[Footnote 29] Traumatic brain injury--an injury resulting from
a blow or jolt to the head or a penetrating head injury that disrupts
the normal function of the brain--is one of the most common wounds of
the current military operations in Afghanistan and Iraq. The nature of
these conflicts, especially the widespread use of improvised explosive
devices, increases the likelihood that servicemembers will be exposed
to incidents that can cause a traumatic brain injury.
We have previously found that veterans with disabilities are an
emerging population in higher education, in part due to the enactment
of the Post-9/11 GI Bill. While some servicemembers and veterans with
disabilities may be attending school using the Post-9/11 GI Bill or
other VA education benefits, others may choose to attend school using
benefits through VA's Vocational Rehabilitation and Employment (VR&E)
program.[Footnote 30] The focus of VR&E is to provide employment for
veterans with disabilities, and we have reported in the past that the
majority of program participants chose to pursue employment through
longer-term education and training, instead of more immediate
employment through VR&E's job placement or other services.[Footnote
31] The benefits that VR&E participants receive are similar to those
offered by the Post-9/11 GI Bill, but there are some key differences.
For example, while both programs offer an allowance for living or
housing expenses, the Post-9/11 GI Bill allowance may be more
generous, depending on where an individual is attending school and
other factors. On the other hand, while the Post-9/11 GI Bill pays
tuition and fees up to a certain rate, the VR&E program pays full
tuition, fees, books, supplies, and other expenses for educational
programs, including those at private schools. If individuals elect to
receive Post-9/11 GI Bill benefits, they are ineligible for the case
management, individualized counseling support, and other benefits that
the VR&E program offers.[Footnote 32]
Implementation of VA Education Benefit Programs by VA, States, and
Schools:
Within VA's Veterans Benefits Administration, the Education Service
division provides policy and program guidance for VA's education
benefit programs. Staff in VA's four regional processing offices
implement the programs, including making benefit decisions and
conducting oversight of schools.
State agencies and schools play key roles in helping implement VA's
education benefit programs (see figure 2). Specifically, VA contracts
with SAAs to determine whether schools and training programs offer
education of sufficient quality. SAAs review and approve individual
education and training programs at schools leading to a degree,
certificate, or diploma.[Footnote 33] SAAs are created or designated
by the governor of each state and staffed by state employees but are
federally funded and responsible for approving and supervising those
programs consistent with federal requirements.[Footnote 34] While SAAs
are responsible for approving programs at schools for VA education
benefits, other government agencies also oversee schools, such as the
U.S. Department of Education (Education) for the purposes of federal
student financial aid under Title IV of the Higher Education Act of
1965, as amended.[Footnote 35] In addition, schools may be licensed by
states and approved by regional and national accrediting agencies.
School employees, known as school certifying officials, are required
to certify students' enrollment status to VA and inform the agency of
any changes during the semester, maintain students' files, and make
them available for inspection by VA and the SAA, among other
responsibilities. All schools approved to receive VA's education
benefits must have a school certifying official. VA pays schools $7
annually for each student receiving these benefits to help defray the
costs associated with fulfilling reporting requirements.[Footnote 36]
Figure 2: Responsibilities of VA, SAAs, and Schools in Administering
Education Benefits:
[Refer to PDF for image: illustration]
Veteran:
* Applies for VA educational benefits;
* Selects and enrolls in an approved program.
VA:
* Pays some benefits to veteran;
* Pays some benefits directly to school;
* Conducts oversight of schools with compliance surveys;
* Oversees activity of SAAs.
SAA:
* Conducts oversight with supervisory visits;
* Reviews and approves schools and programs.
Schools:
* Certifies student enrollment, maintains student files, and sends
regular updates on any status changes to VA.
Source: GAO analysis of VA documents.
[End of figure]
VA Maintains Outreach and Support Activities but Does Not Assess Their
Effectiveness:
VA Has Various Activities to Reach Out to and Support Servicemembers
and Veterans:
VA has a variety of activities to reach out to and support
servicemembers and veterans who may be eligible for education
benefits. VA reaches out to eligible servicemembers by providing
information at Transition Assistance Program (TAP) briefings offered
at the time they separate from the military and has sponsored
marketing campaigns for the new Post-9/11 GI Bill. VA's fiscal year
2010 campaign featured advertisements on Web sites like [hyperlink,
http://www.military.com], and magazines, such as Marine Corps Times,
in addition to placing the Post-9/11 GI Bill logo and Web address on a
NASCAR racecar.
VA provides support during the process of applying for education
benefits by posting information on its Web site and through social
media channels like Facebook, answering questions by phone and e-mail,
and offering free educational and vocational counseling. For example,
VA staff at the toll-free hotline, known as the Education Call Center,
answer individuals' questions about benefits and can provide
information on the status of their claims. VA's Web-based Right Now
Web service provides similar services via secure e-mail. Educational
and vocational counseling is provided by VA's VR&E program in VA's
regional offices and is available to individuals who are eligible for
VA education benefits, regardless of disability status. This
counseling, which may include assessments of individuals' interests
and aptitudes, is designed to help individuals select a career path
and address any barriers to reaching educational or vocational goals.
A senior VA official told us that the counseling does not typically
include helping individuals determine which VA education benefit
program to choose, if they are eligible for more than one. See table 2
for a summary of VA's current outreach and support activities for
servicemembers and veterans who are eligible for education benefits.
VA also is planning to provide students with the ability to check the
status of their education claim online and perform other self-service
functions.[Footnote 37]
Table 2: VA Activities to Reach and Support Servicemembers and
Veterans Applying for Education Benefits:
Outreach activities:
* Letters to servicemembers during the first 2 years of military
service and upon separation;
* TAP briefings for active duty servicemembers at the time they
separate and retire from the military;
* National, regional, and local events for servicemembers and veterans;
* Advertising campaigns for the Post-9/11 GI Bill.
Support during the application process:
* VA's GI Bill Web site and social media portals like Facebook,
Twitter, and YouTube;
* Telephone hotline for VA education benefits
* Right Now Web service;
* Educational and vocational counseling for individuals eligible for
VA education benefits;
* Pamphlets and materials on VA education benefits.
Source: GAO analysis of VA documents and information obtained through
interviews with agency officials.
[End of table]
Program stakeholders--veterans service organizations, school
officials, and students receiving VA education benefits--told us that
VA has taken steps to enhance its outreach and support. For example,
officials from veterans' organizations and school officials said that
VA's new social media presence and marketing campaigns have helped
reach younger servicemembers and veterans. In addition, stakeholders
had positive feedback for a recent redesign of the GI Bill Web site
that highlighted the three main steps in applying for Post-9/11 GI
Bill benefits.
Program Stakeholders Identified Some Limitations in VA's Outreach and
Support:
While program stakeholders told us that general awareness of VA
education benefits among servicemembers and veterans was high, they
also identified some limitations. For example, officials from
veterans' organizations told us that some individuals may have
difficulty determining which VA education program may be right for
them. Similarly, VA does not provide consumer information on various
schools and programs, such as graduation rates or loan default rates,
nor does it provide links on the GI Bill Web site to consumer-focused
information generated by other entities. In contrast, Education's
College Navigator Web site, launched in September 2007, aggregates
information on student outcomes, including graduation and retention
rates, loan default rates, as well as information on the costs of
attendance and available scholarships.
Likewise, based on our survey, an estimated 74 percent of school
certifying officials reported that servicemembers and veterans need
more information on issues such as the impact of transferring from an
existing VA education benefit program into the Post-9/11 GI Bill (see
figure 3).[Footnote 38] School certifying officials and a veterans
service organization official told us that making an informed choice
is particularly important because the decision to use benefits under
the Post-9/11 GI Bill is irrevocable. For instance, these
stakeholders, as well as VA officials, told us that some students have
transferred from the Montgomery GI Bill to the Post-9/11 GI Bill and,
after doing so, realized that they would have had more months to use
their benefits under the Montgomery GI Bill.
Figure 3: Aspects of the Post-9/11 GI Bill Where Servicemembers and
Veterans Have a Moderate to Very Great Need for More Information,
according to School Certifying Officials:
[Refer to PDF for image: horizontal bar graph]
How to compare benefits between Post-9/11 GI Bill and other VA
education benefits:
Moderate need for more information: 16.4%;
Great to very great need for more information: 70.8%.
How to estimate benefit amount:
Moderate need for more information: 21.1%;
Great to very great need for more information: 66%.
Financial impact of dropping or adding classes:
Moderate need for more information: 13.5%;
Great to very great need for more information: 73.4%.
Impact of transferring entitlement from one VA education benefit
program into the Post-9/11 GI Bill:
Moderate need for more information: 13.1%;
Great to very great need for more information: 73.8%.
Definitions of VA education benefit terminology:
Moderate need for more information: 25.6%;
Great to very great need for more information: 60.5%.
VA policy on deducting overpayments from future benefits:
Moderate need for more information: 10.4%;
Great to very great need for more information: 74.5%.
Impact of Post-9/11 GI Bill on other assistance:
Moderate need for more information: 14.5%;
Great to very great need for more information: 69.4%.
The requirement to make an ’irrevocable election“ for the Post-9/11 GI
Bill:
Moderate need for more information: 17.7%;
Great to very great need for more information: 66.1%.
Requirements for receiving housing allowance:
Moderate need for more information: 20%;
Great to very great need for more information: 58.9%.
How to communicate with VA Debt Management Center:
Moderate need for more information: 14%;
Great to very great need for more information: 63.7%.
Financial impact of mid-year school tuition increases:
Moderate need for more information: 26.4%;
Great to very great need for more information: 36.3%.
Source: GAO survey of school certifying officials.
Note: All estimates in this figure have 95 percent confidence
intervals of plus or minus 6.9 percentage points or less.
[End of figure]
Several veterans service organization officials, students, and school
officials also told us that TAP briefings are offered at a time when
separating servicemembers may not be ready to hear about their
education benefits. While some students we interviewed said the
briefings were helpful, others told us that the slide presentation
format was not effective and often provided too much information for
them to readily digest. We reviewed the May 2010 version of the
presentation, and about a third of the 247 slides in the presentation
were dedicated to education benefits. VA is in the process of
redesigning TAP to make its presentation shorter and more effective in
holding participants' attention.
Stakeholders also told us that servicemembers and veterans had
difficulty getting through to VA staff at the toll-free hotline.
Several of the students we interviewed said they waited a long time or
had to call several times before speaking to a call center agent.
Officials from a national association of school certifying officials,
as well as nine officials in open-ended responses to our survey, also
expressed concerns with long wait times. In addition, an official from
this national association and 14 school officials in our survey also
questioned the accuracy or consistency of information call center
agents provide to students and schools. Our analysis of VA's toll-free
hotline performance data from August 2009--the first month Post-9/11
GI Bill benefits were available--through the end of fiscal year 2010
showed that the average wait times for each month ranged from about 3
to 8 minutes. In addition, a high percentage of calls were blocked
(received a busy signal) or abandoned (caller hung up before reaching
a call center agent) during peak periods (see figure 4). We found that
the percentage of blocked calls was higher in months with high call
volume--notably, in the months around the fall and spring enrollment
periods. For example, in September 2010, there were 1.3 million calls
placed to VA's toll-free hotline during business hours. Sixty-three
percent of these calls were blocked, well in excess of VA's
performance target of 12 percent.
To address high blocked-call rates, a VA official told us that the
call center is planning to switch to a new phone system in fiscal year
2011 that has the capacity to handle more calls and offers more
options, such as the ability for a caller to request an automated call-
back from the system when he or she reaches the top of the queue. In
addition, VA is beginning to track the average speed to answer
calls,[Footnote 39] as well as the proportion of abandoned calls that
were terminated by the caller within 160 seconds, as the agency
believes these calls were abandoned for reasons that were outside of
the call center's control.
Figure 4: VA's Education Call Center Monthly Performance Data, August
2009 - September 2010:
[Refer to PDF for image: multiple line graph]
Abandoned goal (caller hung up before reaching agent): 7% maximum;
Blocked goal (caller received a busy signal): 12% maximum.
August 2009:
Abandoned calls: 20%;
Blocked calls: 62%.
September 2009:
Abandoned calls: 19%;
Blocked calls: 77%.
October 2009:
Abandoned calls: 23%;
Blocked calls: 77%.
November 2009:
Abandoned calls: 35%;
Blocked calls: 84%.
December 2009:
Abandoned calls: 27%;
Blocked calls: 88%.
January 2010:
Abandoned calls: 20%;
Blocked calls: 84%.
February 2010:
Abandoned calls: 13%;
Blocked calls: 74%.
March 2010:
Abandoned calls: 7%;
Blocked calls: 16%.
April 2010:
Abandoned calls: 8%;
Blocked calls: 2%.
May 2010:
Abandoned calls: 10%;
Blocked calls: 2%.
June 2010:
Abandoned calls: 15%;
Blocked calls: 14%.
July 2010:
Abandoned calls: 22%;
Blocked calls: 24%.
August 2010:
Abandoned calls: 18%;
Blocked calls: 44%.
