VA Student Financial Aid: Opportunity to Reduce Overlap in Approving
Education and Training Programs (Letter Report, 10/30/95,
GAO/HEHS-96-22).

Pursuant to a congressional request, GAO determined the extent to which
state approving agencies (SAA) assessment activities overlap the efforts
of other agencies.

GAO found that: (1) $10.5 million of the $12 million paid to SAA in 1994
was spent to conduct assessments already performed by the Department of
Education; (2) these assessments involved reviews of accredited academic
and vocational schools; (3) the remaining SAA assessment activities did
not overlap the activities of other agencies, since they involved
on-the-job training programs and unaccredited schools; and (4) although
SAA use evaluation standards that differ from those of other reviewing
agencies, SAA activity should be reduced to schools and programs not
subject to Department of Education approval.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  HEHS-96-22
     TITLE:  VA Student Financial Aid: Opportunity to Reduce Overlap in 
             Approving Education and Training Programs
      DATE:  10/30/95
   SUBJECT:  Employment or training programs
             Institution accreditation
             Veterans education
             Student loans
             State governments
             Education program evaluation
             Evaluation methods
             Vocational education
             Veterans benefits
IDENTIFIER:  Federal Family Education Loan Program
             Dept. of Education Perkins Student Loan Program
             Pell Grant
             Supplemental Educational Opportunity Grant
             College Work-Study Program
             State Student Incentive Grant
             National Direct Student Loan Program
             
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Cover
================================================================ COVER


Report to the Committee on Veterans' Affairs, U.S.  Senate

October 1995

VA STUDENT FINANCIAL AID -
OPPORTUNITY TO REDUCE OVERLAP IN
APPROVING EDUCATION AND TRAINING
PROGRAMS

GAO/HEHS-96-22

VA's Approval of Schools

(104802)


Abbreviations
=============================================================== ABBREV

  OJT - on-the-job training
  SAA - state approving agency
  SPRE - state postsecondary review entity
  VA - Department of Veterans Affairs

Letter
=============================================================== LETTER


B-259871

October 30, 1995

The Honorable Alan K.  Simpson
Chairman
The Honorable John D.  Rockefeller IV
Ranking Minority Member
Committee on Veterans' Affairs
United States Senate

Since the 1940s, the Department of Veterans Affairs (VA) and its
predecessor agencies have contracted with 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.\1 SAAs perform this "gatekeeping" or
approval function through such activities as evaluating course
quality, school financial stability, and student progress.  In fiscal
year 1994, VA paid more than $1 billion in education assistance
benefits to more than 450,000 beneficiaries and spent about $12
million for SAA gatekeeping services. 

Other federal agencies--particularly the Department of Education and
the Department of Labor--also assess schools and programs for various
purposes, such as student loans, apprenticeship assistance, and other
forms of federal support.  Concerned about potential duplication of
effort, you asked us to determine the extent to which SAA assessment
activities overlap the efforts of other agencies. 

We focused our analysis on SAA activities during fiscal year 1994. 
We specifically looked at the degree to which schools or programs
with SAA-approved courses of study were also reviewed as a part of
Education's or Labor's gatekeeping systems.  We analyzed and compared
the gatekeeping activities of the three agencies, especially the
standards used in evaluating the schools and programs.  Much of our
information on SAA activities was supplied by VA regional offices
through the VA central office.  Appendix I contains a more complete
discussion of our scope and methodology.  We conducted our review
from October 1994 through August 1995 in accordance with generally
accepted government auditing standards. 


--------------------
\1 The pertinent federal law--title 38--authorized state governments
to create or designate SAAs (38 U.S.C.  3671(a)).  Although funded by
federal money and responsible for enforcing federal law, SAAs are
usually part of a state's department of education.  In some states,
SAAs are organizationally located in other departments, such as labor
or veterans' services. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

We estimate that $10.5 million of the $12 million paid to SAAs in
1994 was spent to conduct assessments that overlapped those of the
Department of Education.  These assessments involved reviews of
academic and vocational schools that were already accredited by
Education-approved agencies.\2 SAA efforts costing another $400,000
in 1994 may have overlapped assessments of apprenticeship programs
done by Labor, though the data were not available to determine if
overlap was indeed occurring.  The remaining SAA assessment
activity--costing about $1.1 million--did not overlap activities of
other agencies because it involved on-the-job training (OJT) programs
and unaccredited schools, neither of which Education or Labor
assessed. 

