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United States Government Accountability Office: 
GAO: 

Report to the Chairman, Subcommittee on Federal Financial Management, 
Government Information, Federal Services, and International Security, 
Committee on Homeland Security and Governmental Affairs, United States 
Senate: 

March 2011: 

DOD Education Benefits: 

Increased Oversight of Tuition Assistance Program Is Needed: 

GAO-11-300: 

GAO Highlights: 

Highlights of GAO-11-300, a report to the Chairman, Subcommittee on 
Federal Financial Management, Government Information, Federal 
Services, and International Security, Committee on Homeland Security 
and Governmental Affairs, United States Senate. 

Why GAO Did This Study: 

In fiscal year 2009, the Department of Defense’s (DOD) Military 
Tuition Assistance (TA) Program provided $517 million in tuition 
assistance to approximately 377,000 service members. GAO was asked to 
report on (1) DOD’s oversight of schools receiving TA funds, and (2) 
the extent to which DOD coordinates with accrediting agencies and the 
U.S. Department of Education (Education) in its oversight activities. 
GAO conducted site visits to selected military education centers and 
interviewed officials from DOD, its contractors, Education, 
accrediting agencies and their association, and postsecondary 
institutions. 

What GAO Found: 

DOD is taking steps to enhance its oversight of schools receiving TA 
funds, but areas for improvement remain. Specifically, DOD could 
benefit from a systematic risk-based oversight approach, increased 
accountability in its education quality review process, and a 
centralized system to track complaints. DOD does not systematically 
target its oversight efforts based on factors that may indicate an 
increased risk for problems, such as complaints against schools or the 
number of service members enrolled at a school. Instead, DOD’s 
oversight policies and procedures vary by a school’s level of program 
participation, and schools that operate on base are subject to the 
highest level of oversight. DOD plans to implement more uniform 
oversight policies and procedures, but they are not expected to take 
effect until 2012. In addition, the process DOD used to review the 
academic courses and services provided by schools and military 
education centers was narrow in scope and lacked accountability. The 
review was limited to schools offering traditional classroom 
instruction at installations and did not include distance education 
courses, which account for 71 percent of courses taken in fiscal year 
2009. The contract for these quality reviews expired on December 31, 
2010, and DOD plans to resume its reviews on October 1, 2011, when a 
new contractor is selected. DOD is developing an expanded quality 
review process and plans to select schools based, in part, on the 
amount of TA funds received. With regard to accountability, DOD’s 
review process provided recommendations that could improve educational 
programming, but there is no DOD-wide process to ensure that these 
recommendations have been addressed. Furthermore, DOD lacks a system 
to track complaints about schools and their outcomes. As a result, it 
may be difficult for DOD and its services to accurately identify and 
address any servicewide problems and trends. 

DOD’s limited coordination with accreditors and Education may hinder 
its oversight efforts. DOD verifies whether a school is accredited; 
however, it does not gather some key information from accreditors when 
conducting its oversight activities, such as whether schools are in 
jeopardy of losing their accreditation. Accreditors can place schools 
on warning or probation status for issues such as providing inaccurate 
information to the public and poor institutional governance. Schools 
can experience various problems within the 3- to 10-year accreditation 
renewal period, and these problems can negatively affect students, 
including service members. Additionally, DOD does not require schools 
to have new programs and other changes approved by accrediting 
agencies in order to receive TA funds. Currently, students enrolled in 
unapproved programs or locations are ineligible to receive federal 
student aid from Education, but can receive TA funds. DOD’s 
coordination with Education has generally been limited to 
accreditation issues and Education’s online resources about schools 
and financial aid. DOD does not utilize information from Education’s 
school-monitoring activities to inform its oversight efforts. Education’
s findings from program reviews and financial audits of schools 
provide insights about schools’ financial condition, level of 
compliance, and governance. Collectively, this information could 
provide DOD with information that can be used to better target schools 
for review or inform other oversight decisions. 

What GAO Recommends: 

GAO recommends that DOD (1) improve accountability for recommendations 
made by third-party quality reviews, (2) develop a centralized process 
to track complaints against schools, (3) conduct a systemic review of 
its oversight processes, (4) take actions to ensure TA funds are used 
only for accreditor-approved courses and programs, and (5) require and 
verify state authorization for all schools. DOD agreed with our 
recommendations. Also, DOD and Education provided technical comments 
on the draft report. We incorporated each agency’s comments as 
appropriate. 