September 2010:
Abandoned calls: 16%;
Blocked calls: 63%.
Source: GAO analysis of performance data from VA's Education Call
Center.
[End of figure]
In addition, program stakeholders told us that awareness of VA's free
educational and vocational counseling is very low. Most of the
students and veterans service organization officials we interviewed
were not aware that VA offered this service and an estimated 75
percent[Footnote 40] of school certifying officials we surveyed
reported not being aware of VA's educational and vocational
counseling. While the VR&E program conducts some outreach for this
benefit among servicemembers and veterans with disabilities, VA
education program officials told us they have not conducted much
outreach to promote this service to the general population of eligible
individuals beyond posting information on the GI Bill application and
Web site.
VA Targets Outreach and Support for Education Benefits to All Eligible
Individuals, Not Necessarily to Those with Disabilities:
Most of VA's outreach and support activities for education benefits
are targeted to the general population of servicemembers and veterans,
not necessarily to those with disabilities. VA education program and
VR&E officials told us that the VR&E program conducts outreach to
servicemembers and veterans with disabilities. Education program
officials told us that they do not conduct targeted outreach to
individuals with disabilities because eligibility for VA education
benefits is based on length of military service, rather than
disability status.[Footnote 41]
VR&E officials told us that they have a number of efforts to reach out
to and support individuals with disabilities. For example, through the
Coming Home to Work program, VR&E staff in VA's regional offices and
in certain military treatment facilities work with servicemembers who
are on medical hold or awaiting the medical board process to develop a
plan for obtaining training and finding a job if they are unable to
return to active duty. VR&E also offers Disabled Transition Assistance
Program (DTAP) briefings, which are held in conjunction with TAP but
focus solely on the VR&E program and educational and vocational
counseling.[Footnote 42] In addition to these outreach activities,
VR&E counselors provide one-on-one support to individuals during the
application process. For example, VR&E counselors usually meet face-to-
face with individuals who are considering applying for VR&E benefits
to explain the program. Counselors also may explain the difference
between VR&E benefits and those available under VA's education benefit
programs if an individual is eligible for both. For individuals who
are found eligible for VR&E services, counselors also provide case
management and support while they pursue education or training and
look for employment. As mentioned previously, individuals who choose
to receive benefits under the Post-9/11 GI Bill are not eligible for
this case management and support.[Footnote 43]
VR&E has a new pilot program, called VetSuccess on Campus, currently
operating at eight colleges and universities across the country.
Through this program, VR&E counselors have offices on campus to
provide vocational testing, career and academic counseling, and
readjustment counseling services to support servicemembers and
veterans. All servicemembers and veterans attending these schools are
eligible for assistance, regardless of their disability status.
According to a VR&E official, the VetSuccess on Campus office is
designed to provide information and assistance on all benefits,
including VR&E and VA education benefits. For example, if a student
wants to apply for education benefits, the VR&E counselor can refer
them to a point of contact within VA's education programs or walk them
through the application process.
VA education program and VR&E officials told us that these two
programs generally do not coordinate their outreach, but the agency
has taken some steps in this area. VA education program officials told
us they have coordinated with VR&E on policy and have provided some
information, briefings, and training on VA education programs, but the
two programs mostly conduct separate outreach efforts. For example, VA
education program officials told us that they have provided
information and materials to the VetSuccess on Campus program, but
that has been the extent of their involvement with the program.
However, in May 2010, VA established a new office--the Benefits
Assistance Service. A Benefits Assistance Service official told us
that, while the role of the office is still evolving, it is designed
to provide guidance and coordination for outreach across veterans'
benefit programs.[Footnote 44]
VA Has Few Efforts to Measure the Effectiveness of Outreach and
Support Activities:
Little is known about the effectiveness of VA's education outreach and
support because VA currently does not have outcome-oriented
performance measures for these activities. While VA has an agencywide
performance objective to educate and empower veterans and their
families through proactive outreach, the agency lacks specific
performance measures to assess its efforts in relation to its
education programs (see figure 5). As required by law,[Footnote 45] VA
produces a biennial report on its outreach activities. However, this
report is generally focused on the number and type of VA's education
outreach activities rather than the results.[Footnote 46] In addition,
while VA's education program estimates the number of people who view
or listen to a particular Post-9/11 GI Bill online, radio, or print
advertisement, it has not determined the extent to which its outreach
campaign has been effective in informing or changing the behavior of
target audiences. We have found in prior work that key practices for
consumer education campaigns include establishing outcome metrics to
measure success in achieving the objectives of the campaign. In this
instance, such metrics could be employed to evaluate how well VA's
campaign influenced the attitudes and behaviors of servicemembers and
veterans.[Footnote 47]
Figure 5: VA's Performance Goals, Objectives, and Measures Related to
Outreach to and Support for Individuals Applying for Education
Benefits:
[Refer to PDF for image: illustration]
Strategic goals:
* Improve the quality and accessibility of health care, benefits, and
memorial services while optimizing value;
* Increase veteran client satisfaction with health, education,
training, counseling, financial, and burial benefits and services;
* Raise readiness to provide services and protect people and assets
continuously and in time of crisis[A];
* Improve internal customer satisfaction with management systems and
support services to achieve mission performance and make VA an
employer of choice by investing in human capital[A].
Integrated performance objectives (from first two strategic goals):
* Make it easier for veterans and their families to receive the right
benefits, meeting expectations for quality, timeliness, and
responsiveness;
* Educate and empower veterans and their families through proactive
outreach and effective advocacy;
* Build our internal capacity to serve veterans, their families, our
employees, and other stakeholders efficiently and effectively[A].
Performance measures (from first performance objective):
In use:
* Processing time: Average days needed to process original and
supplemental education claims;
* Accuracy: Payment accuracy rate;
* Blocked calls: Rate at which calls to the Education Call Center are
blocked;
* Abandoned calls: Rate at which callers hang up before Education Call
Center answers;
* Montgomery GI Bill usage rate: Percentage of veterans using that
benefit within 10 years of separating;
In development:
* Completion rate: Percent of Montgomery GI Bill or Post-9/11 GI Bill
participants who complete an education or training program.
Performance measures (from second performance objective):
In use:
* None;
In development:
* Education goal attainment: Percent of program participants who
believe VA benefits have been helpful or very helpful in the
attainment of their educational or vocational goals;
* Customer satisfaction: Percent of beneficiaries somewhat satisfied
or very satisfied with the way VA handled their education claim.
Source: GAO analysis of VA Strategic Plan Fiscal Years 2010-2014 and
VA Fiscal Year 2010 Performance and Accountability Report.
[A] The strategic goals and performance objectives that are not
directly related to VA's education benefit programs.
[End of figure]
In addition, VA also does not have measures to assess the quality of
the support it provides to individuals seeking education benefits.
While VA has two performance measures on the percentage of toll-free
hotline calls that are blocked or abandoned, it has not established a
measure for the accuracy of the information provided by call center
staff. VA officials told us that call center supervisors review 5
calls per month for each staff member and assess, among other items,
the accuracy of information they provide to callers. However, VA does
not calculate accuracy for the call center as a whole but recently
implemented a survey to assess callers' satisfaction with the call
center. In addition, VA does not have performance measures for the
timeliness and quality of answers provided to servicemembers' and
veterans' questions through Right Now Web. A VA official told us they
try to respond to inquiries within 5 days and have data on the number
of inquiries that have been pending for longer than this time period,
but do not track the average response time for all inquiries. In our
prior work, we found that agency performance measures should cover
governmentwide priorities, such as the quality of service.[Footnote
48] Although VA lacks such measures for its call center or Right Now
Web, other federal programs have made them a part of their quality
assurance process. For example, Education's Office of Federal Student
Aid has established a target to provide correct answers the first time
for 95 percent of the calls to its Customer Support Center for
schools, students, parents, and others receiving federal student
loans, and measures its progress toward meeting this target.[Footnote
49]
School Certifying Officials' Roles Have Become More Complex and
Challenging:
The Complexity of School Officials' Roles Has Increased Along with
Their Workload:
School certifying officials' core VA responsibilities have become more
complex and time-consuming with the implementation of the Post-9/11 GI
Bill. These officials are required to report the enrollment of each
student receiving VA education benefits, including the credit hours,
tuition, fees, and the beginning and end dates of terms, among other
duties (see table 3). According to school certifying officials we
interviewed, certification was simpler and took less time per student
prior to the Post-9/11 GI Bill. For example, under the Montgomery GI
Bill, certifying officials typically had to report tuition and fees
only if a student was enrolled less than half-time or was on active
duty. Moreover, although certifying officials' roles have become more
complex and time-consuming, they often do not perform VA
responsibilities full time. Based on our survey, an estimated 83
percent[Footnote 50] serve as school certifying officials in addition
to other responsibilities.
Table 3: School Certifying Officials' Required Responsibilities before
and after the Post-9/11 GI Bill:
Required responsibilities before the Post-9/11 GI Bill:
* Report credit hours;
* Report tuition and fees (if enrollment is less than half-time or
student is on active duty);
* Update credit hours within 30 days if student's enrollment changes;
* Review courses to ensure applicability to student's program of study;
* Monitor student progress and report unsatisfactory progress;
* Maintain student records;
* Keep the SAA informed of program and academic changes.
Required responsibilities after the Post-9/11 GI Bill:
* Report credit hours;
* Report tuition and fees;
* Subtract tuition and fees covered by non-Title IV federal sources
(e.g., Department of Defense Tuition Assistance);
* Subtract military and other tuition discounts;
* Determine whether courses are being taken online or on campus and
report credit hour totals for each separately;
* Update credit hours, tuition and fees within 30 days if student's
enrollment changes;
* Report Yellow Ribbon school contributions for tuition and fees (if
school participates in Yellow Ribbon program);
* Review courses to ensure applicability to student's program of study;
* Monitor student progress and report unsatisfactory progress;
* Maintain student records;
* Keep the SAA informed of program and academic changes.
Source: GAO analysis of VA documents.
Note: Title IV generally refers to title IV of the Higher Education
Act and student aid programs administered by the Department of
Education. 20 U.S.C. §§ 1070-1099c-2.
[End of table]
According to our survey, school certifying officials have several
other major program responsibilities they fulfill in addition to those
specifically required by VA (see figure 6). For example, we estimate
that 51 percent[Footnote 51] of school certifying officials consider
coordinating with other campus offices, such as the school business
office, on benefits issues as a major responsibility. Those we
interviewed also said that this coordination has become necessary with
Post-9/11 GI Bill tuition and fee payments being sent directly to
schools. Often, this is the first time that school certifying
officials have had to interact with the business office and other
campus offices. For example, school officials reported that business
offices have received (1) payments for amounts that were different
from what the school certifying official had reported to VA, (2)
duplicate payments for the same student, and (3) other payments that
did not have adequate information to identify the student or term.
School officials we interviewed reported that they often serve as the
liaison between VA and the school business office, because the
business office may not be familiar with VA education benefit program
policies.
Figure 6: School Certifying Officials' Reported Responsibilities for
VA Education Benefit Programs:
[Refer to PDF for image: horizontal bar graph]
Certify students‘ enrollment to VA and notify VA of changes during the
semester[A]:
Not the school official‘s responsibility: 4.2%;
Minor responsibility of the school official: 3.1%;
Moderate responsibility of the school official: 7.8%;
Major responsibility of the school official: 84.9%.
Keep the SAA informed of program and academic changes[A]:
Not the school official‘s responsibility: 13%;
Minor responsibility of the school official: 9.9%;
Moderate responsibility of the school official: 12.5%;
Major responsibility of the school official: 64.6%.
Coordinate with other school offices on VA education benefits issues
(e.g., bursar, financial aid, registrar):
Not the school official‘s responsibility: 9.9%;
Minor responsibility of the school official: 17.7%;
Moderate responsibility of the school official: 21.9%;
Major responsibility of the school official: 50.5%.
Help students apply for VA education benefits:
Not the school official‘s responsibility: 14.5%;
Minor responsibility of the school official: 19.2%;
Moderate responsibility of the school official: 26.4%;
Major responsibility of the school official: 39.9%.
Check on the status of students‘ VA education claims and payments:
Not the school official‘s responsibility: 17.1%;
Minor responsibility of the school official: 21.8%;
Moderate responsibility of the school official: 24.9%;
Major responsibility of the school official: 36.3%.
Provide VA benefits counseling to students:
Not the school official‘s responsibility: 25.4%;
Minor responsibility of the school official: 19.7%;
Moderate responsibility of the school official: 24.9%;
Major responsibility of the school official: 30.1%.
Reconcile payments from VA with individual student accounts:
Not the school official‘s responsibility: 44.2%;
Minor responsibility of the school official: 16.3%;
Moderate responsibility of the school official: 16.8%;
Major responsibility of the school official: 22.6%.
Provide academic counseling to students receiving VA education
benefits:
Not the school official‘s responsibility: 46.6%;
Minor responsibility of the school official: 14.5%;
Moderate responsibility of the school official: 22.3%;
Major responsibility of the school official: 16.6%.