The continued use of SAAs to conduct assessments that overlap other
assessments does not appear to be a useful investment of scarce
federal dollars.  The overlap may not amount to out-and-out
duplication, because SAAs use standards and methods that may differ
somewhat from those of other reviewing bodies.  However, a comparison
of VA's key standards with those used by Education's gatekeepers
shows that the standards are similar.  Given this similarity, and the
significant amount of SAA work (about 87 percent) that overlapped
Education assessments, reducing SAA activity to apply only to those
schools and programs not subject to Education gatekeeping appears
advisable. 


--------------------
\2 Accreditation is the process by which an accrediting agency,
approved by Education, recognizes that an educational institution or
program meets the agency's established standards and requirements. 


   HOW DO VA, EDUCATION, AND LABOR
   PERFORM GATEKEEPING? 
------------------------------------------------------------ Letter :2

In general, the term "gatekeeping" refers to the responsibilities and
activities that entities--VA, Education, and Labor--undertake to
determine whether postsecondary educational and training programs and
institutions meet federal requirements.  Although the standards,
procedures, and methods used by the entities may differ, the
overriding purpose of gatekeeping remains the same regardless of the
programs or agencies involved.  To assess the overlap that occurs, it
is important to first understand each of the three agencies'
particular gatekeeping approaches. 


      VA'S GATEKEEPING
---------------------------------------------------------- Letter :2.1

VA administers a number of programs designed to assist individuals in
gaining access to postsecondary education or training for a specific
occupation.  VA generally provides its assistance in the form of
payments to veterans, service persons, reservists, and certain
spouses and dependents.  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
gatekeeping work.  In all, 61 SAAs existed in the 50 states, the
District of Columbia, and Puerto Rico during 1994.\3

SAAs are responsible both for determining which courses should be
approved and for ensuring that schools are complying with the
schools' established standards relating to the course or courses that
have been approved.  According to a VA official, SAAs are generally
expected to make an annual supervisory visit to each school with
enrolled education beneficiaries.  In fiscal year 1994, about 95
percent of SAA staff performed these primary functions for academic
and vocational schools, with the remaining 5 percent covering
apprenticeship and other OJT training programs.\4

Contract costs paid to each SAA by VA primarily represent
reimbursements to the state for salaries and travel and an allowance
for administrative expenses.  For budgetary purposes, costs are
allocated using formula-driven guidelines and are largely dependent
on such factors as projected school or training program work loads,
state employee salary schedules, and the distances SAA officials must
travel to inspect or supervise schools or training programs. 

SAA contracts have been the focus of cost-cutting activity in recent
years.  VA officials said that before fiscal year 1988, VA was
spending about $17 to $18 million annually for SAA contracts. 
Starting in fiscal year 1988, the Congress set an annual funding cap
of $12 million.  For fiscal year 1994, the 61 SAAs requested VA
funding totaling $14.4 million but received $12 million.  These
requests were to support a total of 164 professional staff in SAAs
whose staffing ranged from 12.3 positions to less than 0.5 position. 
For fiscal year 1995, the Congress increased the cap to $13 million. 


--------------------
\3 Nine states--California, Hawaii, Indiana, Minnesota, New Jersey,
North Carolina, Oregon, Washington, and Wisconsin--had two SAAs. 

\4 The four principal types of training--academic, vocational,
apprenticeship, and other on-the-job training--allowed under VA
educational programs are defined in appendix II.  Appendix II also
contains additional information on VA's educational assistance
programs. 


      EDUCATION'S GATEKEEPING
---------------------------------------------------------- Letter :2.2

Most of the aid associated with Education's programs is provided in
the form of grants and guaranteed student loans under title IV of the
Higher Education Act of 1965, as amended.\5 In fiscal year 1994,
postsecondary student aid administered by Education totaled more than
$32 billion, with more than 6.6 million students receiving some form
of assistance. 