View [hyperlink, http://www.gao.gov/products/GAO-11-300] or key 
components. For more information, contact George Scott at (202) 512-
7215 or scottg@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

DOD Takes Steps to Enhance Its Oversight of Schools Receiving TA 
Program Funds, but Areas for Improvement Remain: 

DOD's Limited Coordination with Accreditors and Education May Hinder 
Its Efforts: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Selected Postsecondary Institutions GAO Interviewed at 
Selected Education Centers: 

Appendix III: Comments from the Department of Defense: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Education's Monitoring of Schools Participating in the Title 
IV Program: 

Figures: 

Figure 1: Military Tuition Assistance Expenditures: 

Figure 2: DOD Participation Requirements by School Level of Program 
Involvement: 

Abbreviations: 

AASCU: American Association of State Colleges and Universities: 

ACE: American Council on Education: 

CCAF: Community College of the Air Force: 

DOD: Department of Defense: 

ESO: education services officer: 

GPA: grade point average: 

HEA: Higher Education Act of 1965, as amended: 

ICE: Interactive Customer Evaluation: 

MIVER: Military Installation Voluntary Education Review: 

MOU: memorandum of understanding: 

MVER: Military Voluntary Education Review: 

SOC: Servicemembers Opportunity Colleges: 

TA: Tuition Assistance: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 1, 2011: 

The Honorable Tom Carper: 
Chairman: 
Subcommittee on Federal Financial Management, Government Information, 
Federal Services, and International Security: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Dear Chairman Carper: 

In fiscal year 2009, the Department of Defense's (DOD) Military 
Tuition Assistance (TA) Program provided $517 million in tuition 
assistance to approximately 377,000 service members who elected to 
pursue off-duty[Footnote 1] postsecondary education.[Footnote 2] DOD 
offers these benefits to service members in order to help them fulfill 
their academic goals and enhance their professional development. In 
order to participate in the program, DOD requires that postsecondary 
institutions must be accredited by an accrediting agency recognized by 
the U.S. Department of Education (Education). These institutions have 
played an important role in providing traditional classroom 
instruction to service members on military installations, but the 
majority of courses service members are taking are distance education 
courses.[Footnote 3] This report examines (1) the Department of 
Defense's process for overseeing postsecondary institutions that 
receive tuition assistance funds, and (2) the extent to which DOD 
coordinates with accrediting agencies and Education in its oversight 
of institutions participating in the tuition assistance program. 

To address these objectives, we reviewed and analyzed relevant federal 
laws, regulations, and program documents and data, including program 
participation and expenditure data from DOD and its military services 
(Army, Air Force, Marine Corps, and Navy). We analyzed available data 
from the military services on service member complaints regarding 
schools receiving tuition assistance funds. We also interviewed 
officials from DOD, its military services, and contractors--- 
Servicemembers Opportunity Colleges (SOC) and the American Council on 
Education. We conducted site visits to education centers located at 
military installations of the four services to gain a better 
understanding of how the program is implemented. We interviewed 
Education officials to determine the extent to which they coordinate 
with DOD as part of DOD's efforts to oversee its TA program. We also 
reviewed Education's monitoring and compliance data. Finally, we 
interviewed representatives from an association of colleges and 
universities and selected accrediting agencies in order to obtain 
information about the extent to which they coordinate and provide 
information to DOD and its military services for monitoring schools. 

We conducted this performance audit from August 2010 to February 2011 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. See appendix I 
for more detailed information about our scope and methodology. 

Background: 

DOD has voluntary education programs in place to facilitate 
educational opportunities for service members to pursue postsecondary 
education during off-duty time.[Footnote 4] Program oversight for 
voluntary education programs is the responsibility of the 
Undersecretary of Defense for Personnel and Readiness.[Footnote 5] In 
addition, the military services are responsible for establishing, 
maintaining, operating, and implementing the programs at 350 education 
centers on military installations worldwide.[Footnote 6] Education 
centers are managed by an education services officer (ESO) and staff, 
such as education guidance counselors. 