Conduct outreach to individuals who may be eligible for VA education
benefits:
Not the school official‘s responsibility: 42.2%;
Minor responsibility of the school official: 28.1%;
Moderate responsibility of the school official: 18.9%;
Major responsibility of the school official: 10.8%.
Source: GAO survey of school certifying officials.
Note: All estimates in this figure have 95 percent confidence
intervals of plus or minus 7 percentage points or less.
[A] Required by VA.
[End of figure]
In addition, we estimate that nearly 40 percent[Footnote 52] of school
certifying officials view helping students apply for VA education
benefits as one of their major responsibilities. Although VA considers
this support a voluntary activity, school certifying officials stated
they often get questions from servicemembers and veterans because they
are frequently the only people students interact with face-to-face to
get answers to their questions about VA education benefits. A majority
of school certifying officials (64 percent[Footnote 53]) in our survey
reported it would be helpful or very helpful to receive more
information about how to help servicemembers and veterans select the
right VA education benefit program when they are eligible for multiple
programs.
School certifying officials' workload also has grown as a result of
their additional required and voluntary responsibilities and greater
numbers of students receiving VA education benefits. School certifying
officials we interviewed, as well as eight certifying officials in
open-ended responses to our survey, told us that their workloads have
grown due to factors such as greater reporting requirements for the
Post-9/11 GI Bill and efforts needed to resolve payment issues.
According to VA's 2010 performance and accountability report, the
number of participants in VA education benefit programs has increased
from about 460,000 in 2008 to 634,000 in 2010,[Footnote 54] an
increase of 38 percent. VA and school officials we interviewed
attributed this increase to the Post-9/11 GI Bill. For example, one
school official we interviewed said she had certified 25 percent more
veterans than prior to Post-9/11 GI Bill implementation.
School Certifying Officials Were Generally Satisfied, but Reported a
Lack of Comprehensive Policy Guidance, among Other Challenges:
Although about 62 percent[Footnote 55] of school certifying officials
stated they were generally or very satisfied with VA's implementation
of the Post-9/11 GI Bill, officials identified a range of challenges
in fulfilling their responsibilities under the program (see figure 7).
About 33 percent[Footnote 56] of school certifying officials cited
great or very great challenges in checking on the status of students'
VA claims and payments. For example, in interviews and in comments to
our survey, school officials discussed delays in expected payments and
difficulty getting through to VA's toll-free hotline when they had
questions.
In addition, school certifying officials cited challenges due to the
lack of a comprehensive source of policy information on the Post-9/11
GI Bill program, such as a VA policy manual. An estimated 32 percent
[Footnote 57] of school officials in our survey stated that the lack
of a manual was a great or very great challenge, and an additional 23
percent[Footnote 58] stated this was a moderate challenge. VA has not
created a policy manual for the Post-9/11 GI Bill since the program
was implemented, nor has the agency published a policy or procedural
manual for any of its other education benefits programs.[Footnote 59]
Figure 7: School Certifying Officials' Reported Challenges in
Fulfilling Responsibilities for the Post-9/11 GI Bill Program:
[Refer to PDF for image: horizontal bar graph]
Estimated percentage of respondents answering:
Checking on the status of students‘ VA education claims and payments:
Don't know: 12.4%;
Slight to no challenge: 26.4%;
Moderate challenge: 28%;
Great to very great challenge: 33.2%.
Lack of a handbook or manual covering all Post-9/11 GI Bill policies:
Don't know: 8.7%;
Slight to no challenge: 35.9%;
Moderate challenge: 23.1%;
Great to very great challenge: 32.3%.
Adequacy of training for School Certifying Officials:
Don't know: 8.2%;
Slight to no challenge: 41.8%;
Moderate challenge: 28.4%;
Great to very great challenge: 21.7%.
Accuracy of information from VA Education Call Center (1-888-GIBILL-1):
Don't know: 21.2%;
Slight to no challenge: 32.6%;
Moderate challenge: 21.8%;
Great to very great challenge: 24.4%.
Ability to locate information on VA's GI Bill Web site:
Don't know: 6.2%;
Slight to no challenge: 48.7%;
Moderate challenge: 28.5%;
Great to very great challenge: 16.6%.
Certifying student's enrollment to VA and notifying VA of changes
during the semester:
Don't know: 7.3%;
Slight to no challenge: 47.7%;
Moderate challenge: 22.3%;
Great to very great challenge: 22.8%.
Clarity of policy guidance and information from VA:
Don't know: 35.4%;
Slight to no challenge: 23.4%;
Moderate challenge: 19.8%;
Great to very great challenge: 21.4%.
Timeliness of policy guidance and information from VA:
Don't know: 29.5%;
Slight to no challenge: 30.5%;
Moderate challenge: 20.5%;
Great to very great challenge: 19.5%.
Reconciling payments from VA with individual student accounts:
Don't know: 31.4%;
Slight to no challenge: 30.4%;
Moderate challenge: 15.5%;
Great to very great challenge: 22.7%.
Coordinating with other school offices (e.g., bursar, financial aid,
registrar):
Don't know: 10.8%;
Slight to no challenge: 61.3%;
Moderate challenge: 16%;
Great to very great challenge: 11.9%.
Keep the SAA informed of program and academic changes:
Don't know: 12.6%;
Slight to no challenge: 62.8%;
Moderate challenge: 16.2%;
Great to very great challenge: 8.4%.
Communicating with the VA Debt Management Center:
Don't know: 57%;
Slight to no challenge: 19.7%;
Moderate challenge: 6.7%;
Great to very great challenge: 16.6%.
Source: GAO survey of school certifying officials.
Note: All estimates in this figure have 95 percent confidence
intervals of plus or minus 7 percentage points or less.
[End of figure]
VA provides policy information to certifying officials through policy
advisories, but we found an example where the information in such
advisories may not provide sufficient guidance. Specifically, VA
issued a policy advisory in October 2009 to clarify how school
certifying officials should report tuition and fee charges when the
student is receiving discounted tuition or other tuition assistance.
This policy advisory explains that school officials should deduct non-
Title IV federal assistance before reporting tuition and fees to VA.
[Footnote 60] However, the advisory does not include a complete list
of federally funded tuition assistance programs. For example, although
certain National Guard tuition assistance programs are federally
funded, they are not included on the list. One school certifying
official we spoke with said that school officials may not know whether
tuition assistance provided by the National Guard is provided with
federal or state funds. As a result, schools may find it difficult to
ensure that students are not receiving funds from both VA and other
federally funded programs for the same courses.
VA officials told us that school certifying officials generally
receive policy advisories via e-mail from their state's VA education
liaison representative, but this approach may not be sufficient for
providing consistent and timely policy information. For example, some
officials from schools with campuses in more than one state told us
that the timeliness of providing these advisories can vary among
education liaison representatives. In addition, a senior VA official
told us that some education liaison representatives expand on VA
policy advisories to assist schools within their state, although
others do not. Further, VA has not cataloged all policy advisories
sent to school officials in a central location accessible to all
schools. In contrast, Education's Office of Federal Student Aid
provides policy and other program information to schools through a Web
site (Information for Financial Aid Professionals). The Web site was
developed to provide schools with electronic access to operational and
policy guidance to administer the Title IV student financial aid
programs. Schools can sign up to receive regular bulletins that
compile all information distributed to schools.
In addition, school certifying officials faced challenges in obtaining
adequate training on the Post-9/11 GI Bill, in part because they
reported that they were too busy with other job responsibilities or
were unaware of training opportunities. VA training opportunities are
available through several channels: one-on-one training provided by VA
education liaison representatives; conferences; and an online training
module available on VA's Web site. However, school certifying
officials were not always able to participate. While an estimated 65
percent[Footnote 61] received training on the Post-9/11 GI Bill,
mostly through VA conferences, others stated they did not attend
because they were too busy with other job responsibilities. In
addition, two school certifying officials and an SAA official we
interviewed told us that sometimes school officials cannot attend
training conferences due to the cost of travel. Moreover, an estimated
85 percent[Footnote 62] of school certifying officials had not taken
VA's online training module, mostly because they were unaware it was
available. Of those who stated they did complete the online training,
about half of the officials said that it was effective or very
effective. While VA considers taking VA-sponsored training a part of
school certifying officials' responsibilities, VA does not track the
extent to which school officials participate in any training.
School certifying officials also reported needing more information or
training on several topics pertaining to the Post-9/11 GI Bill (see
figure 8). For example, 72 percent[Footnote 63] of school certifying
officials said it would be helpful or very helpful to receive more
information on the transferability of entitlement to a spouse or
dependents. School officials also indicated they need more information
on which fees are allowable under the Post-9/11 GI Bill; when to
submit enrollment certifications; and what steps to take when they
receive an incorrect payment.
Figure 8: Aspects of the Post-9/11 GI Bill Where School Certifying
Officials Reported That More Information Would Be Helpful:
[Refer to PDF for image: horizontal bar graph]
Estimated percentage of respondents answering:
Transferability of entitlement to dependents:
Don't know: 2.6%;
Not applicable to my role: 9.9%;
Not to slightly helpful: 6.8%;
Moderately helpful: 8.9v
Helpful to very helpful: 71.7%.
What to do when your school receives incorrect tuition/fee payments
from VA:
Don't know: 2.1%;
Not applicable to my role: 14.6%;
Not to slightly helpful: 8.3%;
Moderately helpful: 6.8%;
Helpful to very helpful: 68.2%.
Which fees are allowable under the Post-9/11 GI Bill program:
Don't know: 2.6%;
Not applicable to my role: 6.2%;
Not to slightly helpful: 16%;
Moderately helpful: 8.8%;
Helpful to very helpful: 66.5%.
How to assist individuals in selecting the VA education benefit right
for them:
Don't know: 4.6%;
Not applicable to my role: 14.9%;
Not to slightly helpful: 9.8%;
Moderately helpful: 6.2%;
Helpful to very helpful: 64.4%.
When to submit enrollment certifications:
Don't know: 1.1%;
Not applicable to my role: 2.6%;
Not to slightly helpful: 28.4%;
Moderately helpful: 7.4%;
Helpful to very helpful: 60.5%.
How to certify enrollment in courses outside traditional academic
calendar (e.g., summers):
Don't know: 3.7%;
Not applicable to my role: 18.4%;
Not to slightly helpful: 20.5%;
Moderately helpful: 11.1%;
Helpful to very helpful: 46.3%.
Source: GAO survey of school certifying officials.
Note: All estimates in this figure have 95 percent confidence
intervals of plus or minus 7 percentage points or less.
[End of figure]
Finally, an estimated 84 percent[Footnote 64] of school certifying
officials have not received training from any source on working with
servicemembers and veterans with disabilities. An estimated 59
percent[Footnote 65] of school officials said it would be helpful or
very helpful to receive information on the unique needs of this
population. VA officials told us the education program has not
developed training or guidance to help school officials better serve
those with disabilities. By comparison, Education is funding efforts
to provide some supports to staff working with servicemembers and
veterans with disabilities. Education recently announced grants to
establish Centers of Excellence for Veteran Student Success at 15
schools across the country. The program is designed to improve support
to veterans in postsecondary education by coordinating services
including personal or mental health counseling and disabilities
services. In particular, some grantees plan to conduct training to
help school staff understand the challenges veterans with disabilities
often face.
VA Lacks Comprehensive Information on the Effectiveness of Its
Oversight of States and Schools:
VA Monitors States' Approval and Supervision of Schools, but Its
Approach Has Limitations:
VA monitors SAAs' performance in approving and supervising schools
through a range of oversight activities, such as reviewing reports
SAAs submit on their activities (see table 4). Pursuant to their
contracts with VA, SAAs approve schools to receive VA education
benefits and generally visit them annually to ensure they continue to
meet VA standards in areas such as course quality, school financial
stability, and student progress.[Footnote 66] To oversee these
activities, VA reviews reports that SAAs prepare after each site
visit, known as supervisory visits, as well as quarterly and annual
reports on their activities. On an annual basis, VA also convenes a
Joint Peer Review Group to assess each SAA's performance, and, in
fiscal year 2009, VA started conducting onsite visits at SAAs.
Table 4: VA Oversight Activities for SAAs:
Oversight activity: SAA approval notices;
Frequency: As provided to VA;
Description: VA reviews and takes appropriate actions on all SAA
approval notices for education and training programs seeking approval
to receive education benefits.
Oversight activity: SAA supervisory visit reports;
Frequency: As provided to VA;
Description: VA reviews and takes appropriate actions, as needed, on
all SAA supervisory visit reports based on their site visits to
previously approved schools, in order to monitor and ensure their
continued approval.
Oversight activity: SAA activity reports;
Frequency: Quarterly;
Description: VA reviews SAA quarterly reports, which contain
information on the number of completed approval notices and
supervisory visits, among other data.
Oversight activity: Joint Peer Review Group;
Frequency: Annually;
Description: VA convenes a Joint Peer Review Group, comprised of both
VA and SAA officials, to review each SAA's performance. This review is
based on an annual SAA self-evaluation and VA's assessment of the
SAAs' performance.
