    [House Hearing, 110 Congress]
    [From the U.S. Government Publishing Office]

                            STATE APPROVING AGENCIES

    =======================================================================

                                    HEARING

                                   before the

                      SUBCOMMITTEE ON ECONOMIC OPPORTUNITY

                                     of the

                         COMMITTEE ON VETERANS' AFFAIRS
                         U.S. HOUSE OF REPRESENTATIVES

                           ONE HUNDRED TENTH CONGRESS

                                 FIRST SESSION

                                   __________

                                 APRIL 19, 2007

                                   __________

                               Serial No. 110-15

                                   __________

           Printed for the use of the Committee on Veterans' Affairs

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                         COMMITTEE ON VETERANS' AFFAIRS

                        BOB FILNER, California, Chairman

    CORRINE BROWN, Florida               STEVE BUYER, Indiana, Ranking
    VIC SNYDER, Arkansas                 CLIFF STEARNS, Florida
    MICHAEL H. MICHAUD, Maine            JERRY MORAN, Kansas
    STEPHANIE HERSETH SANDLIN, South     RICHARD H. BAKER, Louisiana
    Dakota                               HENRY E. BROWN, Jr., South
    HARRY E. MITCHELL, Arizona           Carolina
    JOHN J. HALL, New York               JEFF MILLER, Florida
    PHIL HARE, Illinois                  JOHN BOOZMAN, Arkansas
    MICHAEL F. DOYLE, Pennsylvania       GINNY BROWN-WAITE, Florida
    SHELLEY BERKLEY, Nevada              MICHAEL R. TURNER, Ohio
    JOHN T. SALAZAR, Colorado            BRIAN P. BILBRAY, California
    CIRO D. RODRIGUEZ, Texas             DOUG LAMBORN, Colorado
    JOE DONNELLY, Indiana                GUS M. BILIRAKIS, Florida
    JERRY McNERNEY, California           VERN BUCHANAN, Florida
    ZACHARY T. SPACE, Ohio
    TIMOTHY J. WALZ, Minnesota

                       Malcom A. Shorter, Staff Director

                                     ______

                      SUBCOMMITTEE ON ECONOMIC OPPORTUNITY

              STEPHANIE HERSETH SANDLIN, South Dakota, Chairwoman

    JOE DONNELLY, Indiana                JOHN BOOZMAN, Arkansas, Ranking
    JERRY McNERNEY, California           RICHARD H. BAKER, Louisiana
    JOHN J. HALL, New York               JERRY MORAN, Kansas

    Pursuant to clause 2(e)(4) of Rule XI of the Rules of the House, public
    hearing records of the Committee on Veterans' Affairs are also
    published in electronic form. The printed hearing record remains the
    official version. Because electronic submissions are used to prepare
    both printed and electronic versions of the hearing record, the process
    of converting between various electronic formats may introduce
    unintentional errors or omissions. Such occurrences are inherent in the
    current publication process and should diminish as the process is
    further refined.

                                C O N T E N T S

                                   __________

                                 April 19, 2007

                                                                       Page
    State Approving Agencies.........................................     1

                               OPENING STATEMENTS

    Chairwoman Stephanie Herseth Sandlin.............................     1
        Prepared statement of Chairwoman Herseth Sandlin.............    29
    Hon. John Boozman, Ranking Republican Member.....................     2
        Prepared statement of Congressman Boozman....................    29

                                   WITNESSES

    U.S. Government Accountability Office, George A. Scott, Director,
      Education, Workforce and Income Security Issues................     4
        Prepared statement of Mr. Scott..............................    30
    U.S. Department of Labor, John M. McWilliam, Deputy Assistant
      Secretary for Operations and Management, Veterans' Employment
      and Training Service...........................................    20
        Prepared statement of Mr. McWilliam..........................    49
    U.S. Department of Education, Carol A. Griffiths, Chief,
      Accrediting Agency Evaluation Unit, Office of Postsecondary
      Education......................................................    21
        Prepared statement of Ms. Griffiths..........................    50
    U.S. Department of Veterans Affairs, Keith M. Wilson, Director,
      Education Service, Veterans Benefits Administration............    22
        Prepared statement of Mr. Wilson.............................    52

                                     ______

    National Association of State Approving Agencies, Joan L. Ryan,
      President......................................................     6
        Prepared statement of Ms. Ryan...............................    36
    South Dakota State Approving Agency, George W. Summerside,
      Veterans Education Program Specialist..........................     8
        Prepared statement of Mr. Summerside.........................    44

                           SUBMISSIONS FOR THE RECORD

    American Legion, Ronald F. Chamrin, Assistant Director, Economic
      Director, statement............................................    55
    Council of Regional Accrediting Commissions, Jean Avnet Morse,
      President, Middle States Commission on Higher Education,
      statement......................................................    58

                       MATERIAL SUBMITTED FOR THE RECORD

    U.S. Government Accountability Office, Report to the Ranking
      Minority Member, Committee on Veterans' Affairs, U.S. Senate,
      March 2007, ``VA Student Financial Aid--Management Actions
      Needed to Reduce Overlap in Approving Education and Training
      Programs and to Assess State Approving Agencies,'' GAO-07-384..    61
    Letter, dated April 27, 2007, and Supplemental Statement for the
      Record from Joan L. Ryan, President, and C. Donald Sweeney,
      Legislative Director, National Association of State Approving
      Agencies, responding to a request for additional information
      from Congressman John Boozman..................................    72

                            STATE APPROVING AGENCIES

                                  ----------

                            THURSDAY, APRIL 19, 2007

                 U.S. House of Representatives,
                        Committee on Veterans' Affairs,
                          Subcommittee on Economic Opportunity,
                                                        Washington, DC.

        The Subcommittee met, pursuant to notice, at 2:05 p.m., in
    Room 334, Cannon House Office Building, Hon. Stephanie Herseth
    Sandlin [Chairwoman of the Subcommittee] presiding.
        Present: Representatives Herseth Sandlin, Donnelly, Hall,
    Boozman.

            OPENING STATEMENT OF CHAIRWOMAN HERSETH SANDLIN

        Ms. Herseth Sandlin. Good afternoon, ladies and gentlemen.
    The Committee on Veterans' Affairs, Subcommittee on Economic
    Opportunity hearing on functions performed by State Approving
    Agencies (SAAs) will come to order.
        Before I begin with my opening statement, I would like to
    call attention to the fact that Ms. Jean Morse, President of
    the Middle States Commission on Higher Education, has asked to
    submit a written statement for the record on behalf of the
    Council of Regional Accrediting Commissions.
        If there is no objection, I ask for unanimous consent that
    the statement be entered into the record. Hearing no objection,
    so entered.
        [The statement of Ms. Morse appears on p. 58.]
        Today we will be hearing testimony on State Approving
    Agencies. The authority of SAAs was established by Congress in
    1947 to ensure that veterans and eligible dependents can use
    the GI Bill educational entitlement in an approved educational
    program.
        Under contract with the U.S. Department of Veterans Affairs
    (VA), the key function of SAAs is to ensure that education and
    training programs meet VA's standards through a range of
    approval activities such as conducting on-site visits,
    evaluating course quality, assessing school financial
    stability, and monitoring student progress.
        Every State assesses each program as to its own standards
    and laws in addition to the VA rules and regulations with all
    approved programs undergoing continuous supervision.
        The programs that can be approved include colleges,
    universities, vocational and technical schools, flight schools,
    apprenticeship programs, and on-the-job training programs. In
    addition, SAAs engage in outreach activities to foster the
    usage of the GI Bill.
        This year, my home State of South Dakota is expecting to
    have approximately 2,100 eligible individuals enrolled in GI
    Bill eligible programs. These programs are now found at 47
    schools and 192 training establishments in South Dakota. So I
    have a strong interest in exploring the subject before us today
    to improve the availability of education benefits for our men
    and women in uniform.
        I understand that there are concerns about the funding
    change that is about to occur for the State Approving Agencies.
    From fiscal years 2003 to 2006, their funding increased from
    the statutory level of $13 million to $19 million to expand
    services. However, the funding level for SAAs is scheduled to
    decrease beginning in fiscal year 2008.
        According to a recent report, the U.S. Government
    Accountability Office (GAO) concluded that the responsibilities
    of State Approving Agencies have expanded since 1995 and that
    they add value to the approval process for education and
    training programs. However, the report also concluded that
    there was overlap between the efforts of State Approving
    Agencies and other Federal agencies.
        While the VA now spends $19 million to fund SAA duties and
    functions, it does not track the amount it spends on specific
    SAA activities, especially those that may also be performed by
    other agencies. So I am very interested in hearing your
    insights on how these concerns can be addressed.
        Ranking Member Boozman, I look forward to working with you
    and our colleagues and Subcommittee staff to help with these
    important services offered by the State Approving Agencies, and
    I now recognize the Ranking Member, Mr. Boozman, for any
    opening remarks that he may have.
        [The prepared statement of Chairwoman Herseth Sandlin
    appears on p. 29 and the referenced GAO report, GAO-07-384,
    entitled, ``VA Student Financial Aid: Management Actions Needed
    to Reduce Overlap in Approving Education and Training Programs
    and to Assess State Approving Agencies,'' appears on page 61.]

                 OPENING STATEMENT OF HON. JOHN BOOZMAN

        Mr. Boozman. Thank you very much.
        The State Approving Agencies have for many years been a
    mainstay in ensuring that veterans attending the education and
    training programs under the various GI Bills receive quality
    instruction. That is why I thank you, Madam Chairwoman, for
    holding the hearing today.
        A recent GAO report, that updated a 1995 report, again
    found overlaps in the functions performed by the State
    Approving Agencies, the regional and professional accrediting
    agencies acting on behalf of the Department of Education, and
    the Oversight Committees provided by the State Employment
    Services.
        While the recent report was less critical than its
    predecessor and noted SAAs did, in fact, provide perspective
    not replicated by other organizations, GAO again recommended a
    thorough inter-agency review of how the Federal Government
    oversees the education industry.
        I believe that this is important, that it is important to
    begin the processes and means to improve the education and
    training opportunities for veterans and their dependents.
        Another issue is how much funding should VA provide to the
    States to act as VA's agent. VA currently pays the collective
    SAAs about 19 million out of the readjustment benefits account.
    As such, those payments are mandatory spending and beginning in
    fiscal year 2008, the law cuts that funding to 13 million.
        So the question before us is what is the value of the
    services provided by the SAAs?
        It looks like we are going to get a report from the
    regional accrediting agency as well as having somebody from the
    U.S. Department of Education (DoE) today, so we look forward to
    that, especially the functions associated with their programs.
        I am sorry that witnesses from the accrediting bodies we
    invited were unable to attend. Their testimony would have been
    a valuable perspective relative to GAO's findings.
        I would note the accrediting associations overseeing
    colleges and universities are membership organizations who
    charge their members significant annual dues as well as large
    fees for other functions such as approving new courses for
    instruction.
        For example, the alma mater of one of our staff is a small
    liberal arts school in the Midwest with a full-time enrollment
    of about 1,800 students. That school pays at least $4,000 in
    annual dues to its main accrediting association in addition to
    any fees for special visits.
        I am not criticizing the accrediting bodies for charging
    the fees, but I thought it important that the members know this
    aspect of their operations.
        Regarding the U.S. Department of Labor (DoL), I am looking
    forward to hearing about the level of the interaction with SAAs
    in improving on-the-job training (OJT) and apprenticeship
    programs.
        Again, thank you, Madam Chairwoman, as always for your
    leadership in this area and look forward to hearing the
    testimony.
        [The prepared statement of Congressman Boozman appears on
    p. 29.]
        Ms. Herseth Sandlin. Thank you, Mr. Boozman.
        I would also like to welcome all of today's witnesses, and
    I very much appreciate your testimony as your views and
    insights are critically important to us in examining this
    important issue.
        I am particularly interested in understanding and exploring
    the views and perspectives on the role and function of State
    Approving Agencies, funding needed to perform those functions,
    overlap in the approval process, and coordination between
    Federal and State agencies. I look forward to hearing from all
    of you.
        We have been informed that votes would have been called
    about 25 minutes ago, so they could be called at any time. We
    will go ahead and start testimony and take as much as we can
    from our first panel and get to any questions of the
    Subcommittee.
        I think we will go ahead and start with the first panel.
    Joining us is Mr. George Scott, Director of Education,
    Workforce and Income Security Issues for the U.S. Government
    Accountability Office.
        That gives us 15 minutes, so we will at least start perhaps
    with Mr. Scott's testimony in just one moment. I will introduce
    the other folks on the panel.
        Ms. Joan Ryan, President of the National Association of
    State Approving Agencies; accompanied by Mr. Donald Sweeney,
    Legislative Director of the National Association of State
    Approving Agencies, and my friend, Mr. George Summerside,
    Veterans Education Program Specialist, South Dakota State
    Approving Agency. Welcome to all of you.
        And, Mr. Scott, we will let that buzzer go and then we will
    begin with your testimony. I would ask each of our witnesses to
    do their best to limit their opening statement to five minutes.
    Your full written statement will be submitted for the record.
        Thank you.

     STATEMENTS OF GEORGE A. SCOTT, DIRECTOR, EDUCATION, WORKFORCE
      AND INCOME SECURITY ISSUES, U.S. GOVERNMENT ACCOUNTABILITY
    OFFICE; JOAN L. RYAN, PRESIDENT, NATIONAL ASSOCIATION OF STATE
         APPROVING AGENCIES; ACCOMPANIED BY C. DONALD SWEENEY,
     LEGISLATIVE DIRECTOR, NATIONAL ASSOCIATION OF STATE APPROVING
    AGENCIES; AND GEORGE W. SUMMERSIDE, VETERANS EDUCATION PROGRAM
            SPECIALIST, SOUTH DAKOTA STATE APPROVING AGENCY

                      STATEMENT OF GEORGE A. SCOTT

        Mr. Scott. Thank you.
        Madam Chairwoman, Ranking Member Boozman, and members of
    the Subcommittee, I am pleased to be here today to discuss
    GAO's recent report on State Approving Agencies, SAAs.
        In fiscal year 2006, the Department of Veterans Affairs
    paid approximately $19 million to State Approving Agencies.
    Under contract with the VA, SAAs ensure that education and
    training programs meet VA standards through a number of
    approval activities such as evaluating course quality and
    monitoring student progress.
        My testimony today will focus on what changes have occurred
    in SAA duties and functions since 1995, to what extent VA's
    approval process overlaps with the efforts of other Federal
    agencies, and what additional value do State Approving Agencies
    bring to VA's education benefit program.
        As you know, veterans and other qualified individuals
    receive VA education benefits that allow them to pursue various
    types of educational programs such as a degree program, an
    apprenticeship, or on-the-job training.
        In general, these programs must be approved by a State
    Approving Agency in order for individuals to receive VA
    education benefits. The Departments of Education and Labor also
    assess education and training programs.
        The Department of Education certifies postsecondary
    institutions for participation in Federal student financial aid
    programs through various oversight functions to ensure that
    these schools meet Federal requirements and that they are
    accredited and licensed.
        Similarly, the Department of Labor is authorized to
    formulate and promote labor standards to safeguard the welfare
    of apprentices.
        Given each agency's role, the potential for duplication of
    approval efforts among Federal agencies have been a
    congressional concern.
        In our study, we report the legislative changes effective
    in 2001 created additional responsibilities for State Approving
    Agencies including promoting the development of apprenticeship
    and on-the-job training programs, providing outreach services,
    and approving tests for occupational licensing.
        From fiscal years 2003 to 2006, funding for State Approval
    Agencies increased from $13 million to about $19 million to
    expand services and support the additional responsibilities.
    However, as you noted, its funding is scheduled to decrease
    beginning in fiscal year 2008.
        Many education and training programs approved by SAAs have
    also been approved by other agencies. For example, about 69
    percent of all programs approved by SAAs are also offered by
    institutions that have been certified by Education.
        VA and SAA officials also reported that many apprenticeship
    programs approved by SAAs have also been approved by Labor. The
    agencies also have similar categories of approval standards,
    but the interpretation and application of these standards may
    differ.
        For example, VA and Labor each require that facilities have
    adequate space and instruct their personnel to provide quality
    training, but the definitions of adequacy differ.
        Despite the potential overlap, VA has taken few steps to
    coordinate approval activities with Education and Labor.
        Additionally we found that VA does not require State
    Approving Agencies to collect information on the resources they
    spend on specific approval activities. The lack of such data
    prevented us from determining what portions of funds were spent
    on approval activities that may overlap with those of other
    agencies.
        SAAs reportedly add value to VA's approval process through
    focusing on student services for veterans, ensuring the
    integrity of VA benefits, providing more frequent on-site
    monitoring of education and training programs that are provided
    by other agencies, and assessing and approving a small number
    of programs that are not reviewed by other agencies.
        While VA does measure various outputs resulting from SAA
    activities such as the number of supervisory visits conducted,
    the lack of outcome performance measures makes it difficult to
    assess the significance of such activities.
        In conclusion, VA, Education, and Labor have various
    standards and processes in place to ensure that Federal funds
    are spent on quality education and training programs. While we
    have identified some overlap in approval efforts across these
    agencies, the full extent of the overlap is unknown. It is
    important that VA work with other Federal agencies to determine
    how the scope of its approval process can be streamlined to
    reduce overlap.
        Furthermore, developing outcome measures to more fully
    evaluate SAA performance is important to managing the program
    and improving results.
        To help ensure that Federal dollars are spent efficiently,
    we recommended that VA take steps to monitor its spending on
    approval activities and identify whether any resources are
    spent on activities that duplicate the efforts of other
    agencies.
        We also recommended that VA establish outcome-oriented
    performance measures to assess the effectiveness of State
    Approving Agencies' efforts.
        VA agreed with our recommendations and stated that it will
    take action to implement them. They will continue to monitor
    VA's progress in addressing these issues.
        This concludes my statement, and I would be happy to answer
    any questions that you may have. Thank you.
        [The prepared statement of Mr. Scott appears on p. 30.]
        Ms. Herseth Sandlin. Thank you, Mr. Scott, and thank you
    for the report and the questions that will be derived from that
    report throughout the hearing today.
        We have just under 10 minutes before the vote and we
    generally only need a few minutes to get down for this first
    vote. Ms. Ryan, if you think you can confine your opening
    statement to five minutes, we can go ahead and get yours in now
    before we go down to vote. Okay. Thank you.

                       STATEMENT OF JOAN L. RYAN

        Ms. Ryan. Chairman Herseth Sandlin, Ranking Member Boozman,
    members of the Subcommittee on Economic Opportunity, we are
    pleased to appear today before you on behalf of the National
    Association of State Approving Agencies to provide comments on
    the functions of State Approving Agencies, the value added by
    SAAs, the issue of overlap in the work of various approving
    agencies, and funding needed for SAAs to carry out their
    responsibilities.
        State Approving Agencies add value to the educational
    experience for veterans by promoting and safeguarding quality
    education and training programs, by ensuring greater
    educational and training opportunities, and by assisting the
    DVA in preventing fraud, waste, and abuse in the administration
    of the GI Bill.
        State Approving Agencies carry out their mission through
    core functions of program approval, ongoing contact, and
    supervision, technical assistance, outreach, and liaison.
        As State Approving Agencies working with a Federal program,
    SAAs are in a unique situation to network with stakeholders in
    education and training to coordinate the improved delivery of
    veterans' benefits.
        Frequent interaction with officials at all levels within
    the State provides an understanding of how the system works
    which in turn creates a unique ability to assist veterans in
    accomplishing their training objectives.
        As stated by a former Subcommittee staff director for the
    House Veterans' Affairs Committee in an upcoming SAA outreach
    film, SAAs are the face of the GI Bill at the State level.
        We provide advocacy for veterans, educational consumer
    protection for veterans. We respond to veterans' education
    problems and prevent overpayments to veterans. We provide
    outreach. During the last 10 years, we have tripled our number
    of outreach activities and job training opportunity. The number
    of active apprenticeship and on-the-job training facilities has
    increased over 100 percent in the last 10 years.
        Questions have been raised regarding possible overlap in
    the work of State Approving Agencies with other agencies. A
    recent GAO report states many education and training programs
    approved by SAAs have also been approved by Department of
    Labor. We disagree.
        It is our understanding that Department of Education does
    not directly approve programs. It certifies institutions by
    relying heavily on accreditation which is primarily
    institutional in nature, not programmatic.
        Moreover, accreditation is a voluntary, private-sector,
    quality enhancement process, not a government control
    mechanism.
        Additionally, SAAs do work with other approval institutions
    such as State licensing and degree-granting authorities and
    accrediting agency personnel.
        It is important to note the major differences between SAAs
    and accreditation. Why? Number one, in their mission,
    standards, and purpose and, number two, operationally in the
    depth, breadth, and frequency of their reviews. Each has a
    function, but the functions are not identical or duplicative.
    They are complementary.
        Regarding outcomes measures, we agree that more can be
    done. For example, SAAs are heavily engaged in promoting the
    concept of lifelong learning. We see more veterans who do not
    need a full-scale 2- or 4-year program of education to help
    them achieve their occupational goals. So our work with
    educational institutions has grown in the direction of
    evaluating and approving noncredit programs which we would
    begin to identify more clearly.
        The total allocation for SAA activities is stipulated in
    Title 38. Each SAA's allocation is determined by a formula
    essentially based on the number of active schools and training
    establishments being supervised. The total allocation was
    capped at $19 million for 2006 and 2007. If no action is taken,
    in 2008 the cap will revert back to $13 million, a 32 percent
    cut.
        If the SAAs are unable to perform their duties to the
    fullest, veterans would invariably suffer. SAAs need funding
    stability in order to plan for and execute activities that meet
    the requirements of Title 38 between the State and the VA.
        In order to provide an acceptable level of service to
    veterans, Congress, and the DVA and to continue to take on
    additional roles as needed, SAAs must consistently be funded at
    an adequate level.
        Once restored to the current level of $19 million, the
    amount should be adjusted each year by a government approved
    COLA applied to other benefit programs.
        In closing, Madam Chairman, an important reason for the
    existence of the State Approving Agencies is service to
    veterans. Every one of our activities from TAP briefings on
    bases to job and career fairs, from working with schools and
    registrars and college deans, to helping employers meet
    requirements for approval, each of these add values to the
    educational experience for veterans. It is our purpose and our
    passion. Because we are in the schools, job training sites, and
    on bases, we are the face of the GI Bill to veterans.
        We would like to thank you and the members of the
    Subcommittee again for the opportunity to comment on the
    functions of State Approving Agencies, the value added by State
    Approving Agencies, the issue of overlap in the work of
    approving agencies, and funding needed for SAAs to carry out
    their responsibility so that the GI Bill remains the country's
    premier education assistance program bar none.
        Mr. Sweeney and I would be happy to take questions later.
        [The prepared statement of Ms. Ryan appears on p. 36.]
        Ms. Herseth Sandlin. Yes. Thank you, Ms. Ryan. I appreciate
    that.
        Mr. Summerside, we are going to have to wait. Mr. Boozman
    and I need to get down to the House floor for a couple of
    votes. We will be back hopefully within the half hour and then
    we will resume with your testimony and move to questions.
        Thank you.
        [Recess]
        Ms. Herseth Sandlin. Okay. Well, thank you for your
    patience, and we will just move immediately then to Mr.
    Summerside's testimony. Please begin.