Education's approach involves activities conducted by a gatekeeping
"triad" composed of accrediting agencies, state licensing agencies,
and Education itself.  In order for students attending a school to
receive title IV financial aid, the school must be (1) accredited by
an entity recognized for that purpose by the Secretary of Education,
(2) licensed or otherwise legally authorized to provide postsecondary
education in the state in which it is located, and (3) certified to
participate in federal student aid programs by Education. 

Each part of the gatekeeping triad has its own responsibilities. 
Although specific responsibilities differ, parts of the triad may be
evaluating similar areas, such as aspects of a school's curriculum,
students' progress, or the school's financial capability to
participate in title IV programs.\6

  Accreditation is an essential step in Education's gatekeeping
     process, in that unaccredited schools or programs are ineligible
     to participate in title IV programs.  The process of
     accreditation is a nongovernmental peer evaluation that is
     performed by more than 90 accrediting associations of regional
     or national scope.  Each accrediting body applies a relevant set
     of standards to the institution, department, or program under
     review.  Those that meet the standards become accredited. 

  To participate in title IV programs, each educational institution
     must also have legal authority to operate in the state in which
     it is located.  At the state level, licensing or other approval
     is conducted by a state agency.  Each of the states has its own
     agency structure, and each state can choose its own set of
     standards. 

  Education's own responsibilities include determining the
     administrative and financial capacity of schools to participate
     in title IV programs and monitoring the performance of
     accrediting and licensing bodies.  In all, more than 7,500
     postsecondary institutions were certified to participate in
     title IV student aid programs by Education in 1994. 


--------------------
\5 Title IV programs include Federal Family Education Loans, Federal
Perkins Loans, Federal Direct Student Loans, Pell Grants,
Supplemental Educational Opportunity Grants, College Work-Study, and
State Student Incentive Grants. 

\6 See appendix III for additional information on each part of the
triad. 


      LABOR'S GATEKEEPING
---------------------------------------------------------- Letter :2.3

Apprenticeship programs are a focus of Labor's gatekeeping
activities.  Under the National Apprenticeship Act of 1937, Labor
establishes and promotes labor standards to safeguard the welfare of
apprentices.  Eligibility for various federal programs, including VA
education assistance to veterans attending apprenticeship programs,
is conditioned upon conformance to these standards.  The standards
require, for example, that an apprenticeship program (1) provide for
periodic review and evaluation of the apprentice's progress in job
performance and related instruction and (2) prepare appropriate
progress records documenting such reviews. 

Labor's Bureau of Apprenticeship and Training determines whether a
program conforms to Labor's standards.  If the program is found to be
in conformance, it can be "registered," either by Labor or by a state
apprenticeship agency or council that Labor has recognized. 


   TO WHAT EXTENT DID SAA
   GATEKEEPING OVERLAP OTHER
   EFFORTS? 
------------------------------------------------------------ Letter :3

After examining gatekeepers' activities, comparing their assessment
standards, and conducting other analyses, we determined that most SAA
activity overlapped work done by others.  More specifically, an
estimated 87 percent of SAA staff time, costing about $10.5 million
of the $12 million spent by VA in fiscal year 1994, was spent
reviewing and approving courses at academic and vocational schools
that were also accredited by Education-approved agencies (see fig. 
1).  An estimated 3 percent of SAA staff time, costing about
$400,000, was spent assessing apprenticeships, but we could not
readily determine whether this activity overlapped Labor's efforts. 
The remaining portion of SAA staff time, costing about $1.1 million,
was spent on gatekeeping functions that did not overlap the efforts
of other entities. 

   Figure 1:  Estimated Overlap of
   SAA Efforts With Other
   Gatekeepers' Work, Fiscal Year
   1994

   (See figure in printed
   edition.)