Oversight activity: VA site visits to SAAs;
Frequency: Planning to conduct about 5-10 visits per year;
Description: VA conducts site visits at SAAs to assess their
organization, fiscal management, outreach, and approval processes, and
provides recommendations to ensure that SAAs are fulfilling their
contractual requirements.
Source: GAO review of VA documents and interviews with VA officials.
Note: In addition to the activities listed above, VA also reviews SAA
annual contract proposals, which include their business plans, and SAA
invoices requesting VA reimbursement.
[End of table]
In general, VA's oversight activities indicate that the majority of
the 57 SAAs have fulfilled their responsibilities to VA.[Footnote 67]
For example, all but 3 and 10 of the SAAs in fiscal years 2009 and
2010, respectively, received VA's highest rating of "satisfactory" as
part of VA's annual Joint Peer Review Group. In addition, VA's six
site visits to SAAs in fiscal year 2010 generally resulted in positive
findings with relatively few discrepancies. Furthermore, in recent
years, most SAAs met VA's standard to visit a minimum of 80 percent of
active schools.[Footnote 68] However, 12 and 9 SAAs, respectively, did
not meet this standard in fiscal years 2009 and 2010.
Despite these activities, we identified several limitations that may
hamper the effectiveness of SAAs' oversight of schools. For example,
while VA requires SAAs to visit 80 percent of approved schools, it has
not otherwise identified, nor does it require SAAs to use, any risk-
based factors to develop their site visit schedules.[Footnote 69] A
risk-based approach could help VA better target SAAs' oversight of
schools to assure continued program integrity.[Footnote 70] In our
review of four selected states, we found that the SAAs took different
approaches to scheduling their visits. For example, one SAA told us
that they prioritize schools with higher numbers of VA beneficiaries.
Another SAA we spoke with considered multiple factors in addition to
the number of VA beneficiaries, and targeted, for example, newly
approved schools and for-profit schools. Finally, two of the four SAAs
we spoke with identified schools' geographic locations as a key factor
in prioritizing schools for site visits, in order to minimize travel
costs.
In addition, VA lacks standards for how SAAs should conduct site
visits at schools, which raises questions about the validity of the
findings and makes it difficult to compare across schools and SAAs. In
particular, VA has not set minimum standards for the review of student
files. In our four selected states, we found variation in the
percentage of student files that SAAs reviewed. For example, in one
state, we found that SAA officials generally reviewed a non-random
selection of 10 student files, regardless of the number of VA
education beneficiaries at the school. In comparison, the number and
percentage of student files for another SAA selected varied from visit
to visit, among the reports we reviewed.[Footnote 71] In addition, we
found that all four SAAs sometimes or always allow schools to select
the student files for review. This approach, however, undermines the
independence of the review because schools may not choose the most
complex student files for the SAAs' review.[Footnote 72] Absent
standards, VA lacks assurance that the data collected from these file
reviews by different SAAs are valid, comparable, and useful for
determining whether schools are in compliance with federal
requirements.
VA Suspended Its Required Audits of Schools in Fiscal Year 2010:
Federal law requires VA to monitor and oversee schools through audits,
called compliance surveys.[Footnote 73] Each year, VA is required to
conduct onsite audits at one-third of each region's approved schools,
and in fiscal year 2009, VA conducted nearly 2,600 audits nationwide.
One of VA's four regional processing offices handles school and
program approvals for foreign schools, but VA does not currently
conduct audits of foreign schools receiving its education benefits.
[Footnote 74]
While the purpose of SAAs' site visits is to ensure that schools
remain in compliance with federal requirements for VA education
benefits, VA's audits focus more on the accuracy of benefit payments
to schools and students under all of its education benefit programs
(see table 5 for a comparison of SAA site visits and VA audits). For
the Post-9/11 GI Bill, VA audits must include a review of multiple
payment types made to both schools (e.g., tuition and fee payments)
and students (e.g., housing allowances and books and supplies
stipends). In order to determine the accuracy of these payments, VA
randomly selects student files to identify discrepancies.[Footnote 75]
For example, a payment error may occur when school officials do not
report changes in students' credit hours to VA in a timely manner.
[Footnote 76]
Table 5: Comparison of SAA Site Visits and VA Audits of Schools:
SAA site visits:
Key goals;
* Monitor approval status: Determine whether schools and programs
remain qualified and equipped to furnish education or training;
and remove the program from the approved list if it no longer meets
the approval criteria;
* Technical assistance: Answer specific questions, help identify
solutions to problems, provide guidance or intervention on issues that
are, or could become, a matter of non-compliance with approval
standards or certification requirements;
* Follow-up on problems: Resolve discrepancies or refer them to VA.
Frequency:
SAA site visits: Annually conduct site visits at:
* A minimum of 80 percent of all active schools and training
establishments, including:
- institutions of higher learning;
- non-college degree programs and correspondence schools;
- flight schools, and;
- on-the-job training and apprenticeship programs.
VA audits:
Key goals:
* Payment accuracy: Verify the accuracy of education benefit payments;
* Technical assistance: Assist school officials in better
understanding their responsibilities and VA's procedural requirements;
* Compliance: Determine whether eligible individuals or schools have
fulfilled their responsibilities and requirements;
* Follow-up on problems: Assure that proper action is promptly taken
to correct discrepancies.
Annually conduct audits at:
* A minimum of 33 percent of active institutions of higher learning,
non-college degree programs and correspondence schools each year,
regardless of the number of VA education beneficiaries enrolled;
* All active flight schools;
* Ten percent of active on-the-job;
* training and apprenticeship programs.
Source: VA's M22-4 Education Procedures Manual and other documents and
SAA interviews.
[End of table]
Despite the federal requirement to conduct monitoring and oversight,
in fiscal year 2010, VA suspended its audit program in order to
reassign compliance staff to help process a backlog in Post-9/11 GI
Bill claims.[Footnote 77] As a result, VA did not complete several
thousand audits during the critical first full year of this new
program. According to VA officials, VA's compliance staff did not
fully resume their audits until fiscal year 2011. In preparation to
reinstate these audits, VA provided training to staff in June 2010 and
conducted several preliminary audits following this training. Each of
the 18 preliminary school audits identified at least one error among
the files reviewed for students receiving Post-9/11 GI Bill benefits,
and these errors varied in their scope and magnitude. For example:
* In South Carolina, a school incorrectly made a refund of $1,123 to a
student who reduced his credit hours from six to three. The school
should have returned the funds to VA because the audit revealed the
reduction in credit hours occurred prior to the start of the school's
term.
* In New Jersey, a school failed to notify VA that a student did not
attend a term because he returned to active duty, which resulted in an
overpayment to the school of $4,680.
* In Arizona, a school certified tuition charges to VA without
subtracting the military and other discounts offered to students. In 9
of the 20 student files reviewed, VA found overpayments to the school
totaling nearly $20,000.
Although VA has resumed its audits of schools, there are indications
that it may not be able to complete all required audits in fiscal year
2011. VA officials told us that these audits, compared to those
conducted prior to implementation of the Post-9/11 GI Bill, are taking
longer to complete. VA officials indicated that, given their current
resources, it would be challenging for them to complete all required
audits in fiscal year 2011. Moreover, one VA regional processing
office completed an analysis of the time needed to review files for
students receiving benefits under the Post-9/11 GI Bill and found that
it would require at least four additional full-time staff, beyond
those already assigned, to accommodate the additional workload.
[Footnote 78] Furthermore, even in the fiscal year prior to the Post-
9/11 GI Bill, VA failed to complete over 15 percent of the more than
3,000 audits that were planned nationwide. In addition, we found that
the percentage of completed audits varied greatly among individual
states and that VA completed all of its planned audits in only 13
states (see figure 9).[Footnote 79] Going forward, VA plans to include
audits that it did not conduct in fiscal year 2010 into its schedules
for the next 2 years.
Figure 9: Percentage of Planned VA Audits Conducted, by State, in
Fiscal Year 2009:
[Refer to PDF for image: illustrated U.S. map]
Percentage of planned audits conducted:
Less than 50% (6 states):
Colorado:
Maine:
Oregon:
Pennsylvania:
Vermont:
Wyoming:
50% to 74% (13 states):
Hawaii:
Idaho:
Kansas:
Maryland:
Massachusetts:
Montana:
Nebraska:
New Hampshire:
New York:
New Mexico:
Puerto Rico:
Utah:
Virginia:
75% to 99% (20 states):
Arizona:
Arkansas:
Connecticut:
Florida:
Georgia:
Illinois:
Louisiana:
Michigan:
Missouri:
Nevada:
New Jersey:
North Carolina:
Ohio:
Oklahoma:
Rhode Island:
South Carolina:
South Dakota:
Texas:
West Virginia:
Wisconsin:
100% to 128% (13 states):
Alabama:
Alaska:
California:
Delaware:
District of Columbia:
Indiana:
Iowa:
Kentucky:
Minnesota:
Mississippi:
North Dakota:
Tennessee:
Washington:
Source: GAO analysis of VA data.
Note: In this figure, we refer to the District of Columbia and Puerto
Rico as states when presenting the results of our analyses.
[End of figure]
Finally, VA lacks a comprehensive and nationwide approach to ensure
that individual schools have been audited in a timely manner. VA has a
database, known as WEAMS,[Footnote 80] to track information about the
dates in which audits occurred, but not all of VA's compliance staff
enter information into it, and officials said that VA does not require
them to do so. We found that nearly half of the 6,500 schools listed
in the database were missing a date for the most recent audit. In
addition, based on our review of reports, when available, for 46
randomly selected schools in four states,[Footnote 81] we found that
86 schools in three states had not been audited by VA since at least
fiscal year 2006, even though these schools had active VA education
beneficiaries.[Footnote 82] In fact, in one state we found that the
most recent audit report for a public university with about 240 VA
education beneficiaries dated back to 1997.[Footnote 83]
VA Does Not Systematically Compile and Review Findings of School
Audits:
VA does not systematically consider the findings of its own or other
entities' audits of schools when carrying out its oversight. For
example, VA prepares a report on each school audit, but does not
compile the overall findings for all audits, such as types of
discrepancies and payment errors. Likewise, while SAAs provide some
information on the outcomes of their visits in individual site visit
reports, neither the SAAs nor VA summarize them on a quarterly or
annual basis. Such summary information could be used to identify
common errors among schools and evaluate trends over time.[Footnote
84] As a result, VA lacks a comprehensive, national picture of
schools' performance in a given year or over time.
Furthermore, VA officials told us they do not consider the results of
monitoring or audits conducted by other entities, such as Education's
Office of Federal Student Aid, in determining which schools they
should audit. To monitor schools receiving Title IV funds, the Office
of Federal Student Aid conducts program reviews each year at schools
that it identifies as high-risk, and requires schools to submit annual
independent compliance audits. Moreover, the Office of Federal Student
Aid reviews financial statements for all schools on an annual basis.
It compiles the results of its various oversight mechanisms in a data
system used to track its monitoring and enforcement activities at
schools.[Footnote 85] The Office of Federal Student Aid has additional
oversight measures for for-profit schools and, according to its 5-year
Strategic Plan, is exploring ways to adapt its oversight to the unique
challenges presented by for-profit and distance-learning programs.
[Footnote 86] VA officials told us, by comparison, that they have not
adopted different oversight practices for for-profit schools and
distance-learning courses. VA education program officials told us that
they support, in general, looking across its individual school audits
and taking other government entities' audit findings into
consideration to enhance their oversight of schools.
Conclusions:
The Post-9/11 GI Bill enhanced education benefits for servicemembers,
veterans, and their dependents. Between fiscal year 2009 and 2011, VA
estimates it will triple the amount it pays in education benefits each
year, from $3.6 billion to nearly $10 billion. The majority of these
funds will be paid under the Post-9/11 GI Bill, and expenditures are
poised to grow beyond 2011 due to the rising cost of higher education.
Given this potential for growth, it is important to ensure that VA has
a process in place that provides timely and accurate benefits to those
who are truly eligible, while also ensuring program integrity. With
major statutory changes to the Post-9/11 GI Bill taking effect in the
early fall of 2011, VA has an opportunity to reexamine and adjust its
management approach to the program, particularly in regard to its
oversight and quality assurance activities. These upcoming changes
also require VA to effectively educate and inform all of the players
in the process--servicemembers, veterans, and state and school
officials.
Given that program stakeholders identified some areas where
servicemembers and veterans may need more information about VA
education benefits, it will be important for VA to have better
measures of the effectiveness of its outreach and support. These
measures could provide key information to help VA strengthen and
inform future program and resource decisions, improve critical program
activities, and help verify that resources are being used responsibly.