                   STATEMENT OF GEORGE W. SUMMERSIDE

        Mr. Summerside. Thank you, Chairwoman Herseth Sandlin and
    members of the Subcommittee on Economic Opportunity.
        I am pleased to appear before you today on behalf of the
    South Dakota State Approving Agency to discuss the functions of
    the State Approving Agencies and the value our agency has in
    the State of South Dakota.
        Sixty years ago, Congress determined that each State should
    create an agency that approved programs within its boundaries
    and to determine which programs it was appropriate for veterans
    to enroll and receive their VA educational benefits.
        After a few years, States realized that a national
    association was needed. And in 1948, the National Association
    of State Approving Agencies was formed.
        One of the keys to the success of our association has been
    the use of technology. We created a viable Internet website for
    the utilization of our members, our service partners, and our
    customer, the American veteran.
        South Dakota has been the web master for this site since
    its creation in 1998. The primary responsibility and focus of
    our agency continues to be the review, evaluation, and approval
    of quality programs of education and training. Our agency
    conducts annual supervisory visits to each active facility to
    review the resources and capabilities which are required for
    continued approval. This on-site, ongoing supervision is vital
    to ensure these approved institutions continue to provide
    quality educational programs and meet VA compliance
    requirements.
        We have become advocates for quality education and training
    for veterans and other eligible persons. We have developed
    service partnerships with veterans' groups and other agencies
    to facilitate even greater and more diverse educational
    opportunities for those we serve.
        We provide technical assistance on a wide range of VA
    educational issues. Our staff is continually developing
    creative and innovative ways to promote and educate the public
    on VA educational programs.
        Last fiscal year, we distributed over 6,000 brochures and
    other outreach materials to those within our service network.
        You have asked what is the value of our agency. This can be
    best answered by those we serve. The following comments offer
    their opinion.
        I was most appreciative for the professionalism from the
    person from the State Approving Agency who worked with my
    employer and me to design a tailored training program. No
    doubt, without availability of this education benefit, I would
    not have been able to accept this training position. Ron Boyd,
    State Adjutant, South Dakota American Legion.
        On behalf of the veterans and their dependents attending
    the University of South Dakota, I can honestly claim that the
    support of our State Approving Agency is essential to our
    success. Jennifer Jost, Association Registrar.
        The philosophy that bigger is better does have its limits
    and the impact on our smaller States can be negative. There is
    a need for each State to have a fully staffed SAA so the
    veterans in that State do not suffer with additional delays in
    obtaining their educational benefits. These agencies are vital
    and any reduction in funding would negatively impact VA
    educational programs. Del Johnson, retired South Dakota ELR.
        To ever lose or restrict the State Approving Agency due to
    Federal budget restraints would be a huge disservice to South
    Dakota veterans. Ken Lindblad, Beadle County Veteran Service
    Officer.
        State Approving Agencies have not only ensured that those
    eligible for VA educational benefits enroll in quality
    education and training programs, but they have also served as a
    champion of veterans' educational benefits. Bill Locken, South
    Dakota Veterans Commissioner.
        In the past few months, George Summerside has been an
    excellent client advocate. Without his dedication and loyalty,
    the veterans' education program would be nothing. Sincerely,
    Samantha Donley. She is a Chapter 35 recipient.
        Our agency has a proven record of dedicated and
    professional service as depicted in the comments I just read.
    If a funding solution is not found, South Dakota's contract
    would be reduced by 32 percent next fiscal year. This would be
    a reduction of over $66,000. The many things we are doing in
    outreach and customer service would no longer be possible.
        The testimonies today cannot truly measure our value. Our
    true value rests in the heart of each of the dedicated staff
    whose sole purpose is the approval of quality programs of
    education and training. Our agency's worth is found in the
    dedicated devotion to excellence and our Nation's veterans
    deserve no less.
        In closing, Madam Chairwoman, I would like to thank you and
    the members of the Subcommittee again for the opportunity to
    comment on the functions of the South Dakota State Approving
    Agency and the value we add to our State. I would be happy to
    respond to any questions you might have.
        [The prepared statement of Mr. Summerside appears on p.
    44.]
        Ms. Herseth Sandlin. Well, thank you, Mr. Summerside, and
    all of our witnesses on the first panel for your testimony.
        I have a number of questions, but I will defer to our
    Ranking Member and then we have also been joined by Mr. Hall
    who has another Subcommittee hearing that is going on
    simultaneously.
        In an effort to accommodate him, I would like to ask Mr.
    Boozman to begin the questioning so that we can move to Mr.
    Hall for any opening statement or questions he may have and we
    will circle back to me at the end.
        Mr. Boozman. Thank you, Madam Chairwoman.
        I appreciate your testimony, Mr. Summerside. I think that
    in visiting with your Arkansas equivalents, I think they would
    concur with your testimony or it would be very, very similar.
    So it is good to have you here to kind of give us some, you
    know, firsthand as to effects testimony.
        For the State Approving Agencies, can you provide us some
    details how the State Approving Agencies differ from other
    organizations performing similar functions, if that makes
    sense?
        Ms. Ryan. I would like to give that to Mr. Sweeney, if you
    do not mind.
        Mr. Boozman. Yes.
        Mr. Sweeney. I think Ms. Ryan really summed it up in her
    comments when she said the Department of Education's process
    relies heavy upon accreditation which is primarily
    institutional.
        The Department of Education certifies institutions that
    offer programs to those people who are entitled to or eligible
    for Title 4 funding.
        There is a huge difference between saying that programs
    approved by State Approving Agencies are also approved by the
    Department of Education. As I said to one of the staff members
    during the break, it is not quite 180 degrees, but it is close
    to 179. There is a huge difference between certifying
    institutions that offer programs than approving each and every
    program in accordance with provisions of Title 38.
        The basis for Title 38, beyond ensuring the academic
    integrity and quality of a learning experience--which could be
    anywhere from a certificate program in automotive technology to
    a Bachelor of Science Degree in Engineering--is also to ensure
    that the provisions of Title 38 that pertain to payment of
    benefits are in place as well. They are intertwined.
        So when we talk about the differences between the two
    processes, Mr. Boozman, if I understand the question correctly,
    it seems like much of this really centers around accreditation.
    Am I correct in the intent of the question more so than it is,
    for example, State licensing or degree granting authority? It's
    really around accreditation. And the vast majority of
    accreditation is institutional.
        For example, before leaving the State of Maine where I
    happened to be--we are all volunteers. The National Association
    of State Approving Agencies has no paid staff. I mean, I am the
    Director of the Maine State Approving Agency. Joan is the
    Director of Illinois. We take on these titles of President and
    Legislative Director and basically what it does, it keeps us in
    the office to eight o'clock at night and on weekends.
        But by and large, one of the things that I took a look at
    before leaving the State of Maine was how many of the
    University of Maine system programs have specialized
    accreditation. Now, that gets us a little bit closer to the
    process utilized by State Approving Agencies.
        Stop me if I am losing you here, but there are the various
    types of accreditation that we refer to in our written
    testimony, there is institutional accreditation, there is
    programmatic accreditation.
        And the programmatic accreditation is probably the closest
    that you will find to the State Approving Agency process where
    we take a look at the legitimacy of the objective, what is that
    program objective, is it, for example, someone that wishes to
    be an automotive technician, what does it take to learn those
    skills, how are those skills taught, by whom, and under what
    circumstances.
        And Title 38, as the Committee is aware, is quite
    prescriptive in that regard with respect to admissions
    requirements, credit for prior learning, satisfactory progress,
    all those kinds of things that pertain to student enrollment.
        Well, anyway, taking a look at the University of Maine
    system of which there are seven campuses, we have roughly about
    600 programs. A little over 125 have specialized accreditation,
    so that leaves 500 or close to 500 that are strictly viewed as,
    quote, approved under an institutional umbrella of
    accreditation, not programmatic, institutional.
        That institutional accreditation, and I have had the
    privilege and honor of serving on a number of accrediting teams
    over the years. I have about close to 35 years in the field of
    education. I have been an administrator. I have served as an
    instructor and again on accrediting teams.
        That process, when I say institutional, I could go on for
    hours on this just to give you some idea of what I mean by
    institutional, but suffice it to say for the hearing purposes,
    it is far more superficial than the programmatic accreditation
    and the process used by State Approving Agencies.
        And I thank you for all the time you have given me because
    I think I have already gone too far.
        Mr. Boozman. No. That is fine.
        Let me just ask one more thing if it is okay, Madam
    Chairwoman? My time is up in a little bit.
        But I guess really the bottom line, and you alluded to it,
    Mr. Summerside, with the cutting in funding, what it would do
    in your State.
        Again, if we go from the current $19 million to $13
    million, what is the practical effect that that is going to
    have on the program?
        Ms. Ryan. The effect will be local. Each State may approach
    it a little differently. There are some States who may, in
    fact, choose not to contract with VA, some of the smaller
    States who have small contracts. If that is the case, then VA
    would have to pick up the approval function in that State.
        There are some States who may not do outreach. There just
    will not be the time, the budget. There are States who will lay
    people off, I have no doubt. But, you know, it is an
    individual, it will be a local decision how it is made.
        Mr. Sweeney. Is it possible to add to that, Mr. Boozman?
        I think a big piece for us is that State Approving Agencies
    truly believe that, as Ms. Ryan stated in her closing remarks,
    the GI Bill should be the premier educational assistance
    program in this country bar none.
        We have one percent of our population defending the other
    99 percent and for many of us these days, we are not sure how
    large of a portion of that 99 percent really care about the
    other one percent.
        Veterans, as Mr. Summerside said, deserve no less than the
    fullest attention that we can give. Removing the amount of
    funding that is currently provided a State Approving Agency is
    definitely going to jeopardize, after 30 plus years in the
    business, is definitely going to jeopardize the success of the
    GI Bill, no doubt in my mind.
        We are, as stated earlier, the face of the GI Bill at the
    State level. The level of interaction that we have with the
    players--there is no comparison to other processes. That level
    of interaction gives us an opportunity to not only know the
    folks but know the systems, but also to be able to identify
    what areas need attention and what areas do not really need
    attention. And that is what helps us to be as effective as I
    think we are.
        Mr. Boozman. Thank you, Madam Chair.
        Ms. Herseth Sandlin. Yes. Thank you.
        And thank you both to Ms. Ryan and Mr. Sweeney.
        Mr. Hall, do you have questions for the panel?
        Mr. Hall. Briefly. Thank you, Madam Chairwoman.
        I apologize for being late and leaving early, but I am
    double and triple booked today.
        But I thank you, panelists, for your testimony which I have
    been reading. I heard part of Mr. Summerside's testimony that
    was given earlier.
        I just want to say that the cut from $19 million or the
    drop this action has taken from $19 to $13 million seems like
    whoever made that decision must have made it in a vacuum.
        But there is a lot of talk going on now on the full
    Veterans' Affairs Committee and the Subcommittees and when I go
    home and meet with veterans in my district about outreach and
    communicating what programs are available, what help is
    available to our veterans.
        And so I hope and believe that we will find a way to keep
    you performing your services that you have been so generously
    performing to date.
        I wanted to ask whether there is a difference, whether you
    are seeing a difference in terms of program targeting or
    tailoring of programs for, yet this may be that it is too early
    in terms of OEF/OIF, but whether the veterans coming back from
    these wars are in need of different things or different kind of
    programs or different assistance than vets you worked with
    before to anybody who would like to answer or not answer.
        Ms. Ryan. Well, one of our association's focuses in the
    last few years has been a concept of lifelong learning. As I
    said in my statement, many of them do not want or need the two-
    or four-year college education. They want to, for example,
    learn how to start their own business, so now there are
    entrepreneurship courses that they can take and use GI Bill to
    do that.
        There are the licensure and certification test
    reimbursements that they can get reimbursed, you know, they can
    get reimbursed for the cost of the course, those kind of
    things.
        In Illinois, we are seeing a tremendous increase in the on-
    the-job training and apprenticeship. Many of them do not want
    to go to school, do not want to go to college. They want to
    work. They have families. They are older. So that has been a
    big increase for us.
        And, you know, employers in the State are very, very
    interested in hiring veterans. You know, they recruit for
    veterans. They love having them. And so it is an easy sell in
    many ways.
        Mr. Hall. Thank you.
        And I am just curious. How much overlaps are you aware of
    or any of you aware of between the work that you do and the
    work that is being done either by the VA or by the VSOs? I
    mean, do you consider the work that you do to be filling a
    unique niche that otherwise would go unfilled?
        Ms. Ryan. Absolutely. And I do not want to overstate it,
    but we really are the face of the GI Bill out there in the
    schools and in the job training establishments. When we
    approach our approvals, we do it from the standpoint of Title
    38, what is required for veterans, which is different sometimes
    than for just students in general.
        Mr. Hall. And, last, maybe, you two, you could just pick a
    figure out of the air, what do you think this 2008 budget
    should allot for SAAs?
        Ms. Ryan. We would be happy with 19 percent or $19 million.
        Mr. Hall. Nineteen-percent increase?
        Ms. Ryan. Yeah. No. No, no, no, no. I am thinking of the
    COLA.
        Mr. Hall. If we continue the existing funding, you----
        Ms. Ryan. Yeah, what the COLA would be.
        Mr. Hall. You could work with that?
        Ms. Ryan. Yeah. That would be adequate for sure.
        Mr. Hall. Thank you very much, Madam Chairman. I yield
    back.
        Ms. Herseth Sandlin. Thank you, Mr. Hall.
        Mr. Summerside, did you have anything you wanted to add to
    Ms. Ryan's answers to Mr. Hall's question from your
    perspective?
        Mr. Summerside. I can just say in South Dakota, I know if
    there is anything to do with VA educational programs, the
    office they call is ours. That can be from a County Service
    Officer. That can be from a vet rep or a DVOP. That can be from
    other agencies within State government.
        You know, I do work closely with Department of Education in
    South Dakota with some of my high school approvals, but they do
    not look at the things that we look at. They do not look at the
    things and they do not measure the things that the VA does.
        You know, a lot of the things is not just the quality of
    the program, but it is also based on how they can measure the
    payment for that program as far as the VA and their benefits.
    And that is unique to State Approving Agencies.
        Now, I am not as knowledgeable as my esteemed colleague,
    Don, over here, but I do know in our State as far as on-the-job
    and apprenticeship training, we are not a highly regulated
    State. A lot of our apprenticeship programs are nonregistered.
    They are not registered apprenticeships that have oversight of
    the Bureau of Apprenticeship and Training.
        And the other thing, the Bureau of Apprenticeship and
    Training from my point of view has a wider spectrum to look at.
    We have one focus; it is the veteran. That is our only focus
    and that makes us uniquely qualified to serve them in this
    role.
        Ms. Herseth Sandlin. Well, thank you for your response.
        I would like to go back to Mr. Sweeny and Ms. Ryan, if that
    is okay, if I direct the question directly to Mr. Sweeney,
    because you both talked a lot about the differentiation between
    the State Approving Agency's process versus the DOE's
    accreditation process.
        Would you wish to elaborate on where you see this same type
    of differentiation or not, perhaps taking issue with how the
    GAO report characterized overlap as it relates to the
    Department of Labor?
        I think Mr. Summerside touched on it to an extent, but if
    you wanted to elaborate.
        Mr. Sweeney. Well, what I recall, and I brought this huge
    notebook and put everything in it, but it might take too long
    to find the page that I need to find so what I recall is this.
    Certainly with registered apprenticeship programs where what is
    to be taught, for example, what knowledge and skills are to be
    taught, developed by the Federal Department of Labor or by the
    State Apprenticeship Councils where they exist. George knows
    this probably better than I, with State Councils, it is very
    similar to institutional programs. For example, a Bachelor of
    Science Degree in Engineering, you compare that to an
    apprenticeship program that is registered and you know that
    your State Council has already taken a look at what is to be
    taught, what knowledge and skills are to be learned. We can
    oversee that process in much less time in our evaluation than
    what it would take for a nonregistered apprenticeship program
    or what we term other on-the-job training.
        And I think the Department of Labor did mention in their
    comments or the GAO did with regard to apprenticeship and OJT
    that Department of Labor has no influence whatsoever on OJT
    programs. They do not have responsibility for them. There is no
    jurisdiction. So that is strictly an SAA function.
        I mean, for us, many times we are the only ones that take a
    look at that kind of a training program. We are the only ones
    that say it leads to a legitimate objective, here is what it is
    going to take to achieve the objective, here is what the
    process is going to be, and you can be reasonably assured that
    you will get a job in that occupation once you go through the
    process.
        Ms. Herseth Sandlin. Thank you.
        Mr. Scott, let us give you a chance to respond to some of
    the testimony and the answers to questions already posed as
    they relate to the accreditation process. And you did mention
    where you see some overlap and obviously some concerns have
    been raised and some respectful disagreement with how that has
    been characterized.
        When you undertook this review, did you conclude anything
    with regard to an approximate number or percentage of programs
    that are not reviewed by other agencies as just described by
    Mr. Sweeney?
        Mr. Scott. Well, thank you, Madam Chairwoman. Just a couple
    points if I could in terms of clarification.
        Just overall, I think looking at our report in terms of
    percentage of veterans and others enrolled in programs, the
    vast majority are, in fact, enrolled in an institution of
    higher education, colleges and universities. So from our
    perspective, that is one of the key areas to look at.
        And as such, the Department of Education is not simply
    reviewing schools for accreditation purposes. The Department of
    Education also looks at schools for ongoing compliance with the
    rules and regulations required to participate in Federal
    student aid programs.
        So I am hearing a lot of talk about accreditation, but that
    is just one part of the story. The Department has ongoing
    monitoring of colleges and universities and other schools who
    participate in Title 4 programs, the ``Higher Education Act.''
    So in our view, that is another level of on-site overview at
    the Department of Education.
        I think more fundamentally one of the things that I think
    is important about this hearing today is that in light of the
    number of changes in Federal oversight of colleges and
    universities, since State Approving Agencies were first
    created, clearly there is a much different role now in terms of
    the Department of Education's oversight, in terms of their
    ongoing monitoring of these schools.
        So I think it is appropriate to now take a step back and
    look at given the role of the Department of Education, what is,
    in fact, the appropriate role for State Approving Agencies in
    terms of their oversight and monitoring of institutions that
    have been certified by the Department of Education.
        Ms. Herseth Sandlin. Well, let me stick with you for the
    remaining time I have and we will do another round of questions
    here.
        Mr. Scott, are State Approving Agencies positioned to
    provide better site monitoring than other agencies as it
    relates to on-the-job training, apprenticeship programs, and
    others?
        Mr. Scott. Well, I think clearly as we pointed out in our
    report, there are areas where State Approving Agencies do add
    value. I think the reason we recommended that the Department of
    Veterans Affairs sort of get together with the Departments of
    Education and Labor is to sort out exactly where are the
    overlaps.
        I mean, clearly there are some areas where no one is
    looking on accredited schools and programs, for example. That
    is one potential area where SAAs clearly add value because no
    one is looking at those. I mean, clearly some of the
    apprenticeship programs, that is another area where they add
    value.
        I think our more fundamental message, though, is it is
    important to take a step back, look, and sort of given the
    current funding problems that the SAAs are likely to face,
    where is the best way for them to use their limited resources.
        And I think our recommendations to the Department of
    Veterans Affairs to take a look at the overall potential
    overlap will help sort of sort out where, in fact, it is best
    to use those limited resources.
        Ms. Herseth Sandlin. Thank you.
        Mr. Boozman, do you have some followup?
        Mr. Boozman. The only comment I would make, Madam
    Chairwoman, and, again just really what he was discussing, I
    think it does make all the sense in the world for VA and the
    State Approving Agencies and GAO to get together and really
    sort out the overlaps. Which is, it just does not seem that is
    being done. And so that certainly would be very helpful to
    myself and I think all of us, and our staffs are kind of
    sorting out where we go.
        But that is really the only comment I would make and I
    yield my time.
        Ms. Herseth Sandlin. We have also been joined by Mr.
    Donnelly on the Subcommittee. I would recognize Mr. Donnelly
    for any opening statement or questions he might have for the
    panel.
        Mr. Donnelly. I would want to support the Chairwoman's
    comments, also our Ranking Member's as well, and yield back.
        Ms. Herseth Sandlin. Let me follow up on a couple of
    things. We know that some States have more than one State
    Approving Agency.
        Ms. Ryan, which States have more than one and are there any
    areas of responsibility that are divided up there or is it a
    matter of population only, again in an effort to prevent what
    can be overlap or duplication of services and how we best
    maximize the resources that are allocated to each State?
        Ms. Ryan. Okay. I can't tell you exactly how many States
    have more than one. Several have two. Often there is one agency
    that handles the schools, the other that handles apprenticeship
    and on-the-job training. More often the on-the-job training
    aspect is in a Department of Labor kind of agency, State
    Apprenticeship Council, something like that.
        There are a couple where the division is with higher ed and
    nondegree and proprietary and nonproprietary. Basically,
    however, it is a local decision. Again, it is up to the
    Governor in each State to decide and appoint who is going to be
    the State Approving Agency in that State.
        We have seen in the past, since more States have taken on
    the OJT and apprenticeship function, we have seen a few more
    with two contracts. We have had a few who have combined.
        Mr. Scott. Madam Chairwoman, based on the information I
    have, there are eight States with two State Approving Agencies.
        Ms. Herseth Sandlin. Which are they?
        Mr. Scott. California, Connecticut, Indiana, Minnesota,
    North Carolina, Oregon, Washington, and Wisconsin.
        Ms. Herseth Sandlin. Thank you.
        For Mr. Summerside and Ms. Ryan, the issue of outreach and
    how your services have increased. Could either of you elaborate
    on how your outreach activities through your State Approving
    Agency have increased since National Guard and Reserve
    deployments that began in 2003?
        Mr. Summerside. Madam Chairwoman, in the State of South
    Dakota, we kind of geared up for the activation of the Guard
    and Reserve in our State. I think there is over 3,000 that have
    been activated since 2003.
        Our agency was the lead as far as a welcome home brochure
    and since 2004, we distributed a little over 14,000. It is kind
    of the mainstay when they do the demobs.
        And that was the other thing Governor Rounds did. He
    obligated our division and other partners within our veteran
    service network to go actually to the sites where these
    National Guard and Reservists were being--the demob site. They
    would travel out of State wherever it was.
        And a big part of those briefings was the part on
    educational benefits. Many times if I was not there or other
    staff were not there, I would receive calls on the various
    different things on educational benefits.
        I recently did an outreach effort in Aberdeen. And at the
    end of that, it was an Army Reserve unit, there was various
    groups there and agencies and the longest line was the one to
    talk to me about educational benefits bar none. I was the one
    that was there far longer than anyone else.
        We have a combination of effort as far as outreach. But,
    you know, this is not new and did not start in 2003 in South
    Dakota. It started 50, 60 years ago in South Dakota. On-the-job
    and apprenticeship training is a byproduct of that aggressive
    outreach effort that we have always done.
        And in the last 25 years, we have been part of the
    Department of Military and Veterans Affairs. We have a direct
    connection not only with the veterans, the Guard, Reservists,
    and the dependents or survivors, but those county and tribal
    service officers and those veteran groups that make it just a
    great relationship in our development of any outreach plan that
    we do have.
        Ms. Herseth Sandlin. Let me just ask you another followup
    question then. For you, Ms. Ryan, how many State Approving
    Agencies do you know have actually been present at the
    demobilization sites for National Guard or Reserve soldiers?
        Ms. Ryan. I cannot tell you exactly. Many, many, many. We
    talk about it often in our National meetings. I can certainly
    get you that information.
        Ms. Herseth Sandlin. Mr. Summerside or Ms. Ryan, you have
    already talked about a reduction in funding and how that would
    affect your outreach and customer service efforts.
        As you made some decisions working with Governor Rounds and
    with the State Adjutant General, were the funds coming from the
    VA for the State Approving Agency? Did you allocate more of the
    funding in the last two years to the cost associated with
    providing specific outreach or has it just been broader and
    some of the issues that we have talked to as it relates to your
    relationship with the processing of education claims and the
    veterans that are coming to you? Are you allocating funding
    differently in any way over the last five to six years?
        Mr. Summerside. The only thing that I can say from my
    perspective, we have always done outreach. Over the last couple
    of years, the VA has actually afforded us a payment for that
    outreach. And primarily in our State, it is the many outreach
    materials that we are able to--you know, sometimes we use a
    vendor as far as these quick reference guides that we provide
    on a wide range of topics, but specifically all the different
    chapters of education, you know, that is one thing that we
    progressively pursued in our State.
        And then that is the in-house stuff that we do, the welcome
    home, the OJT brochure, the school benefits brochure. We have
    two different brochures that we have developed in our State.
    And the other things, the technical manuals that we try to use
    and train these service professionals within our State, the
    County Service Officers, the vet reps, and Veteran Service
    Organizations.
        So to answer your question, we do have a line item for
    outreach over the last few years and I cannot go back to the
    exact contract year it started, but we have always done it
    somehow.
        Ms. Herseth Sandlin. Mr. Boozman?
        Mr. Boozman. Very quickly. On page 20 of the GAO report,
    there is a graph, a summary of the functions. I guess what I
    would like to know is if you all, the State Approving Agencies,
    could get with GAO and really provide a more detailed breakdown
    than what we have got on the page. I think it would be very
    helpful to me to know what these different things represent and
    exactly what you are doing and, know what Education and Labor
    is represented.
        Again, if you could show us the contrast in this kind of
    vehicle, it would be very helpful. Thank you.
        Ms. Ryan. We would be glad to do that.
        [A followup letter, dated April 27, 2007, and supplemental
    information was provided by Ms. Ryan and Mr. Sweeney in
    response to Mr. Boozman's request.]
        Mr. Boozman. Thank you.
        Ms. Herseth Sandlin. One final question for Mr. Summerside
    and Ms. Ryan. Ms. Ryan, you stated in your testimony as it
    related to the GAO recommendation for the VA to establish
    outcome-oriented performance measures and you acknowledge that
    more could be done in that area. I am interested in your and
    Mr. Summerside's perspectives on the other recommendation which
    would require SAAs to track and report data on resources spent
    on specific activities.
        Could you comment on how you view that recommendation and
    the administrative ease or difficulty in tracking and
    monitoring these activities?
        Ms. Ryan. We already do track the activities pretty
    extensively. We have quarterly reporting. George has developed
    a pretty extensive mechanism to do that. We report, you know,
    all kinds of numbers, outreach activities and approvals, and it
    is part of our self-evaluation process that happens at the end
    of the year.
        Ms. Herseth Sandlin. And each State Approving Agency does
    that or is this----
        Ms. Ryan. Absolutely.
        Ms. Herseth Sandlin. Okay.
        Ms. Ryan. Yeah, absolutely.
        Ms. Herseth Sandlin. So this would be a matter of sitting
    down with the folks at the VA who agreed with that
    recommendation, showing them what you have----
        Ms. Ryan. Yes. Yes.
        Ms. Herseth Sandlin [continuing]. And making any changes
    that may be necessary, but perhaps none would be required as
    they see the depth and breadth of what you are tracking?
        Ms. Ryan. Right. And they have access to that information.
        Ms. Herseth Sandlin. Okay.
        Ms. Ryan. They do have that. What we do not do is take it
    to the next step where we assign dollar figures to what we do,
    you know, X amount of dollars for outreach, X amount of dollars
    for approvals. We do not do that at this time.
        Ms. Herseth Sandlin. How difficult would it be to do that?
        Ms. Ryan. It would be difficult.
        Ms. Herseth Sandlin. Okay.
        Mr. Sweeney. Could I add to that?
        Ms. Herseth Sandlin. Yes, please.
        Mr. Sweeney. I think in part because it is a profession, we
    are not on a clock eight to five. I mean, I can be shoveling
    snow or riding around on my lawn mower cutting grass on a
    Saturday morning thinking about how I am going to resolve a
    problem.
        It is literally a profession. I think for most of us it is
    definitely not an eight to five, 40 hour week. So, you know, we
    could do a time clock mentality and try to break this out, but
    there is going to be some limitations on that. And that is part
    of the difficulty.
        Ms. Herseth Sandlin. I understand.
        Mr. Scott, do you have any comments?
        Mr. Scott. Yes, Madam Chairwoman. I think as we point out
    in our report along with the recommendations that we would hope
    that the recommendations in terms of how they would be
    implemented would be in proportion to the amount of program
    dollars we are talking about here. So we, of course, would not
    expect SAAs to come up with a multi-million dollar tracking
    system to keep track of $19 million.
        On the other hand, though, to the extent that these are
    Federal taxpayers' dollars being spent, we do think it is
    important to make sure we can account for how the money is
    being spent. We did ask for data on sort of, you know, could
    you tell us how much, you know, of the resources are spent
    toward site visits, how much of the resources are spent toward
    outreach and that sort of thing. And they were not able to
    provide that information, they being the Department of Veteran
    Affairs.
        So we do think it is important to come up with some
    mechanism to provide a better accounting of how dollars are
    being spent and so that will help in terms of developing more
    outcome-oriented performance measures.
        Ms. Ryan. As a followup, we have had discussions with Keith
    Wilson at the central office about doing that very thing.
        Ms. Herseth Sandlin. I appreciate that because I did not
    want to get into the minutiae of how we go about doing that
    now. I would think that with the data that you have been
    collecting and sitting down as it relates to all three of these
    recommendations, there might be a way to address the issue of
    accountability that Mr. Scott has raised.
        Well, if there is nothing further from the members of the
    Subcommittee, I thank you each for your testimony and for being
    here today. We will look forward to following up with you as
    our staff and the other members may have additional questions
    that will be submitted as part of the hearing and record for
    today. Thank you.
        I would now invite our second panel to the witness table
    and as they are coming up allow me to introduce them to those
    who are at the hearing today.
        We have Mr. John McWilliam, Deputy Assistant Secretary for
    Operations and Management, Veterans' Employment and Training
    Service of the U.S. Department of Labor; accompanied by Mr.
    Anthony Swoope, Administrator, Office of Apprenticeship,
    Employment and Training Administration for the U.S. Department
    of Labor; Ms. Carol Griffiths, Chief, Accrediting Agency
    Evaluation Unit, Office of Postsecondary Education of the U.S.
    Department of Education; and Mr. Keith Wilson, Director of the
    Education Service, Veterans Benefits Administration of the U.S.
    Department of Veterans Affairs respectively.
        All of you are very familiar with the Subcommittee and we
    appreciate you being here again today. We will go ahead and
    start with you, Mr. McWilliam, with your opening statement.

    STATEMENTS OF JOHN M. McWILLIAM, DEPUTY ASSISTANT SECRETARY FOR
     OPERATIONS AND MANAGEMENT, VETERANS' EMPLOYMENT AND TRAINING
       SERVICE, U.S. DEPARTMENT OF LABOR; ACCOMPANIED BY ANTHONY
    SWOOPE, ADMINISTRATOR, OFFICE OF APPRENTICESHIP, EMPLOYMENT AND
      TRAINING ADMINISTRATION, U.S. DEPARTMENT OF LABOR; CAROL A.
    GRIFFITHS, CHIEF, ACCREDITING AGENCY EVALUATION UNIT, OFFICE OF
      POSTSECONDARY EDUCATION, U.S. DEPARTMENT OF EDUCATION; AND
    KEITH M. WILSON, DIRECTOR, EDUCATION SERVICE, VETERANS BENEFITS
          ADMINISTRATION, U.S. DEPARTMENT OF VETERANS AFFAIRS

                     STATEMENT OF JOHN M. McWILLIAM

        Mr. McWilliam. Thank you, ma'am.
        Chairwoman Herseth Sandlin, Ranking Member Boozman, Mr.
    Donnelly, I am pleased to appear today before you on functions
    performed by the State Approving Agencies. Accompanying me
    today is Mr. Tony Swoope, Administrator of the Office of
    Apprenticeship in the Department of Labor.
        DoL has a separate responsibility from that of the State
    Approving Agencies. Under the ``National Apprenticeship Act
    1937,'' Labor is the Federal agency authorized to register
    apprenticeship programs for Federal purposes. Federal purposes
    include any Federal contract, grant, agreement, or arrangement
    and all Federal financial assistance.
        Department of Labor's role is to safeguard the welfare of
    apprentices, ensure equality of access to apprenticeship
    programs, and provide integrated employment and training
    information to sponsors and the local employment and training
    community.
        Title 38 states that an eligible veteran may be paid a
    training allowance while pursuing a full-time program of
    apprenticeship when that program is approved by a State
    Approving Agency as meeting the standards published by the
    Secretary of Labor.
        Those standards require that the program be registered by
    either Department of Labor or a DoL recognized State
    apprenticeship agency. These State apprenticeship agencies are
    separate from the State Approving Agencies being discussed at
    today's hearing.
        Labor has not determined what, if any, overlap exists
    between reviews conducted by Labor and the State Approving
    Agencies. We believe there may be overlap in the review of
    program sponsors' performance.
        Labor supports working with the Departments of Veterans
    Affairs and Education to review both the similarities and
    differences between the assessment components. We met with the
    VA in March on this subject. We look forward to continuing
    collaboration with our partners.
        DoL does not have any responsibility for, as mentioned
    earlier, nor do we participate in OJT programs for veterans.
        Madam Chairwoman, that concludes my testimony. Mr. Swoope
    and I will be pleased to answer your questions.
        [The prepared statement of Mr. McWilliam appears on p. 49.]
        Ms. Herseth Sandlin. Thank you very much, Mr. McWilliam.
        Ms. Griffiths.