      MOST SAA ACTIVITY OVERLAPPED
      EDUCATION'S GATEKEEPING
---------------------------------------------------------- Letter :3.1

Most SAA activity occurred at academic and vocational schools that
had been accredited by nationally recognized accrediting
agencies--part of the activity of Education's gatekeeping triad.  In
fiscal year 1994, SAAs reviewed and approved 6,294 academic and
vocational schools that had been accredited by accrediting agencies. 

These schools were also potentially subject to the two other parts of
Education's gatekeeping triad.  We examined how likely it was that
these schools had also been certified by Education itself.\7 We
selected a judgmental sample of five states (Mississippi, Vermont,
Washington, West Virginia, and Wyoming) and the District of Columbia. 
For these six jurisdictions, we obtained (1) a list from VA of 273
SAA-approved vocational and academic schools that had also been
accredited and (2) a list from Education of all schools that were
Education-certified.  In all, 255 (93 percent) of the schools on the
VA list were also Education-certified. 

While SAA reviews may differ somewhat from those conducted by
Education gatekeepers, SAAs and Education use similar standards for
approving education and training programs.  Both VA and Education
base their standards for approving or certifying schools and courses
on federal laws and regulations.  We identified 15 key standards in
the law and regulations that academic and vocational schools must
meet to be approved by SAAs (see app.  IV).  We compared these key
standards with those used by accrediting bodies, states, and
Education and found them to be similar (see app.  V).  Examples
follow. 

  A school seeking SAA approval must have a policy that gives
     veterans appropriate credit for previous education and training. 
     Of the seven accrediting agencies whose standards we reviewed,
     five required schools to have such a policy, and the policies
     were similar. 

  Schools seeking SAA approval must also demonstrate that they have
     sufficient financial resources to ensure their proper operation
     and to fulfill their commitment to provide quality education for
     their students.  Both Education and accreditation agencies had
     similar requirements concerning financial resources. 


--------------------
\7 Each of the 50 states has its own agency structures and standards,
and we did not attempt to test the degree to which schools had been
reviewed by them (see app.  III). 


      SAA OVERLAP OF LABOR'S
      GATEKEEPING EFFORTS IS
      UNKNOWN
---------------------------------------------------------- Letter :3.2

The possibility exists that SAA reviews of apprenticeship programs
also overlap Labor's gatekeeping efforts.  The law requires SAA
approval of an apprenticeship if a student in the program is to
receive VA educational assistance.  Before approving such a program,
an SAA must determine that the training establishment and its
apprentice courses are in conformance with Labor's standards of
apprenticeship.  However, VA regulations do not require that an
SAA-approved apprenticeship program be registered by Labor. 

While the potential for overlap exists, we were unable to determine
if it actually occurred because data were not available to determine
whether SAA-approved programs were also registered by Labor. 


      SOME SAA GATEKEEPING EFFORTS
      DID NOT OVERLAP
---------------------------------------------------------- Letter :3.3

About 9 percent of SAAs' staff effort did not overlap other
gatekeeping efforts.  This portion of SAA activity fell into two
categories:  approval of unaccredited schools and programs, and
approval of OJT programs other than apprenticeships. 

Unaccredited institutions.  Under the law, SAAs may approve courses
of study at unaccredited institutions, thereby making veterans
eligible to receive assistance for attending.  By contrast,
Education's regulations generally require schools to be accredited
before they are certified, thereby making students eligible for title
IV programs.  As of September 30, 1994, SAAs had approved courses of
study for veterans at 534 unaccredited academic and vocational
schools.  The SAA staff that reviewed and approved these
schools--about 7 percent of SAA staff--did not duplicate Education's
efforts. 

Other OJT programs.  SAAs also review and approve other OJT programs
that do not qualify as apprenticeship programs and that are not
subject to review and registration by Labor.  SAAs' efforts to assess
other OJT programs thus did not overlap Labor's gatekeeping efforts. 
We estimate that for fiscal year 1994, these approvals took about 2
percent of SAA staff time. 