Service members must meet certain requirements in order to participate 
in the program. These requirements include consulting with a counselor 
in order to develop an education goal and degree plan, maintaining a 
2.0 grade point average (GPA) for undergraduate-level courses, and 
maintaining a 3.0 GPA for graduate-level courses. In accordance with 
DOD policy, tuition assistance covers up to $250 per credit hour, with 
a maximum of $4,500 per year.[Footnote 7] In fiscal year 2009, the 
military services' TA program expenditures were $517 million, as shown 
in figure 1. 

Figure 1: Military Tuition Assistance Expenditures: 

[Refer to PDF for image: stacked line graph] 

Fiscal year: 2000; 
Air Force: $56.2 million; 
Army: $48.5 million; 
Navy: $35.8v; 
Marine Corps: $16.7 million; 
Total: $157 million. 

Fiscal year: 2001; 
Air Force: $64.1 million; 
Army: $72.9 million; 
Navy: $38 million; 
Marine Corps: $17.4 million; 
Total: $192 million. 

Fiscal year: 2002; 
Air Force: $67.2 million; 
Army: $114.9 million; 
Navy: $42.6 million; 
Marine Corps: $18.5 million; 
Total: $243 million. 

Fiscal year: 2003; 
Air Force: $122.9 million; 
Army: $152.1 million; 
Navy: $60.7 million; 
Marine Corps: $35.1 million; 
Total: $371 million. 

Fiscal year: 2004; 
Air Force: $140.6 million; 
Army: $217.4 million; 
Navy: $71.3 million; 
Marine Corps: $37.7 million; 
Total: $467 million. 

Fiscal year: 2005; 
Air Force: $139.4 million; 
Army: $211.8 million; 
Navy: $72.6 million; 
Marine Corps: $37.6 million; 
Total: $461 million. 

Fiscal year: 2006; 
Air Force: $149.4 million; 
Army: $140.9 million; 
Navy: $95.2 million; 
Marine Corps: $45.5 million; 
Total: $431 million. 

Fiscal year: 2007; 
Air Force: $164.9 million; 
Army: $154.7 million; 
Navy: $103.8 million; 
Marine Corps: $41.6 million; 
Total: $465 million. 

Fiscal year: 2008; 
Air Force: $175.1 million; 
Army: $170.4 million; 
Navy: $94.9 million; 
Marine Corps: $33.8 million; 
Total: $474 million. 

Fiscal year: 2009; 
Air Force: $178.8 million; 
Army: $187.4 million; 
Navy: $102.8 million; 
Marine Corps: $48.2 million; 
Total: $517 million. 

Source: GAO analysis of DOD data. 

[End of figure] 

In order to receive TA funds, DOD requires postsecondary institutions 
to be accredited by an agency recognized by Education. Accreditation 
is a peer review evaluative process that compares a school against its 
accrediting agency's established standards. The accrediting agency 
conducts institutional reviews to assess the school in its entirety, 
including its resources, admissions requirements, and services 
offered, and the quality of its degree programs. The schools' 
accreditation is then periodically reevaluated every 3 to 10 years, 
depending on the accrediting agency. Schools may lose accreditation if 
their accrediting agency determines that they no longer meet the 
established standards. 

Since 1972, SOC has enhanced educational opportunities for service 
members. SOC, a consortium of approximately 1,900 colleges and 
universities, is funded by DOD through a contract with the American 
Association of State Colleges and Universities (AASCU). SOC functions 
in cooperation with 15 higher-education associations, DOD, and active 
and reserve components of the military services to expand and improve 
voluntary postsecondary education opportunities for service members 
worldwide. SOC criteria stipulate that school policies and practices 
be fair, equitable, and effective in recognizing the special 
conditions faced by military students, such as trouble completing 
college degrees because of their frequent moves. Colleges and 
universities within SOC must have policies that meet four SOC criteria 
relating to transfer of credit, academic residency 
requirement,[Footnote 8] credit for military training and experience, 
and credit for nationally recognized testing programs. In addition, 
they must also follow SOC's three principles: (1) service members 
should share in the postsecondary educational opportunities available 
to other citizens; (2) educational programs for service members should 
rely primarily on programs, courses, and services provided by 
appropriately accredited institutions and organizations; and (3) 
institutions should maintain a necessary flexibility of programs and 
procedures, such as recognition of learning gained in the military and 
part-time student status.[Footnote 9] 