                    STATEMENT OF CAROL A. GRIFFITHS

        Ms. Griffiths. Good afternoon, Madam Chairwoman, Ranking
    Member Boozman, and Mr. Donnelly.
        I appreciate the opportunity to be here today to share with
    you information regarding the Secretary's recognition process.
        In context, the ``Higher Education Act 1965'' requires that
    the Secretary publish a list of accrediting agencies and State
    Approval Agencies that she recognizes as reliable authorities
    as to the quality of education provided by the institutions and
    programs that they accredit. Currently she recognizes 62
    accrediting agencies and five State Approval Agencies.
        Understand that State Approval Agencies in the context of
    our process are units within the State Departments of Education
    whose function is the approval and oversight of public
    postsecondary vocational education. These programs are usually
    offered via the K through 12 school districts to adult
    students.
        The Secretary's recognition enables over 8,100 institutions
    they accredit to establish eligibility to participate in the
    Title 4 student financial aid programs administered by the
    Department of Education as well as programs offered by other
    Federal departments.
        Recognition provides access to approximately $90 billion
    annually by institutions of higher education, students, and
    their families.
        The recognition process includes a self-review by the
    accrediting or State Approval Agency, a review conducted by the
    Department staff, review by an external body representative of
    the higher education community. This 15-member body is known as
    the Secretary's National Advisory Committee on Institutional
    Quality and Integrity, the NACIQI.
        Ultimately after those reviews, the Secretary makes a
    decision of recognition. The review conducted is a compliance
    model review against the Secretary's criteria for recognition.
    Accreditors must not only describe their policies, procedures,
    standards, and practice, they must show evidence or
    documentation of how they apply them.
        Department analysts review and evaluate that information
    and also conduct on-site evaluations and observations of
    accrediting agency activities in regard to the accreditation
    process as well as conduct file reviews at the agencies.
        Staff review includes an assessment of an agency's
    organizational structure, its administrative and financial
    capacity, its adherence to principles of due process, what
    mechanisms it has in place to prevent conflicts of interest,
    its responsiveness to complaints, and its use of public input
    in the review of its standards and policies and practices, as
    well as, at the core of the accreditation process, a review of
    the agency's quality standards by which they evaluate
    institutions and programs for accreditation and their
    consistent application of these and ongoing monitoring for
    compliance with them.
        Specifically as outlined in the ``Higher Education Act''
    and in the Secretary's criteria, these standards include
    administrative and fiscal capacity of an institution or
    program, an evaluation of curriculum, of faculty, of student
    support services, facilities and other resources and standards
    in the area of student achievement.
        From that Department staff draw conclusions of compliance
    and make a recommendation regarding recognition. All of the
    information provided by agency and by the Department staff go
    forward to the Secretary's National Advisory Committee who meet
    twice a year to review agencies seeking both initial
    recognition or renewal of their recognition.
        After hearing from Department staff, from the agency, and
    other third-party commenters who show an interest, the
    Committee deliberates and provides the Secretary with a
    recommendation as to whether they recommend that she defer,
    deny, or renew recognition of that agency.
        Each accrediting agency is reviewed once every five years
    and State Approval Agencies are reviewed once every four years.
        In summary, currently the Secretary recognizes 62
    accrediting agencies and five State Approval Agencies as
    reliable authorities of the quality of education and training
    provided by the institutions and programs they accredit.
        The recognition process is comprehensive, it is ongoing. It
    includes input from both internal and external sources. The
    recognition provides a critical oversight function for many
    Federal programs and, as I said before, enables access to $90
    billion annually.
        I hope this information has been helpful to you and your
    members, and I am ready to answer any questions you may have
    regarding the recognition process. Thank you.
        [The prepared statement of Ms. Griffiths appears on p. 50.]
        Ms. Herseth Sandlin. Ms. Griffiths, thank you very much.
        Mr. Wilson, you are recognized.

                      STATEMENT OF KEITH M. WILSON

        Mr. Wilson. Good afternoon, Madam Chairwoman, Ranking
    Member Boozman, and members of the Subcommittee. Thank you for
    the opportunity to discuss VA's education programs and the role
    of the State Approving Agencies in those programs.
        My testimony will highlight the vital role of SAAs in
    ensuring that veterans receive the maximum benefit for their
    educational programs.
        VA and the SAAs work together to ensure the successful
    readjustment of veterans to civilian life through educational
    opportunities. VA administers educational assistance to
    eligible veterans and dependents while the SAAs ensure the
    quality of the educational and vocational programs pursued and
    monitor the institutions providing education and training to
    veterans.
        Since 2001, they also conduct outreach programs and provide
    outreach services to eligible servicemembers and veterans.
    Title 38 establishes the parameters for this relationship.
        A recent GAO report contained three major recommendations.
    VA generally agrees with all three recommendations. We are
    taking actions to address these recommendations in cooperation
    with the National Association of State Approving Agencies as
    well as our colleagues at the Department of Labor and
    Department of Education.
        Public Law 100-323 requires an annual joint peer review
    group to meet for the purposes of evaluating performance of the
    individual State Approving Agencies. The JPRG is composed of
    four SAA representatives as well as four VA representatives.
    There are three designated ratings, satisfactory, minimally
    satisfactory, and unsatisfactory.
        For 2006, two SAAs received an unsatisfactory rating, three
    received a minimally satisfactory rating, and 54 agencies
    received a satisfactory rating.
        In fiscal year 2007, VA will provide approximately $19
    million in funding to the SAAs. For fiscal year 2008, the
    amount of funding for SAAs will decrease to approximately $13
    million per section 301 of Public Law 107-330.
        The outreach activities added to the SAA's role in 2001 may
    be impacted by the reduction in SAA funding. However, VA has
    taken steps to mitigate this impact.
        Information concerning VA education benefits is mailed
    three times to servicemembers while they are on active duty and
    again at separation.
        The Transition Assistance Program operated jointly by DoL,
    VA, and DoD, as well as benefit briefings for demobilizing
    National Guard and Reserve members provides information on
    education benefits available to these members.
        VA has also participated in the training of newly created
    State benefits advisors.
        Despite these efforts, a reduction in SAA funding may
    negatively impact our efforts to promote the use of VA
    education benefits, particularly the promotion of OJT and
    apprenticeship programs with employers. The extent to which
    these efforts could be impacted is difficult to predict.
        Madam Chairwoman, this concludes my statement. I would be
    pleased to answer any questions you or other members of the
    Subcommittee may have.
        [The prepared statement of Mr. Wilson appears on p. 52.]
        Ms. Herseth Sandlin. Thank you all for your testimony.
        I will start with a brief question. Mr. Wilson, you just
    said that there were two SAAs in 2006 that received an
    unsatisfactory rating; is that correct?
        Mr. Wilson. That is correct.
        Ms. Herseth Sandlin. Did either of them lose funding due to
    that unsatisfactory rating?
        Mr. Wilson. No. The way we approach this is from a
    progressive standpoint. We set up training and mentoring
    relationships with them. Ultimately if they do not perform to
    an acceptable level, we have the option of reducing funding or
    not opting to offer them a contract entirely, which we have
    done in the past.
        Ms. Herseth Sandlin. Okay. Do you know if the
    Administration intends to take a position as it relates to the
    need for increased resources beyond $13 million for the State
    Approving Agencies?
        Mr. Wilson. The Administration will not take a position.
        Ms. Herseth Sandlin. And, Ms. Griffiths, have you found it
    beneficial to maintain the distinction between national and
    regional institutional accreditors and is there overlap between
    the two?
        Ms. Griffiths. Thank you for the question.
        In terms of the Secretary's recognition process, all
    accreditors that seek recognition must comply with the same
    criteria, you know, in the context of the scope of their
    accrediting activities.
        Ms. Herseth Sandlin. So it has been beneficial to maintain
    the distinction between national or regional accreditors?
        Ms. Griffiths. I think that, yes, that we have to evaluate
    and make the distinction based on the type of accrediting
    activity with the type of educational and training program
    being provided.
        Ms. Herseth Sandlin. Does the activity of the national
    accreditor and the regional accreditor differs in the process,
    in the review process? I am a little unclear as to--maybe you
    could just explain what a national institutional accreditor
    does that a regional one does not or there are distinctions in
    their--I know you just said that they use the same criteria.
        Ms. Griffiths. Yes. Their processes are the same. They are
    free to develop their own standards, but the components of the
    accreditation process are the same between national
    institutional accreditors and regional and even programmatics.
        But an agency that evaluates a specialized single program
    perhaps applies those standards differently. They all have to
    have standards in the same areas, but they apply them in the
    context of the type of accrediting activity they do.
        Ms. Herseth Sandlin. Okay.
        Ms. Griffiths. I hope that helps.
        Ms. Herseth Sandlin. I may have some other questions. We
    just have another series of votes, so let me move quickly to
    our Ranking Member for any questions.
        Mr. Boozman. Thank you very much.
        First of all, I want to thank all of you. I know that you
    worked very hard and, we are trying to move things forward and
    do the very best that we can for our veterans.
        But I am a little bit concerned. Mr. Wilson, on your
    testimony at the end you alluded to the fact that we really did
    not know how this was going to affect the ability of our men
    and women to know what was going on and things.
        And I guess one of the threads that I have seen, and I
    think we work really hard at this now, but one of the threads I
    have seen in being with our troops, from the testimony that we
    have taken in different deals was right now, was then many of
    our people in uniform do not understand the flexibility that
    they have in the GI Bill and what they can be used for.
        It sounds like you are not supporting an increase from the
    $13 million; is that correct?
        Mr. Wilson. We are not taking a position on the increased
    funding.
        Mr. Boozman. But on the other hand, that is going to be
    potentially even more of a problem, even though we are working
    on it hard now, that is a big problem.
        Mr. Wilson. It is a concern for us as well. One of the
    unknowns as we move forward into a potential reduction is
    whether we have the flexibility in VA obviously to manage this
    contract. On the other hand, the States also have the
    flexibility of deciding whether or not they want to enter into
    a contract with us.
        And it may be simply that there could be some States that
    it is no longer to their benefit, that we are not able to
    reimburse them to the level that they need. And that is the
    unknown that we have difficulty quantifying.
        Mr. Boozman. Well, our Committee really is to interface in
    that regard with you. And so, if we lose any of that--in fact,
    I would like for us to push that we do a better job of making
    that known because it is so important. The benefit is there
    and, again, a lot of them do not understand.
        When you look at the numbers of taking up the slack through
    the rest of the agency and when you look at the average salary,
    then according to Mike Smith, and you are talking about 76, in
    the 70s FTEs doing that. So when you do that, we already have a
    problem with processing educational claims, I just do not see
    how you can do it. And so, again I guess I feel very strongly
    that we are going to hold you accountable to do that.
        You mentioned the fact that some of the agencies, had
    problems. And, again, we very much need to rectify that. And I
    think it is good that we have the process in place so we can
    recognize when somebody is not doing their job.
        On the other hand, as we, the VA Committee, you the VA, run
    into problems all the time and we solve those problems. You do
    not throw away everything.
        So, again, I would just say that I would hope VA really
    thinks this through. I want to help you. I want to get you the
    funding that you need. I want to fight for it.
        But if you do not feel like, and it sounded like in your
    testimony you were waffling a little bit, you cannot do it,
    then, like I said, we are going to come after you because you
    are going to mess up in these other areas and we are going to
    have a bigger mess. But I would say that in some of those
    areas, we are not doing a very good job now.
        So I would appreciate if VA would really think this through
    and then I think you need to come out one way or the other. If
    you cannot do your job with $13 million, then you need to tell
    us what it is going to take. And it sounds to me like we are
    really having a little bit of trouble with the $19 million.
        I yield back to the Chairwoman.
        Ms. Herseth Sandlin. Thank you, Mr. Boozman.
        I associate myself with his comments and we are trying to
    just determine what level of activity is best to be maintained
    which is why some of our earlier questions from the prior panel
    tried to probe this area, this issue of overlap or duplication.
        I understand because it is a statutory cap, the
    Administration may not want to take a position at this point,
    but would you at least share with us from your perspective as
    the Director if the Secretary feels? As I think we heard from
    the first panel, that Operation Iraqi Freedom and Operation
    Enduring Freedom have had an impact, an expansive impact on the
    mission of the State Approving Agencies.
        Mr. Wilson. It absolutely has, particularly from the
    perspective of outreach as we have been talking about.
        What we do not have a good handle on, and an area that I
    look forward to working with my colleagues in DoL and DoE on,
    is where is potential overlap and are there things that we can
    do more efficiently that will allow us yet further to mitigate
    the impact of any potential reduction in funding.
        I think the folks at GAO did a very good job with their
    report. However, one thing that troubles me is I believe that
    there may be a belief that our responsibility, the programs
    that we administer in VA are equivalent to Federal student aid,
    even to the point of GAO using aid as a term when they talked
    about veterans' programs.
        Speaking as a veteran now, I do not equate it with aid.
    That is a benefit that is earned. And I believe we have a
    higher level of responsibility than really exists with Federal
    student aid. And we have to find a way of meeting that.
        Ms. Herseth Sandlin. I appreciate that comment, Mr. Wilson.
    I think it is a very good point for us to keep in mind as we do
    maybe go another level or two further, as the Ranking Member
    has suggested, as I think it is a good recommendation talking
    with staff about this issue of overlap and how these measures
    in the matrix are used. We need some more specificity so that
    distinctions such as you just articulated are adequately
    accounted for.
        That does lead me to a question, Mr. McWilliam, did you
    mention that DoL has yet to determine if overlap exists between
    reviews by the registered apprenticeship system and the State
    Approving Agencies?
        Mr. McWilliam. That is correct, ma'am, and I will ask Mr.
    Swoope, if I may, to elaborate on that.
        Ms. Herseth Sandlin. I appreciate that. Is the review being
    undertaken currently?
        Mr. Swoope. Yes, Madam Chairwoman. We are having
    conversations with the Department of Veterans Affairs and we
    hope to continue with that conversation to see how we can
    better partner our activities to benefit the veterans that are
    coming out and receiving the services that are required and we
    would like for them to participate in that. In our case, the
    National Apprenticeship System.
        Ms. Herseth Sandlin. Have the State Approving Agencies, or
    any of their representatives, been at the table in these
    discussions as they relate to not just coordination between DoL
    and the VA but as we heard from the first panel, the importance
    of what they have been sitting down with you about, Mr. Wilson?
    Have they been----
        Mr. Swoope. Two things. At the national level, we just had
    a conversation with the VA. At the State level where our staff
    is working in that area in Federal States where they had the
    responsibility for registering program, we encourage our staff
    to partner and work with the veteran organizations or approving
    agency so that veterans can receive VA benefits.
        So we try to include that on an ongoing basis by our
    Federal staff and the State agency staff at the local level to
    ensure that they know where we are, what we are, what we are
    doing, and how do we have this partnership where the veteran
    can receive VA benefits that they are entitled to, going
    through an apprenticeship program.
        Ms. Herseth Sandlin. I appreciate that.
        One final question and then I am going to see if the
    Ranking Member has any further followup.
        Ms. Griffiths, you said that the Department of Education
    recognizes five State Approving Agencies. Describe these five
    for me. When you say State Approving Agencies, are you talking
    about a different type of entity than what we are talking about
    when we say State Approving Agencies that work with VA funding
    and how would you characterize or describe Department of
    Education's relationship with the State Approving Agencies that
    testified today?
        Ms. Griffiths. In terms of the recognition process, we do
    not have a relationship with State Approving Agencies from the
    Department of Veterans Affairs. What we have, our State
    Approval Agencies, they are units within State Departments of
    Education that have an oversight function for public post-
    secondary vocational education in their states.
        And these approval agencies, some of them, should they
    choose to, seek the Secretary's recognition by submitting to
    this evaluation and review. If they are recognized State
    Approval Agencies, again units in State Departments of
    Education that have that function, then those public
    postsecondary vocational education programs that they approve
    are eligible to participate in Title 4 student financial aid
    programs.
        Ms. Herseth Sandlin. Okay. But separate from this formal
    recognition of an agency, if they do not go through that
    process because that might require substantial changes at the
    State level with some of the folks that we heard from earlier.
    How do you envision the Department of Education being a part of
    this collaboration with the VA and the Department of Labor and
    the State Approving Agencies that work with the VA?
        Ms. Griffiths. I am not sure I can answer that question. I
    do not know that I today have sufficient information to talk
    about what that would look like. But I do know that we would be
    most open and willing and eager to sit down and talk with and
    find out more information and see what we can do in the best
    interest of the use of tax dollars. Yes.
        Ms. Herseth Sandlin. I appreciate that. I do think it is
    important as, Mr. Swoope, as you worked to undertake this
    review and analysis, that DoE's perspective be shared. It will
    help us answer some questions raised in the GAO report so we
    can have a better understanding from the State Approving
    Agencies' perspective where they do not really consider it an
    overlap of services but actually a more targeted service to the
    veteran himself or herself.
        Any final comments from any our panelists on that point
    with regard to collaboration?
        Mr. Wilson. If I could add just a brief comment to Mr.
    Swoope's statement.
        Ms. Herseth Sandlin. Sure.
        Mr. Wilson. Getting back to your original question, we will
    be engaging the SAAs in these discussions. We are not at that
    point yet. We will be engaging them as I would hope that we
    would be engaging the staff of this Committee. We certainly
    will be looking at procedural and regulatory issues, but I
    think it is important to look at the statutory requirements
    that we are all responsible for meeting as well.
        Ms. Herseth Sandlin. Another point well-taken. Thank you,
    Mr. Wilson.
        Mr. Boozman.
        Mr. Boozman. No. With the Committee's approval, we might
    have a question or two that we will submit. Thank you.
        Ms. Herseth Sandlin. Certainly. Thank you again. I
    appreciate the insight and perspective you have offered. As is
    common with the Subcommittee, first under Mr. Boozman's
    leadership as Chairman and now in the 110th Congress, we
    appreciate the working relationship we have with all of your
    offices, the work of our staff who worked with you in the past
    and not only as staff of this Subcommittee but other VSOs that
    they have worked with. We look forward to the followup that I
    think will be necessary for us to take full advantage of the
    good work as you described it, Mr. Wilson, in the GAO report
    and the perspective of the State Approving Agencies that was
    offered today.
        Thank you very much.
        We have got three minutes from the vote, so this hearing
    better stand adjourned.
        [Whereupon, at 3:53 p.m., the Subcommittee was adjourned.]

                                A P P E N D I X

                                  ----------

         Opening Statement of the Honorable Stephanie Herseth Sandlin,
                Chairwoman, Subcommittee on Economic Opportunity

        Good afternoon, ladies and gentlemen. The Veterans' Affairs
    Economic Opportunity Subcommittee hearing on functions performed by
    State Approving Agencies (SAA) will come to order.
        Before I begin with my opening statement, I would like to call to
    attention to the fact that Ms. Jean Morse, President of the Middle
    States Commission on Higher Education has asked to submit a written
    statement for the record on behalf of the Council of Regional
    Accrediting Commissions. If there is no objection I ask for unanimous
    consent that this statement be entered for the record.
        Today we will be hearing testimony on State Approving Agencies. The
    authority of SAAs was established by Congress in 1947 to ensure that
    veterans and eligible dependents can use the G.I. Bill educational
    entitlement in an approved educational
    program. Under contract with the Department of
    Veterans' Affairs (VA), the key func- tion of SAAs is to ensure that
    education and training programs meet VA standards through a range of
    approval activities, such as: conducting on-site visits, evaluating
    course quality, assessing school financial stability, and monitoring
    student progress.
        Every state assesses each program as to its own standards and laws
    in addition to the VA rules and regulations, with all approved programs
    undergoing continuous supervision. The programs that can be approved
    include colleges, universities, vocational and technical schools,
    flight schools, apprenticeship programs, and other on-the-job training
    programs. In addition, SAAs engage in outreach activities to foster the
    usage of the G.I. Bill.
        This year, my home state of South Dakota is expecting to have
    approximately 2,100 eligible people enrolled in G.I. Bill eligible
    programs. These programs are now found in 47 schools and 192 training
    establishments in my state. I have a strong interest in exploring the
    subject before us today to improve the availability of educational
    benefits for our men and women in uniform.
        I understand there are concerns about the funding change that is
    about to occur for SAAs. From fiscal years 2003 to 2006, their funding
    increased from $13 million to $19 million to expand services. However,
    the funding level for SAAs is scheduled to decrease beginning in fiscal
    year 2008.
        According to a recent report, the Government Accountability Office
    concluded that there was overlap between the efforts of SAAs and the
    other federal agencies. While VA spends $19 million to fund SAA duties
    and functions, it does not track the amount it spends on specific SAA
    activities, especially those that may also be performed by other
    agencies. I am very interested in hearing your insights on how these
    concerns are being addressed.

                Opening Statement of the Honorable John Boozman,
        Ranking Republican Member, Subcommittee on Economic Opportunity

        Good afternoon, everyone.
        The State Approving Agencies have, for many years, been a mainstay
    in ensuring that veterans attending education and training programs
    under the various GI Bills receive quality instruction. That is why I
    thank you, Madam Chairwoman, for holding this hearing.
        A recent GAO report that updated a 1995 report again found overlaps
    in the functions performed by the State Approving Agencies, the
    regional and professional accrediting agencies acting on behalf of the
    Department of Education, and the oversight services provided by the
    state employment services. While the recent report was less critical
    than its predecessor and noted that SAAs did, in fact, provide
    perspectives not replicated by the other organizations, GAO again
    recommended a thorough interagency review of how the federal government
    oversees the education industry. I believe that it is important to
    begin that process as a means to improve the education and training
    opportunities for veterans and dependents.
        Another issue we face is how much funding should VA provide to the
    states to act as VA's agent. VA currently pays the collective SAAs
    about $19 million out of the Readjustment Benefits Account (RBA). As
    such, those payments are mandatory spending and beginning in FY 08, the
    law cuts that funding to $13 million. So, the question before us is
    what is the value of the services provided by the SAAs?
        I note that we will also hear from a regional accrediting agency as
    well as a representative from the Department of Education. I look
    forward to their testimony, especially the functions and costs
    associated with their programs.
        I am sorry that witnesses
    from the accrediting bodies we invited were unable to at- tend. Their
    testimony would have been a valuable perspective relative to the GAO's
    findings. I would note that accrediting associations overseeing
    colleges and universi- ties are membership organizations
    who charge their members significant annual dues as well as large fees
    for other functions such as approving new courses of instruction. For
    example, the alma mater of one of our staff is a small liberal arts
    school in the Midwest with a full time enrollment of about 1,800
    students. That school pays at least $4,000 in annual dues to its main
    accrediting association in addition to any fees for special visits. I
    am not criticizing the accrediting bodies for charging
    fees, but I thought it important that the Members know this aspect of th
    eir operations.
        Regarding the Department of Labor, I am looking forward to hearing
    about the level of their interaction with the SAAs in approving OJT and
    apprenticeship programs.
        Madame Chairwoman, thanks again for your leadership on this issue
    and I yield back.

    Statement of George A. Scott, Director, Education, Workforce and Income
             Security Issues, U.S. Government Accountability Office

        Madame Chairwoman and Members of the Subcommittee:
        I am pleased to be here today to present information from our March
    2007 report on state approving agencies (SAA).\1\ In fiscal year 2006,
    the Department of Veterans Affairs (VA) paid approximately $2.1 billion
    in education assistance benefits to more than 470,000 beneficiaries and
    about $19 million to state approving agencies to assess whether schools
    and training programs offer education of sufficient quality for
    veterans to receive VA education assistance benefits when attending
    them. Qualified individuals--veterans, service persons, reservists, and
    certain spouses and dependents--receive benefits through a number of
    education assistance programs for the pursuit of various types of
    programs, such as a degree program, vocational program, apprenticeship,
    or on-the-job training. In general, these programs must be approved by
    an SAA in order for qualified individuals to receive VA education
    assistance benefits. Under contracts with VA, SAAs ensure that
    education and training programs meet VA standards through a variety of
    approval activities, such as evaluating course quality, assessing
    school financial stability, and monitoring student progress.
    ---------------------------------------------------------------------------
        \1\ GAO, VA Student Financial Aid: Management Actions Needed to
    Reduce Overlap in Approving Education and Training Programs and to
    Assess State Approving Agencies, GAO-07-384 (Washington, D.C.: Mar. 8,
    2007).
    ---------------------------------------------------------------------------
        The Departments of Education (Education) and Labor (Labor) also
    assess education and training programs for various purposes, primarily
    for awarding student aid and providing apprenticeship assistance. These
    assessments are based, in part, on evaluations against standards set by
    laws and regulations, such as those applicable to accrediting agencies.
    In 2006, under Title IV of the Higher Education Act, Education provided
    nearly $77 billion in student aid in the form of both grants and loans.
    Education assesses and certifies postsecondary institutions for
    participation in Title IV programs through various oversight functions
    to ensure that these schools meet federal administrative and financial
    requirements and that they are accredited and licensed. Similarly,
    under the National Apprenticeship Act 1937, Labor is authorized to
    formulate and promote the furtherance of labor standards to safeguard
    the welfare of apprentices. To ensure programs comply with federal
    standards, Labor directly registers and oversees apprenticeship
    programs in less than half of the states and has given state
    apprenticeship agencies or councils in the remaining states such
    authority over their own programs.
        Given each agency's role, the potential of duplicative efforts
    among federal agencies has been a congressional concern. In 1995, GAO
    reported on this matter and concluded that there was a substantial
    amount of overlap between the efforts of SAAs and the other federal
    agencies.\2\ My testimony today is based on information from our recent
    report and will focus on (1) changes that have occurred in state
    approving agencies' duties and functions since 1995, (2) the extent to
    which the SAA approval process overlaps with efforts by the Departments
    of Education and Labor, and (3) the additional value that SAA approval
    activities bring to VA education benefit programs.
    ---------------------------------------------------------------------------
        \2\ GAO, VA Student Financial Aid: Opportunity to Reduce Overlap in
    Approving Education and Training Programs, GAO/HEHS-96-22 (Washington,
    D.C.: Oct. 30, 1995).
    ---------------------------------------------------------------------------
        In summary, we found that:

          Since 1995, legislative changes effective in 2001 created
    additional responsibilities for SAAs, including promoting the
    development of apprenticeship and on-the-job training programs,
    providing outreach services, and approving tests for occupational
    licensing.\3\ From fiscal years 2003 to 2006, SAA funding increased
    from $13 million to $19 million to expand services and support the
    additional responsibilities. However, funding is scheduled to decrease
    beginning in fiscal year 2008.
    ---------------------------------------------------------------------------
        \3\ Veterans Benefits and Health Care Improvement Act of 2000, Pub.
    L. No. 106-419 (2000); and Veterans Education and Benefits Expansion
    Act of 2001, Pub. L. No. 107-103 (2001).
    ---------------------------------------------------------------------------
          Many education and training programs approved by SAAs
    have also been approved by Education or Labor, and VA and SAAs have
    taken few steps to coordinate approval activities with these agencies.
    In addition, information is not available to determine the amount of
    resources spent on SAA duties and functions, including those that may
    overlap with other agencies and programs.
          SAAs reportedly add value to the approval process for
    education and training programs through (1) a focus on student services
    for veterans and on the integrity of VA benefits, (2) more frequent on-
    site monitoring of education and training programs than provided by
    Education or Labor, and (3) assessments and approval of a small number
    of programs that are not reviewed by other agencies. However, VA's lack
    of outcome-oriented performance measures for evaluating SAAs makes it
    difficult to assess the significance of these efforts.