   CONCLUSIONS
------------------------------------------------------------ Letter :4

The substantial amount of overlap that occurred between SAA and other
gatekeepers' efforts raises questions about whether SAA efforts
should continue at their current level.  We estimated that 87 percent
of the approval effort expended by SAAs related to schools and
programs also subject to accreditation by Education-approved
entities.  Also, in our review of six jurisdictions, 93 percent of
the accredited schools were also certified by Education to
participate in title IV student aid programs.  School certification
involves applying standards that are similar to those used by SAAs. 
On its face, an SAA review of courses of study at an
Education-certified school would appear to add only marginal value. 
The same may be true for SAA reviews of apprenticeship programs,
though the lack of information precludes us from determining if
overlap exists with Labor's oversight. 

We believe an opportunity exists for reducing federal expenditures by
over $10 million annually through the elimination of overlapping SAA
gatekeeping efforts.  VA and SAA efforts would be better focused on
such activities as reviewing courses offered by unaccredited schools,
for which no other form of federal oversight currently exists. 


   MATTERS FOR CONGRESSIONAL
   CONSIDERATION
------------------------------------------------------------ Letter :5

The Congress may wish to consider whether it is necessary for VA to
continue contracting with SAAs to review and approve educational
programs at schools that have already been reviewed and certified by
Education. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :6

We requested comments on a draft of this report from the Secretaries
of Education and Veterans Affairs.  Education provided several
clarifying and technical suggestions, which we incorporated where
appropriate. 

In general, VA said that it has reservations about relying upon
Education's gatekeeping system to ensure the integrity and quality of
education and training programs made available to VA education
program beneficiaries.  VA's two principal comments were that

  the draft report did not elaborate on the specific mechanisms or
     organizational elements within Education that are in place to
     ensure that the requirements of title 38 of the U.S.  Code are
     met and

  it is questionable whether accreditation, in the absence of funding
     for the state postsecondary review entities (SPRE)\8 program,
     will accomplish the approval, monitoring, and supervisory
     requirements of the laws governing VA education programs. 

In the report, we do discuss Education's gatekeeping triad composed
of accrediting agencies, state licensing agencies, and Education
itself, which performs the same basic function as SAAs for many of
the same schools.  Under title 38, the essential responsibility of
SAAs is to determine which courses should be approved and to ensure
that schools are complying with their established standards relating
to the courses that have been approved before an individual entitled
to VA education assistance can obtain money for an education or
training program.  Education's gatekeeping triad does similar work: 
assessing whether schools and training programs offer education of
sufficient quality for students to receive federal financial
assistance under title IV of the Higher Education Act, as amended. 

In fiscal year 1994, the Department of Education provided more than
$32 billion in financial aid to 6.6 million students.  The SPRE
program has never been fully operational, and only nine states' SPREs
had been approved by Education as of September 30, 1995.  Thus, the
elimination of SPRE funding should have little impact on the
operation of the gatekeeping triad.  In addition, before the SPRE
program was initiated, the majority of education and training
programs approved by SAAs were offered by schools that were also
accredited and certified by Education's gatekeeping system.  And, as
illustrated in this report, we found that both VA and Education
gatekeepers apply similar standards in determining educational
program acceptability at the same schools. 

VA also said that the role states and SAAs perform in approving
education and training programs should continue and that it believes
that such a function should not be centralized at the federal level. 
However, as noted in our report, just as the SAA functions are not
totally centralized at the federal level, neither are the gatekeeping
efforts of Education's triad, which relies on the nonfederal work of
accrediting entities and state licensing bodies to perform an
important portion of the school approval work. 

The full text of VA's comments appears in appendix VI of this report. 


--------------------
\8 State-created SPREs were authorized by the Higher Education
Amendments of 1992 to help ensure the quality of education, financial
responsibility, and administrative capability of postsecondary
institutions participating in title IV programs.  SPREs support the
state's review of problem schools that are referred to the state by
Education.  However, federal funding for SPREs was rescinded by P.L. 
104-19. 


---------------------------------------------------------- Letter :6.1

Copies of this report are being sent to the Chairman and Ranking
Minority Member, House Committee on Veterans' Affairs; the
Secretaries of Veterans Affairs, Education, and Labor; appropriate
congressional committees; and other interested parties. 