Since 1991, DOD's Military Installation Voluntary Education Review 
(MIVER) process has provided an independent third-party assessment of 
the quality of postsecondary education programs offered to off-duty 
service members at military installations around the world. DOD 
contracted with the American Council on Education (ACE) to administer 
the MIVER.[Footnote 10] The MIVER had two purposes: (1) to assess the 
quality of selected on-installation voluntary education programs and 
(2) to assist in the improvement of such education through appropriate 
recommendations to institutions, installations, DOD, and the military 
services. To assess the quality of education programs offered by 
schools on installations and to ensure that these program are 
comparable to those offered at a school's other campuses, MIVER 
assessed schools' missions, education programs, program 
administration, resources, and program evaluation. The MIVER also 
examined the installations' mission statements and command support, 
program management and leadership, student services, resources, and 
the voluntary education program plans to determine the quality of 
their education programs and services. A visiting team composed of 
college and university professors selected by the contractor evaluated 
the quality of educational services and support provided by the 
installation's education center and servicing institutions. The MIVER 
provided installations and schools with commendations for their areas 
of strength, and recommendations for areas needing improvement. It 
also provided the military services with observations on issues that 
require the military services' attention. MIVERs were for the purpose 
of quality assessment and enhancement only; these reviews were not 
intended to replace institutional accreditation. The MIVER contract 
with ACE expired on December 31, 2010, and DOD elected not to renew 
the contract because it is expanding the scope of these reviews, but 
DOD is currently in the process of obtaining a new contract for its 
reviews. According to DOD, a contractor will be selected in 2011 and 
the new third-party review process will commence on October 1, 2011. 

On August 6, 2010, DOD published a proposed rule for its voluntary 
education programs in the Federal Register for public comment. 
[Footnote 11] Included in this rule, among other things, are 
guidelines for establishing, maintaining, and operating voluntary 
education programs, including instructor-led courses offered on and 
off installations, distance education courses, and the establishment 
of a DOD Voluntary Education Partnership Memorandum of Understanding 
(MOU) between DOD and all educational institutions receiving TA funds. 
DOD estimates that this new rule will become effective at the 
beginning of 2012. 

While Education does not have a role in overseeing DOD education 
programs, it is responsible for the administration of the federal 
student aid programs under Title IV and oversees over 6,000 
postsecondary institutions receiving these funds.[Footnote 12] 
Education determines which institutions of higher education are 
eligible to participate in Title IV programs, which include the 
following:[Footnote 13] 

* Public institutions--institutions operated and funded by state or 
local governments, which include state universities and community 
colleges. 

* Private nonprofit institutions--institutions owned and operated by 
nonprofit organizations whose net earnings do not benefit any 
shareholder or individual. These institutions are eligible for tax- 
deductible contributions in accordance with the Internal Revenue Code 
(26 U.S.C. § 501(c)(3)). 

* For-profit institutions--institutions that are privately owned or 
owned by a publicly traded company and whose net earnings can benefit 
a shareholder or individual. 

Education is also responsible for overseeing school compliance with 
Title IV statutory and regulatory provisions and ensuring that only 
eligible students receive federal student aid. As part of compliance 
monitoring, Education employees conduct program reviews of schools. 
The reviewers examine school records, interview institution staff and 
students, and review relevant student information, among other things. 
In addition to program and eligibility reviews conducted by Education 
employees, independent auditors conduct annual compliance and 
financial audits of schools, and Education's Office of the Inspector 
General conducts its own audits and provides information and referrals 
to Education.[Footnote 14] Education resolves program deficiencies 
identified in both program reviews and audit reports and may impose 
penalties or other sanctions on schools found in violation of Title IV 
requirements.[Footnote 15] 

DOD Takes Steps to Enhance Its Oversight of Schools Receiving TA 
Program Funds, but Areas for Improvement Remain: 

DOD's Oversight Policies and Procedures Vary by Schools' Level of 
Program Involvement but Could Benefit from a Systematic Risk-Based 
Approach: 

DOD policies and procedures to oversee schools receiving TA funds vary 
based on the school's level of involvement in the program. While DOD 
monitors enrollment patterns and schools' funding levels, and 
addresses complaints about postsecondary schools on a case-by-case 
basis, its oversight activities do not include a systematic approach 
that considers these factors when targeting schools for review. 
[Footnote 16] At a minimum, all postsecondary schools receiving TA 
funds are required to be accredited by an agency recognized by the 
Department of Education to ensure the quality of education programs 
being offered to its service members. Schools that are members of the 
SOC consortium or offer classes on an installation are subject to 
additional DOD oversight, as shown in figure 2. 