        To help ensure that federal dollars are spent efficiently and
    effectively, our report recommended that the Secretary of the
    Department of Veterans Affairs take steps to monitor SAA spending and
    identify whether any resources are spent on activities that duplicate
    the efforts of other agencies. We also recommended that the Secretary
    establish outcome-oriented performance measures to assess the
    effectiveness of SAA efforts. VA agreed with our findings and
    recommendations and stated that it will take a number of steps to
    address them.
        To conduct our work, we reviewed applicable laws, regulations, and
    program materials; and interviewed officials from each of the entities
    involved in the various approval processes, including federal agencies,
    state approving agencies, schools and training programs. We also
    reviewed and analyzed data on approval decisions from VA, Education,
    and Labor. Our work was performed in accordance with generally accepted
    government auditing standards.
    Background
        VA, Education, and Labor assess education and training programs for
    various purposes. VA's approval process is meant to ensure that
    education and training programs meet VA standards for receipt of
    veteran education assistance benefits, while Education's and Labor's
    processes are primarily for awarding student aid and providing
    apprenticeship assistance.
        VA administers a number of programs designed to assist individuals
    in gaining access to postsecondary education or training for a specific
    occupation (see table 1). VA generally provides its assistance in the
    form of payments to veterans, service persons, reservists, and certain
    spouses and dependents.

      Table 1:  VA Beneficiaries of and Funding for Education and Training
                     Assistance Programs in Fiscal Year 2006
    ------------------------------------------------------------------------
                  Programs *                 Beneficiaries     Expenditures
    ------------------------------------------------------------------------
    Montgomery GI Bill (Chapter 30)                 313,766   $1,909,014,605
    ------------------------------------------------------------------------
    Reserve Educational Assistance Program           23,747     $151,397,610
     (Chapter 1607)
    ------------------------------------------------------------------------
    Educational Assistance for the
     Selected Reserve
      (Chapter 1606)                                 65,145      $48,716,031
    ------------------------------------------------------------------------
    Dependents and Survivors Educational
     Assistance
      Program (Chapter 35)                           74,532      $38,787,332
    ------------------------------------------------------------------------
    Veterans Educational Assistance                     575          $59,113
     Program (Chapter 32)
    ------------------------------------------------------------------------
        Total                                       477,765   $2,147,974,691
    ------------------------------------------------------------------------
    Source: VA.
    * No payments for the National Call to Service program were made in
      fiscal year 2006.

        Benefits can be used to pursue a degree program, vocational
    program, apprenticeship, and on-the-job training (see fig. 1). Before
    an individual entitled to VA education assistance can obtain money for
    an education or training program, the program must be approved by an
    SAA, or by VA in those cases in which an SAA has not been contracted to
    perform the work.
       Figure 1:  Veteran Enrollment by Program Type in Fiscal Year 2006
    [GRAPHIC] [TIFF OMITTED] T5634A.001

        VA's administrative structure for the education and training
    assistance programs includes its national office, which oversees the
    four regional processing offices (RPO), and the national contract with
    SAAs. RPOs administer the education assistance programs and process
    benefits for veterans. SAAs review education and training programs to
    determine which programs should be approved and ensure schools and
    training providers are complying with VA standards. SAAs have six core
    duties: (1) approval of programs, (2) visits to facilities, (3)
    technical assistance to individuals at facilities, (4) outreach, (5)
    liaison with other service providers, and (6) contract management.
    Sixty SAAs exist in the 50 states, the District of Columbia, and Puerto
    Rico. Eight states have two SAAs. SAAs are usually part of a state's
    department of education (31 SAAs). In some states, SAAs are
    organizationally located in other departments such as labor (9 SAAs) or
    veterans' services (19 SAAs).
        The U.S. Department of Education's approval process is to ensure
    that schools meet federal Education standards to participate in federal
    student financial aid programs. In order for students attending a
    school to receive Title IV financial aid, a school must be (1) licensed
    or otherwise legally authorized to provide postsecondary education in
    the state in which it is located, (2) accredited by an entity
    recognized for that purpose by the Secretary of Education, and (3)
    certified to participate in federal student aid programs by Education.
    As such, the state licensing agencies, accrediting agencies, and
    certain offices within Education are responsible for various approval
    activities.

          State licensing agencies grant legal authority to
    postsecondary institutions to operate in the state in which they are
    located. Each of the states has its own agency structure, and each
    state can choose its own set of standards.
          Accrediting agencies develop evaluation criteria and
    conduct peer evaluations to assess whether or not those criteria are
    met by postsecondary institutions. Institutions or programs that meet
    an agency's criteria are then ``accredited'' by that agency. As of
    November 2005, there were 60 recognized private accrediting agencies of
    regional or national scope.
          The U.S. Department of Education's Office of
    Postsecondary Education evaluates and recognizes accrediting agencies
    based on federal requirements to ensure these agencies are reliable
    authorities as to the quality of education or training provided by the
    institutions of higher education and the higher education programs they
    accredit.
          The U.S. Department of Education's Office of Federal
    Student Aid determines the administrative and financial capacity of
    schools to participate in student financial aid programs, conducts
    ongoing monitoring of participant schools, and ensures participant
    schools are accredited and licensed by the states.

        The purpose of the Department of Labor's approval process is to
    establish and promote labor standards to safeguard the welfare of
    apprentices. Labor establishes standards and registers programs that
    meet the standards. Labor directly registers and oversees programs in
    23 states but has granted 27 states, the District of Columbia, and 3
    territories authority to register and oversee their own programs,
    conducted by state apprenticeship councils (SACs). Labor reviews the
    activities of the SACs. SACs ensure that apprenticeship programs for
    their respective states comply with federal labor standards, equal
    opportunity protections, and any additional state standards.
        Figure 2 shows the agencies responsible for the approval processes
    for the various types of education and training programs.

    Figure 2:  Agencies Responsible for the Approval Process for Education
                             and Training Programs

    [GRAPHIC] [TIFF OMITTED] T5634A.002

        Source: GAO Analysis.

    Legislative Changes Effective in 2001 Created Additional
            Responsibilities for SAAs
        In 2001, SAAs received additional responsibilities as a result of
    legislative changes. This included responsibility for actively
    promoting the development of apprenticeship and on-the-job training
    programs and conducting more outreach activities to eligible persons
    and veterans to increase awareness of VA education assistance. SAAs
    were also charged with approving tests used for licensing and
    certification, such as tests to become a licensed electrician. For
    those tests that have been approved, veterans can use VA benefits to
    pay for testing fees. From fiscal years 2003 to 2006, SAA funding
    increased from $13 million to $19 million to expand services and
    support the additional responsibilities. Funding is scheduled to begin
    to decrease in fiscal year 2008.
    Many Education and Training Programs Approved by SAAs Have Also Been
            Approved by Education or Labor, and VA Has Taken Few Steps to
            Coordinate Approval Activities with These Agencies
        Many education and training programs approved by SAAs have also
    been approved by Education and Labor. Sixty-nine percent of all
    programs approved by SAAs are offered by institutions that have also
    been certified by Education. Seventy-eight percent of SAA-approved
    programs in institutions of higher learning (e.g., colleges and
    universities) have been certified by Education. Also, 64 percent of
    SAA-approved non-college degree programs are in institutions that have
    been certified by Education. Although less than 2 percent of all
    programs approved by SAAs are apprenticeship programs, VA and SAA
    officials reported that many of these programs have also been approved
    by Labor.
        Similar categories of approval standards exist across agencies, but
    the specific standards within each category vary and the full extent of
    overlap is unknown. For example, while VA and Education's approval
    standards both have requirements for student achievement, the New
    England Association of Schools and Colleges, an accrediting agency,
    requires that students demonstrate competence in various areas such as
    writing and logical thinking, while VA does not have this requirement.
    Also among the student achievement standards, VA requires schools to
    give appropriate credit for prior learning, while Education does not
    have such a requirement. Table 2 shows the similar categories of
    standards that exist across agencies.

                                                                                                                                                    Appren-
                                                                                                                                                   ticeship

                                Table 2.  Approval Standards of Education and Training Programs Used by VA, Education, and Labor
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                         SAA \1,2\                                     Education \3\                 Labor
                                                  ----------------------------------------------------------------------------------------------------------
                                                                                                                          Federal
           Categories of approval standards                     IHL/NCD non-                    On the                   Standards    Connecticut
                                                     IHL/NCD     accredited   Apprenticeship     job      Education's       for          state
                                                    accredited                                 training  certification  accrediting    licensing
                                                                                                                          agencies      agency
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Student                                                 X            X             X             X                           X            X           X
      achievement
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Curricula, program objectives, and faculty              X            X             X             X            X              X            X           X
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Facilities,                                             X            X             X             X                           X            X           X
      equipment,
      and supplies
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Institutional                                           X            X                                        X              X            X           X
      objectives,
      capacity, and
      administration
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Student support services                                                                                                     X            X
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Recruiting and admission                                X            X                                        X              X            X           X
      practices
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Record of student complaints                                                                                                 X                        X
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Process related requirements (e.g.                      X            X             X             X            X                           X           X
     application requirements)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Source: GAO analysis of VA, Education, and Labor Standards.
    Notes: GAO constructed these categories to encompass the numerous and broad range of standards used by agencies. SAAs have different sets of standards
      for each program type (e.g. IHL and NCD). Education's approval process involves different sets of standards used by different entities, such as
      accrediting agencies. Labor has one set of standards that is applicable to apprenticeship programs.
    \1\ By statute, courses must meet certain criteria. These relate to: (1) recordkeeping of student progress; (2) recordkeeping of students' previous
      education; (3) quality, content and length of courses; (4) qualifications of administrators and instructors; and (5) equipment, space, and
      instructional materials. We categorized the first two criteria as student achievement, criteria (3) and (4) as Curricula, Program Objectives and
      Faculty, and criterion (5) as Institutional objectives, capacity, and administration.
    \2\ SAA approval requirements for non-accredited courses encompass a number of additional criteria, such as having a tuition refund policy and
      enrollment limitations.
    \3\ Connecticut's standards may not be representative of standards across the country.

        While agencies have the same approval standards in some instances,
    the interpretation and application of these standards may differ. For
    example, VA, accrediting agencies, and Labor each require that
    facilities have adequate space, equipment, and instructor personnel to
    provide quality training, but the definitions of adequacy differ in the
    level of specificity. Similarly, VA and accrediting agencies both
    require that schools have policies related to student achievement, such
    as minimum satisfactory grades, but the requirements differ in level of
    specificity.
        Despite the overlap in approved programs and standards, VA and SAAs
    have made limited efforts to coordinate approval activities with
    Education and Labor. VA reported that while it has coordinated with
    Education and Labor on issues related to student financial aid and
    apprentices' skill requirements, it believes increased coordination is
    needed for approval activities in order to determine the extent of
    duplicative efforts. Most of the SAA officials we spoke with reported
    that they have coordinated with SACs to register apprenticeship
    programs in their states. Labor reported that it coordinated with VA's
    national office in several instances, including providing a list of
    registered apprenticeship programs. Education reported that it does not
    have formalized coordination with VA but has had some contacts to
    inform VA of its concerns regarding specific institutions.
        Information is not available to determine the amount of resources
    spent on SAA duties and functions, including those that may overlap
    with those of other agencies. VA does not require SAAs to collect
    information on the amount of resources they spend on specific approval
    activities. The SAA officials we spoke with said that their most time-
    consuming activity is conducting inspection and supervisory visits of
    schools and training facilities. However, the lack of data on resource
    allocation prevented us from determining what portions of funds spent
    by SAAs were for approval activities that may overlap with those of
    other agencies.
    SAAs Reportedly Add Value to the Approval Process for Education and
            Training Programs, but the Lack of Outcome-Oriented Performance
            Measures Makes It Difficult to Assess the Significance of Their
            Efforts
        SAA and other officials reported that SAA activities add value
    because they provide enhanced services to veterans and ensure program
    integrity. According to these officials, SAAs' added value includes a
    focus on student services for veterans and on VA benefits, more
    frequent on-site monitoring of education and training programs than
    Education and Labor, and assessments and approval of a small number of
    programs that are not reviewed by other agencies, such as programs
    offered by unaccredited schools, on-the-job training programs, and
    apprenticeship programs not approved by Labor.
        SAA approval activities reportedly ensure that (1) veterans are
    taking courses consistent with occupational goals and program
    requirements, (2) schools and training programs have evaluated prior
    learning and work experience and grant credit as appropriate, and (3)
    school or program officials know how to complete paperwork and comply
    with policies required by VA educational assistance through technical
    assistance. According to officials we interviewed, SAAs generally
    conduct more frequent on-site monitoring of education and training
    programs than Education or Labor, possibly preventing fraud, waste, and
    abuse. Some officials reported that SAAs' frequent visits were
    beneficial because they ensure that schools properly certify veterans
    for benefits and that benefits are distributed accurately and quickly.
    States, schools, and apprenticeship officials we spoke with reported
    that without SAAs, the quality of education for veterans would not
    change. However, veterans' receipt of benefits could be delayed and the
    time required to complete their education and training programs could
    increase.
        Despite areas of apparent added value, it is difficult to fully
    assess the significance of SAA efforts. VA does measure some outputs,
    such as the number of supervisory visits SAAs conduct, but it does not
    have outcome-oriented measures, such as the amount of benefit
    adjustments resulting from SAAs' review of school certification
    transactions, to evaluate the overall effectiveness and progress of
    SAAs. (See table 3.)

                         Table 3:  Examples of VA Output Measures and Potential Outcome Measures
    ----------------------------------------------------------------------------------------------------------------
                  Examples of Existing VA Output Measures                  Examples of Potential Outcome Measures
    ----------------------------------------------------------------------------------------------------------------
    Percentage of visits to facilities for supervisory                      Amount of benefit adjustments resulting
      and inspection purposes completed within                            from SAAs' review of school certification
      VA specified timeframes                                                                          transactions
    ----------------------------------------------------------------------------------------------------------------
    Number of times technical assistance provided                          Error rate of certification transactions
      to interested parties such as individuals and                                              identified by SAAs
      schools
    ----------------------------------------------------------------------------------------------------------------
    Number of approved facilities with approved                                   Completion rates of beneficiaries
      programs
    ----------------------------------------------------------------------------------------------------------------
    Source: GAO analysis.

    Prior Recommendations and Agency Response
        We made several recommendations to the Department of Veterans
    Affairs to help ensure that federal dollars are spent efficiently and
    effectively. We recommended that the Secretary of the Department of
    Veterans Affairs take steps to monitor its spending and identify
    whether any resources are spent on activities that duplicate the
    efforts of other agencies. The extent of these actions should be in
    proportion to the total resources of the program. Specifically:

          VA should require SAAs to track and report data on
    resources spent on approval activities such as site visits, catalog
    review, and outreach in a cost-efficient manner, and
          VA should collaborate with other agencies to identify any
    duplicative efforts and use the agency's administrative and regulatory
    authority to streamline the approval process.

        In addition, we recommended that the Secretary of the Department of
    Veterans Affairs establish outcome-oriented performance measures to
    assess the effectiveness of SAA efforts.
        VA agreed with the findings and recommendations and stated that it
    will (1) establish a working group with the SAAs to create a reporting
    system to track and report data for approval activities with a goal of
    implementation in fiscal year 2008, (2) initiate contact with
    appropriate officials at the Departments of Education and Labor to
    identify any duplicative efforts, and (3) establish a working group
    with the SAAs to develop outcome-oriented performance measures with a
    goal of implementation in fiscal year 2008. While VA stated that it
    will initiate contact with officials at Education and Labor to identify
    duplicative efforts, it also noted that amending its administrative and
    regulatory authority to streamline the approval process may be
    difficult due to specific approval requirements of the law. We
    acknowledge these challenges and continue to believe that collaboration
    with other federal agencies could help VA reduce duplicative efforts.
    We also noted that VA may wish to exam-
    ine and propose legislative changes needed to further streamline its app
    roval process.
        Madame Chairwoman, this completes my prepared statement. I would be
    happy to respond to any questions that you or other members of the
    subcommittee may have.
    GAO Contacts
        For further information regarding this testimony, please contact me
    at (202) 512-7215. Individuals making key contributions to this
    testimony include Heather McCallum Hahn, Andrea Sykes, Kris Nguyen,
    Jacqueline Harpp, Cheri Harrington, Lara Laufer, and Susannah Compton.

     Prepared Statement of Joan L. Ryan, President and C. Donald Sweeney,
     Legislative Director, National Association of State Approving Agencies
    INTRODUCTION
        Chairwoman Herseth Sandlin, Ranking Member Boozman and members of
    the Subcommittee on Economic Opportunity, we are pleased to appear
    before you today on behalf of the National Association of State
    Approving Agencies to provide comments on the functions of State
    Approving Agencies (SAAs), the value added by SAAs, the issue of
    overlap in the work of various ``approving agencies'' and funding
    needed by SAAs to carry out their responsibilities.
    BACKGROUND
        State Approving Agencies recently celebrated sixty years of
    partnership with the U.S. Department of Veterans Affairs (DVA) in the
    administration of the veterans' educational assistance programs, more
    commonly known as the GI Bill. Through the program approval and
    supervision process, they ensure that money spent on veterans education
    is money well spent, and assist in reducing the opportunities for
    fraud, waste and abuse.
        In many ways the fundamental mission of State Approving Agencies
    (SAA) is the same today as it was when they were founded sixty years
    ago. State Approving Agencies:

          promote and safeguard quality education and training
    programs for veterans;
          ensure greater educational and training opportunities to
    meet the changing needs of veterans; and
          assist the DVA in preventing fraud, waste and abuse in
    the administration of the GI Bill.

        As State entities acting on behalf of the Federal government, they
    have been an outstanding example of the workability of the Federal-
    State partnership, allowing Federal interests to be pursued at the
    local level while preserving the identity, interests and sovereignty of
    State's rights in education.
        Under Title 38, United States Code, each Governor designates a
    state bureau or department as the State Approving Agency for the state.
    Today there are 59 State Approving Agencies (some states have two) with
    about 200 professional and support personnel, supervising over 10,000
    active facilities with approximately 200,000 programs. Located in
    various state offices, including state departments of education, higher
    education boards, departments of labor, departments of veterans affairs
    and stand alone agencies--SAA professionals bring a wealth of formal
    education, training and experience to the appraisal of programs for
    veterans benefits.
    REMARKS
    A. Functions
        State Approving Agencies carry out their mission through their core
    functions of program approval, on-going contact and supervision,
    technical assistance, outreach, and liaison. As described below, each
    of these core functions continues to evolve as State Approving Agencies
    meet the challenge of a dynamic educational and training environment.

    1. Program Approval--The appraisal process whereby SAAs determine
    whether new programs meet the requirements of law and are eligible for
    veterans' benefits.
        Under federal law, there are a host of approval criteria designed
    to (a) facilitate the accurate and timely payment of benefits; (b)
    minimize erroneous payments and opportunities for fraud, waste, and
    abuse; and (c) ensure that tax dollars spent on veterans education and
    training are dollars well spent. Programs are required to meet
    acceptable standards regarding student progress; credit for prior
    learning; establishment of branch campuses; treatment of residencies;
    independent study and practicums; educational contracting; student
    recordkeeping; program content; instructor expertise; sufficiency of
    facilities and equipment; and methods of instruction.
        SAAs also focus on policy issues and practices which frequently
    lead to problems with non-compliance. SAAs are particularly concerned
    with branch campuses, educational contracting, distance education, high
    tech courses of short duration, adult education, and accelerated
    classes. Often, it is the systems and policies in place that receive
    SAA attention. This is in addition to a detailed examination of the
    curricular structure and faculty credentials. Much of this can be done
    during a visit to the school in conversation with various school
    officials and a review of student records.

          Total Program Approvals Actions (both approvals and
    disapprovals) rose 97% from FY 97 to FY 05 and Apprenticeship and On-
    The-Job Training program approvals rose 54% from 2,444 in FY 97 to
    3,760 in FY 05.
          SAAs work with deficient programs to assist them to meet
    approval standards and therefore only about five percent of all program
    reviews result in disapproval.

    2. On-going Contact and Supervision--General and continuing oversight
    of our institutions to verify continued compliance with federal
    requirements; to prevent fraud, waste and abuse; to offer training;
    and--at the request of the VA--to investigate and provide assistance
    with compliance/program issues.
        Even at established schools and longstanding training programs,
    problems can crop up which will adversely affect the quality of the
    veteran's program or the amount of benefits paid. Pivotal to the
    protections the GI Bill affords its recipients is the on-going, on-site
    monitoring and supervision of institutions wishing to have their
    programs approved. In this regard there is no comparable association or
    agency which provides this level of proactivity. And this is why SAAs
    maintain their discretion to visit even highly regarded institutions.
        In the course of an oversight and training visit to the school or
    training establishment, the SAA determines whether each of the programs
    continues to meet the approval requirements of Federal and State law.
    Just as importantly the SAA assist the school/facility in maintaining
    continued compliance.
        An Oversight and Training Visit usually includes:

          A review of institutional policies and practices affected
    by the regulations. SAAs make note of changes to programs, facilities,
    ownership, off-campus offerings, internship policies, contracts with
    other training providers, transfer credit and the like. If a policy is
    not in accordance with the requirements of the regulations, SAAs often
    are able to negotiate a special policy for veterans or assist with the
    development of a general, school-wide policy that is in compliance.
          An investigation of the systems in place to carry out
    these policies. The SAA looks at such questions as: Is the school
    certifying official in a position to know about changes in a veteran's
    status? Are veterans being certified only for those courses that lead
    toward their educational, vocational or professional objective? Has the
    veteran's prior learning been evaluated and the veteran been notified
    of transfer or other credit which actually applies toward their degree?
    How quickly is the VA notified of a veteran's change in status? (For
    example, withdrawal from school or a change in programs).
          An examination of school and student records to verify
    that institutional policies are being enforced and that the required
    system of records is in place. SAAs also review veteran's records to
    ensure that veterans are being certified correctly and that the VA is
    not making payments based on erroneous information. This activity may
    save the veteran from having to return funds because of an overpayment
    when a problem is discovered on a compliance survey (audit) up to three
    years later. They also uncover evidence of inappropriate activity such
    as false and misleading advertisement.
          Visits also assist in the development of a good on-going
    relationship with school and training establishment officials. SAAs
    answer their questions, provide training, help them to problem-solve
    compliance issues, and encourage a greater sensitivity and awareness of
    veterans' benefits and needs. By nature of their job, SAAs have a broad
    overview of the education and training systems within the state. SAAs
    serve as consultants providing examples of best practices from other
    schools which interested schools can adopt.

        SAAs also conduct Inspection Visits to new schools and programs to
    ensure that they can comply with approval requirements and are familiar
    with certification and reporting procedures.

          On-going Oversight and Training Visits to all schools and
    programs increased 30% from 9,210 in FY 97 to 11,994 in FY 05.
          Inspection Visits to new schools and programs increased
    25% from 2,362 in FY 97 to 2,955 in FY 05.

    3. Technical Assistance--Assistance given to schools, training
    establishments and individuals regarding approval of programs and
    certification of veterans. Schools and veterans rely on SAAs for
    timely, on-the-spot information--answering a seemingly endless stream
    of questions.
        SAAs render assistance to new schools seeking approval of their
    courses, employers looking to have their apprenticeship or other on-
    the-job training programs approved, veterans and their families,
    members of the reserve components, etc. SAAs answer questions about how
    to apply for approval or how to certify a veteran with a special
    problem. They answer questions about program length requirements, how
    to write a training agreement including appropriate wage scale and
    related instruction, questions about the requirements for practical
    training, contract courses and institutional recordkeeping.
        Further, the SAA serves as a facilitator between the school, the
    veteran and the VA. SAAs are arbitrators of complaints and the advocate
    for maximization of a veteran's benefits. They are often the de facto
    trainers of new school certifying officials and they keep the schools
    apprised of new developments, often holding regional workshops for
    school certifying officials.

          Total overall training/assistance actions increased 43%
    from 19,635 in FY 97 to 28,107 in FY 05.
          Training/assistance given to Apprenticeship/On-the-Job
    Training facilities rose from 7,359 in FY 97 to 8,959 in FY 05 and
    training/assistance actions for Institutions of Higher Education and
    Non College Degree schools rose from 12,001 in FY 97 to 18,588 in FY
    05.

    4. Outreach Activities--Efforts undertaken to reach out to various
    groups and promote the increased usage of veterans' educational
    benefits. At the request of the DVA, State Approving Agencies are
    heavily engaged in outreach efforts to promote the usage of veterans'
    educational benefits.
        Some SAAs have developed radio spots, television videos and print
    advertising to encourage veterans to take advantage of the GI Bill and
    especially apprenticeship and on-the-job training programs. Other SAAs
    do ``welcome home'' mailings to newly separated veterans congratulating
    them on their service and informing them of their benefits and the
    educational/training opportunities available to them in their State.
    Many SAAs make presentations at military retirement seminars and the
    transition assistance programs (TAPS) for those leaving the service.
    SAAs participate in local military and veterans events; job fairs,
    welcome home activities, supermarkets of benefits and other venues
    where they can encourage the use of benefits. They work with their
    state's departments of labor to assist veterans to find appropriate
    employment and training. In some states, the National Guard looks to
    the SAA approval in identifying programs eligible for national guard
    members to receive tuition support. Additionally, States have developed
    Web sites allowing veterans to learn about their State and Federal
    benefits and to search for what programs and schools are approved and
    available in their state.

    5. Liaison Activities--Coordination with government, veteran and
    educational entities to facilitate the approval of programs and
    increase educational opportunities for veterans. As State agencies
    working with a Federal program, SAAs are uniquely situated to network
    with stakeholders in education and training to coordinate the improved
    delivery of veterans' benefits.
        State Approving Agencies work with others to exchange information,
    facilitate the increased approval of programs and raise awareness of
    the veteran, their educational needs and benefits. SAAs have forged
    links with State Agencies such as Departments of Veterans Affairs,
    Departments of Education, Higher Education Governing Boards,
    Departments of Labor and other licensing boards. They meet with
    representatives of accreditation associations, the National Guard and
    the Reserves, apprenticeship councils, union boards, and military
    service organizations. Some SAA staff members also participate on
    accreditation visits. At a national level, contacts are made with the
    Departments of Defense, Education, Labor, and Agriculture, as well as
    the Federal Aviation Administration, and Federal Trade Commission.
        State Approving Agency activities often complement what is being
    done at the state level and since not all states have program review
    offices, those SAAs become the de facto review entity for the State.
    SAAs often have ready access to information of value to program
    appraisal such as: a school's audited financial statements; school
    evaluation reports; results of in-depth assessments in particular
    areas; program review by governing or coordinating boards; and,
    institutional statistics and research findings.
    B. Added Value
        In addition to the contributions stated in part A. Functions, State
    Approving Agencies help to ensure the success of the GI Bills by
    responding to new trends in education and training and by working with
    the DVA to take-on new challenges. As stated by a former Subcommittee
    Staff Director of the House Veterans Affairs Committee in an upcoming
    SAA outreach film--``SAAs are the face of the GI Bill at the state
    level.''
        Frequent interaction with officials at all levels within the state
    provides understanding of how the system works which in tern creates a
    unique ability to assist Veterans in accomplishing their education and
    training objectives.