In addition, the Post-9/11 GI Bill has increased the workloads for
school certifying officials, who play a critical role in ensuring
servicemembers and veterans receive the right benefits in a timely
manner. Establishing timely and comprehensive channels for
communicating policy information and guidance on this new and complex
program and raising awareness of available training opportunities
would help provide school officials with the tools to effectively
fulfill their roles in implementing VA education benefits. Moreover,
school certifying officials are a key point of contact on campus for
students receiving benefits, and some of these students may have
physical and cognitive disabilities. With increased awareness of how
to meet the needs of those with disabilities, school certifying
officials may be able to help ensure that these students have adequate
support as they transition into a school setting.
VA has also faced challenges in meeting the increased demand for Post-
9/11 GI Bill benefits, and has had to make a number of trade-offs as
it focused on reducing the backlog of education claims, such as
curtailing its oversight of schools. As a result, VA did not take
sufficient steps to ensure program integrity and minimize waste,
fraud, and abuse in its education benefit programs. As VA renews its
oversight of schools, our work has found some early indications of
continuing challenges, including difficulty completing required audits
of schools. As a result of upcoming legislative changes to the role of
State Approving Agencies, VA has an opportunity to systematically
review the federal-state oversight structure and resource allocation.
By undertaking such a review, VA may be able to achieve greater
efficiencies and to strike a balance between the need to process
claims in a timely manner while ensuring program integrity.
Recommendations for Executive Action:
To improve VA's outreach and support for eligible servicemembers and
veterans, communication with school officials, and oversight of its
education benefit programs, we recommend that the Secretary of
Veterans Affairs take the following five actions:
* Develop outcome-oriented performance measures for outreach to
servicemembers and veterans who are seeking VA education benefits.
This could include measures of VA's success in reaching out to target
populations, including servicemembers and veterans with disabilities,
and in addressing areas where more information about education
benefits may be needed.
* Establish performance measures for the quality of information
provided by VA's toll-free hotline and for the timeliness and quality
of its Right Now Web service.
* Provide more timely, accessible, and comprehensive education program
policy information. This could include developing and maintaining an
online policy manual for the Post-9/11 GI Bill and providing e-mail
updates to school certifying officials nationwide.
* Increase efforts to make school certifying officials aware of
available training opportunities, including VA's online training
module, and consider providing information for school certifying
officials on working with servicemembers and veterans with
disabilities.
* Undertake a systematic review of VA's and SAAs' oversight of
schools, focusing on opportunities to improve resource allocation,
adopt risk-based approaches, consider cost-effective ways to oversee
foreign schools, and evaluate the results of its oversight activities
on a routine basis.
Agency Comments and Our Evaluation:
We provided a draft of this report to VA for review and comment. In
its comments, VA generally agreed with our conclusions, concurred with
four of our recommendations, and concurred in principle with the fifth
recommendation. Specifically, with regard to our recommendation to
establish outcome-oriented performance measures for outreach to
servicemembers and veterans seeking education benefits, VA reported
that it will develop performance measures for a new communications
tool it is creating to provide specialized information on VA benefits.
In response to our second recommendation to establish performance
measures for the quality of information provided by VA's toll-free
hotline and for the timeliness and quality of its Right Now Web
service, VA noted that it will develop a national standard and
policies for monitoring the quality and timeliness of customer service
for its education benefits. In order to provide more timely,
accessible, and comprehensive education program policy information, VA
stated that it will meet with school certifying officials and other
stakeholders to develop a plan for improving policy information
dissemination. Regarding raising awareness of training opportunities
for school certifying officials, VA reported that it will examine how
it is currently relaying information to these officials and look for
improvements and alternative mechanisms. Collectively, these efforts
should help improve VA's outreach and support for eligible
servicemembers and veterans and enhance communication with school
officials.
VA concurred in principle with our fifth recommendation to undertake a
systematic review of VA's and SAA's oversight of schools. In its
response, VA noted that it recently acquired an independent assessment
of the SAAs' activities by a private contractor. In addition, VA
mentioned that it submitted recommended changes to SAAs' activities as
part of a legislative package, provisions of which have been enacted
as part of the Post-9/11 Veterans Educational Assistance Improvements
Act of 2010. These changes, effective August 1, 2011, reduce SAAs'
responsibilities for school approval by allowing VA to rely on
accreditations already in place by Education. As a result, VA
indicated that it will have more flexibility in utilizing SAAs to
provide additional outreach, training, and oversight of school
officials. However, VA's written comments did not respond to all of
the areas of a systematic review that we are encouraging VA to focus
on, including improving agency resource allocation, adopting a risk-
based approach to better target oversight activities, considering cost-
effective ways to oversee foreign schools, and routinely evaluating
oversight results. We believe that directing sustained management
attention to these additional areas, in conjunction with recent
legislative changes, will help ensure program integrity. VA's comments
are reproduced in appendix IV.
As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after its issue date. At that time we will send copies of this report
to the Secretary of Veterans Affairs, relevant congressional
committees, and other interested parties. In addition, this report
will also 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 bertonid@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 members who made key
contributions to this report are listed in appendix V.
Sincerely yours,
Signed by:
Daniel Bertoni:
Director, Education, Workforce and Income Security Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
The objectives of our report were to examine: (1) what is known about
the effectiveness of VA's outreach to and support for individuals
applying for education benefits, particularly for servicemembers and
veterans with disabilities, such as post-traumatic stress disorder and
traumatic brain injury; (2) the role of school officials and the
challenges they face in fulfilling their responsibilities for VA's
education benefit programs; and (3) how VA monitors and oversees
states' and schools' implementation of its education benefit programs.
While our scope included all of VA's active education benefit
programs, we had a particular focus on the Post-9/11 GI Bill program,
as it is the newest and most complex.
VA's Outreach and Support for Eligible Servicemembers and Veterans:
To address our first research objective, we reviewed relevant federal
laws, regulations, and agencywide plans and reports regarding outreach
to and support for eligible servicemembers and veterans and conducted
interviews with VA officials. Specifically, we reviewed statutory
requirements for outreach, which is defined as: "the act or process of
reaching out in a systematic manner to proactively provide
information, services, and benefits counseling to veterans, and to the
spouses, children, and parents of veterans who may be eligible to
receive benefits under the laws administered by the Secretary, to
ensure that such individuals are fully informed about, and receive
assistance in applying for, such benefits." VA is also required to
produce a biennial report to Congress and a biennial outreach plan on
its outreach efforts.[Footnote 87] We reviewed the most recent
outreach report, for 2010, and an outreach plan for fiscal year 2010-
2011, among other relevant documents. In addition, we interviewed VA
officials responsible for outreach and support within VA's Education
Service; Education Call Center; Vocational Rehabilitation and
Employment Service; Benefits Assistance Service; and the Office of the
Assistant Secretary for Public and Intergovernmental Affairs,
including the National Outreach Office.
In addition, we assessed VA's current and planned performance
objectives and measures related to outreach and support by comparing
them to requirements in the Government Performance and Results Act of
1993[Footnote 88] and key attributes for performance measures GAO has
developed in prior work.[Footnote 89] For example, one of the key
attributes is "linkage," which refers to the extent to which the
measure is aligned with division and agencywide goals and mission and
clearly communicated throughout the organization. In addition, another
key attribute is the extent to which each measure covers a
governmentwide priority, such as the quality, timeliness, and cost of
service. We assessed the reliability of VA's data for its toll-free
hotline performance measures by reviewing existing information about
the data and the systems that produced them and interviewing
knowledgeable agency officials. We determined that the toll-free
hotline performance measures data were sufficiently reliable for the
purposes of this report.
We also gained the perspectives of program stakeholders on the
effectiveness of VA's outreach and support, including servicemembers
and veterans receiving VA education benefits, veterans service
organizations, and school officials. Specifically, we conducted two
discussion groups with VA education beneficiaries enrolled in schools
in Oklahoma and Virginia. We selected these schools because they
represented different types of schools (2-year community college and 4-
year public university, respectively) with relatively high veteran
populations. We worked with school officials to identify students for
these discussion groups, including students with disabilities. We also
interviewed representatives of three national veterans service
organizations. In addition, we interviewed (1) school certifying
officials at the two schools where we conducted discussion groups of
students and a predominately online university, (2) representatives
from a national group representing school certifying officials, and
(3) conducted a nationwide survey of school certifying officials. See
below for more information on this survey.
Roles and Challenges of School Certifying Officials:
To address our second research objective, we reviewed relevant federal
laws, regulations, and agency documents and interviewed VA officials.
We also interviewed national groups representing State Approving
Agencies (SAA) and school certifying officials, as well as veterans
service organizations and students receiving VA education benefits,
regarding the roles of school certifying officials. We assessed VA's
coordination with these officials using government internal control
standards for coordinating with external parties that have a
significant impact on agency goals. We also assessed VA's survey of
SAAs and school certifying officials on the effectiveness of VA's
communications and training initiatives for the Post-9/11 GI Bill. The
survey was fielded in August 2009 and again in April 2010. We
determined that the results of this survey were not sufficiently
reliable for our use, due to a low response rate and the lack of a
nonresponse analysis.
In addition, we selected a simple random sample of 273 facilities from
VA's public Web Enabled Approval Management System (WEAMS) database of
6,403 active facilities, as of August 2010, and conducted a Web-based
survey of each facility's school certifying official. "Facility"
refers to a school or one of its campuses or units, such as a medical
school. In order to be an "active facility," a facility must have at
least one educational or training program approved to receive VA
education benefits. We matched this public data with internal VA data
from the same system to obtain the facility code and names of the
school certifying official assigned to the facility. We assessed the
reliability of WEAMS data by reviewing documentation and interviewing
officials knowledgeable about the data, and conducting electronic
testing. We determined that the data from the WEAMS database were not
sufficiently reliable for our purposes, primarily due to missing data
on school certifying officials, and thus we conducted additional work
to overcome this limitation. Specifically, VA has not required that
all fields be populated, and, as a result, there are fields with
missing information, including the school certifying official's name
and e-mail address fields. Twenty-seven percent of the facilities in
our sample had either an incorrect name listed or no name listed for
the school certifying official. To improve the accuracy and
completeness of the data, we conducted additional research, including
performing Internet searches and making telephone calls to schools, to
obtain complete contact information for nearly all school certifying
officials.[Footnote 90]
Although they are not required to do so, schools may request to have
multiple facilities listed separately in VA's WEAMS database to
account for different campus locations or degree programs within the
school. Each facility listed separately must have a designated school
certifying official and the capacity to maintain students' records. In
some cases, a school may have the same school certifying official for
several or all of its facilities. Our sample included three facilities
within a school that had the same school certifying official. In this
case, we contacted the official to determine whether the official
preferred to complete all three questionnaires or ask another school
certifying official at the campus to participate. The official
responded to two of the questionnaires and designated another school
certifying official to respond to the third questionnaire.
After we drafted the questionnaire, we asked for comments from
knowledgeable school certifying officials, internal GAO subject matter
experts, and GAO survey methodologists. We conducted four pretests
with school certifying officials to help ensure that (1) the questions
were clear and unambiguous, (2) terminology was used correctly, (3)
the questionnaire did not place an undue burden on agency officials,
(4) the information could feasibly be obtained, and (5) the survey was
comprehensive and unbiased.
We chose the four pretest sites to include major subgroups: public and
private institutions; community colleges and 4-year colleges and
universities; and locations across a wide geographic area. We
conducted one pretest in person and three over the phone. We made
changes to the content and format of the questions after each of the
pretests, based on the feedback we received.
We administered this Web-based questionnaire through a secure server.
Just prior to activating the final survey, we sent an e-mail
announcement of the survey to an official at each of the 273
facilities on August 23, 2010. In this e-mail, we asked each official
if he or she was the correct respondent and if not, we asked for a
referral to the appropriate official. Officials were notified that the
questionnaire was available online and were given unique passwords and
usernames on August 27, 2010. We sent follow-up e-mail messages on
September 13 and 22, 2010, to those who had not yet responded. We
contacted all remaining nonrespondents by telephone, starting
September 20, 2010. The questionnaire was available online until
October 7, 2010.
In all, we received 195 completed surveys, for a response rate of 71
percent. We conducted a nonresponse bias analysis by comparing
respondents and nonrespondents on school type, which was available in
the WEAMS data. We determined that respondents and nonrespondents did
not differ significantly on this characteristic. Unless otherwise
noted, the margin of error associated with the confidence intervals of
our survey estimates is no more than plus or minus 7 percentage points
at the 95 percent level of confidence.
Survey results based on probability samples are subject to sampling
error. The sample we drew for our survey is only one of a large number
of samples we might have drawn. Because different samples could have
provided different estimates, we express our confidence in the
precision of our particular sample results as a 95 percent confidence
interval. This is the interval that would contain the actual
population values for 95 percent of the samples we could have drawn.
As a result, we are 95 percent confident that each of the confidence
intervals in this report will include the true values in the study
population.
In addition to sampling errors, surveys are also subject to
nonsampling errors. The practical difficulties of conducting any
survey may introduce such errors. For example, difficulties in how a
particular question is interpreted, in the sources of information that
are available to respondents, and in how the data are entered into a
database or are analyzed can introduce unwanted variability into
survey results. We took steps in the development of the questionnaire,
the data collection, and the data analysis to minimize these errors.