Figure 2: DOD Participation Requirements by School Level of Program 
Involvement: 

[Refer to PDF for image: illustration] 

Level of oversight: progresses from Low to High: 

All school participants: 
* Must be accredited by an agency recognized by the Department of 
Education. 

Schools that belong to Servicemembers Opportunity Colleges (SOC)[A]: 
* Sign a SOC agreement; 
* Subject to an accreditation check every 2 years; 
* Undergo verification of their loan default rates. 

Schools with signed memorandums of understanding (MOU) with 
installations: 
* Must be members of SOC; 
* Must be chartered or licensed by a state government; 
* Must abide by MOU agreement with base commander that governs 
solicitation policies, reporting requirements on academic offerings 
and student academic status, and other terms of operations on the base; 
* Were subject to Military Installation Voluntary Education Review 
(MIVER)[B]. 

Source: GAO analysis of program policies and testimonial evidence from 
DOD and SOC officials. 

[End of figure] 

Schools that elect to become members of the SOC consortium must comply 
with SOC principles and criteria, which promote institutional 
flexibility with regard to transfer of credits, the development of 
programs and procedures appropriate to the needs of service members, 
and safeguarding the quality of educational programs offered to 
service members. SOC also reviews member schools' student loan default 
rates and verifies their accreditation status every 2 years, according 
to a SOC official.[Footnote 17] In addition, SOC considers recruitment 
practices such as high-pressure promotional activities and "limited 
time only" enrollment discounts inappropriate activities for its 
member institutions to engage in. According to a SOC official, SOC 
will submit a formal complaint to the school's accreditor when it 
becomes aware of serious violations of prohibited marketing practices. 

Schools offering classes on an installation are subject to additional 
oversight measures. Aside from accreditation and mandatory membership 
of SOC institutions that provide academic courses on military 
installations,[Footnote 18] schools are subject to additional 
oversight measures including state licensure, MIVER quality reviews, 
and the terms and conditions of an individualized MOU with the 
installation commander.[Footnote 19] The MOU governs the school's 
operations on an installation; for example, it can cover reporting 
requirements on course offerings and the maintenance of student data 
such as course grades and degrees completed. Education center 
officials at two installations we visited reported that they stay in 
constant contact with on-installation schools and review relevant 
information such as school term schedules and class rosters to ensure 
that schools comply with their MOUs. If a school does not comply with 
the MOU requirements, the installation commander can require the 
school to leave the installation, according to education center 
officials at two of the installations we visited. In general, DOD and 
its military services' oversight of schools is based on a school's 
level of program participation rather than a risk-based approach. 

To address the varying levels of oversight and create a more uniform 
set of program oversight policies, DOD has developed a new standard 
MOU for all schools receiving TA funds. Under the new MOU, all schools 
will be required to, among other things, abide by SOC principles and 
criteria and provide an evaluated educational plan to service members. 
DOD estimates that this new rule will be implemented at the beginning 
of 2012. 

DOD's Education Quality Review Process Was Narrow in Scope and Needed 
Increased Accountability: 

The MIVER was limited to institutions that offer face-to-face courses 
at military installations. While distance learning courses accounted 
for 71 percent of courses paid for with TA funds in fiscal year 2009, 
DOD did not have a review process in place to assess the quality of 
these institutions. In addition, quality reviews were not conducted at 
all installations. According to DOD officials, since the MIVER process 
was first initiated, in 1991, all Marine Corps installations were 
visited, while only a portion of installations of the other military 
services were reviewed (86 percent of Navy installations, 56 percent 
of Army installations, and 30 percent of Air Force installations). 
[Footnote 20] Under the expanded review process that is being 
developed, all institutions receiving TA funds will be subject to a 
new third-party review process--a Military Voluntary Education Review 
(MVER)--regardless of whether the school delivers courses face to face 
or by distance education. In addition, DOD officials said that schools 
will be selected for the MVER process based on the amount of TA funds 
they receive. 