Please call me at (202) 512-7014 if you or your staff have any
questions regarding this report.  Major contributors include Joseph
J.  Eglin, Jr., Assistant Director; Charles M.  Novak; Daniel C. 
Jacobsen; and Robert B.  Miller. 

Cornelia M.  Blanchette
Associate Director, Education
 and Employment Issues


SCOPE AND METHODOLOGY
=========================================================== Appendix I

To determine the functions of SAAs, we reviewed various VA and SAA
documents, including regulations, policies, procedures, contracts,
budget submissions, training manuals, and congressional testimony. 
We also held discussions with VA, SAA, and National Association of
State Approving Agencies officials.  On the basis of these efforts
and additional discussions with officials from Education and Labor,
we confirmed that the work of Education and Labor gatekeepers would
be most appropriate to compare with SAA gatekeeping work. 

As an indicator of overlapping or duplicative functions, we analyzed
SAAs' gatekeeping activities for fiscal year 1994 to determine the
extent that schools with SAA-approved courses of study were also
reviewed as part of Education's gatekeeping system.  Since much of
the SAA data we needed for analysis were not centrally available from
VA, the VA central office gathered the information we requested from
its regional offices and provided it to us.  We did not verify the
accuracy of this information. 

VA was unable to readily provide a listing of SAA-approved
apprenticeship programs or to determine whether such approved
programs were also registered by Labor.  Therefore, we had no basis
on which to determine the existence or the extent of overlapping
functions between SAAs and Labor for apprenticeship programs. 

As an indicator of the similarities between Education and VA
gatekeeping work, we identified, from the law and VA regulations, key
standards used by SAAs in reviewing schools and educational courses
and compared them with standards used by Education in evaluating
schools for participation in title IV programs.\9 The focus of our
review was overlapping and duplicative functions between SAAs and
other entities; we were not asked to analyze the effectiveness of
these functions. 


--------------------
\9 See appendix IV for a listing of key VA standards.  See appendix V
for standards used by the Education gatekeeping triad. 


VA POSTSECONDARY EDUCATIONAL
ASSISTANCE PROGRAMS
========================================================== Appendix II

SAAs administer VA's largest education benefits programs:  the
Montgomery G.I.  Bill, the Post-Vietnam Era Veterans' Educational
Assistance, and the Survivors' and Dependents' Educational Assistance
programs.  In fiscal year 1994, these programs served 453,973
trainees at an estimated cost of about $1 billion (see table II.1),
an average of $2,223 per trainee.  The Montgomery G.I.  Bill, which
covers veterans, military personnel, and selected reservists, is the
largest program and accounts for over 85 percent of the total funds
expended. 



                         Table II.1
          
            Trainees Participating in, and Funds
              Expended for, VA's Three Primary
          Educational Assistance Programs, Fiscal
                         Year 1994

                                       Funds
                     Number of  expended (in    Percent of
Program               trainees    thousands)   total funds
----------------  ------------  ------------  ------------
Montgomery G.I.        387,907     $ 858,908          85.1
 Bill
Post-Vietnam Era        25,806        48,114           4.8
 Veterans'
 Educational
 Assistance
Survivors' and          40,260       102,384          10.1
 Dependents'
 Educational
 Assistance
==========================================================
Total                  453,973    $1,009,406         100.0
----------------------------------------------------------
VA categorizes the types of training allowed under its educational
programs as

  academic--degree and certain professional programs at institutions
     of higher learning;

  vocational--noncollege degree, vocational, or technical diploma or
     certificate programs;

  apprenticeship--OJT typically requiring a minimum of 2,000 hours'
     work experience supplemented by related classroom instruction,
     leading to journeyman status in a skilled trade; and

  other OJT--typically requiring supervised job instruction for a
     period of not less than 6 months and not more than 2 years,
     leading to a particular occupation. 

During fiscal year 1994, over 91 percent of VA education
beneficiaries received academic training at institutions of higher
learning (see fig.  II.1). 

   Figure II.1:  Percent of VA
   Education Beneficiaries by Type
   of Training, Fiscal Year 1994

   (See figure in printed
   edition.)


EDUCATION'S GATEKEEPING TRIAD
========================================================= Appendix III