          Special attention has been and continues to be given to
    the request by Congress and the DVA to promote the development and
    approval of apprenticeship and on-the-job training programs. Extensive
    efforts have been made by SAAs to make employers and unions aware of
    this benefit and to assist them in having these programs promoted and
    approved. As a result, the number of active apprenticeship/on-the-job
    training (or OJT) facilities has increased over 100% in 10 years from
    2,086 (in 1997) to 4,891 (in 2006). New initiatives include the
    approval of preparatory courses, licensure and certification
    examinations, and entrepreneurship programs.
          SAAs have expanded their outreach efforts to promote
    increased usage of GI Bill benefits as described in the Outreach
    Activities section of part A of this testimony. In FY 97 SAAs conducted
    12,724 outreach activities and in FY 05, 49,885. They continue to
    actively search for new ways to increase usage of the GI Bill and
    counsel veterans on available benefits and educational programs within
    their state.
          SAAs are directly involved with the new and emerging
    trends in education and training--ensuring their quality and
    availability for veterans. More and more distance education programs
    are now being approved. SAAs are reviewing and approving new short-term
    certification programs as illustrated by the growth in non-accredited
    NCD facilities and programs--from 605 in FY 97 to 835 in FY 03, an
    increase of 38% percent. Also SAAs continue to evaluate accelerated
    degree programs, external degree offerings, new branch campuses and
    traditional colleges contracting with private occupational schools to
    provide training for college credit.
          SAAs also are directing more attention to promoting and
    insuring the evaluation and acceptance of credit for military training
    and experience.
          And for the benefit of veterans, other GI Bill eligible
    persons, and the DVA, SAA personnel participate in on-going
    professional development activities to ensure the availability of a
    wide range of quality learning experiences. The National Association of
    State Approving Agencies (NASAA) is in the process of completely
    updating its National Training Curriculum required under law. Training
    Institutes are held for new staff approximately every eighteen months.
    One was just held last week in Chicago where over 50 SAA and VA
    personnel participated. All national meetings have a professional
    development component designed to provide specialized, advanced
    training in leading edge developments in our field such as, distance
    education, state licensing, outreach techniques, DOD recruitment
    concerns, and approval of short term on-going professional development
    courses such as Microsoft and Novell.
          State Approving Agencies have been at the forefront of
    the enactment of many of the improvements to the various GI Bills. They
    have first hand insights into the education and training needs of
    veterans and are able to bring recommendations to members of Congress
    and the responsible Committees. SAA personnel have had the honor and
    privilege of working with current and former members of Congress,
    including former Chairman Montgomery, to enact the Montgomery GI Bill
    (MGIB) and to expand program opportunities available under the law.
    Examples include the addition of apprenticeship and other on-the-job
    training (OJT) to Chapters 30 and 1606; non college degree and graduate
    programs to Chapter 1606; accelerated payments for high technology
    programs; increased benefit levels for apprenticeship and OJT
    participants; and revisions to the laws governing the approval of
    programs such as the period of operation rule, OJT wage requirements
    and pro rata refund policy.
          As founding member of the Partnership for Veterans
    Education, SAAs represented by their national association, is currently
    recommending the enactment of a Total Force MGIB that would simplify
    the administration of the law and bring equity to those who serve in
    defense of the freedoms that we all so thoroughly enjoy--equal program
    opportunity and benefits for equal service rendered. As you know Madame
    Chairwoman, this Subcommittee held an excellent hearing on the topic
    just a few weeks ago.

        In short SAAs are the face of the GI Bill at the state level.
        We provide:

          Veteran advocacy
          Outreach to Veterans
          Job training opportunity
          Consumer protection for Veterans entering education and
    training programs
          Assistance to Veteran who encounter problems at schools
    and training facilities
          Assistance with the prevention of waste, fraud and abuse

    C. Overlap in the Work of Approving Agencies
        Sixty years ago the Congress chose a path that has served the
    veteran and the taxpayer exceptionally well. Instituting a state level,
    program approval process to ensure the quality and integrity of the
    various learning experiences in which veterans engage and to assist the
    federal government in preventing waste, fraud and abuse has proven to
    be an excellent decision.
        To the casual observer, it would appear that the work done by SAAs
    and that of the federal Departments of Education and Labor is similar,
    if not identical. A closer look reveals some stark distinctions,
    especially among ``approval'' activities for institutions and their
    programs.
        Earlier pages of this testimony provided insights into the
    processes used by SAAs. To summarize, the SAA program approval process
    is:

          Program oriented--Certificate in Automotive Technology,
    Associate of Science in Nursing, Bachelor of Science in Biology, et al.
    In lay terms, an evaluation of the appropriateness of the program
    objective, what is being taught to achieve the objective, by whom, with
    what resources and under what circumstances. The latter category
    includes, for example, an evaluation of policies and practices
    pertaining to program admission, credit for prior learning, and
    satisfactory progress.
          Built upon evaluations by other state and private sector
    entities when appropriate; e.g., state licensing, degree granting
    authority, and accreditation (institutional and/or specialized/
    programmatic)
          Ongoing contact and monitoring on an annual or bi-annual
    basis

        Now let's take a look at the process used by the Department of
    Education and, in particular, accreditation since this element of the
    DOE process seems to be the major focal point of the discussion about
    overlap.
        The Departments of Education's direct involvement in the
    administration of Title IV, Student Financial Aid programs is limited
    to (1) the authorization and reauthorization of an institution to
    participate in Title IV through an application process that is heavily
    dependent upon third parties and (2) compliance visits which are
    monetarily oriented, sporadic and generally conducted at an institution
    where there have been reported or perceived problems. Of the two third
    parties connected to the initial (and continuing) authorization,
    accreditation is perceived to be the one that actually attempts to
    ensure overall quality and integrity at the institutional level. The
    other activity, state licensing, has long been proven to be limited in
    scope (generally applicable to proprietary business, trade and
    technical schools only) and generally ineffective because of lack of
    State funding to conduct full scale initial and followup evaluations.
    The United States has no Federal Ministry of Education or other
    centralized authority exercising single national control over
    postsecondary educational institutions in this country. The States
    assume varying degrees of control over education, but, in general,
    institutions of higher education are permitted to operate with
    considerable independence and autonomy. As a consequence, American
    educational institutions can vary widely in the character and quality
    of their programs.
        In order to ensure a basic level of quality, the practice of
    accreditation arose in the United States as a means of conducting non-
    governmental, peer evaluation of educational institutions and programs.
    Private educational associations of regional or national scope have
    adopted criteria reflecting the qualities of a sound educational
    program and have developed procedures for evaluating institutions or
    programs to determine whether or not they are operating at basic levels
    of quality. (U.S. Department of Education)
    Types of Accreditation
        Institutional accreditation normally applies to an entire
    institution, indicating that each of an institution's parts is
    contributing to the achievement of the institution's objectives,
    although not necessarily all at the same level of quality. The various
    commissions of the regional accrediting associations, for example,
    perform institutional accreditation, as do many national accrediting
    agencies.
        Specialized or programmatic accreditation normally applies to
    programs, departments, or schools that are parts of an institution. The
    accredited unit may be as large as a college or school within a
    university or as small as a curriculum within a discipline. Most of the
    specialized or programmatic accrediting agencies review units within an
    institution of higher education that is accredited by one of the
    regional accrediting commissions. However, certain accrediting agencies
    also accredit professional schools and other specialized or vocational
    institutions of higher education that are free-standing in their
    operations. Thus, a ``specialized'' or ``programmatic'' accrediting
    agency may also function in the capacity of an ``institutional''
    accrediting agency. In addition, a number of specialized accrediting
    agencies accredit educational programs within non-educational settings,
    such as hospitals. (U.S. Department of Education)
    Types of Accrediting Organizations
        Regional accrediting organizations operate in six different regions
    of the country and review entire organizations, 98 percent or more of
    which are both degree-granting and nonprofit. Regional organizations
    may also accredit non-degree, for-profit institutions, but this is a
    rare occurrence.
        National accrediting organizations operate throughout the country
    and review entire institutions. Of the nationally accredited
    institutions, 34.8 percent are degree-granting and 65.1 percent are
    non-degree-granting. 20.4 percent are nonprofit and 79.5 percent are
    for-profit. Many are single purpose institutions (i.e. information
    technology or business) and some are faith based.
        Specialized accrediting organizations operate throughout the
    country and review programs and some single-purpose institutions. There
    are more than 17,600 of these accredited programs and single-purpose
    operations. (Council on Higher Education Accreditation)
    Recognized Accrediting Organizations
        There are no laws regarding the development or operation of an
    accrediting organization. Therefore, some are considered more
    legitimate than others. Similar to ``diploma mills'' there are some
    organizations considered ``accreditation mills'' that will accredit
    institutions for a fee without the utilization of what is generally
    considered acceptable standards.
        There are two organizations that are currently considered to
    ``recognize'' legitimate accrediting agencies, the U.S Department of
    Education (USDE) and the Council for Higher Education Accreditation
    (CHEA). For USDE recognition, accreditation from the organization is
    used by an institution or program to establish eligibility to
    participate in federal student aid or other federal programs. The
    Council for Higher Education Accreditation is a private nongovernmental
    coordinating agency for accreditation. As defined by CHEA, it is ``A
    national advocate and institutional voice for self-regulation of
    academic quality through accreditation. . . .'' Individual accrediting
    organizations may be ``recognized'' by CHEA, the U.S. Department of
    Education, or both.
    Quality
        The term ``quality'' is used by multiple organizations however, it
    is rarely defined. For the purposes of this document, ``quality'' will
    refer to meeting or exceeding a minimum set of standards. A functional
    reality of this definition is that the establishment of the designation
    ``quality'' is dependent on the minimum standards of the organization
    performing a review. While an institution may be considered of quality
    by one organization, it may not meet the designation of quality by a
    different organization using a different set of standards.
    Section Purpose
        The purpose of this section of the testimony is not to portray
    either State Approving Agencies or accrediting organizations as having
    more or less value than the other. Each serves a purpose in
    relationship to the educational community. However, the value of each
    differs in terms of mission, standards, and purpose. State Approving
    Agencies and accreditation organizations each have a function, but the
    functions are not duplicative. State Approving Agency approval and
    accreditation are complimentary, not identical, processes.
        To assist in gaining a better understanding of what accreditation
    is and is not, the following excerpts from a book entitled
    Understanding Accreditation by Kenneth E. Young, et.al. are reprinted.
    Dr. Young was the founding President of the Council on Postsecondary
    Accreditation, the former umbrella organization for accrediting
    associations.
             ``Accreditation is a process by which an institution of
    postsecondary education evaluates it educational activities and seeks
    an independent judgment to confirm that it substantially achieves its
    objectives and is generally equal in quality to comparable institutions
    or specialized units. Essential elements in the accreditation process
    are (1) a clear statement by the institution of its education
    intentions, (2) the conduct of a directed self-study focused on the
    achievement of these intentions, (3) an on-site evaluation by a
    selected group of peers, and (4) a decision by an independent
    accrediting commission (comprised of fellow educators) that, in light
    of its standards, the institution or specialized unit is worthy of
    accreditation. The accreditation process is designed primarily to
    encourage and assist the institution to evaluate itself objectively and
    then for the accrediting body to validate what the institution has said
    about itself.''
             ``Institutional accreditation (1) deals with the total
    institution, (2) is almost always the basis for institutional
    membership, and (3) focuses primarily on institution-wide objectives,
    processing, and outcomes.''
            The major characteristics of accreditation are the following:

            1.  It is predominantly a voluntary, private-sector activity
    and therefore cannot mandate compliance or control behavior except by
    persuasion and peer influence.
            2.  It is the premier example of self-regulation (as opposed to
    government regulation) in postsecondary education.
            3.  It focuses primarily on judging educational quality--an
    elusive concept--and, given the great diversity of postsecondary
    educational institutions in the United States, criteria tend to be
    general and variable.
            4.  It functions essentially as an evaluative process, and
    institutional self-study is at the heart of the process, and
            5.  It provides outside consultation, closely tied to the
    institution's own research and planning.

             To understand what accreditation is not is also important.
    Accreditation is not governmental, although both federal and state
    agencies use it--to determine eligibility for certain government
    programs and in relation to professional licensing. It is not
    mandatory, although there are strong social and political pressures and
    even some legal prods to encourage participation. It is not a rating
    system, although institutions and programs generally do get compared.
    It is not a mechanism for formally policing institutional behavior;
    accrediting bodies do not have to assess compliance, even if they
    wanted to. Rather, it depends on informal monitoring, generally through
    the accrediting body following up on a complaint about an institution
    (usually from an unhappy faculty member or student, another institution
    or state agency). It does not deal directly with credits, despite its
    name, although it is often used to help distinguish (sometimes
    erroneously) between worthy and unworthy prior educational experiences.
    And it is not a stamp of approval on individual students or courses; it
    does not operate at that level of analysis, although it is often
    perceived that way.
             The public is often led to believe that accreditation forces
    compliance on institutions. Although colleges and universities are
    certainly expected to comply with the policies, procedures, and
    requirements established by the accrediting body to maintain
    membership, the value and effectiveness of the entire process
    nevertheless lies in the institution's own commitment to excellence and
    continuous self-study and evaluation. The public has little
    understanding of the voluntary nature of accreditation and the fact
    that compliance guarantees are not systematically built in. ``Indeed,
    any guarantees reside in the individual institution's seriousness of
    purpose and its sincerity.''
        In summary, other speakers at this hearing today already have or
    will address the DOE process for Title IV eligibility and the role of
    accreditation in that process so our testimony will not go into greater
    detail. However, we believe that it is important to restate that the
    major differences between SAAs and accreditation lie (1) in their
    mission, standards, and purpose and (2) operationally in the depth,
    breadth and frequency of their reviews. They each have a function, but
    the functions are not identical or duplicative--they are complimentary.
    The SAA process is a governmental quality control mechanism while
    accreditation is a private sector quality enhancement process.
    Apprenticeship and Other On-The-Job Training
        The distinctions between the work of SAAs and the federal
    Department of Labor on the approval of apprenticeship and other on-the-
    job training (OJT) programs also can be described as complimentary. The
    additional work by SAAs with Registered Apprenticeship Programs is
    almost exclusively connected to the specific requirements of Title 38,
    U.S. Code pertaining to the payment of VA benefits.
        Unregistered apprenticeship and OJT programs are another matter.
    For the vast majority it is only the SAA that works with the program
    sponsor to review what is to be taught/learned, by whom, with what
    expertise, with what resources and under what circumstances. This is in
    addition to insuring that the requirements of Title 38 are also being
    met.
    D. Funding
        The total annual allocation for SAA activities is stipulated in
    Title 38. The annual share of the allocation awarded to each SAA is
    determined by a formula essentially based upon the number of active
    schools and training establishments being supervised. The total annual
    allocation was capped at 12 million dollars from 1989 to 1994. In 1995,
    the cap was increased to 13 million dollars until 2001, when it is
    being raised to 14 million dollars. From 2004 thru 2005, the cap was
    raised to 18 million dollars and for 2006 thru 2007 it was raised to 19
    million dollars. If no action is taken, in 2008 the cap will revert
    back to 13 million dollars--a 32 percent cut!

          The SAAs are periodically in a state of uncertainty.
    Without either the ability to carryover funds from one year to the next
    or to rely on an annual cost of living adjustment, prudent planning is
    not possible.
          SAAs/States need funding stability in order to plan for
    and execute activities that meet the requirements of law and the
    contract between the State and the VA. Many SAAs are comprised of one
    full time professional staff person--some have only a part time person.
    Program approval and monitoring activities, especially those associated
    with apprenticeship and other on-the-job training programs, require
    expertise and timely action. Unstable funding does little to support
    this.
          In order to provide an acceptable level of service to
    veterans, the Congress, and the DVA and to continue to take on
    additional roles as needed, SAAs must be consistently funded at an
    adequate level. Once restored to the current level of $19 million, the
    amount should be adjusted each year by the government-approved COLA
    applied to other benefit programs.

        In summary, SAAs make major contributions to the success of the
    various GI Bills in many ways. These contributions far exceed the
    proportionate amount of funds received by the Agencies when compared to
    the amount of benefits provided to veterans and other GI Bill eligible
    persons. The contributions include, but are not limited to, the
    following:

          determinations regarding the quality and integrity of
    just about any kind of learning experience imaginable (institutional,
    job training, flight, correspondence, etc.);
          work with employers to develop and enroll veterans in job
    training programs;
          assessments of tests for professional and occupational
    licensing and certification;
          training of VA Certifying Officials at educational
    institutions and job training establishments;
          briefings during transition assistance programs and
    retirement seminars, mailings to recently discharged veterans and
    Selected Reserve personnel, and other outreach activities to increase
    the utilization of the GI Bills;
          providing advice and guidance directly to veterans and
    other GI Bill eligible persons and indirectly through educators,
    trainers and others who counsel veterans;
          serving as the gatekeepers for the ``GI Bill'' and
    advocates for veterans at the state and local levels;
          assisting the federal government to eliminate waste,
    fraud and abuse; and,
          state based SAAs provide local insights to the Congress
    and the VA on revisions to law that would better help to meet the
    education and training needs of veterans.
    CLOSING
        In closing, Madame Chairwoman, we would like to thank you and
    members of the Subcommittee again for the opportunity to comment on the
    functions of State Approving Agencies (SAAs), the value added by SAAs,
    the issue of overlap in the work of various ``approving agencies'' and
    funding needed by SAAs to carry out their responsibilities so that the
    GI Bill remains the country's premier educational assistance program
    bar none. Mr. Sweeney and I would be happy to respond to any questions
    that you might have.

         Statement of George W. Summerside, Veterans Education Program
                Specialist, South Dakota State Approving Agency

    INTRODUCTION
        Chairwoman Herseth Sandlin, Ranking Member Boozman and members of
    the Subcommittee on Economic Opportunity, I am pleased to appear before
    you today on behalf of the South Dakota State Approving Agency to
    discuss the functions of State Approving Agencies and the value these
    agencies have for those eligible for VA educational benefits in South
    Dakota.

    BACKGROUND
        Sixty years ago Congress, determined that each State should create
    an agency to approve the programs within its borders and to determine
    in which programs it was appropriate for Veterans to enroll, in order
    for them to utilize their VA educational benefits. The first State
    Approving Agencies (SAA) were formed for Veterans after World War II.
    Each State has one and a few states have two or three. One agency would
    approve all school programs, another agency would approve all on-the-
    job training programs, and then possibly a third agency would approve
    the flight schools. Our state approves all programs for those wishing
    to utilize their VA educational benefits.
        After a few years States realized that a national Association was
    needed and in 1948 the National Association of State Approving Agencies
    (NASAA) was formed. The National Association assisted states in
    coordinating their efforts to do a better job for our nation's
    Veterans. Also it was a tool to resolve mutual problems that were
    affecting our members.
        One of the keys to the success of this association has been the use
    of technology. Our association created a viable Internet Web site for
    the utilization of our association, our service partners and our
    customer ``The American Veteran.'' Capabilities include: directories
    for State Approving Agencies and State Veterans Affairs Offices,
    legislative updates, State and Federal regulatory information, and
    veteran-related career, educational, and benefit information. Our site
    is being re-designed and should be completed by the end of this month.
    The redesign will bring many new enhancements which will further
    improve communication between our members and the Veterans we serve.
    South Dakota has been the webmaster for this site since it's creation
    in 1998.
        Our website also has a section exclusively for our members. This
    members' section includes: directories for our membership and other
    service partners, presidential updates/briefings, committee updates,
    association projects, calendar of upcoming events, samples of work
    processes for training programs (over 1,000), national training
    curriculum, outreach materials and online quarterly reporting system.
    Members can also send e-mail to other members and post information
    through the NASAA bulletin board.

                        ROLE OF STATE APPROVING AGENCIES

        In many ways the fundamental role of state approving agencies is
    the same today, as it was when they were founded. As state entities
    acting on behalf of the Federal Government, the SAA's have been an
    outstanding example of the workability of the State-Federal
    partnership, allowing Federal interests to be pursued at the local
    level while preserving the identity, interests and sovereignty of
    States' Rights in education.

    PROGRAM APPROVAL
        The primary responsibility and focus of the SAA's continues to be
    the review, evaluation and approval of quality programs of education
    and training under State and Federal criteria. SAA's continue to
    conduct on-site inspection visits to approved institutions and schools
    seeking approval. The programs that can be approved are found in
    institutions of higher learning (colleges and universities), non-degree
    institutions (vocational and technical schools), apprenticeship
    programs, other on-the-job training programs, and flight training
    schools. Each State reviews the appropriateness of each program as to
    its own standards and laws in addition to VA rules and regulations
    along with any other applicable laws and/or regulations. Then it is
    either approved or disapproved; continuous supervision is required of
    approved programs. The following statement is provided to illustrate a
    school's viewpoint of the approval process for a non-degree
    institution:

              As Director of the Career Learning Center of the Black Hills
            (CLC), I was approached by Mr. Ken Moon, South Dakota Veteran's
            Outreach Representative who asked me if I had considered
            applying to the South Dakota State Approving Agency for
            approval of our short-term skill training programs as non-
            degree level courses. Mr. Moon conveyed to me that he believed
            the CLC training programs may fit the needs of some of the
            veterans who are in need of skill training, but who are not
            willing and/or able to commit to a formal postsecondary
            educational program. Mr. Moon gave me the name and telephone
            number of the Education Program Specialist from the South
            Dakota State Approving Agency, Mr. George Summerside, to
            contact about making application.
              From the first conversation I had with Mr. Summerside, I felt
            confident and assured that any assistance I needed in
            completing the application would be provided. It was also very
            evident to me that George had the utmost respect for the
            process and the requirements for the application and would make
            certain that all required components of the application would
            be included in the utmost organized and detailed manner.
              My experience in working with the South Dakota State
            Approving Agency, in preparation of the application for Non-
            Degree Level Courses was one of high-level professionalism with
            exemplary technical assistance provided. Mr. Summerside is
            acutely aware of the requirements for this application and was
            extremely interested in assisting with inclusion of all the
            requirements for the application. George looked over numerous
            drafts of the application and attachments before we submitted
            the final and completed application for consideration. Since
            this time, The South Dakota State Approving Agency has provided
            additional advice and assistance in completing paperwork for VA
            students of our courses.
              There is no question that without the assistance, direction,
            advice and support of Mr. Summerside, the application process
            would have been much more difficult and time consuming.
                                             Gloria Pluimer, Director
                            Career Learning Center of the Black Hills

        The next statement illustrates a veteran's viewpoint of the
    approval process for an On-The-Job training program:

              I retired from the U.S. Navy in 1993 following 27 years of
            active service. I had not used any of my GI Bill Education
            benefits at the time of my retirement. I returned to South
            Dakota with the intent of going back to school and completing
            my college education.
              I applied for the On-The-Job Training Program in 1994 through
            the SD Division of Veterans Affairs--State Approving Agency--
            and was enrolled. I was most appreciative of the
            professionalism of the person from the State Approving Agency
            who worked with my employer and me to design a tailored
            training program. No doubt without the availability of this
            education benefit, I would not have been able to accept this
            training position.
              Not everyone or every discipline is suited to the traditional
            classroom style of training and education. The On-The-Job
            Training Program offers an excellent alternative educational
            benefit opportunity for those individuals and disciplines.
            Without this program, it is most probable that my GI Bill
            Educational Benefits would have gone unused.
                                             Ron Boyd, State Adjutant
                                                   SD American Legion
    PROGRAM SUPERVISION
        Our agency conducts annual supervisory visits to each active
    facility to review the resources and capabilities which are required
    for continued program approval. The ongoing, on-site monitoring and
    supervision are vital to ensure these approved institutions continue to
    provide quality educational programs and meet VA compliance
    requirements. The following statement illustrates the importance of
    these visits and supervisory support provided.

              ``When I took over supervision of USD Veterans' Services in
            2005, our practices needed to be revamped to meet our
            obligations to the VA and our students. I met with George
            Summerside, SD State Approving Agency, in June 2005 at a
            regional training session for which he was one of the main
            speakers and coordinators. George immediately offered his full
            support and assistance to the University, and he followed
            through.
              Throughout 2005 and 2006, George was readily available to
            clarify laws and policies surrounding education benefits. He
            frequently gave suggestions (sometimes directives) about how
            The University could meet its obligations, which have improved
            our services to the students a hundred fold. He provided us a
            network of other higher education administrators and people
            employed by the VA who provided invaluable advice.
              During the same time period, George visited our campus on
            three occasions. Two were supervisory visits to help us gauge
            our progress, and one was to sit on a panel discussion for a
            Veterans Day event hosted by the USD Veterans Club (a student
            group). George's participation in the Veterans' Day event was
            widely appreciated by our students and the community, because
            it demonstrated a positive link to the individuals in
            Vermillion and the SD Division of Veterans Affairs.
              In addition, George was able to provide me much of the
            information and support I needed to take to my superiors to
            request the assignment of a full-time employee to USD Veterans'
            Services. A full-time position was filled in September 2006.
              On behalf of the veterans and their dependents attending The
            University of South Dakota, I can honestly claim that the
            support of our state approving agency is essential to our
            success. Thank you for the opportunity to submit this
            statement.''
                                    Jenifer Jost, Associate Registrar
                                       The University of South Dakota

        The next statement provides the prospective from Brink
    Constructors, Inc., an approved training establishment:

              First let me say what a pleasure it has been working with the
            SD State Approving Agency and associated staff. The staff is
            very knowledgeable and always able to assist us with our
            questions.
              The veterans who join our apprenticeship program are greatly
            benefited by the financial assistance provided to them through
            the GI Bill and Apprenticeship Program.
                                                                  Judith M.
            Michael
                            Robin Cressy-Eddy

            Apprenticeship
                            Human Resource Administrator

            Coordinator
    LIAISON
        Yet, while the fundamental role of the SAA has remained the same,
    the SAA's have grown with the changes in our society over the past
    sixty years. They have become advocates for quality education and
    training for Veterans and other eligible persons. They have become
    educational partners with the institutions themselves, facilitating
    even greater and more diverse educational opportunities for Veterans.
    They have become strong advocates for the usage of the GI Bill and have
    developed a working partnership with the Federal government, which
    other Federal agencies have tried to emulate.
        As State and National priorities change, as the function of
    government undergoes perpetual re-examination, and as the needs of our
    Veterans evolve with changes in American society, state approving
    agencies stand ready to meet the challenges before them. In spite of
    the need for new approaches and technologies, differing styles of
    oversight and enhanced criteria for performance, the fundamental
    reasons for which the SAA's were originally created remain as valid
    today as they were sixty years ago. Mr. Del Johnson, Retired SD
    Education Liaison Representative (ELR) offers his opinion on State
    Approving Agencies. Del retired with over 28 years of experience with
    VA educational services.

              In my opinion there is a real value in having a State
            Approving Agency in each state. Approval of VA educational
            programs requires extensive knowledge of many complicated laws
            and regulations. It is absolutely necessary that the local
            schools and training establishments have someone with whom they
            can have personal contact. My experience was that there will
            always be differences in interpretation and the SAA serves a
            very important role between the Veterans Administration and the
            institutions which offer these programs. Now that the
            Department of Veterans Affairs has become more regionalized we
            have states that do not have an ELR (Education Liaison
            Representative) located in the Regional Office in their state,
            South Dakota is one of those states. This makes the
            institutions and veterans more isolated from the VA.
              The philosophy that ``bigger is better'' does have its limits
            and the impact on our smaller states can be negative. There is
            a need for each state to have a fully staffed SAA so the
            veterans in that state do not suffer with additional delays in
            obtaining their educational benefits. These agencies are vital
            and any reduction in funding would negatively impact VA
            educational programs.

                                                          Del Johnson
                                                       Retired SD ELR

        Our office has developed strong partnerships with many within our
    veterans' service network and the following comments illustrate these
    relationships.

              The State Approving Agency is a valuable resource for South
            Dakota's County and Tribal Veteran Service Officers whose job
            it is to properly serve these veterans.
              With the new influx of veterans from the War on Terrorism, it
            is more important than ever that they are provided with all the
            benefits they are entitled to, including education.
              The State Approving Agency has been there for me on countless
            occasions to provide quick and highly professional assistance
            at any time a question arises while initiating an education
            claim or by personally contacting the St. Louis Regional
            Processing Center on our behalf when a problem arises during
            the life of the claim or benefit.
              To ever lose or restrict the State Approving Agency, in
            particular George Summerside or Dr. Tom Murphy, due to federal
            budget restraints would be a HUGE disservice to South Dakota's
            veterans.
                                                         Ken Lindblad
                               Beadle County Veterans Service Officer

        The next statement was submitted by one of our SD Veterans
    Commissioners.

              The SD Veterans Commission relies on select individuals to
            advise the Commission on veteran related issues and programs.
            Without the SD State Approving Agency's valuable input our
            Commission would not be able to make informed decisions on VA
            educational issues. State Approving Agencies have not only
            ensured that those eligible for VA educational benefits enroll
            in quality education and training programs, but they have also
            served as a champion of veterans educational benefits.
                                            Bill Locken, Commissioner
                                               SD Veterans Commission

        The following statement provides a viewpoint from Muth Electric
    Inc., an approved training establishment.