For example, a social science survey specialist designed the
questionnaire, in collaboration with GAO staff with subject matter
expertise. As we mentioned earlier, the draft questionnaire was
pretested and was reviewed by experts in the subject matter area and
by a second GAO social science analyst. When data were analyzed, an
independent analyst verified the statistical program used for the
analysis. Since this was a Web-based survey, respondents entered their
answers directly into the electronic questionnaire, thereby
eliminating the need to have the data keyed into a database and
avoiding data entry errors.
VA Oversight of States and Schools:
Finally, to address our third research objective, we reviewed relevant
federal laws and regulations, as well as available reports and other
information that offered a national perspective on VA's oversight of
SAAs and schools and interviewed VA officials. We also interviewed
representatives from national organizations representing SAAs and
school officials. Regarding oversight of SAAs, we obtained and
reviewed the contract between VA and its 57 SAAs for fiscal year 2010.
In addition, we reviewed the state-by-state results of VA's Joint Peer
Review Group from fiscal years 2009 and 2010, which annually evaluates
SAA performance. We also obtained data from VA on the number of SAA
supervisory visits to schools, by state, in fiscal years 2009 and
2010. Regarding oversight of schools, we obtained data on the number
of VA audits, known as compliance surveys, conducted in fiscal years
2009 and 2010. Finally, we reviewed national data on these audits from
VA's WEAMS database.
In addition to national reports and data, we examined VA's monitoring
and oversight activities in four states: California, Georgia,
Kentucky, and Massachusetts. We selected these states for a number of
reasons, including geographic location, as well as to obtain variation
in: (1) the number of schools within a state that have been approved
to participate in VA education benefit programs, (2) program
expenditures, and (3) the number of VA education beneficiaries. In
addition, we made sure that one of our four states (Kentucky) had a VA
education liaison representative based at a VA office located outside
of the assigned state, as this is the situation for 17 states. For
each of the four states, we conducted interviews with relevant VA and
SAA officials and reviewed the most recent oversight reports from VA
and the SAA for randomly selected schools. We used VA's WEAMS data to
randomly select 12 schools for each of our four states, using their
numeric facility codes: two public, two private nonprofit, and two
private for-profit schools in each of the following two categories: 2-
year community or junior colleges and colleges and universities
offering 4-year degrees and graduate degrees. We found that some of
our selected schools did not have a current SAA supervisory visit or
VA compliance survey report on file because it was a newly approved
school and had not yet been scheduled for either one or both of these
types of site visits (see table 6). Overall, we reviewed 43 SAA
supervisory visit reports and 40 VA compliance survey reports.
Table 6: Summary of the Number of SAA Supervisory Visit and VA
Compliance Survey Reports at Selected Schools in Four States:
State: California;
SAA Supervisory Visit Reports: Reviewed reports from 10 out of 12
selected schools:
* Two (2) newly approved schools did not yet have a report on file.
These schools included: one private, nonprofit 2-year community or
junior college and one private, for-profit college or university
offering 4-year degrees and graduate degrees;
VA Compliance Survey Reports: Reviewed reports from 10 out of 12
selected schools:
* Two (2) newly approved schools did not yet have a report on file.
These schools included: one private, nonprofit 2-year community or
junior college and one private, for-profit college or university
offering 4-year degrees and graduate degrees.
State: Georgia;
SAA Supervisory Visit Reports: Reviewed reports from 12 out of 12
selected schools;
VA Compliance Survey Reports: Reviewed reports from 10 out of 12
selected schools;
* Two (2) newly approved schools did not yet have a report on file.
These schools included one private, for-profit 2-year community or
junior college; and one private, for-profit college or university
offering 4-year degrees and graduate degrees.
State: Kentucky[A];
SAA Supervisory Visit Reports: Reviewed reports from 9 out of 10
selected schools;
* One (1) newly approved private, for-profit 2-year community or
junior college did not yet have a report on file;
VA Compliance Survey Reports: Reviewed reports from 9 out of 10
selected schools;
* One (1) newly approved private, for-profit 2-year community or
junior college did not yet have a report on file.
State: Massachusetts;
SAA Supervisory Visit Reports: Reviewed reports from 12 out of 12
selected schools;
VA Compliance Survey Reports: Reviewed reports from 11 out of 12
selected schools;
* One (1) private, for-profit 2-year community or junior college did
not yet have a report on file.
State: Total number of reports reviewed;
SAA Supervisory Visit Reports: 43 reports;
VA Compliance Survey Reports: 40 reports.
Source: GAO analysis of SAA and VA reports.
[A] In Kentucky, we selected 10 schools because this state does not
have any private, nonprofit 2-year community or junior colleges that
are approved to receive VA's education benefits.
[End of table]
Overall, we compared VA's policies and procedures related to its
monitoring and oversight of SAAs and schools to government internal
control standards.[Footnote 91] In addition, we compared VA's
oversight performance in relation to its own standards. For example,
we examined data on the percentage of VA audits, known as compliance
surveys, against its requirement to conduct these audits at a
percentage of active schools and training establishments each year.
Overall, among all the different types of schools--including on-the-
job training and apprenticeship programs, as well as flight schools--
VA has an annual goal to complete a minimum number of required
compliance surveys.[Footnote 92] We compared the percentage of
completed surveys for regional processing offices and individual
states against this standard to assess VA's performance in fulfilling
their oversight responsibilities in fiscal year 2009. Finally, we
reviewed reports and other information on Education's Office of
Federal Student Aid's oversight efforts of schools, in order to
identify alternative oversight approaches and mechanisms used by
another federal agency responsible for administering student aid.
[End of section]
Appendix II: Overview of Post-9/11 Veterans Educational Assistance
Improvements Act of 2010:
On January 4, 2011, the President signed the Post-9/11 Veterans
Educational Assistance Improvements Act of 2010,[Footnote 93] which
revises the Post-9/11 GI Bill program, established in 2008. Some major
provisions of the new law are summarized below:
Eligibility of servicemembers and veterans:
* Expands current definition of active duty service under the Post-
9/11 GI Bill to include National Guard activation for events like
national emergencies. § 101(a)(1), 124 Stat. 4107 (to be codified at
38 U.S.C. § 3301(1)(C)). This provision is retroactive to August 1,
2009, but benefits will not be paid until October 1, 2011. §
101(d)(1), 124 Stat. 4108.
Eligible programs:
* Allows payment of benefits for the pursuit of non-degree granting
programs including apprenticeships or other on-the-job training,
flight training, or training by correspondence. § 105(b), 124 Stat.
4113-17 (to be codified at 38 U.S.C. § 3313(g)). This provision
becomes effective October 1, 2011. § 105(d), 124 Stat. 4117.
Amount of benefit payments:
* Replaces the current state-by-state system of limits on payments to
institutions of higher education with a two-tiered payment system.
Costs of in-state tuition and fees are covered for public schools.
Tuition and fee payments are capped at $17,500 a year for non-public
or foreign schools. § 102(a)(1), 124 Stat. 4108-09 (to be codified at
38 U.S.C. § 3313(c)(1)(A)). This provision becomes effective with
respect to distance learning on October 1, 2011, and otherwise on
August 1, 2011. § 102(c), 124 Stat. 4110.
* Provides for payment of tuition and fees after the application of
any waiver of, or reduction in tuition and fees; and any scholarship
or other federal, state, institutional, or employer-based assistance.
§ 102(a)(1)(B) and 103(a)(2)(D), 124 Stat. 4110-11 (to be codified at
38 U.S.C. § 3313(c)(1)(A) and (e)(2)(A)). This provision becomes
effective August 1, 2011, with respect to veterans, but March 5, 2011,
with respect to active duty personnel. § 102(c)(1) and 103(c)(1), 124
Stat. 4112.
* Provides the monthly housing allowance for (1) more than half-time
study in pursuit of a degree; (2) pursuing a program of education in a
foreign country; and (3) more than half-time study solely by distance
learning. Limits the monthly housing stipend by prorating the payment
to the rate of pursuit (based on number of course hours taken). For
example a half-time student will receive 50 percent of the current
housing allowance. § 102(b), 124 Stat. 4109-10 (to be codified at 38
U.S.C. § 1330(c)(1)(B)). Individuals pursuing distance learning
exclusively will receive half of the housing allowance to which they
would otherwise be entitled. This provision becomes effective with
respect to distance learning on October 1, 2011, and otherwise on
August 1, 2011. § 102(c), 124 Stat. 4110.
* Provides a books and supplies stipend for individuals on active duty
pursuing a program of education more than half-time. § 103(a)(2)(E),
124 Stat. 4111 (to be codified at 38 U.S.C. 3313(e)(2)(B)). This
provision becomes effective on October 1, 2011. 103(c)(2), 124 Stat.
4112.
Servicemembers and veterans with disabilities:
* Enables individuals who are entitled to the Vocational
Rehabilitation and Employment program and the Post-9/11 GI Bill to
receive the Post-9/11 GI Bill housing allowance in place of the
Vocational Rehabilitation and Employment subsistence allowance. §
205(a), 124 Stat. 4126 (to be codified at 38 U.S.C. § 3108(b)(4)).
This provision becomes effective on August 1, 2011. § 205(b), 124
Stat. 4126.
Role of State Approving Agencies (SAA):
* Grants the Secretary of Veterans Affairs the authority to use SAAs
for such compliance and oversight purposes as it considers
appropriate. § 203(b), 124 Stat. 4125 (to be codified at 38 U.S.C. §
3673(d)). This provision becomes effective on August 1, 2011. §
203(e), 124 Stat. 4126.
Other provisions:
* Allows certain education and training programs and courses with an
existing approval from or offered by certain federal, state or local
agencies--such as institutions accredited by agencies recognized by
the U.S. Department of Education--to automatically receive approval
for VA's education benefit programs. § 203(a), 124 Stat. 4124-25 (to
be codified at 38 U.S.C. § 3672(b)(2)). This provision becomes
effective on August 2011. § 203(e), 124 Stat. 4126.
* Increases the amount of fees generally paid by the VA to
participating educational institutions from $7 to $12 per student for
providing information concerning an individual's enrollment in a
program of education. § 204(a), 124 Stat. 4126 (to be codified at 38
U.S.C. § 3684(c)). Requires institutions to use these fees solely for
making such certifications or for otherwise supporting programs for
veterans. § 204(b), 124 Stat. 4126 (to be codified at 38 U.S.C. §
3684(c)). These provisions become effective on October 1, 2011. §
204(c), 124 Stat. 4126.
[End of section]
Appendix III Comparison of VA Education Benefit Programs:
Program name: Post-9/11 GI Bill; (enacted 2008)[A];
Purpose: Provides individuals with active-duty service after September
10, 2001, tuition and fees, housing allowance, and books and supplies
stipend. Benefit amounts are based on length of active-duty service,
the location of the school attended, and other factors. For example,
in the 2010-2011 academic year, a veteran with 36 months of active-
duty service taking 12 credits at a school in Fairfax, VA, can receive
up to $4,242 per term for tuition, up to $3,969 per term in fees,
$1,941 per month for housing, and up to $1,000 per year for books and
supplies;
Education programs covered and types of payments: Eligible Programs
and Training:
* Institutions of higher learning;
* One licensing or certification exam (e.g., to become a licensed
practical nurse or plumber);
* Tutorial assistance;
Types of Payments;
* Tuition and fees;
* Housing allowance;
* Books and supplies stipend;
* One-time rural relocation allowance;
FY 2010 (Estimated): Expenditures: $7.4 billion;
FY2011 (Estimated): Participants: 461,676;
Expenditures: $8.6 billion;
Participants: 510,149.
Program name: Montgomery GI Bill-Active Duty (MGIB-AD); (enacted 1984);
Purpose: Provides a monthly benefit to four categories of individuals
based on service in active or reserve components of the Armed Forces.
The amount is the same, regardless of where a school is located. In
fiscal year 2011, the benefit is $1,426 per month for full-time
study[B];
Education programs covered and types of payments: Eligible Programs
and Training:
* Institutions of higher learning;
* Non-college degree programs;
* Apprenticeship and on-the-job training;
* Flight training;
* Correspondence courses;
* Licensing and certification exams;
* Tutorial assistance;
Types of Payments:
* One monthly payment for subsistence, tuition and fees, supplies,
books, and equipment;
FY 2010 (Estimated): Expenditures: $574 million[B];
FY2011 (Estimated): Participants: 63,500[B];
Expenditures: $434 million;
Participants: 40,630.
Program name: Montgomery GI Bill-Selected Reserve (MGIB-SR); (enacted
1984);
Purpose: Provides a monthly benefit payment for Reservists, including
the National Guard, who agree to serve for 6 years. In fiscal year
2011, the benefit is $337 per month for full-time study;
Education programs covered and types of payments: Eligible Programs
and Training:
* Institutions of higher learning;
* Non-college degree programs;
* Apprenticeship and on-the-job training;
* Flight training;
* Correspondence courses;
* Licensing and certification exams;
* Tutorial assistance;
Types of Payments:
* One monthly payment for subsistence, tuition and fees, supplies,
books, and equipment;
FY 2010 (Estimated): Expenditures: $245 million;
FY2011 (Estimated): Participants: 93,886;
Expenditures: $274 million;
Participants: 103,581.