DOD has relied on MIVER to evaluate the quality of the education 
services being provided to its service members at installations; 
however, three of the four services lacked a process to follow up on 
and respond to the findings of the MIVER process. During the MIVER 
process, reviewers developed a report listing their recommendations, 
commendations, and observations of the educational services provided 
by the installation it was reviewing and the institutions offering 
courses at that installation. MIVER final reports were distributed to 
the institutions and installations that were reviewed as well as DOD 
officials and its military services. The Army was the only military 
service that required installations that received a MIVER visit to 
submit a follow-up report indicating actions taken in response to the 
MIVER review. The Air Force recognizes the importance of having such a 
process and was considering adopting a policy that would implement a 
formal process of tracking and following up on items mentioned in 
MIVER reports. The Navy and Marine Corps reported that they did not 
have a formal process requiring their installations to track the 
outcome of MIVER recommendations, commendations, and observations. 
[Footnote 21] These military services also reported that they review 
and maintain copies of all MIVER reports. One DOD official reported 
that MIVER reports were helpful in identifying the strengths, 
weaknesses, and areas for improvement in DOD educational programming. 
[Footnote 22] Additionally, according to ESOs we interviewed, some 
MIVER recommendations were implemented with successful results. For 
example, an ESO told us that some of the Navy installations 
implemented a MIVER recommendation to strengthen their coordination 
with nearby schools. Given that there was no DOD-wide requirement to 
track the outcomes of MIVER recommendations and some of the military 
services did not require schools and installations to formally respond 
to MIVER findings, it is unclear to what extent recommendations that 
could improve the quality of education services offered at schools and 
installations were addressed. There is currently no such requirement 
in place for its new third-party process, according to DOD officials. 

DOD Has Several Ways to Receive Reports of Problems but Needs a 
Centralized System to Track Complaints: 

While DOD has several mechanisms for service members to report 
problems associated with their TA funding, it lacks a centralized 
system to track these complaints and how they are resolved. If service 
members have a complaint or issue regarding a school, they can speak 
with a counselor at their installation's education center, contact a 
representative from SOC, use the call center service,[Footnote 23] or 
use the Interactive Customer Evaluation (ICE).[Footnote 24] According 
to DOD officials, DOD's practice is to have ESOs and education center 
staff resolve complaints at the installation level and to only elevate 
issues that warrant greater attention at the military service level. 
However, DOD and its military services do not have a formal process or 
guidance in place for when ESOs should elevate a complaint to their 
military service chief or DOD. 

DOD reported that most of the complaints it receives are 
administrative in nature, but a few complaints involve improper or 
questionable marketing practices. ESOs we spoke with reported that the 
most frequent complaints they receive from all sources tend to be 
administrative, such as billing issues. These complaints are often 
handled directly by counseling staff at the education offices and are 
generally resolved immediately at the installation level, according to 
DOD officials. ESOs told us that they also receive complaints about 
improper or questionable marketing practices by schools receiving TA 
funds. ESOs and their staff mentioned cases where school 
representatives have conducted marketing activities at installations 
without the installation commander's or ESO's permission. Although the 
ESOs do not maintain an official record of all complaints, ESOs we 
spoke with recalled that most of the instances of a school engaging in 
improper or questionable marketing practices have involved for-profit 
schools. They provided us with documentation of a few examples of 
these complaints. In one case, a for-profit school was found to be 
charging higher tuition rates to service members than civilians and 
offering service members $100 gas cards upon course completion. The 
ESO at the installation where this incident occurred told us that this 
issue was resolved by speaking with school officials and an 
accrediting agency. An official also told us that another for-profit 
school representative continually called and e-mailed a service member 
during day and evening hours after he elected not to attend that 
institution. 

SOC also helps DOD and its military services in resolving complaints. 
SOC produces and disseminates quarterly reports to the voluntary 
education service chiefs of each of the military services to inform 
them of the issues that SOC has addressed on behalf of DOD and its 
military services. SOC addresses various administrative matters such 
as answering questions from schools and service members about the TA 
program. A SOC official told us that SOC also resolves complaints 
involving aggressive marketing, claims of unfair grading, and issues 
relating to deployment and transfer of credit between institutions. 
For example, SOC intervened on a student's behalf and successfully 
secured transfer of credits when a school failed to honor its 
agreement with the service member to do so upon course completion. 