              We appreciate the value that the SD State Approving Agency
            provides to the employees of Muth Electric. Any time there is a
            benefit that we can offer to our employees, especially those in
            transition from military to civilian life, we are more than
            willing to do so. Working with the SD State Approving Agency
            has allowed our employees an opportunity to utilize their
            military benefits while learning an exciting and challenging
            trade.
                                                             Amy Tlam
                                                           HR Manager

        Our agency acts as the state liaison in assisting veterans groups,
    schools, training establishments, and other service partners with a
    better understanding of the many VA educational opportunities. By
    working together we can facilitate even greater and more diverse
    educational opportunities for those who are eligible for these well
    deserved and earned benefits.
    TECHNICAL ASSISTANCE
        This assistance is provided to schools, training establishments,
    County and Tribal Veterans Service Officers, and individuals on a wide
    range of VA educational issues and concerns. The information is
    provided during phone conversations, in emails, during visits and in
    correspondence. These inquiries are increasing and they require a
    considerable amount of staff time to be addressed.
        The needs of the VA student are and always will be of primary
    concern to this office. The following statement depicts one student's
    opinion of our office.

              In the past few months George Summerside has been an
            excellent client advocate. Without his dedication and loyalty
            the Veterans Education Program would be nothing. Personally I
            could not have done the nursing program at Western Dakota
            Technical Institute without him, for he made sure my VA
            benefits were released to me in enough time to pay my bills,
            and I did not have to go back to work.
              Sincerely,
                                                      Samantha Donley
    OUTREACH
        Our agency is continually developing creative and innovative ways
    to promote and educate the public on VA educational programs. During FY
    2006 our staff developed and distributed over 6,000 brochures/posters
    to Veterans, guardsmen/reservists, dependents/survivors and other
    partners within our veterans' service network. Our agency participates
    in veterans' forums, demob briefings, workshops, and other events
    whenever our presence can inform or educate the public on the excellent
    learning opportunities for those eligible for VA educational benefits.
    SUMMARY
        The core functions that I have discussed today all center around
    the program approval. The primary responsibility and focus of the SAA's
    continue to be the review, evaluation and approval of quality programs
    of education and training. Our agencies have sixty years of experience
    with this process.
        Our National Association has developed the National Training
    Curriculum to serve as a reference and training tool for both new staff
    and existing agency professionals. This excellent reference guide
    ensures that staff is trained adequately to perform the comprehensive
    functions of a State Approving Agency professional. In addition to the
    National Training Curriculum our association has created the National
    Training Institute. This Institute provides classroom training for new
    staff, and both SAA and VA personnel participate. They are held
    approximately every eighteen months.
        If this funding solution is not resolved, there will be a reduction
    of 32% from the current funding level. South Dakota's contract will be
    reduced by over $66, 000 dollars in FY 2008. This will have a negative
    impact not only on our state but across this nation. The many things
    that we are doing in outreach and customer service would no longer be
    possible.
        Today you have heard from different agencies and groups;
    statistical and narrative information has been provided for your
    review. The testimonies today are not a true measure of our value; our
    true value rests in the heart of each of the dedicated staff whose sole
    purpose is the approval of quality programs of education for those
    eligible for VA educational benefits. Our agencies worth is measured by
    this dedicated devotion to excellence, and our nation's Veterans
    deserve no less.
    Closing
        In closing, Madam Chairwoman, I would like to thank you and members
    of the Subcommittee again for the opportunity to comment on the
    functions of the South Dakota State Approving Agency and the value they
    add in the State of South Dakota. I would be happy to respond to any
    questions that you might have.

                        Statement of John M. McWilliam,
           Deputy Assistant Secretary for Operations and Management,
      Veterans' Employment and Training Service, U.S. Department of Labor
        Chairwoman Herseth Sandlin, Ranking Member Boozman, and
    distinguished members of the Subcommittee:
        I am pleased to appear before you today on the subject of the role
    of the State Approving Agencies (SAAs) in assisting the Department of
    Labor (DOL) and other issues related to apprenticeships and on-the-job-
    training (OJT) programs.
        DOL has a separate responsibility from that of the SAAs. Under the
    National Apprenticeship Act 1937, DOL is the only federal agency
    authorized to register apprenticeship programs for federal purposes.
    ``Federal purposes'' includes any federal contract, grant, agreement or
    arrangement dealing with apprenticeship; and any federal financial or
    other assistance, benefit, privilege, contribution, allowance,
    exemption, preference or right. DOL's role is to safeguard the welfare
    of apprentices, ensure equality of access to apprenticeship programs,
    and provide integrated employment and training information to sponsors
    and the local employment and training community.
        Title 38, section 3687(a)(1) indicates that an eligible veteran may
    be paid a training allowance while pursuing a full time ``program of
    apprenticeship approved by a State approving agency as meeting the
    standards of apprenticeship published by the Secretary of Labor. . .
    .'' (Emphasis added).
        Therefore, for an apprenticeship program to be approved for
    veterans' benefits, it first must meet the standards of apprenticeship
    published by the Secretary of Labor. These standards require that the
    program be registered by either DOL or a DOL-recognized State
    Apprenticeship Agency. These State Apprenticeship Agencies are separate
    from the State Approving Agencies being discussed at today's hearing.
        State Apprenticeship Agencies and DOL use basically the same
    assessment and approval criteria. State Apprenticeship Agencies'
    regulations conform to federal regulations for the registration of
    apprenticeship programs. There are, however, variations in the
    operational procedures between State Apprenticeship Agencies and the
    Office of Apprenticeship (OA) in DOL's Employment and Training
    Administration.
        Registration of an apprenticeship program by DOL or a DOL-
    recognized State Apprenticeship Agency must comply with the
    requirements set in 29 Code of Federal Regulations (CFR) parts 29 and
    30, the Department's regulations for registered apprenticeship.
    Apprenticeship program sponsors prepare and submit Standards of
    Apprenticeship for review and approval by DOL or a DOL-recognized State
    Apprenticeship Agency. Standards must state the term of the
    apprenticeship (not less than 2,000 hours); the work processes in which
    the apprentice will receive supervised work experience and training on
    the job; provision for related technical instruction (a minimum of 144
    hours per year of apprenticeship is recommended); the progressively
    increasing schedule of wages to be paid to the apprentice consistent
    with the skill acquired; and other requirements pertaining to program
    administration. When DOL or a DOL-recognized State Apprenticeship
    Agency has determined that the standards comply with 29 CFR parts 29
    and 30, DOL or the DOL-recognized State Apprenticeship Agency issues
    the program a Certificate of Registration, which recognizes the program
    as a registered apprenticeship program for federal purposes. DOL or
    DOL-recognized State Apprenticeship Agency staff provides technical
    assistance to current and potential program sponsors for the
    preparation or modification of apprenticeship standards and to promote
    compliance with the apprenticeship regulations.
        DOL has not yet determined what, if any, overlap currently exists
    between reviews by the Registered Apprenticeship System (State
    Apprenticeship Agencies and DOL's Office of Apprenticeship in the
    Employment and Training Administration) and State Approving Agencies.
    We believe there may be overlap in the review of program sponsors'
    performance. As provided by the regulations for registered
    apprenticeship (29 CFR parts 29 and 30), DOL and DOL-recognized State
    Apprenticeship Agency staff conduct periodic reviews and evaluations of
    registered apprenticeship programs, including Quality Assurance
    Assessment reviews. These reviews may overlap with monitoring and
    assessments conducted by State Approving Agencies.
        Registered apprenticeship programs must maintain compliance with
    the standards for registered apprenticeship, whether they are
    registered with DOL or a DOL-recognized State Apprenticeship Agency.
    DOL and DOL-recognized State Apprenticeship Agenciescurrently register
    over 29,000 apprenticeship programs nationally with approximately
    250,000 participating employers. Veterans comprise more than 8% of the
    currently 449,000 registered apprentices.
        DOL supports working with the VA and the Department of Education to
    assess both the similarities and the differences between the assessment
    components of the VA and DOL regulations and to determine how to
    further collaborate. In fact, the first such meeting between DOL and VA
    occurred on March 20, 2007, to discuss possible cooperative efforts. We
    look forward to continued collaboration with partners at VA and the
    Department of Education.
        DOL does not have any responsibility for, nor do we participate in,
    OJT programs for veterans in relation to the national apprenticeship
    system. Our enabling legislation, the National Apprenticeship Act 1937,
    deals specifically with registered apprenticeship. However, OJT is an
    allowable use of funds through other DOL authorizing statues, such as
    the Workforce Investment Act 1998.
        Thank you for the opportunity to discuss this important issue. I
    would be pleased to respond to any questions.

                        Statement of Carol A. Griffiths,
                   Chief, Accrediting Agency Evaluation Unit,
        Office of Postsecondary Education, U.S. Department of Education

        Good afternoon Chairwoman Herseth-Sandlin, Ranking Member Boozman,
    and members of the Subcommittee. I appreciate the opportunity to appear
    before you today to share with you the Department of Education's
    activities related to the accreditation of postsecondary education
    institutions and programs. My testimony will describe the U.S.
    Secretary of Education's accrediting agency recognition process--
    providing you with a snapshot of the type and breadth of accrediting
    agencies currently recognized by the Secretary and the components of
    the recognition process, as well as--highlighting some of the criteria
    for recognition and the role of the Secretary's Advisory Committee in
    the recognition process.
        The Department of Education relies on accreditation by recognized
    accrediting agencies and State approval agencies as a primary factor in
    establishing the eligibility of institutions to participate in federal
    student financial aid programs authorized by Title IV of the Higher
    Education Act 1965 (HEA). Other Federal departments also rely on the
    Secretary's recognition of accrediting agencies as an eligibility
    factor for participation in various programs they administer. In the
    context of the recognition process, State approval agencies are units
    within State Departments of Education that have responsibility for the
    oversight of postsecondary vocational education.
    Authority
        Since 1952, the Secretary of Education has published a list of
    recognized accrediting agencies that the Secretary determines are
    reliable authorities of the quality of education and training provided
    by the institutions and programs they accredit. The initial authority
    for this was in the Servicemen's Readjustment Act; the recognition
    authority is now part of the HEA, which establishes the requirements
    for recognition of accrediting and state agencies.
        Currently the Secretary recognizes 62 institutional and
    programmatic accrediting agencies. There are 4 types of institutional
    accrediting agencies, though the distinctions between them are
    diminishing.
        National institutional accreditors--as the name suggests--accredit
    schools throughout the United States. Historically, they've accredited
    private for-profit institutions offering predominantly non-degree,
    vocational technical education programs. However, their recognized
    accrediting activities have expanded to include accreditation at all
    educational levels, including doctoral degrees and the accreditation of
    private non-profit institutions. Their emphasis remains, however, on
    the accreditation of institutions providing professional, technical,
    and occupational education programs.
        Regional institutional accreditors, as the label implies, accredit
    in a specific geographic region of the U.S. There are 6 regional
    accrediting associations--New England, Middle States, North Central,
    Northwest, Western, and Southern. Historically, the regional
    accrediting associations accredited public and private-nonprofit
    degree-granting institutions of higher education. Again, as for-profit
    education has expanded into the degree-granting realm, regional
    accreditors have expanded their accreditation activities to include
    accreditation of for-profit institutions. Also, as public and private
    degree-granting institutions have expanded their offerings to include
    non-degree programs, regional accreditors have augmented accrediting
    activities to include these non-degree programs.
        The New York State Board of Regents is the sole accrediting body in
    a third category of institutional accreditor. The Board of Regents is,
    by federal statute, eligible to seek recognition for its accreditation
    of a limited universe of degree-granting institutions (24 institutions)
    in New York seeking to participate in HEA programs.
        The fourth type of institutional accreditor is the specialized,
    programmatic accreditor that accredits single-programs and single-
    purpose institutions, so that those schools may be eligible to
    participate in the federal student financial aid programs. These
    include accreditors of free-standing schools of osteopathic or
    podiatric medicine, free-standing schools of music, dance, or theater,
    or schools of mortuary science. These specialized accreditors accredit
    a specific type of educational program and are usually closely
    associated with, or part of, an association of individuals employed in
    that profession.
        The Secretary's recognition process also includes 5 State approval
    agencies in 4 States (New York, Oklahoma, Pennsylvania, and Puerto
    Rico) that have sought and received recognition for their oversight of
    public, postsecondary, vocational-technical education in their
    respective States to enable those programs to participate in student
    aid programs authorized by Title IV of the HEA. These agencies are a
    part of the State educational agency in their respective States, and
    this recognition enables access to Federal student aid by adults
    enrolled in programs usually offered through the adult vocational
    education program of the local K-12 school district.
    The Recognition Process
        The recognition process is voluntary. The Secretary's recognition
    is not required for accrediting agencies to exist, or to accredit.
    However, recognized accreditation is a requirement for institutions'
    and programs' participation in the Title IV student aid programs and in
    many other Federal programs.
        Also, since the 1992 reauthorization of the HEA, an accreditor must
    demonstrate a Federal purpose for seeking the Secretary's recognition.
    The accreditor must establish that its accreditation is necessary to
    enable one or more of its accredited institutions or programs to
    participate in a Federal program. Therefore, not all accreditors, even
    those that may desire to submit to the Secretary's review process, are
    eligible for recognition.
    Components of the Recognition Process
        To some extent, the components of the recognition process parallel
    the accreditation process. Like the accreditation process, the
    recognition process includes an agency self-review, Department review
    of the agency's policies, standards, procedures and practices,
    solicitation of public input, a review by the Secretary's National
    Advisory Committee on Institutional Quality and Integrity (NACIQI), a
    Committee representative of the higher education community, and a
    decision by the Secretary. Each agency is reviewed at least once every
    5 years (4 years for State approval agencies).
        Eligible accrediting agencies seeking recognition must demonstrate
    their compliance with the criteria for recognition published in 34 CFR
    Part 602. As a first step of the process, an accreditor conducts a
    self-review of its compliance with the Secretary's criteria for
    recognition and submits a statement of its requested scope of
    recognition along with a narrative describing its compliance with each
    of the 18 criteria for recognition and documentation evidencing that
    compliance. The agency also submits to observations of its activities
    and reviews of its files by Department staff. State approval agencies
    must demonstrate compliance with 34 CFR Part 603 in the same manner.
        The requested scope of recognition includes the range of
    accrediting activities for which the Secretary recognizes an
    accreditor. This includes the types of accrediting activity--
    institutional or programmatic, types of degrees or certificates,
    geographic area of accreditation, type of pre-accreditation if any, and
    activities related to distance education, if any. Accreditors may, and
    many do, conduct activities outside their recognized scope of
    accreditation. For example, a number of U.S. accreditors also accredit
    foreign institutions, but as the Secretary's recognition authority is
    limited to U.S. institutions, the Secretary does not evaluate an
    accreditor's activities in relation to the foreign institutions and
    this aspect of an accreditor's activities is not included in the
    agency's recognition.
        The 18 recognition criteria are used to examine an accrediting
    agency's organizational structure and administrative and fiscal
    responsibilities; the agency's standards and their application,
    enforcement and review; and the agency's operations regarding
    monitoring and oversight of its accredited institutions and programs.
    There are also criteria that address an agency's adherence to due
    process, conflict of interest practices, and its practices regarding
    its responsiveness to complaints and the public notice of its
    accreditation decisions.
        An agency's organizational structure is evaluated with a focus on
    the ability of the agency to demonstrate that its accrediting
    activities and decisions are separate and independent from influence by
    related, associated, or affiliated trade or membership organizations.
        The agency must demonstrate its administrative capability to
    conduct its accreditation activities by evidencing the composition and
    competency of staff, evaluators and decisionmakers who are free of
    conflicts of interest. It must also demonstrate its financial viability
    to carry out its accrediting functions.
        The agency must demonstrate that its standards are sufficiently
    rigorous, and adequate to measure the quality of the education and
    training of the institutions or programs it accredits, and that they
    continue to be relevant to the education and training needs of
    students. The areas for which the accreditor must have standards are
    outlined in statute and include an evaluation of curriculum, faculty,
    fiscal/administrative capacity, admissions, recruiting and
    publications, student services, facilities and resources, and the
    institution or program's success with respect to student achievement.
        The agency must demonstrate that its accreditation decisions are
    consistent, based on its published standards, made without conflict of
    interest, that its institutions and programs are provided due process,
    and that the agency has processes for evaluating change and for
    monitoring its accredited institutions or programs.
        Department staff evaluate the written evidence, observe one or more
    accrediting agency activities, such as training sessions, agency
    evaluations of institutions or programs, accreditation decision
    meetings, file reviews, or appeal hearings. From this evaluation and
    observation, the staff draws conclusions of compliance and drafts a
    report of findings that is provided to the agency. The agency then may
    respond with further evidence of its compliance with the criteria.
        A concurrent step in the process, public input, is solicited via
    Federal Register notices inviting comments regarding the agency's
    compliance with the Secretary's criteria.
    National Advisory Committee on Institutional Quality and Integrity
            (NACIQI)
        The final step before reaching the Secretary is a review of the
    agency by the Secretary's National Advisory Committee on Institutional
    Quality and Integrity (NACIQI). This is a 15-member committee
    authorized under the HEA and appointed by the Secretary to advise her
    on matters related to accreditation. This Committee, representative of
    the higher education community, meets twice a year (June and December)
    and, in a public forum, reviews each agency's petition for recognition.
    In preparation for that review, the Committee members are provided all
    agency information and the Department staff analysis of the petition.
    After hearing from Department staff, the agency and any 3rd parties
    present at the meeting, the Committee deliberates and makes a
    recommendation to the Secretary to grant, defer, or deny recognition.
    For accrediting agencies, the period of recognition cannot exceed 5
    years. Decisions on agencies that have outstanding issues may be
    deferred and the agency given a limited window of 12 months in which to
    correct deficiencies. The agency may appeal the Committee's
    recommendation to the Secretary. With or without an appeal, the
    Secretary makes the final decision.
        In conclusion, the Department of Education recognizes 62
    accrediting agencies and 5 State approval agencies as reliable
    authorities of the quality of education provided by postsecondary
    institutions and programs. This recognition process is a critical part
    of the oversight needed on a variety of Federal programs that provide
    access to approximately 90 billion dollars annually by institutions of
    higher education, students, and their families. The recognition process
    is comprehensive and ongoing and includes input from entities both
    internal and external to the Federal government. I hope this
    information is useful to you, Madame Chairwoman, and I would be pleased
    to answer any questions you or any of the other members of the
    Committee may have.

      Statement of Keith M. Wilson, Director, Education Service, Veterans
          Benefits Administration, U.S. Department of Veterans Affairs

        Good afternoon, Chairwoman Herseth-Sandlin, Ranking Member Boozman,
    and members of the Subcommittee. I appreciate the opportunity to appear
    before you today to discuss the Department of Veterans Affairs (VA)
    education benefit programs and the role of State Approving Agencies
    (SAAs). My testimony will highlight the vital role of SAAs in ensuring
    that veterans receive the maximum benefit from their educational
    programs. I will specifically address the program services, fraud
    prevention, oversight, and outreach functions of the SAAs, and the
    legislatively mandated funding decrease scheduled to take effect in
    fiscal year 2008.
        VA and the SAAs work together to ensure the successful readjustment
    of veterans to civilian life through educational opportunities. VA
    administers educational assistance, generally in the form of monthly
    benefits, to eligible veterans and dependents, while the SAAs ensure
    the quality of the educational and vocational programs pursued and
    monitor the institutions providing education and training to veterans.
    Title 38 of the United States Code establishes the parameters for the
    relationship.
    Role of SAAs
        38 U.S.C. Sec. 3671(a) requests that each state create or designate
    a state department or agency as the ``State Approving Agency.'' The
    SAAs are charged with approving courses in accordance with the
    provisions of chapters 34, 35 and 36 of title 38 U.S.C., including
    apprenticeship programs. They also conduct outreach programs and
    provide outreach services to eligible servicemembers and veterans about
    education and training benefits available. Our relationship is a
    cooperative one and we consider the SAAs to be vital partners in
    fulfilling our mission.
        Under contracts with VA, SAAs ensure that education and training
    programs meet federal VA standards through a variety of approval
    activities, such as evaluating course quality, assessing school
    financial stability, and monitoring student progress. In 2001, the SAAs
    were also given responsibility to actively promote the development of
    apprenticeship and on-the-job training programs and to approve tests
    used for licensing and certification.
        The SAAs maintain regular contact with the educational institutions
    and other program facilities within their jurisdiction, keeping them
    informed of on-going activities and allowing them to monitor the
    institutions compliance with VA's approval standards and enrollment
    restrictions. VA and the SAAs exchange information on activities of
    education institutions, paying particular attention to enforcement of
    approval standards, enforcement of enrollment restrictions, and
    possible fraudulent or criminal activities on the part of persons
    connected with educational institutions where veterans are enrolled. VA
    staff perform compliance site visits at participating institutions
    every three years, while SAA staff conduct site visits at many
    institutions annually. They are a critical component in reducing the
    opportunities for fraud, waste and abuse in the veterans educational
    assistance program.
        While it is true that some of the programs monitored and approved
    by SAAs are also reviewed by the Departments of Education and Labor,
    SAAs approve a number of programs that are not reviewed by other
    agencies. These programs include on-the-job training programs,
    cosmetology and massage training offered by unaccredited schools, and
    apprenticeship programs not approved by the Department of Labor. SAAs
    tend to conduct more frequent on-site monitoring than other
    governmental entities and, for less-established institutions and
    programs, they provide more extensive review to ensure the quality and
    integrity of the veterans' learning experiences.
        The SAAs also assist school certifying officials in understanding
    and complying with the law and regulations governing payment of VA
    educational assistance.
    GAO Report
        A recent GAO report, ``VA Student Financial Aid: Management Actions
    Needed to Reduce Overlap in Approving Education and Training Programs
    and to Assess State Approving Agencies'' (GAO-07-384, March 2007),
    contained three major recommendations. First, VA should require SAAs to
    track and report data on resources spent on approval activities such as
    site visits, catalog review, and outreach in a cost-efficient manner.
    Second, VA should collaborate with other agencies to identify any
    duplicative efforts and use the agency's administrative and regulatory
    authority to streamline the approval process. Finally, VA should
    establish outcome-oriented performance measures to assess the
    effectiveness of SAA efforts.
        VA generally agreed with all three recommendations. We are taking
    action to implement the first and third recommendations (resources
    expenditures and outcome-oriented performance measures) in cooperation
    with the National Association of State Approving Agencies (NASAA).
        VA diligently tracks SAA activities. SAAs report their activities
    to us quarterly including the number of programs approved, the number
    of programs disapproved, the number of supervisory visits conducted,
    and the number of outreach activities or visits conducted. However,
    based on the report findings, VA will review current tracking
    mechanisms to further ensure that resource allocation decisions for SAA
    activities are made efficiently and effectively.
        Regarding the second recommendation to collaborate with other
    agencies, we have already met with Department of Labor staff to discuss
    how we can improve our communication processes and coordinate our
    respective activities. We intend to hold similar discussions with the
    Department of Education in the near future.
    SAA Performance Evaluation Process
        Public Law 100-323 requires an annual Joint Peer Review Group
    (JPRG) to meet for the purpose of evaluating the performance of the
    individual State Approving Agencies during the preceding fiscal year.
    The JPRG is composed of eight members, four SAA representatives and
    four VA representatives. The President of the National Association of
    State Approving Agencies selects the SAA representatives. The VA
    representatives are the Chief Education Liaison Officers from the four
    Regional Processing Offices located in Buffalo, NY; Muskogee, OK;
    Atlanta, GA; and St. Louis, MO.
        For FY 2006, the JPRG reviewed self-evaluations from 59 SAAs and
    written assessment reports from 50 Education Liaison Representatives
    (ELRs) nationwide. These reports were reviewed by the JPRG to determine
    each SAA's annual performance rating. There are three designated
    ratings: Satisfactory, Minimally Satisfactory or Unsatisfactory. For
    2006, the JPRG assigned the following ratings: two SAAs received an
    ``unsatisfactory'' rating, three received a ``minimally satisfactory''
    rating, and 54 agencies received a ``satisfactory'' rating.
        All SAAs received notices of their ratings in writing. SAAs with
    less than satisfactory ratings received written guidance on how to
    improve their job performance. For one SAA that was rated
    unsatisfactory, a ``mentoring'' relationship was developed with a
    neighboring SAA to improve performance during the remainder of this
    contract year.
    Funding for SAAs
        In fiscal year 2006, VA paid approximately $2.1 billion in
    education assistance benefits to more than 470,000 beneficiaries. In
    that year, VA also provided approximately $19 million in funding to the
    SAAs, and will pay a similar amount in fiscal year 2007. For fiscal
    year 2008, the amount of funding for SAAs will decrease to
    approximately $13 million, per section 301 of Public Law 107-330. SAA
    funding is not tied to the Consumer Price Index (CPI) which causes a
    continual erosion of funding for the SAAs.
    VA Actions to Mitigate the Impact of the SAA Funding Reduction
        The outreach activities which were added to the SAA's roles in 2001
    may be impacted by the reduction in SAA funding. However, we have taken
    steps to mitigate this impact. Information concerning VA education
    benefits is mailed three times to servicemembers while they are on
    active duty and again at separation. Information is also provided
    annually while veterans are using their education benefits. VA's
    Transition Assistance Program (TAP), as well as benefit briefings for
    demobilizing National Guard and Reserve members, provides information
    on education benefits available to these members. VA has participated
    in the training of the newly created State Benefits Advisors. State
    Benefits Advisors are Department of Defense (DoD) employees located
    within the Adjutant General's office of each state. They assist in the
    dissemination of benefits information to National Guard and Reserve
    units. Despite these efforts, a reduction in SAA funding may negatively
    impact our efforts to promote the use of VA education benefits,
    particularly the promotion of OJT and apprenticeship programs with
    employers. The extent to which these efforts would be impacted is
    difficult to predict.
        We will continue to monitor the performance of SAAs in conducting
    program approvals, fraud prevention, oversight, and outreach. If SAAs
    operating at the new funding levels are unable to perform these
    services, then the Department will reallocate existing VA staff and
    resources to cover the services previously provided by the SAAs. Our
    ultimate concern is always for the effective administration of
    educational benefits to our veterans. If it is determined that
    increased resources are required, appropriate budget requests will be
    made.
        Madame Chairwoman, this concludes my statement. I would be pleased
    to answer any questions you or any of the other members of the
    Committee may have.