Program name: Reserve Educational Assistance Program (REAP); (enacted
2004);
Purpose: Provides benefits to Reservists with at least 90 days of
consecutive active-duty service after September 10, 2001. In fiscal
year 2011, the benefit is $1,140.80 per month for full-time study,
with at least 2 years of consecutive active-duty service;
Education programs covered and types of payments: Eligible Programs
and Training:
* Institutions of higher learning;
* Non-college degree programs;
* Apprenticeship and on-the-job training;
* Flight training;
* Correspondence courses;
* Licensing and certification exams;
* Tutorial assistance;
Types of Payments:
* One monthly payment for subsistence, tuition and fees, supplies,
books, and equipment;
FY 2010 (Estimated): Expenditures: $61 million;
FY2011 (Estimated): Participants: 14,514;
Expenditures: $56 million;
Participants: 13,379.
Sources: Congressional Research Service, Educational Assistance
Programs Administered by the U.S. Department of Veterans Affairs, 7-
5700 (Washington, D.C.: Feb. 1, 2010); and VA documents.
Note: Although VA has published data on the total expenditures for VA
education benefits and the number of participants for FY 2010, those
data are not broken out by program. As such, we are presenting VA's FY
2010 budget estimates in the table above.
[A] On January 4, 2011, the President signed the Post-9/11 Veterans
Educational Assistance Improvements Act of 2010 (Pub. L. No. 111-377),
which revises the Post-9/11 Veterans Educational Assistance Act
enacted in 2008 (known as the Post-9/11 GI Bill). See appendix II for
a summary of the major provisions of the new law.
[B] The maximum monthly benefit amounts for VA education benefits
other than the Post-9/11 GI Bill will be adjusted annually based on
the annual average cost of undergraduate tuition as determined by the
National Center for Education Statistics (NCES).
[C] Estimated costs for MGIB-AD includes costs for the Post-Korean
Conflict and Vietnam Era GI Bill (ch. 34).
[End of table]
[End of section]
Appendix IV: Comments from the U.S. Department of Veterans Affairs:
Department Of Veterans Affairs:
Washington DC 20420:
February 9, 2011:
Mr. Daniel Bertoni:
Director, Education, Workforce and Income Security Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Bertoni:
The Department of Veterans Affairs (VA) has reviewed the Government
Accountability Office's (GAO) draft report, "VA Education Benefits:
Actions Taken, but Outreach and Oversight Could Be Improved" (GA0-11-
256). VA generally agrees with GAO's conclusions and concurs with four
recommendations and concurs in principle with one recommendation to
the Department.
The enclosure specifically addresses GAO's recommendations. VA
appreciates the opportunity to comment on your draft report.
Sincerely,
Signed by:
John R. Gingrich:
Chief of Staff:
Enclosure:
[End of letter]
Enclosure:
Department of Veterans Affairs (VA) Comments to Government
Accountability Office (GAO) Draft Report:
VA Education Benefits: Actions Taken, but Outreach and Oversight Could
Be Improved (GA0-11-256):
GAO Recommendation: To improve VA's outreach and support of eligible
service members and veterans, communication with school officials, and
oversight of its education benefits program, we recommend that the
Secretary of Veterans Affairs take the following five actions:
Recommendation 1: Develop outcome-oriented performance measures for
outreach to service members and veterans who are seeking VA education
benefits. This could include measures of VA's success in reaching out
to target populations, including service members and veterans with
disabilities, and in addressing areas where more information about
education benefits may be needed.
VA Response: Concur. The Veterans Benefits Administration's (VBA)
Benefits Assistance Service (BAS), through the eBenefits portal, is
creating an early communication tool to provide specialized VA benefit
information to Servicemembers and Veterans upon various trigger
events. These events may include when eligibility may occur for VA
benefits or services such as transfer of entitlement to the Post 9/11
GI Bill. BAS will develop performance measures associated with the early
communication tool. Anticipated deployment of the tool is scheduled
for June 30, 2011, and performance measure implementation for
September 30, 2011.
Recommendation 2: Establish performance measures for the quality of
information provided by VA's toll-free hotline and for the timeliness
and quality of its Right Now Web service.
VA Response: Concur. VBA's Education Service will develop a national
standard and policies for monitoring the quality and timeliness of
customer service. Target Completion Date: December 31, 2011.
Recommendation 3: Provide more timely, accessible, and comprehensive
education program policy information. This could include developing
and maintaining an online policy manual for the Post-9/11 GI Bill and
providing e-mail updates to school certifying officials nationwide.
VA Response: Concur. During upcoming meetings with school certifying
officials and other stakeholders, VBA will assess and develop a plan
for improved timely, accessible, and comprehensive education program
policy information dissemination. Target Completion Date: June 30,
2011.
Recommendation 4: Increase efforts to make school certifying officials
aware of available training opportunities, including VA's online
training module, and consider providing information for school
certifying officials on working with service members and veterans with
disabilities.
VA Response: Concur. VBA will examine the ways in which training
opportunities and knowledge are currently relayed to school certifying
officials and look for improvements and alternative mechanisms of
contact (e.g., the GI Bill Web site, the VA-Once Web site, etc.) in
addition to the traditional Education Liaison Representative/Chief
Education Liaison Officer method. Target Completion Date: March 31,
2011.
Recommendation 5: Undertake a systematic review of VA's and SAAs'
oversight of schools, focusing on opportunities to improve resource
allocation, adopt risk-based approaches, consider cost-effective ways
to oversee foreign schools, and evaluate the results of its oversight
activities on a routine basis.
VA Response: Concur in principle. VBA previously identified the same
issue and addressed the concern through recent acquisition of an
independent assessment of the state approving agencies' (SAA) activity
by a private contractor. Additionally, VA submitted recommended
changes to the SAAs' activity as part of its legislative proposal
package submitted to Congress in March 2010. Congress enacted
provisions of this proposal as part of Public Law 111-377. These
changes reduce the SAAs' responsibilities for school approval by
allowing VA to rely on accreditations already in place by the
Department of Education. As a result, VA will have more flexibility in
how to best utilize the SAAs to provide additional outreach, training,
and oversight to school officials. These provisions will be effective
August 1, 2011.
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Daniel Bertoni (202) 512-7215 or bertonid@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, the following staff members
made important contributions to this report: Brett Fallavollita,
Assistant Director; Rachael C. Valliere, Analyst in Charge; Dana
Hopings; Heddi Nieuwsma; and Max Yurkofsky. Also, Greg Wilmoth, Stu
Kaufman, Carl Barden, and Cathy Hurley provided guidance on the
study's design and data analysis; Craig Winslow provided legal advice;
and James Bennett created the report graphics. In addition, Susannah
Compton advised the team on writing the report; and Joel Green, James
Lloyd, Wayne Sylvia, Eve Weisberg, and Amber Yancey-Carroll verified
our findings.
[End of section]
Footnotes:
[1] According to VA's 2010 Performance and Accountability Report, the
$9 billion includes benefits for more than 77,000 participants in the
Vocational Rehabilitation and Employment program.
[2] Pub. L. No. 110-252, tit. V, 122 Stat. 2323, 2357-87 (to be
codified at 10 U.S.C. §§ 16132a and 16163a, and 38 U.S.C. §§ 3015,
3020, 3301-3324, and 3674).
[3] The law defines an "institution of higher learning" as an
institution offering postsecondary level academic instruction that
leads to an associate or higher degree if the school is empowered by
the appropriate state education authority under state law to grant an
associate or higher degree, or in the absence of a state education
authority if the school is accredited for degree programs by a
recognized accreditor. 38 U.S.C. §§ 3313(b) and 3452(f). Institutions
of higher learning can also be hospitals offering educational programs
at the postsecondary level and recognized foreign educational
institutions that offer courses leading to a standard college degree,
or the equivalent. For the purposes of this report, we refer to
institutions of higher learning as "schools." SAAs are state agencies
that are responsible for reviewing and approving schools for
participation in VA education benefit programs.
[4] These programs include the Post-9/11 GI Bill, the Montgomery GI
Bill-Active Duty, the Montgomery GI Bill-Selected Reserve, and the
Reserve Educational Assistance Program. Although potentially eligible
for multiple programs, individuals cannot receive benefits from more
than one VA education program at the same time. 38 U.S.C. § 3322. VA
also has two other programs: (1) the Survivors' and Dependents'
Educational Assistance Program, which provides benefits to the spouse
and children of servicemembers who, as a result of service, are
seriously disabled, die, or are detained (38 U.S.C. §§ 3500-3566), and
(2) the Marine Gunnery Sergeant John David Fry Scholarship, which
provides Post-9/11 GI Bill benefits for children of servicemembers who
die in the line of duty on or after Sept. 11, 2001(Act of June 24,
2009, Pub. L. No. 111-32, § 1002, 123 Stat. 1859, 1889-90) (to be
codified at 38 U.S.C. § 3311(b)(9) and (f)). However, we did not
include these programs within the scope of this review.
[5] 38 U.S.C. § 3104(a)(2).
[6] Pub. L. No. 103-62, 107 Stat. 285.
[7] See GAO, Tax Administration: IRS Needs to Further Refine Its Tax
Filing Season Performance Measures, [hyperlink,
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22,
2002).
[8] We selected these schools because they represented different types
of schools (2-year community college and 4-year public university,
respectively) with relatively high veteran populations.
[9] "Facility" refers to a school or one of its campuses or units,
such as a medical school.
[10] All estimates from our survey have a margin of error of plus or
minus 7 percentage points, unless otherwise noted, at the 95 percent
confidence level.
[11] We used VA data to randomly select 12 schools for each state: 2
public, 2 private nonprofit, and 2 private for-profit schools in each
of the following two categories: (1) 2-year community or junior
colleges and (2) colleges and universities offering 4-year degrees and
graduate degrees. In Kentucky, we selected 10 schools because this
state does not have any private, nonprofit 2-year community or junior
colleges that are approved to receive VA's education benefits.
[12] GAO, 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).
[13] 38 U.S.C. §§ 3311 and 3313.
[14] Under the Post-9/11 Veterans Educational Assistance Improvements
Act of 2010, individuals pursuing distance learning half-time or more
will be eligible for a portion of the housing allowance. Pub. L. No.
111-377, § 102(b), 124 Stat. 4109-10 (2011) (to be codified at 38
U.S.C. § 3313(c)(1)(B)). See appendix II.
[15] Under the Post-9/11 Veterans Educational Assistance Improvements
Act of 2010, individuals on active duty pursuing a program of
education more than half-time will be eligible for a books and
supplies stipend. § 103(a)(2)(E), 124 Stat. 4111 (2011) (to be
codified at 38 U.S.C. § 3313(e)(2)(B)). See appendix II.
[16] By regulation, "fees" are defined as any mandatory charges (other
than tuition, room, and board) that are applied by the institution of
higher learning for pursuit of an approved program of education. 38
C.F.R. § 21.9505 (2009). Fees include, but are not limited to, health
premiums, freshman fees, graduation fees, and lab fees. Fees do not
include those charged for a study abroad course(s) unless the
course(s) is a mandatory requirement for completion of the approved
program of education. The Post-9/11 Veterans Educational Assistance
Improvements Act of 2010 will eliminate the state maximum tuition and
fee rates, and cap the tuition and fee benefits for private and
foreign schools at $17,500 per year. § 102(a)(1), 124 Stat. 4108-09
(to be codified at 38 U.S.C. § 3313(c)(1)). See appendix II.
[17] According to VA, all undergraduate program costs were taken into
consideration to determine the highest in-state maximum tuition per
credit hour and the maximum fees per term. As a result, the
calculation of these rates may include the tuition for high cost
programs, such as flight courses taken as part of a degree requirement
or undergraduate pharmacy, nursing, and engineering charges.
[18] Through the Yellow Ribbon G.I. Education Enhancement Program,
which is part of the Post-9/11 GI Bill, schools enter into agreements
with VA to pay a portion of the tuition and fees that exceed an
individual's Post-9/11 GI Bill benefit. 38 U.S.C. § 3317. VA matches
the schools' contribution.
[19] 38 U.S.C. §§ 3002, 3034(d), 3241(b), and 3491. Non-college degree
programs and flight schools may be eligible for Post-9/11 GI Bill
benefits if they are offered at an institution of higher learning. The
Post-9/11 Veterans Educational Assistance Improvements Act of 2010
will allow individuals receiving Post-9/11 GI Bill benefits to pursue
non-degree granting programs including resident training, distance
learning, apprenticeships or other on-the-job training, flight
training or correspondence training. § 105(b), 124 Stat. 4113-17 (to
be codified at 38 U.S.C. § 3313(g)). See appendix II.
