[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
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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
[email protected]. 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 [email protected].
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.