                           SUBMISSIONS FOR THE RECORD

              Statement of Ronald F. Chamrin, Assistant Director,
                      Economic Commission, American Legion

        Chair Herseth Sandlin and members of the Subcommittee, the American
    Legion appreciates this opportunity to share its views on State
    Approving Agencies (SAA) and the impact they have regarding the
    veterans' education benefits.
    STATE APPROVING AGENCIES
        The American Legion is deeply concerned with the timely manner that
    veterans, especially returning wartime veterans, receive their
    education benefits. Annually, approximately 300,000 servicemembers
    (90,000 of them belonging to the National Guard and Reserve) return to
    the civilian sector and use their earned education benefits from the
    Department of Veterans Affairs (VA).
        Any delay in receipt of education benefits or approval of courses
    taken at institutions of higher learning can adversely affect a
    veteran's life. There are time restrictions on most veterans' education
    benefits, significantly, the National Guard and Reserve in which they
    must remain in the Selected Reserve to use their earned benefits.
        The American Legion believes that every effort should be made to
    ensure that the Montgomery GI Bill (MGIB) and related veterans'
    education benefits are delivered without problems or delays.
    Furthermore, veterans are unique in that they volunteer for military
    service; therefore, these educational benefits are earned as the thanks
    of a grateful nation. The American Legion believes it is a national
    obligation to provide timely oversight of veterans' education programs
    to assure they are administered in a timely, efficient, and accurate
    manner.
        A recent Government Accountability Office (GAO) Report entitled
    ``VA Student Financial Aid; Management Actions Needed to Reduce Overlap
    in Approving Education and Training Programs and to Assess State
    Approving Agencies'' (GAO-07-384) focuses on the need to ``ensure that
    Federal dollars are spent efficiently and effectively.''
        GAO recommends that VA should require SAA to track and report data
    on resources spent on approval activities, such as site visits, catalog
    review, and outreach in a cost-efficient manner. The American Legion
    agrees. Additionally, GAO recommended that VA establish outcome-
    oriented performance measures to assess the effectiveness of SAA
    efforts. The American Legion fully agrees. In response, VA Deputy
    Secretary Mansfield plans to establish a working group with SAA to
    create a reporting system for approval activities and develop outcome-
    oriented measures with a goal of implementation in the FY 2008 budget
    cycle.
        Finally, GAO recommended that VA should collaborate with other
    agencies to identify any duplicate efforts and use the agency's
    administrative and regulatory authority to streamline the approval
    process. The American Legion agrees. VA Deputy Secretary Mansfield
    responded that VA will initiate contact with appropriate officials at
    the Departments of Education and Labor to help identify any duplicate
    efforts.
        SEC. 301 of PL 107-330 created increases in the aggregate annual
    amount available for state approving agencies for administrative
    expenses from FY 2003-FY 2007 to the current funding level of $19
    million. The American Legion fully supports reauthorization of SAA
    funding.
        The American Legion opposes the President's budget request for SAA
    funding at just $13 million for FY 2008. The American Legion believes
    this is totally inadequate, especially for a nation at war, and
    strongly recommends keeping SAA funding at $19 million in FY 2008 to
    assure current staffing and activities.
    SERVICES TO VETERANS
        State Approving Agencies have the function of ensuring that
    qualified educational institutions and vocational training
    establishments (offering apprenticeship and other on-the-job training)
    meet and maintain acceptable approval standards for enrollment of
    eligible VA educational beneficiaries. State Approving Agencies
    currently provide qualified personnel with extensive knowledge in
    education administration and a full understanding of the laws and
    regulations that govern VA education benefits.
        Receiving earned educational benefits under the Montgomery GI Bill
    usually takes 30 days. For veterans previously enrolled, current law
    authorizes VA to backdate the approval for up to one year, depending on
    the start date of the veteran's training. This usually covers most
    delays in the approval process.
        After receipt of the veteran's original visit and submission of the
    approval package, SAA will request annual updates of the approval
    package. This is required when the school publishes a new catalog.
    Also, for veterans enrolled for the fiscal year (October-September),
    SAA will conduct an annual supervisory visit to the learning facility
    to check veterans' records. The approval to train an eligible veteran
    is strictly voluntary on the part of the training facility and can be
    withdrawn upon the participating veteran's request at any time.
        State Approving Agencies operate under contract with VA. As such,
    SAA have their foundations in Federal law, Title 38, United States Code
    (USC). SAA operate as part of the government of the State and maintain
    the State's authority to approve or disapprove veterans' education and
    training programs. They also serve to prevent abuses and promote
    equality in veterans' education by evaluating and monitoring education
    and training programs.
        The Code of Federal Regulations [38 CFR 21.4151(b)] summarizes SAA
    responsibilities:

          to inspect and supervise schools and training
    establishments within the State,
          to determine those programs of education and training
    which may be approved for veterans and other eligible students,
          to determine whether a school or training establishment
    at all times complies with established standards relating to the
    approved programs, and
          to render services and obtain information necessary for
    VA to approve or disapprove programs offered by any agency or
    instrumentality of the Federal government within the State.

        The USC further requires SAA to cooperate with VA and pay
    particular attention:

          to enforcing approval standards,
          to enforcing enrollment restrictions, and
          to identifying fraudulent and other criminal activities
    by persons connected with educational institutions and training
    establishments where veterans are enrolled.

        As a part of the State government, SAA are also responsible for
    enforcing standards set by the various branches and licensing agencies
    of the State.
        For eligible veterans to receive their Montgomery GI Bill education
    benefits, they must be matriculated in a SAA approved program, and
    attend training during a period of time (semester, term, etc.) under
    which the training has been approved. It is the responsibility of the
    institution to maintain current approvals. SAA assist institutions with
    maintaining updated program information and approval. Institutions are
    required to send SAA four copies of the catalog every time a new
    edition is published, or at least once every three years. Institutions
    are also expected to keep the SAA informed on a change of ownership,
    change in policy, new programs, program changes, and current or
    projected term dates.
    VETERANS' HIGHER EDUCATION ADVOCACY
        For such an important benefit, the ratio of support to overall
    benefit SAA provides to America's veterans is quite astonishing. In
    this current era of high speed Internet and electronic data sharing,
    the temptation to believe the need for staff is dwindling, especially
    as advanced technology is increasing. However, The American Legion
    believes that personal interaction is imperative and cannot be
    replaced.
        The American Legion believes on-site visits to institutions of
    higher learning and vocational training facilities, interface with
    school officials, and one-on-one personal interaction with veterans is
    irreplaceable.
        SAA act as monitors or ``watchdogs'' to higher education academia
    in that by SAA very presence helps to assure that veterans are being
    afforded the same opportunities compared to the larger non-veteran
    student population. Our country's history has not always been kind and
    welcoming to recently separated veterans into the classroom. Through
    the tireless efforts of veterans' advocates and other interest groups,
    such as SAA, higher education has gained valuable insight and now seems
    to welcome veterans into their culture. SAA continue to be visible
    instruments of veterans' advocacy and any diminishing of their presence
    would adversely affect currently enrolled veterans, as well as future
    generations of veterans.
        The American Legion recognizes the importance to assure that
    veterans' education programs are beneficial to veterans and not just
    universities, colleges, and vocational training facilities.
    Administrators and other educational officials are constantly striving
    to morph, advance, expand, and explore new avenues of research and
    education, but must never forget the veterans' portion of their student
    population. SAA oversee and inform universities, on-the-job-training
    and apprenticeship programs when their courses do not meet the required
    standards for entitlement to veterans' education benefits.
        Interpersonal relationships between SAA staff and veterans ensure
    that an individual enters a program that will lead to productive
    educational and/or developmental goals. Also, notification of changes
    in veterans' benefits, in addition to technical assistance for
    education, is relayed from SAA officials to veterans. Students are
    usually so engrossed in collegiate activities that they are too busy to
    know events outside of scholastic life. Acting as veterans' counselors,
    SAA fill an important role in the lives of veterans utilizing their
    earned educational benefits.
    INCREASE IN USE OF VETERANS' EDUCATION BENEFITS
        Starting in 2001, the total use of education benefits by veterans
    continues to increase. The following graphs reflect the changes from
    2001-2006. Chart 1 shows the increasing trend in usage of all VA
    education benefits programs. Chart 2 shows the increasing trend of the
    MGIB.

    [GRAPHIC] [TIFF OMITTED] T5634A.003

    [GRAPHIC] [TIFF OMITTED] T5634A.004

        In FY 2006, approximately 470,000 individuals received education
    benefits. This equates to approximately 3 million courses taken by
    veterans. Such an astronomical number for such a minute unit of
    measurement emphasizes the importance of timely and accurate oversight
    of VA's education benefits.
        The National Association of State Approving Agencies (NASAA) states
    that there are currently 200,000 approved programs. These programs are
    evaluated on a rotational basis, with new, old, and failed programs
    contributing to their tally.
        With the current increasing rate of eligible veterans and the
    increasing quantity of discharged veterans, the need for assistance and
    implementation of all elements of veterans' benefits will continue to
    rise. At the very least, maintaining the current level of SAA programs
    and staff will provide a baseline for oversight of VA's education
    programs.
    CONCLUSION
        Historically, The American Legion has encouraged the development of
    essential benefits to help attract and retain servicemembers into the
    Armed Services, as well as to assist them in making the best possible
    transition back to the civilian community. The Servicemen's
    Readjustment Act 1944, the ``GI Bill of Rights'' is a historic piece of
    social legislation, authored by The American Legion, that enabled
    millions of veterans to purchase their first homes, to attend college,
    obtain vocational training, receive quality health care and start
    private businesses.
        The role from SAA is especially critical in providing wise counsel,
    moral support and technical expertise in the seamless transition from
    honorable military service to classroom academics. In a time of war,
    every effort to promote and facilitate the use of veterans' education
    benefits must be a national priority.
        The American Legion believes that honorable military service,
    combined with improved education and vocational training opportunities,
    enhances an individual, increases diversity, and betters society as a
    whole. The education pillar is continuous and ever evolving.
    Diminishment in support for education and ability to gain knowledge for
    veterans will harm the nation as a whole, decrease the ability to
    recruit new servicemembers, and unfairly subject veterans to barriers
    of benefits that they have earned.
        State Approving Agencies are instrumental in the education process.
    The American Legion fully supports all efforts to maintain and enhance
    veterans' education benefits and recommends that State Approving
    Agencies remain funded at $19 million in FY 2008.
        The American Legion appreciates the opportunity to present this
    statement for the record.

                   Statement of Jean Avnet Morse, President,
                 Middle States Commission on Higher Education,
          on behalf of the Council of Regional Accrediting Commissions

        Mr. Chairman and Members of the Committee, I appreciate the
    opportunity to submit testimony on the issue of whether the work of
    accreditors and state approval agencies (SAAs) overlaps. This issue was
    raised in the March 2007 GAO report on VA Student Financial Aid, and I
    have been asked to comment.
    Summary
        Regional accreditors already cooperate with state licensing
    agencies to prevent duplication. It is not likely that accreditors'
    general review of all areas overlaps with the areas relating
    specifically to veterans. The research that would be required into the
    varying practices of 60 accrediting agencies and specific requirements
    for SAAs would probably be extensive.
    The Role of Regional and Other Accreditors
        I am the president of the Middle States Commission on Higher
    Education of the Middle States Association of Colleges and Schools. The
    Commission has a membership of more than 500 colleges and universities
    located in Delaware, Maryland, New Jersey, New York, Pennsylvania, the
    District of Columbia, Puerto Rico, the U.S. Virgin Islands, and in
    other countries.
        I am testifying on behalf of the Council of Regional Accrediting
    Commissions, known as C-RAC. It includes the seven U.S. regional
    accreditors that accredit institutions enrolling over 16,000,000
    students. Regional accrediting agencies have assured the quality of
    higher education in the United States for over 100 years, providing
    self-regulation and shared assistance for improving education. For the
    past 50 years, these agencies have supported federal funding functions:
    when an agency is ``recognized'' by the U.S. Department of Education,
    the students of institutions accredited by that agency are eligible for
    federal grants and loans under Title IV of the Higher Education Act.

    1. There is not a single type of accreditation review. Although all
    accreditors review the areas required by the Higher Education Act and
    USED regulations, the review varies among 3 different types of
    accreditors within types of accreditors.

        The three types of accreditors are ``regional,'' ``national,'' and
    ``specialized.'' Of the 60 accreditors mentioned in the March 2007 GAO
    report, most are specialized accreditors.
        Seven regional accreditors (such as mine--the Middle States
    Commission on Higher Education) accredit only degree-granting
    institutions of higher education. There are over 3,000 regionally
    accredited institutions.
        National accreditors (such as ACCSCT, which was interviewed by the
    GAO) accredit institutions across the U.S. that may or may not grant
    college degrees and that have historically fallen within specific types
    of categories (distance learning, etc.). They are expanding their
    coverage.
        Specialized accreditors accredit specific programs, such as law or
    medicine, rather than whole institutions.
        Some accreditors of each type are ``recognized'' by the U.S.
    Department of Education. These are ``gatekeeper'' accreditors whose
    accreditation allows students at accredited institutions to receive
    federal grants and loans. Unrecognized accreditors are not governed by
    the federal regulations for ``recognized'' accreditors.
        My testimony relates to regional accreditors.

    2. Accreditors review and monitor colleges and universities at no cost
    to taxpayers.

        Evaluators, task force members, and other experts virtually
    volunteer their time. A small permanent staff is supported by dues and
    fees. Training and other activities are paid for by attendees.
        Therefore, even if there were overlap between SAAs and accreditors,
    the government would not be paying twice.

    3. Accreditors do not typically interact with SAAs.

        The GAO report notes that the reviews conducted by the SAAs and
    accreditors might overlap. However, because accreditors rarely work
    directly with SAAs, it is difficult for us to determine this based upon
    actual experience. When accreditors work with a state agency, it is
    typically its Department of Education (the ``licensing'' agency
    described on p. 10 of the GAO report). (See #6, 7, & 8 below for how
    overlap is prevented between licensing and accreditation.) However, the
    Department of Education only serves as the SAA in 31 states. Even in
    those 31 states, the personnel who handle SAA matters are not always
    the licensing personnel with whom accreditors work.

    4. For the six core duties of SAAs described briefly by the GAO on page
    9, a careful review of the statutes and regulations governing SAAs
    would be required to determine how they relate to the federal
    regulations for ``recognized'' accreditors and the actual practices of
    accreditors.

        (a) ``Approval of Programs'': Accreditors approve some, but not all
    programs. The federal criteria for review by ``recognized'' accreditors
    do not relate to veterans.
        (b) ``Visits to Facilities'': Accreditors visit facilities in some,
    but not all, cases. Again, the federal regulations for visits from
    ``recognized'' accreditors do not refer specifically to veterans.
        (c) ``Technical Assistance to Individuals at Facilities'':
    Accreditors require that accredited institutions provide student
    support services, but the federal regulations for student services
    requirements by ``recognized'' accreditors do not specifically refer to
    the ``technical assistance to individuals'' required of SAAs.
        (d) ``Outreach'': Accreditors do outreach, but not specifically to
    veterans.
        (e) Liaison with Other Service Providers: Accreditors ``liaise''
    with other service providers, but my agency's standards to not
    specifically relate to veterans.
        (f) Contract Management: Accreditors review institutional contracts
    in some cases, but probably not in the areas required of SAAs.

    5. The GAO states that ``similar categories of standards exist across
    agencies, but the specific standards within each category vary and the
    full extent is unknown.'' This is correct.

        Accreditors certainly address 6 of the 7 areas listed on page 15 of
    the GAO report. However, interests and coverage of state and federal
    agencies differ from those of accreditors. The GAO report gives
    examples of how SAA requirements may exceed those of accreditors (p.
    15).
        Those areas are: student achievement; curricula, program
    objectives, and faculty; facilities, equipment, and supplies;
    recruiting and admissions practices; and record of student complaints.

    6. Many states in our region require both initial and ongoing
    accreditation as a pre-condition for licensing institutions of higher
    education.

        This reflects their practice of relying on accreditation to ensure
    compliance and monitoring in areas that states do not evaluate
    themselves. This is done to avoid duplication.

    7. Accreditors and state agencies in the Middle States region have also
    established other methods of preventing duplication.

        Middle States convenes periodic meetings with state licensing
    agencies to compare practices and to avoid duplication.
        We invite representatives from state agencies to join our visiting
    teams, in order to prevent duplication.
        Conversely, Middle States' policies state that institutions may
    submit materials prepared for state agencies to satisfy Middle States'
    requirements.
        Thank you for the opportunity to submit testimony about these
    issues.
                       MATERIAL SUBMITTED FOR THE RECORD
                     U.S. Government Accountability Office
                     Report to the Ranking Minority Member,
            Committee on Veterans' Affairs, U.S. Senate, March 2007
     VA STUDENT FINANCIAL AID--Management Actions Needed to Reduce Overlap
       in Approving Education and Training Programs and to Assess State
                         Approving Agencies, GAO-07-384
                                   __________
                                    Contents

    Letter

    Appendix I_Briefing Slides

    Appendix II_Comments from the Department of Veterans Affairs

    Appendix III_GAO Contact and Staff Acknowledgements

          Abbreviations

          Education--Department of Education
          IHL--institution of higher learning
          Labor--Department of Labor
          NASAA--National Association of State Approving Agencies
          OJT--on-the-job training
          RPO--regional processing office
          SAA--state approving agency
          SAC--state apprenticeship council
          VA--Department of Veterans Affairs

                                   __________
                                  U.S. Government Accountability Office
                                                        Washington, DC.
                                                          March 8, 2007

    The Honorable Larry E. Craig
    Ranking Minority Member
    Committee on Veterans' Affairs
    United States Senate

    Dear Senator Craig:

        In fiscal year 2006, the Department of Veterans Affairs (VA) paid
    approximately $2.1 billion in education assistance benefits to more
    than 470,000 beneficiaries and about $19 million to state approving
    agencies (SAA) to assess whether schools and training programs offer
    education of sufficient quality for veterans to receive VA education
    assistance benefits when attending them. Qualified individuals--
    veterans, service persons, reservists, and certain spouses and
    dependents--receive benefits through a number of education assistance
    programs for the pursuit of various types of programs, such as a degree
    program, vocational program, apprenticeship, or on-the-job training. In
    general, these programs must be approved by an SAA in order for
    qualified individuals to receive VA education assistance benefits.
    Under contracts with the VA, SAAs ensure that education and training
    programs meet federal VA standards through a variety of approval
    activities, such as evaluating course quality, assessing school
    financial stability, and monitoring student progress. In fiscal year
    2006, the Department of Veterans Affairs (VA) paid approximately $2.1
    billion in education assistance benefits to more than 470,000
    beneficiaries and about $19 million to state approving agencies (SAA)
    to assess whether schools and training programs offer education of
    sufficient quality for veterans to receive VA education assistance
    benefits when attending them. Qualified individuals--veterans, service
    persons, reservists, and certain spouses and dependents--receive
    benefits through a number of education assistance programs for the
    pursuit of various types of programs, such as a degree program,
    vocational program, apprenticeship, or on-the-job training. In general,
    these programs must be approved by an SAA in order for qualified
    individuals to receive VA education assistance benefits. Under
    contracts with the VA, SAAs ensure that education and training programs
    meet federal VA standards through a variety of approval activities,
    such as evaluating course quality, assessing school financial
    stability, and monitoring student progress.
        The Departments of Education (Education) and Labor (Labor) also
    assess education and training programs for various purposes, primarily
    for awarding student aid and providing apprenticeship assistance. These
    assessments are based, in part, on evaluations against standards set by
    laws and regulations, such as those applicable to accrediting agencies.
    In 2006, under Title IV of the Higher Education Act, Education provided
    nearly $77 billion in student aid in the form of both grants and loans.
    The Department of Education assesses and certifies postsecondary
    institutions for participation in Title IV programs through various
    oversight functions to ensure that these schools meet federal
    administrative and financial requirements and that they are accredited
    and licensed. Similarly, under the National Apprenticeship Act 1937,
    the Department of Labor is authorized to formulate and promote the
    furtherance of labor standards to safeguard the welfare of apprentices.
    To ensure programs comply with federal standards, Labor directly
    registers and oversees apprenticeship programs in less than half of the
    states and has given state apprenticeship The Departments of Education
    (Education) and Labor (Labor) also assess education and training
    programs for various purposes, primarily for awarding student aid and
    providing apprenticeship assistance. These assessments are based, in
    part, on evaluations against standards set by laws and regulations,
    such as those applicable to accrediting agencies. In 2006, under Title
    IV of the Higher Education Act, Education provided nearly $77 billion
    in student aid in the form of both grants and loans. The Department of
    Education assesses and certifies postsecondary institutions for
    participation in Title IV programs through various oversight functions
    to ensure that these schools meet federal administrative and financial
    requirements and that they are accredited and licensed. Similarly,
    under the National Apprenticeship Act 1937, the Department of Labor is
    authorized to formulate and promote the furtherance of labor standards
    to safeguard the welfare of apprentices. To ensure programs comply with
    federal standards, Labor directly registers and oversees apprenticeship
    programs in less than half of the states and has given state
    apprenticeship agencies or councils in the remaining states such
    authority over their own programs.
        Given each agency's role, the potential of duplicative efforts
    among federal agencies has been a congressional concern. In 1995, GAO
    reported on this matter and concluded that there was a substantial
    amount of overlap between the efforts of SAAs and the other federal
    agencies.\1\ In light of continued congressional interest in this
    issue, we have now answered the following questions: (1) What changes
    have occurred in state approving agencies' duties and functions since
    1995? (2) To what extent does the SAA approval process overlap with
    efforts by the Departments of Education and Labor? (3) What, if any,
    additional value do the SAA approval activities bring to VA education
    benefit programs?
    ---------------------------------------------------------------------------
        \1\ GAO, VA Student Financial Aid: Opportunity to Reduce Overlap in
    Approving Education and Training Programs, GAO/HEHS-96-22 (Washington,
    D.C.: Oct. 30, 1995).
    ---------------------------------------------------------------------------
        To address all three questions, we reviewed legislation,
    regulations, federal guidance, and other documents relevant to the
    approval processes for education and training programs. We also
    interviewed officials from each of the entities involved in the
    approval processes of VA, Education and Labor. Specifically, we
    interviewed federal officials from VA, Education, and Labor as well as
    officials representing three SAAs, three institutions of higher
    learning (IHL), and state apprenticeship councils in Connecticut,
    Maryland, and Washington. We also interviewed officials from one IHL
    that operates in multiple states and officials from the National
    Association of State Approving Agencies (NASAA), an accrediting agency
    (Accrediting Commission of Career Schools and Colleges of Technology),
    the Connecticut state licensing agency, and three apprenticeship
    programs (in Connecticut, Illinois, and Maryland). We selected
    Connecticut, Washington, Illinois, and Maryland based on VA's
    recommendation of knowledgeable SAA officials, to include both state
    and federally monitored states for apprenticeship programs, and
    geographic diversity. To identify the programs that were approved by
    the Departments of Veterans Affairs, Education, and Labor, we compiled
    and analyzed data on approved programs from each of the three agencies.
    To assess the reliability of the data, we talked with knowledgeable
    officials in each of the agencies, reviewed relevant documentation, and
    performed electronic testing of files. We determined that the data we
    have included in this briefing were sufficiently reliable for this
    purpose. We conducted our work from October 2006 to January 2007 in
    accordance with generally accepted government auditing standards.
        On February 1, 2007, we briefed your office on the results of our
    analysis. This report formally conveys information provided during that
    briefing, which is contained in appendix I. In summary, we reported the
    following findings:

          Since 1995, legislative changes effective in 2001 created
    additional responsibilities for SAAs, including promoting the
    development of apprenticeship and on-the-job training programs,
    providing outreach services, and approving tests for occupational
    licensing.\2\ From fiscal years 2003 to 2006, SAA funding increased
    from $13 million to $19 million to expand services and support the
    additional responsibilities. However, funding is scheduled to decrease
    beginning in fiscal year 2008.
    ---------------------------------------------------------------------------
        \2\ Veterans Benefits and Health Care Improvement Act of 2000, Pub.
    L. No. 106-419 (2000); and Veterans Education and Benefits Expansion
    Act of 2001, Pub. L. No. 107-103 (2001).
    ---------------------------------------------------------------------------
          Many education and training programs approved by SAAs
    have also been approved by Education or Labor, and VA and SAAs have
    taken few steps to coordinate approval activities with these agencies.
    In addition, information is not available to determine the amount of
    resources spent on SAA duties and functions, including those that may
    overlap with other agencies and programs.
          SAAs reportedly add value to the approval process for
    education and training programs through (1) a focus on student services
    for veterans and on the integrity of VA benefits, (2) more frequent on-
    site monitoring of education and training programs than provided by
    Education or Labor, and (3) assessments and approval of a small number
    of programs that are not reviewed by other agencies. However, VA's lack
    of outcome-oriented performance measures for evaluating SAAs makes it
    difficult to assess the significance of these efforts.

        In conclusion, while VA spends $19 million (less than 1 percent of
    the total benefit amount) to fund SAA duties and functions, it does not
    track the amount it spends on specific SAA activities, especially those
    that may also be performed by other agencies. Without knowing the
    amount of resources spent on specific duties and functions, VA does not
    have all relevant information for making resource allocation decisions
    and cannot determine if it is spending its federal dollars efficiently
    and effectively. In addition, VA, Education, and Labor have various
    standards and processes in place, in part to ensure that federal funds
    are being spent on quality education and training programs. While we
    have identified some overlap in approval efforts across agencies, the
    full extent of the overlap between SAA duties and other agencies'
    oversight efforts is unknown. It is important that VA work with other
    federal agencies to determine how the scope of the approval process
    could be streamlined to reduce overlap and ensure that federal dollars
    are spent efficiently. Finally, it is difficult to assess the
    effectiveness of SAA activities, in part because VA does not have
    outcome measures in place to fully evaluate SAA performance. Evaluating
    the effectiveness of VA's approval process is vitally important in
    order to manage the program and improve program results.
        To help ensure that federal dollars are spent efficiently and
    effectively, we are recommending that the Secretary of the Department
    of Veterans Affairs take steps to monitor SAA spending and identify
    whether any resources are spent on activities that duplicate the
    efforts of other agencies. The extent of these actions should be in
    proportion to the total resources of the program. Specifically:

          VA should require SAAs to track and report data on
    resources spent on approval activities such as site visits, catalog
    review, and outreach in a cost-efficient manner; and
          VA should collaborate with other agencies to identify any
    duplicative efforts and use the agency's administrative and regulatory
    authority to streamline the approval process.

        In addition, we are recommending that the Secretary establish
    outcome-oriented performance measures to assess the effectiveness of
    SAA efforts.
        We provided a draft of this report to officials of the U.S.
    Department of Veterans Affairs for review and comment. In addition, we
    provided a draft of this report to officials of the U.S. Departments of
    Education and Labor for their technical review. In written comments on
    a draft of this report, VA agreed with our findings and recommendations
    and stated that it will (1) establish a working group with the SAAs to
    create a reporting system to track and report data for approval
    activities with a goal of implementation in fiscal year 2008, (2)
    initiate contact with appropriate officials at the Departments of
    Education and Labor to identify any duplicative efforts, and (3)
    establish a working group with the SAAs to develop outcome-oriented
    performance measures with a goal of implementation in fiscal year 2008.
    While VA stated that it will initiate contact with officials at
    Education and Labor to identify duplicative efforts, it also noted that
    amending its administrative and regulatory authority to streamline the
    approval process may be difficult due to specific approval requirements
    of the law. We acknowledge these challenges and continue to believe
    that collaboration with other federal agencies could help VA reduce
    duplicative efforts. In addition, VA may wish to examine and propose
    legislative changes needed to further streamline its approval process.
        Labor provided technical comments and we incorporated them into
    this report where appropriate.
        We are sending copies of this report to relevant congressional
    Committees and other interested parties and will make copies available
    to others upon request. In addition, this report will be available at
    no charge on GAO's Web site at www.gao.gov. If you or your staff have
    any questions about this report, please contact me at (202) 512-7215 or
    scottg@gao.gov. Contact points for our Offices of Congressional
    Relations and Public Affairs may be found on the last page of this
    report. GAO staff that made major contributions to this report are
    listed in appendix III.

                Sincerely,
                                                        George A. Scott
                                                        Acting Director
                       Education, Workforce, and Income Security Issues

                                   __________
                          Appendix I:  Briefing Slides
     VA Student Financial Aid: Management Actions Needed to Reduce Overlap
                  in Approving Education and Training Programs
                     and to Assess State Approving Agencies
           Briefing for Staff of Senator Larry Craig, Ranking Member,
              Committee on Veterans' Affairs, United States Senate
                               February 01, 2007
    Objectives:
        Since the 1940's, the Department of Veterans Affairs (VA) and its
    predecessor agencies have contracted with state approving agencies
    (SAAs) to assess whether schools and training programs offer education
    of sufficient quality for veterans to receive VA education assistance
    benefits. SAAs are created or designated by state governments but are
    federally funded and responsible for enforcing federal law. Concerns
    have been raised about whether SAA approval activities are duplicative
    of efforts conducted under other federal programs.
        Key questions:

          What changes have occurred in State Approving Agencies'
    duties and functions since 1995.
          To what extent does the SAA approval process overlap with
    efforts by the Departments of Education and Labor?
          What, if any, additional value do the SAA approval
    activities bring to veterans' education benefit programs?
    Scope and Methodology:
        To address our key questions, we:

          Reviewed legislation, regulations, federal guidance, and
    other documents relevant to the approval processes for education and
    training programs.
          Compiled and analyzed data on approved programs from the
    Departments of Veterans Affairs, Education, and Labor (DOL).
          Interviewed federal officials from VA, Education, and
    DOL.
          Interviewed officials representing 3 SAAs, 3 institutions
    of higher learning (IHL), and state apprenticeship councils in
    Connecticut, Maryland, and Washington. We also interviewed one IHL that
    operates in multiple states.
          Interviewed officials from the National Association of
    State Approving Agencies (NASAA), an accrediting agency (Accrediting
    Commission of Career Schools and Colleges of Technology), Connecticut
    state licensing agency, and 3 apprenticeship programs (in Connecticut,
    Illinois, Maryland).
          Our work was performed from October 2006 to January 2007
    in accordance with generally accepted government auditing standards.
    Summary of Findings:
          Since 1995, legislative changes effective in 2001 created
    additional responsibilities for SAAs, including promoting the
    development of apprenticeship and on the job training programs,
    providing outreach services, and approving tests for occupational
    licensing.
          Many education and training programs approved by SAAs
    have also been approved by Education or Labor and VA and SAAs have
    taken few steps to coordinate approval activities with these agencies.
          SAAs reportedly add value to the approval process for
    education and training programs, but the lack of outcome-oriented
    performance measures makes it difficult to assess the significance of
    their efforts.
    Background:
    VA Funding for Educational Assistance Programs and SAAs
          In fiscal year 2006, VA provided over $2.1 billion in
    educational assistance benefits to more than 470,000 beneficiaries.
          In the same year, SAAs received $19 million to assess the
    quality of schools and training programs for veterans.