[20] Veterans' Educational Assistance Act of 1984, Pub. L. No. 98-525,
§ 702, 98 Stat. 2492, 2553-63, (codified as amended at 38 U.S.C. §§
3001-3036). The New GI Bill Continuation Act renamed the Veterans'
Educational Assistance Act of 1984 the Montgomery GI Bill Act of 1984.
Pub. L. No. 100-48, §2, 101 Stat. 331, 331. (1987) (codified at 38
U.S.C. § 101 note).
[21] Veterans' Educational Assistance Act of 1984, Pub. L. No. 98-525,
§ 705, 2492, 2564-67 (codified as amended at 10 U.S.C.§§ 16131-16137).
The New GI Bill Continuation Act renamed the Veterans' Educational
Assistance Act of 1984 the Montgomery GI Bill Act of 1984. Pub. L. No.
100-48, §2, 101 Stat. 331, 331 (1987) codified at 38 U.S.C. § 101
note).
[22] Ronald W. Reagan National Defense Authorization Act for Fiscal
Year 2005, Pub. L. No. 108-375, § 527(a), 118 Stat. 1811, 1890-94
(2004) (codified as amended at 10 U.S.C. 16161-16166).
[23] 10 U.S.C. §§ 16131(c)(2) and 16162(d)(1), and § 38 U.S.C. §§
3013(e) and 3312. Servicemembers and veterans can combine benefits
with other VA education benefits and receive up to 48 months of
education benefits, but benefits cannot be received concurrently, and
the eligibility periods cannot overlap. 38 U.S.C. § 3694.
[24] 38 U.S.C. § 3321(a).
[25] 38 U.S.C. § 3031(a). One exception is the Montgomery GI Bill-
Selected Reserve. Reservists must generally use this benefit while
still serving in the reserves, unless the separation is because of a
disability. 10 U.S.C. § 16164.
[26] 38 U.S.C. § 3319. While the service branches are authorized to
allow servicemembers in the Montgomery GI Bill-Active Duty, Montgomery
GI Bill-Selected Reserve and the Reserve Educational Assistance
Program to transfer benefits to dependents (38 U.S.C. § 3020), only
the Army has offered such an option under the Montgomery GI Bill-
Active Duty.
[27] Servicemembers who have already served a 6-year commitment must
agree to serve 4 additional years in the military to be able to
transfer benefits. Servicemembers who have already served 10 years but
are precluded from serving an additional 4 years can agree to serve
the maximum additional years allowable.
[28] Pub. L. No. 111-377, 124 Stat. 4106 (2011).
[29] Post-traumatic stress disorder symptoms can be debilitating and
include insomnia; intense anxiety; and difficulty coping with work,
social, and family relationships. Symptoms may appear within months of
the traumatic event or be delayed for years. Left untreated, post-
traumatic stress disorder can lead to substance abuse, severe
depression, and suicide.
[30] To receive VR&E services, veterans with disabilities generally
must have a 20 percent disability rating from VA and an employment
handicap. Veterans with a 10 percent disability rating may also be
entitled to receive services if they have a serious employment
handicap. In addition, injured servicemembers may be eligible for VR&E
services before being discharged from the military if they request a
"memorandum rating" from VA and have one or more service-connected
disabilities that are 20 percent or higher. VR&E vocational
rehabilitation counselors determine entitlement to services, which
generally provides a 12-year period of eligibility and up to 48 months
of benefits.
[31] GAO, VA Vocational Rehabilitation and Employment: Better
Incentives, Workforce Planning, and Performance Reporting Could
Improve Program, [hyperlink, http://www.gao.gov/products/GAO-09-34]
(Washington, D.C.: Jan. 26, 2009).
[32] Under the Post-9/11 Veterans Educational Assistance Improvements
Act of 2010, individuals receiving VR&E benefits will be permitted to
elect to receive the Post-9/11 GI Bill housing allowance in lieu of
the VR&E allowance. § 205, 124 Stat. 4126 (to be codified at 38 U.S.C.
§ 3108(b)(4)). See appendix II.
[33] The Post-9/11 Veterans Educational Assistance Improvements Act of
2010 will limit SAAs' approval functions. § 203(a), 124 Stat. 4124-25
(to be codified at 38 U.S.C. § 38 U.S.C. § 3672(b)). Specifically,
under the law, certain programs--such as those at schools that are
accredited by agencies recognized by the Department of Education--will
be deemed approved for VA education benefits. See appendix II.
[34] 38 U.S.C. §§ 3671-3679.
[35] 20 U.S.C. §§ 1001-1140d.
[36] Under the Post-9/11 Veterans Educational Assistance Improvements
Act of 2010, the fee will be increased from $7 to $12 per student. §
204(a), 124 Stat. 4126 (to be codified at 38 U.S.C. § 3684(c)). See
appendix II.
[37] This capability was initially scheduled for December 2010.
However, due to delays in implementing its long-term information
technology solution for processing Post-9/11 GI Bill claims, VA
reported that it will provide this functionality in a future release
of the system or as a separate initiative. See GAO, Information
Technology: Veterans Affairs Can Further Improve Its Development
Process for Its New Education Benefits System, GAO-11-115 (Washington,
D.C.: Dec. 1, 2010).
[38] The 95 percent confidence interval for this estimate is (67.7,
80.0).
[39] In comparison to the average wait time measure, the average speed
to answer measure will not include calls that were abandoned.
[40] The 95 percent confidence interval for this estimate is (68.6,
80.7).
[41] Individuals with service-connected disabilities may be eligible
for the maximum Post-9/11 GI Bill benefits with as few as 30
continuous days on active duty.
[42] A VR&E official told us that, like TAP, DTAP is also being
redesigned to be more effective.
[43] However, under the Post-9/11 Veterans Educational Assistance
Improvements Act of 2010, individuals receiving VR&E benefits may
elect to receive the Post-9/11 GI Bill housing allowance in lieu of
the VR&E allowance. See appendix II.
[44] In fiscal year 2010, VA also established a National Outreach
Office to coordinate outreach agencywide.
[45] 38 U.S.C. § 6308.
[46] A senior VA official told us that the agency will be revising
this biennial outreach report after fiscal year 2010 to provide more
information on the effectiveness of VA's outreach.
[47] GAO, Digital Television Transition: Increased Federal Planning
and Risk Management Could Further Facilitate the DTV Transition,
[hyperlink, http://www.gao.gov/products/GAO-08-43] (Washington, D.C.:
Nov. 19, 2007).
[48] GAO, Tax Administration: IRS Needs to Further Refine Its Tax
Filing Season Performance Measures, [hyperlink,
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22,
2002).
[49] Education's Office of Federal Student Aid officials reported that
it monitors a minimum of 1 percent of all interactions per month. Of
those interactions monitored, 95 percent must be error-free. Office of
Federal Student Aid officials reported that they do not make their
standards, which are standards for contractor performance, available
to customers because they were not intended to inform the public. See
GAO, Managing for Results: Opportunities to Strengthen Agencies'
Customer Service Efforts, [hyperlink,
http://www.gao.gov/products/GAO-11-44] (Washington, D.C.: Oct. 27,
2010).
[50] The 95 percent confidence interval for this estimate is (77.1,
88.1).
[51] The 95 percent confidence interval for this estimate is (43.5,
57.5).
[52] The 95 percent confidence interval for this estimate is (33.1,
46.7).
[53] The 95 percent confidence interval for this estimate is (57.8,
71.1).
[54] VA officials cautioned that these numbers may not be unique
counts of participants, as an individual may be counted as receiving
benefits under two different programs.
[55] The 95 percent confidence interval for this estimate is (55.6,
69.1).
[56] The 95 percent confidence interval for this estimate is (26.6,
39.7).
[57] The 95 percent confidence interval for this estimate is (25.8,
38.8).
[58] The 95 percent confidence interval for this estimate is (17.2,
28.9).
[59] VA officials told us that the agency does not currently plan to
develop a policy manual on the Post-9/11 GI Bill for school certifying
officials, but would consider developing one if they saw a need.
[60] Under the Post-9/11 Veterans Educational Assistance Improvements
Act of 2010, school officials will have to deduct scholarships and
state, institutional, and employer-based aid, in addition to non-Title
IV federal aid. See appendix II.
[61] The 95 percent confidence interval for this estimate is (58.7,
71.9).
[62] The 95 percent confidence interval for this estimate is (79.0,
89.7).
[63] The 95 percent confidence interval for this estimate is (65.4,
78.0).
[64] The 95 percent confidence interval for this estimate is (77.6,
88.5).
[65] The 95 percent confidence interval for this estimate is (52.3,
66.2).
[66] As mentioned earlier, under the Post-9/11 Veterans Educational
Assistance Improvements Act of 2010, some programs will be deemed
approved for benefits and, therefore, will not need to be approved by
SAAs. See appendix II.
[67] Some states have more than one SAA with separate responsibilities
to approve specific types of programs, such as on-the-job and
apprenticeship programs.
[68] VA only requires SAAs to conduct site visits at active schools
(i.e., approved schools with at least one VA education beneficiary
enrolled).
[69] VA can require SAAs to visit individual schools with known
problems during a given year.
[70] Government internal control standards call for management to
comprehensively identify risks and consider all significant
interactions between the entity and other parties. For example, risk
identification methods could include considering findings from audits
and other assessments. GAO, 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).
[71] SAAs in our four states generally did not review more than 15
student files, regardless of the number of VA education beneficiaries.
[72] Government internal control standards call for the separation of
key duties and responsibilities among different people to reduce the
risk of error or fraud, such as responsibilities for reviewing
transactions. [hyperlink,
http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[73] 38 U.S.C. § 3693.
[74] According to VA officials, as of fall 2010, there were
approximately 152 active foreign schools that had at least one VA
education beneficiary.
[75] During these audits, VA must review student files for at least 10
percent of the veterans and eligible persons currently enrolled under
VA's education benefit programs at a school. The maximum sample size
is 50 student files, and the minimum sample size is 10 student files
or the total number of veterans and eligible persons currently
enrolled, whichever is less.
[76] According to VA guidance, when an audit identifies payment
errors, VA compliance staff must make a referral by submitting a memo
within 30 days of the audit's completion, over the signature of a
senior VA official, to the appropriate division within VA in order to
request corrective action and a response when the action is completed.
This action is recorded and tracked in VA's data system, the Benefits
Delivery Network.
[77] Some VA officials also stated that VA needed time to create
policies and develop training for how to conduct audits under the new
Post-9/11 GI Bill.
[78] VA is required to assign at least one education compliance
specialist to conduct these audits for every 40 audits that are
required each year. 38 U.S.C. § 3693(a).
[79] In seven states, VA completed more than 100 percent of the audits
it had originally planned for the year.
[80] WEAMS stands for Web Enabled Approval Management System and
serves as VA's database of educational and job-training programs,
which provides approval information used to determine servicemembers'
and veterans' eligibility to benefits for training offered by these
programs.
[81] Three schools had not yet been audited by VA because they were
recently approved to receive VA education benefits. In addition, VA
could not locate any audit reports for one of the schools we randomly
selected.
[82] We estimate that each of these schools should have been scheduled
for an audit, at the latest, in fiscal year 2009. In three states, we
also identified schools that we estimate should likely have been
audited in fiscal year 2010, but VA did not complete these audits due
to its suspension of this oversight mechanism.
[83] Given the number of errors found at this school, the report
suggested a follow-up audit in fiscal year 1999. While VA had
additional documents on file indicating that audits were conducted
again in 1999 and 2002, it had no reports on file for these audits.
According to a VA official, the VA position responsible for conducting
these audits was vacant for an 18-month period, and many records went
unaccounted for during this time.
[84] Government internal control standards call for internal control
monitoring that assesses performance over time. Furthermore, these
standards indicate that operating information is needed to determine
whether agencies are achieving their compliance requirements under
various laws and regulations (see [hyperlink,
http://www.gao.gov/products/GAO/AIMD-00-21.3.1]).
[85] This data system is called the Postsecondary Education
Participants System (PEPS).
[86] U.S. Department of Education, Federal Student Aid, Federal
Student Aid: Strategic Plan, FY 2011-15 (Washington, D.C.: September
2010).
[87] 38 U.S.C. § 6308.
[88] Pub. L. No. 103-62, 107 Stat. 285 (codified as amended at 5
U.S.C. § 306; 31 U.S.C. §§ 1115-1119, and 9703 and 9704, and 39 U.S.C.
§§ 2801-2805).
[89] GAO, Tax Administration: IRS Needs to Further Refine Its Tax
Filing Season Performance Measures, [hyperlink,
http://www.gao.gov/products/GAO-03-143] (Washington, D.C.: Nov. 22,
2002).
[90] Through our research, we were able to obtain deliverable e-mail
addresses for all but three facilities (about 1 percent) in the sample.
[91] GAO, 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).
[92] On an annual basis, according to VA's guidance, it should audit
at least 33 percent of active institutions of higher learning, non-
college degree, and correspondence schools each year. In addition, it
must survey all flight schools and 10 percent of active on-the-job
training and apprenticeship establishments.
[93] Pub. L. No. 111-377, 124 Stat. 4106 (2011).
[End of section]
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