    ------------------------------------------------------------------------
                  Programs *                 Beneficiaries     Expenditures
    ------------------------------------------------------------------------
    Montgomery GI Bill (Chapter 30)                313,766    $1,909,014,605
    ------------------------------------------------------------------------
    Reserve Educational Assistance                  23,747      $151,397,610
     Program (Chapter 1607)
    ------------------------------------------------------------------------
    Educational Assistance for the
     Selected Reserve
      (Chapter 1606)                                65,145       $48,716,031
    ------------------------------------------------------------------------
    Dependents and Survivors Educational
     Assistance
      Program (Chapter 35)                          74,532       $38,787,332
    ------------------------------------------------------------------------
    Veterans Educational Assistance                    575           $59,113
     Program (Chapter 32)
    ------------------------------------------------------------------------
        Total                                      477,765    $2,147,974,691
    ------------------------------------------------------------------------
    * No payments for the National Call to Service program were made in
      fiscal year 2006.
    Source: VA.

    VA Educational Assistance Programs:
          Benefits are designed to assist individuals in gaining
    access to postsecondary education or training for a specific
    occupation. Benefits can be used to pursue a degree program, vocational
    program, apprenticeship and on-the-job training.
          Qualified individuals include veterans, service persons,
    reservists, and certain spouses and dependents.
    Veteran Enrollment by Program Type in Fiscal Year 2006:
    [GRAPHIC] [TIFF OMITTED] T5634A.005

        Source: GAO analysis of VAN enrollment data.

    Agencies Responsible for the Approval Process for Education and
            Training Programs
            [GRAPHIC] [TIFF OMITTED] T5634A.006

        Source: GAO Analysis.

    VA's Approval Process: Purpose and Responsible Entities
          Purpose--To ensure education and training programs meet
    VA standards for receipt of veteran education assistance benefits.
          Entities, Roles and Responsibilities:
            VA national office oversees the 4 regional processing
    offices (RPOs) and national contract with SAAs.
            RPOs administer the education assistance programs and
    process benefits for veterans.
            SAAs review education and training programs to
    determine which programs should be approved and ensure schools and
    training providers are complying with VA standards.
              Duties and functions--SAAs have 6 core duties: (1)
    Approval of programs, (2) Visits to facilities, (3) Technical
    assistance to individuals at facilities,
    (4) Outreach, (5) Liaison with other service providers, and (6)
    Contract management.
              Structure--60 SAAs exist in the 50 states, the
    District of Columbia, and Puerto Rico. Eight states have two SAAs. SAAs
    are usually part of a state's department of education (31 SAAs). In
    some states, SAAs are organizationally located in other departments
    such as labor (9 SAAs) or veterans' services (19 SAAs).*
    ---------------------------------------------------------------------------
        * The Washington, DC SAA office is overseen by VA.
    ---------------------------------------------------------------------------
    Education's Approval Process: Purpose and Responsible Entities:
          Purpose--To ensure schools meet federal Education
    standards to participate in the student financial aid programs. As part
    of Education's approval process, the state licensing agencies,
    accrediting agencies, and certain offices within Education are
    responsible for various approval activities.
          Entities, Roles and Responsibilities:

            State licensing agencies grant legal authority to
    postsecondary institutions to operate in the state in which they are
    located. Each of the states has its own agency structure, and each
    state can choose its own set of standards.
            Accrediting agencies develop evaluation criteria and
    conduct peer evaluations to assess whether or not those criteria are
    met by postsecondary institutions. Institutions and/or programs that
    meet an agency's criteria are then ``accredited'' by that agency. As of
    November 2005, there are 60 recognized private accrediting agencies of
    regional or national scope.
            Office of Postsecondary Education evaluates and
    recognizes accrediting agencies based on federal requirements to ensure
    these agencies are reliable authorities as to the quality of education
    or training provided by the institutions of higher education and the
    higher education programs they accredit.
          Office Federal Student Aid determines the administrative
    and financial capacity of schools to participate in student financial
    aid programs, conducts ongoing monitoring of participant schools, and
    ensures participant schools are accredited and licensed by the states.
    Labor's Approval Process: Purpose and Responsible Entities:
          Purpose--To establish and promote labor standards to
    safeguard the welfare of apprentices.
          Entities, Roles and Responsibilities:

            Department of Labor establishes standards and registers
    programs that meet the standards. Labor directly registers and oversees
    programs in 23 states but has granted 27 states, the District of
    Columbia, and 3 territories authority to register and oversee their own
    programs, conducted by State Apprenticeship Councils (SACs). Labor
    reviews the activities of the SACs.
            SACs ensure that apprenticeship programs for their
    respective states comply with federal labor standards, equal
    opportunity protections, and any additional state standards.
    Objective One: Changes in SAA duties and functions:

    Legislative Changes Effective in 2001 Created Additional
    Responsibilities for SAAs, Including Promoting the Development of
    Apprenticeship and On the Job Training Programs, Providing Outreach
    Services, and Approving Tests for Occupational Licensing

        In 2001, SAAs received additional responsibility for:

          Actively promoting the development of apprenticeship and
    on the job training programs.
          Conducting more outreach activities to eligible persons
    and veterans to increase awareness of VA education assistance.
          Approving tests used for licensing and certification,
    such as tests to become a licensed electrician. (For those tests that
    have been approved, veterans can use VA benefits to pay for testing
    fees.)

        From fiscal years 2003 to 2006, SAA funding increased from $13
    million to $19 million to expand services and support the additional
    responsibilities. Funding will begin to decrease in fiscal year 2008.
    Objective Two: Overlap in Approval Efforts:

    Many Education and Training Programs Approved by SAAs Have Also Been
    Approved by Education or Labor and VA Has Taken Few Steps to Coordinate
    Approval Activities with These Agencies

          Many education and training programs approved by SAAs
    have also been approved by Education and Labor.
          Similar categories of approval standards, such as student
    achievement and institutional capacity (e.g. fiscal stability), exist
    across agencies, but the specific standards within each category vary
    and the full extent of the overlap is unknown.
          VA and SAAs have made limited efforts to coordinate
    approval activities with other federal agencies.
          Information is not available to determine the amount of
    resources spent on SAA duties and functions, including those that may
    overlap with other agencies.

    Many Education and Training Programs Approved by SAAs Have Also Been
    Approved by Education And Labor

        69% of all programs approved by SAAs are offered by institutions
    that have been certified by Education.

          78% of SAA approved programs in institutions of higher
    learning (e.g. colleges and universities) have been certified by
    Education.
          64% of SAA approved non-college degree programs are in
    institutions that have been certified by Education.

        Less than 2% of all programs approved by SAAs are apprenticeship
    programs. VA and SAA officials reported that many of these programs
    have also been approved by Labor.

    Similar Categories of Standards Exist Across Agencies, but the Specific
    Standards within Each Category Vary and the Full Extent of Overlap is
    Unknown

        Similar categories of standards exist across agencies.\1\

                                                                                                                                                    Appren-
                                                                                                                                                   ticeship

    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                         SAA \2,3\                                     Education \4\                 Labor
                                                  ----------------------------------------------------------------------------------------------------------
                                                                                                                          Federal
           Categories of approval standards                     IHL/NCD non-                    On the                   Standards    Connecticut
                                                     IHL/NCD     accredited   Apprenticeship     job      Education's       for          state
                                                    accredited                                 training  certification  accrediting    licensing
                                                                                                                          agencies      agency
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Student                                                 X            X             X             X                           X            X           X
      achievement
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Curricula, program objectives, and faculty              X            X             X             X            X              X            X           X
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Facilities,                                             X            X             X             X                           X            X           X
      equipment,
      and supplies
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Institutional                                           X            X                                        X              X            X           X
      objectives,
      capacity, and
      administration
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Student support services                                                                                                     X            X
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Recruiting and admission                                X            X                                        X              X            X           X
      practices
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Record of student complaints                                                                                                 X                        X
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Process related requirements (e.g.                      X            X             X             X            X                           X           X
     application requirements)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Source: GAO analysis of VA, Education, and Labor Standards.
    Note: GAO constructed these categories to encompass the numerous and broad range of standards used by agencies.

        Specific standards within each category vary across agencies.
    ---------------------------------------------------------------------------
        \1\ SAA has different sets of standards for each program type (e.g.
    IHL and NCD). Education's approval process involves different sets of
    standards used by different entities, such as accrediting agencies.
    Labor has one set of standards that is applicable to apprenticeship
    programs.
        \2\ By statute, courses must meet certain criteria. These relate
    to: (1) recordkeeping of student progress; (2) recordkeeping of
    students' previous education; (3) quality, content and length of
    courses; (4) qualifications of administrators and instructors; and (5)
    equipment, space, and instructional materials. We categorized the first
    two criteria as student achievement, criteria (3) and (4) as Curricula,
    Program Objectives and Faculty, and criterion (5) as Institutional
    objectives, capacity, and administration.
        \3\ SAA approval requirements for non-accredited courses encompass
    a number of additional criteria, such as having a tuition refund policy
    and enrollment limitations.
        \4\ Connecticut's standards may not be representative of standards
    across the country.

          For example, while VA and Education's approval standards
    have requirements for student achievement, the New England Association
    of Schools and Colleges, an accrediting agency, requires that students
    demonstrate competence in various areas such as writing and logical
    thinking and VA does not have this requirement.
          Also under student achievement, VA requires schools to
    give appropriate credit for prior learning while Education does not
    have such a requirement.

        While agencies have the same standards in some instances, the
    interpretation and application of these standards may differ. For
    examples:

          VA, accrediting agencies, and Labor require that
    facilities have adequate space, equipment and instructor personnel to
    provide quality training, but the definition of adequacy differs in the
    level of specificity.
          VA and accrediting agencies require that schools have
    policies related to student achievement such as minimum satisfactory
    grades, but the requirement differs in the level of specificity.

    VA and SAAs Have Made Limited Efforts to Coordinate Approval Activities
    with Education and Labor

          VA reported that while it has coordinated with Education
    and Labor on issues related to student financial aid and apprentices'
    skill requirements, it believes increased coordination is needed for
    approval activities in order to determine the extent of duplicative
    efforts.
          Most of the SAA officials we spoke with reported that
    they have coordinated with SACs to register apprenticeship programs in
    their states.
          Labor reported that it coordinated with VA's national
    office in several instances including providing a list of registered
    apprenticeship programs.
          Education reported that it does not have formalized
    coordination with VA but has had some contacts to inform VA of its
    concerns regarding specific institutions.

    Information Is Not Available to Determine the Amount of Resources Spent
    on SAA Duties and Functions, Including Those That May Overlap with
    Other Agencies

          VA does not require SAAs to collect information on the
    amount of resources they spend on specific approval activities.
          The SAA officials we spoke with said that their most time
    consuming activity is conducting inspection and supervisory visits of
    schools and training facilities.
          Lack of data on resource allocation prevented us from
    determining what portion of funds spent by SAAs were for approval
    activities that may overlap with other agencies.

    Objective Three: Value of SAA Services:

    SAAs Reportedly Add Value to the Approval Process for Education and
    Training Programs, but the Lack of Outcome-oriented Performance
    Measures Makes it Difficult to Assess the Significance of Their Efforts

          SAA and other officials reported that SAA activities add
    value because they provide enhanced services to veterans and ensure
    program integrity.
          VA uses output measures rather than outcome-oriented
    performance measures to evaluate SAA performance and progress.

    SAA and Other Officials Reported that SAA Activities Add Value Because
    They Provide Services to Veterans and Ensure Program Integrity

        SAA and Other Officials Reported SAAs' added value includes:

          A focus on student services for veterans and on VA
    benefits;
          More frequent on-site monitoring of education and
    training programs than Education and Labor; and
          Assessments and approval of a small number of programs
    that are not reviewed by other agencies.

    The SAA Approval Activities Focus on Student Services for Veterans and
    on VA Benefits

        SAA approval activities:

          Ensure that veterans are taking courses consistent with
    occupational goals and program requirements.
          Ensure that schools and training programs have evaluated
    prior learning and work experience and grant credit as appropriate.
          Ensure that school or program officials know how to
    complete paperwork and comply with policies required by VA educational
    assistance through technical assistance.

        States, schools, and apprenticeship officials we spoke with
    reported that without SAAs, the quality of education for veterans would
    not change; however, their receipt of benefits could be delayed and the
    time required to complete their education and training programs could
    increase.

    SAAs Generally Conduct More Frequent On-Site Monitoring of Education
    and Training Programs Than Education and Labor

        Oversight of veterans assistance is generally more frequent than
    oversight by Education and Labor, which may prevent fraud, waste, and
    abuse.

          Some officials reported that SAAs' frequent visits were
    beneficial because they ensure schools properly certify veterans for
    benefits, ensuring that benefits are distributed accurately and
    quickly.
          Officials from one school reported that SAAs' visits were
    unnecessary because many schools are sufficiently monitored by their
    accreditors and Education.

    ----------------------------------------------------------------------------------------------------------------
                             Entity                                   Frequency of site visits to each school
    ----------------------------------------------------------------------------------------------------------------
    SAA                                                                                                   1-3 years
    ----------------------------------------------------------------------------------------------------------------
    VA's RPOs                                                                                               3 years
    ----------------------------------------------------------------------------------------------------------------
    Education                                                 Only schools that have performance issues are visited
                                                                                                                \1\
    ----------------------------------------------------------------------------------------------------------------
    Accrediting agencies                                                                             2-10 years \2\
    ----------------------------------------------------------------------------------------------------------------
    Labor                                                                                            1-3+ years \3\
    ----------------------------------------------------------------------------------------------------------------
    \1\ Education also performs ongoing monitoring by reviewing schools' annual compliance audits and financial
      statements.
    \2\ Accrediting agencies' frequencies vary depending on whether the agency is a national or regional agency.
    \3\ Labor--See Registered Apprenticeship Programs: Labor Can Better Use Data to Target Oversight, GAO-05-886
      (Washington D.C.: August 29, 2005).

    SAAs Approve a Small Number of Programs that Are Not Reviewed by Other
    Agencies

        SAAs approve a small number of programs that are not reviewed by
    other agencies:

          Programs, such as cosmetology and massage training,
    offered by unaccredited schools.
          On-the-job-training programs.
          Apprenticeship programs not approved by Labor.

    VA Uses Output Measures Rather Than Outcome Measures to Evaluate SAA
    Performance and Progress

        Although VA does have some output measures in place, such as the
    number of supervisory visits SAAs conduct, it does not have outcome-
    oriented performance measures to evaluate the overall effectiveness and
    progress of SAAs.

    ----------------------------------------------------------------------------------------------------------------
                  Examples of Existing VA Output Measures                  Examples of Potential Outcome Measures
    ----------------------------------------------------------------------------------------------------------------
    Percentage of visits to facilities for supervisory                      Amount of benefit adjustments resulting
      and inspection purposes completed within                            from SAA's review of school certification
      VA specified timeframes                                                                          transactions
    ----------------------------------------------------------------------------------------------------------------
    Number of times technical assistance provided                          Error rate of certification transactions
      to interested parties such as individuals and                                             identified by SAA's
      schools
    ----------------------------------------------------------------------------------------------------------------
    Output Measures: Number of approved                                           Completion rates of beneficiaries
      facilities with approved programs
    ----------------------------------------------------------------------------------------------------------------
    Source: GAO analysis.

    Conclusions:
          While VA spends $19 million (less than 1% of total
    benefit amount) to fund SAA duties and functions, it does not track the
    amount it spends on specific SAA activities, especially those that may
    be performed by other agencies. Without knowing the amount of resources
    spent on specific duties and functions, VA does not have all relevant
    information for making resource allocation decisions and cannot
    determine if it is spending its federal dollars efficiently and
    effectively.
          VA, Education, and Labor have various standards and
    processes in place, in part to ensure that federal funds are being
    spent on quality education and training programs. While we have
    identified some overlap in approval efforts across agencies, the full
    extent of the overlap between SAA duties and other agencies' oversight
    efforts is unknown. It is important that VA work with other federal
    agencies to determine how the scope of the approval process could be
    streamlined, such as to determine the extent to which SAAs could rely
    on recognized accreditors' assessments of institutions' policies on
    student achievement to reduce overlap and ensure that federal dollars
    are spent efficiently.

        It is difficult to assess the effectiveness of SAA activities, in
    part because VA does not have outcome measures in place to fully
    evaluate SAA performance, such as the outcomes of site visits. Under
    the Government Performance Results Act, federal agencies must report on
    their results in achieving their agency program goals. Outcome-oriented
    performance measures are should be used to assess program activity.
    Evaluating the effectiveness of VA's approval process is vitally
    important in order to manage the program and improve program results.
    Recommendations for Executive Action:
        To help ensure that federal dollars are spent efficiently and
    effectively, we are recommending that the Secretary of the Department
    of Veterans Affairs take steps to monitor its spending and identify
    whether any of its resources are spent on activities that duplicate the
    efforts of other agencies. The extent of these actions should be in
    proportion to the total resources of the program. Specifically:

          VA should require SAAs to track and report data on
    resources spent on approval activities such as site visits, catalog
    review, and outreach in a cost-efficient manner.
          VA should collaborate with other agencies to identify any
    duplicative efforts and use the agency's administrative and regulatory
    authority to streamline the approval process.

        In addition, we are recommending that the Secretary establish
    outcome--oriented performance measures to assess the effectiveness of
    SAA efforts.
                                   __________
         Appendix II:  Comments from the Department of Veterans Affairs

                               The Deputy Secretary of Veterans Affairs
                                                         Washington, DC
                                                      February 27, 2007

    Mr. George Scott
    Acting Director
    Education, Workforce, and Income Security Issues
    441 G Street, NW
    Washington, DC 20548

    Dear Mr. Scott:

        The Department of Veterans Affairs (VA) has reviewed the Government
    Accountability Office's (GAO) draft report, VA Student Financial Aid:
    Management Actions Needed to Reduce Overlap in Approving Education and
    Training Programs and to Assess State Approving Agencies (GAO-07-384).
    VA agrees with your findings and concurs with your recommendations. The
    enclosure details VA's actions to implement Government Accountability
    Office's recommendations.
        I appreciate the opportunity to comment on your draft report.

                Sincerely Yours,
                                                    Gordon H. Mansfield
    Enclosure
                      Department of Veterans Affairs (VA)
             Comments to the Government Accountability Office (GAO)
      Draft Report, VA Student Financial Aid: Management Actions Needed to
       Reduce Overlap in Approving Education and Training Programs and to
                        Assess State Approving Agencies
                                  (GAO-07-384)
            To ensure that federal dollars are spent efficiently and
            effectively, GAO recommends that the Secretary of the
            Department of Veterans Affairs take steps to monitor its
            spending and identify whether any of its resources are spent on
            activities that duplicate the efforts of other agencies. The
            extent of these actions should be in proportion to the total
            resources of the program. Specifically:

                VA should require SAAs to track and report data on
            resources spent on approval activities, such as site visits,
            catalog review, and outreach in a cost-efficient manner.

    Concur--VA will establish a working group with the SAAs to create a
    reporting system for approval activities with a goal of implementation
    in the FY08 budget cycle.

                VA should collaborate with other agencies to
            identify any duplicate efforts and use the agency's
            administrative and regulatory authority to streamline the
            approval process.

    Concur--VA will initiate contact with appropriate officials at the
    Department of Education and Labor to identify any duplicative efforts.
    However, amending the agency's administrative and regulatory authority
    to streamline the approval process may be difficult due to the specific
    approval requirements of the law.

                VA should establish outcome-oriented performance
            Measures to assess the effectiveness of SAA efforts.

    Concur--VA will establish a working group with the SAAs to develop
    outcome-oriented measures with a goal of implementation in the FY08
    budget cycle.
                                   __________
              Appendix III:  GAO Contact and Staff Acknowledgments

    GAO Contact: George A. Scott (202) 512-7215 or scottg@gao.gov.

    Staff Acknowledgments: In addition to the contact named above, Heather
    McCallum Hahn, Assistant Director, Tranchau T. Nguyen, Jacqueline
    Harpp, Cheri Harrington, Richard Burkard, Susannah Compton, John
    Mingus, and Jim Rebbe made key contributions to this report.

                       National Association of State Approving Agencies
                                                          Winthrop, ME.
                                                         April 27, 2007

    The Honorable John Boozman
    United States House of Representatives
    1519 Longworth House Office Building
    Washington, DC 20515

    Congressman Boozman:

        Thank you for the opportunity to discuss the functions of State
    Approving Agencies (SAAs) and other related issues. We appreciate your
    support of SAAs and look forward to working with you on the funding
    issue so that we can continue to provide the kind of service that our
    nation's veterans deserve.
        During the hearing on April 19th you asked us to provide further
    detail on the matrix that is located on page 20 of the recent GAO
    report. We are in the process of expanding the matrix and expect to be
    able to provide this information to you in a couple of weeks.
        We also would like to take this opportunity to supplement the
    response to the question that you posed during the hearing about the
    differences in approval activities. We provide this information because
    the issue of differences or overlap appears to be critical in the
    analysis of the value of State Approving Agencies to the success of the
    ``GI Bills.'' We respectfully request that this supplemental
    information be officially entered into the Congressional record of the
    proceedings connected to the hearing and therefore, have submitted the
    information as an enclosure to this letter. We are prepared to submit
    an electronic copy of the enclosure and meet any other requirements as
    well.
        Thank you again for your interest in and support of State Approving
    Agencies. Thank you also in advance for accepting and placing into the
    record the enclosed supplemental information in response to your
    question about differences in approval activities.

                Sincerely,
                                                      C. Donald Sweeney
                                                   Legislative Director
    C:
       Chairwoman Herseth Sandlin
       Congressman Donnelly
       Congressman Hall
       Selected Congressional Staff

                     SUPPLEMENTAL STATEMENT FOR THE RECORD
                  IN SUPPORT OF RESPONSE TO QUESTION ASKED BY
                            CONGRESSMAN JOHN BOOZMAN
            AT HEARING ON STATE APPROVING AGENCIES ON APRIL 19, 2007
                    PROVIDED BY JOAN RYAN AND DONALD SWEENEY
                NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES
                                 APRIL 27, 2007
     Question--Provide details of how State Approving Agencies differ from
                  other agencies performing similar functions.
    Preface--The following comments are limited to a comparison between the
    approval activities of State Approving Agencies (SAAs) for
    institutional programs and accreditation which is the primary component
    of the certification process used by the federal Department of
    Education for Title IV, Student Financial Aid. The comments are limited
    to this comparison because the majority of veterans using GI Bill
    benefits are enrolled in programs at accredited educational
    institutions and the differences between the work of State Approving
    Agencies and accrediting agencies appear to be the area of greatest
    misunderstanding. The comments are further limited to a comparison
    between regional accreditation and SAAs due to the fact that the vast
    majority of veterans are enrolled in programs that fall under this type
    of institutional accreditation.

        1.  SAAs are under contract with the VA and are state governmental
    entities.

           Regional accrediting agencies are voluntary, private sector
    organizations.

        2.  The SAA process is a quality control mechanism, protecting the
    veteran and taxpayer. SAAs have the authority to approve or disapprove
    within a reasonably short period of time.

           Accrediting agencies are a quality enhancement process. ``They
    cannot mandate compliance or control behavior except by persuasion and
    peer influence.'' ``The accreditation process is designed primarily to
    encourage and assist the institution to evaluate itself objectively and
    then for the accrediting body to validate what the institution has said
    about itself.''

        3.  SAAs review and reevaluate programs for compliance with
    approval criteria every year or two.

           Regional accrediting agencies re-evaluate institutions as a
    whole, not each specific program, generally once every 10 years for
    established institutions with a 5-year interim report submitted by the
    institution to the accrediting agency.

        4.  Although not a perfect analogy and without consideration to the
    frequency of re-evaluations for established institutions (2 years
    versus 10), the two processes could be compared to a real estate
    salesperson who lives a few towns away from the location of the home
    that they are selling and the home inspector that lives in the town
    where the home is located.

           The salesperson's responsibilities are to describe the home as
    reported by the homeowner and to conduct a review to ensure that the
    statements made by the homeowner appear to be factual. The home is a 22
    year old, two story modified cape with one and a half baths, three
    bedrooms, wood siding, asphalt shingled roof, baseboard hot water heat,
    100 amp electrical service, 200 foot drilled well, on site septic
    system with leaching field and a two car garage. The home is located on
    one and half acres and was recently painted inside and out. It is
    aesthetically appealing.

           The home inspector will be able to determine that the life
    expectancy of the boiler is twenty-five years and that since the home
    is located in a cold climate, has 2 by 4 studs and blown in insulation,
    the boiler is probably due for replacement. The inspector can also
    determine that carpenter ants have eaten away the sills on one side of
    the home which will need to be replaced along with one floor joist,
    some sheathing and siding. Although recently painted, some of the lower
    wood siding on another side of the home has sustained water damage and
    should be replaced before further damage occurs. Although the owner has
    said that there has never been any water in the basement, the inspector
    sees lime stains on the basement walls approximately 3 inches from the
    floor which could indication some seepage from the high water table in
    the area and the potential for water damage later, the installation of
    a sub pump is advisable. When inspecting the roof from the attic, the
    inspector sees water stains on one of the roof rafters and leakage
    around the chimney that has led to some damage to the sheetrock sealing
    over one of the bedrooms that is currently not visible from the inside
    of the room. This leakage has the potential to cause greater damage if
    not repaired soon. The inspector finds that the septic tank has not
    been pumped for almost 10 years which means that the leaching field may
    have sustained some damage so a qualified technician should be
    consulted, especially since the area has a high water table throughout
    the entire year.

           We could go on, but hopefully the comparison is helpful to a
    better understanding the differences between the evaluative activities
    of SAAs and accreditation which is the heart of the DOE process.

    In conclusion, we disagree with the GAO statements that many programs
    approved by SAAs are already approved by the Department of Education
    and the statement that SAAs approve a small number of programs that are
    not reviewed by other agencies. From these erroneous conclusions, the
    GAO then implies that there is significant overlap in the approval
    functions. We disagree.

    Even if one assumes that there is considerable overlap between the SAA
    approval process and regional accreditation (which there is not), this
    overlap will occur every 10 years. The institution submits an interim
    report to the accrediting agency at the five-year point, but unless the
    agency sees a problem in the report--there is no further review or
    investigation--the report is filed. Beyond the fact that a 10-year
    cycle does not provide adequate opportunity for the VA or SAAs to
    ensure that the requirements of Title 38 are being met, is this really
    the kind of service that we want to give to our veterans? Who will
    respond to veterans' requests for detailed information on approved
    programs and requests to evaluate new programs of education and
    training? Who will work with school officials to ensure that veterans
    receive credit for prior learning and advanced standing at the
    institution and are meeting the requirements of Title 38 for proper
    payment of benefits? Who will provide training to school officials on
    VA certification procedures and other relevant matters? These are just
    a few of the questions that are pertinent to the work of SAAs with
    educational institutions.