Education center staff elevate issues that cannot be handled locally 
to the military service chief level, but DOD does not have specific 
guidance explaining when to do so. When a school distributed flyers 
and e-mails at an installation to advertise courses it planned to 
offer on-installation without an MOU and misrepresenting the number of 
credits service members would receive from taking the school's 
courses, DOD officials and SOC were notified of these activities. In 
response to these issues, DOD shared its concerns and copies of the 
school's marketing materials with Education. Additionally, SOC filed a 
complaint with the school's accrediting agency. Education planned to 
review the school' marketing materials, and the accreditor plans to 
hold a meeting to determine the appropriate actions to address SOC's 
complaint, according to DOD officials. DOD's Interservice Voluntary 
Education Working Group serves as a forum for service officials to 
share information, including complaints they might be made aware of, 
with DOD headquarters officials. The group, with representation from 
each military service, meets quarterly to discuss various DOD 
voluntary education-related issues and share information among the 
four military services. Despite such examples of complaints being 
referred up the chain of command, one military service official said 
that it is difficult to establish policy on how to handle every 
complaint or issue that may arise. Without polices and a centralized 
system to track complaints and their outcomes, DOD may not have 
adequate information to assess trends across its military services or 
determine whether complaints have been adequately addressed. 

Military Education Center Staff and School Representatives Identified 
Areas Needing Improvement: 

Education center staff and school representatives outlined several 
areas that could improve program oversight--(1) requiring schools to 
offer distance learning tutorials, and (2) developing a uniform 
installation access policy for schools. 

Require schools to offer a distance learning tutorial: Officials at 
the military education centers we visited suggested that the 
availability of a distance learning tutorial for all service members 
accessing online courses is important to ensure that service members 
successfully complete these courses. Because of the mobile nature of a 
service member's life, online education offerings provide an 
opportunity for service members to access and complete postsecondary 
courses. However, counseling staff and school representatives we 
interviewed at one installation reported that some service members 
have had difficulty using the course software to access discussion 
boards and/or submit assignments because they had not previously taken 
an Internet-based course. Officials from one of the institutions we 
spoke with told us that they offer online tutorials and technical 
support for their distance learning courses, and participation in the 
online tutorial is strongly encouraged. 

Uniform installation access policy for schools: School representatives 
we met with suggested that DOD establish a uniform installation access 
policy for all schools participating in the TA program. Installation 
access policies are determined at the installation level by the ESO 
and installation commander, and these policies tended to vary with 
installations we visited. In addition to schools that offer courses on 
an installation and have a signed MOU, some schools are granted access 
to the installation by the ESO as visiting schools. These schools do 
not offer courses on an installation but instead offer periodic office 
hours and academic support for the students they serve at that 
installation. At one installation we visited, the ESO grants access to 
only a few visiting schools and requires that they all sign an MOU 
outlining the terms of their operations on an installation. However, 
at another installation we visited, the ESO allows any school that 
currently serves students on an installation to hold office hours with 
the education center's approval. A few school representatives 
expressed concerns about their limited or lack of installation access 
to support their students. 

DOD's Limited Coordination with Accreditors and Education May Hinder 
Its Efforts: 

DOD Coordinates with Accrediting Agencies but Does Not Use Information 
about Schools That Have Been Sanctioned or Have Unapproved Changes: 

While DOD coordinates with accrediting agencies, it does not use 
accrediting agencies' monitoring results or consider schools' 
unapproved substantive changes as it carries out its oversight. DOD 
officials told us they communicate with accrediting agencies through 
SOC to verify accreditation, and report complaints or problems with 
schools. SOC, on the behalf of DOD, contacts accrediting agencies 
biannually to verify the accreditation status of its member 
institutions, according to a SOC official.[Footnote 25] DOD and its 
military services officials reported that they also contact 
accrediting agencies directly or through SOC when they cannot resolve 
complaints against schools. For example, one military service worked 
with SOC to file a complaint against a school when it found that a 
school was falsely marketing its courses to its service members. 
According to DOD, this complaint led to an investigation into the 
matter by the school's accrediting agency. DOD also reported that it 
holds annual meetings with accrediting agencies to discuss DOD 
policies and procedures and the delivery of educational programs to 
its military services. 

DOD's oversight process does not take into account accrediting 
agencies' monitoring results of schools that could negatively affect 
students and service members. Schools can be sanctioned by accrediting 
agencies when they fail to meet established accrediting standards, 
such as providing sound institutional governance, providing accurate 
information to the public, and offering effective educational 
programs. For example, on the basis of an accrediting agency's 
monitoring results that were publicly available, a school was warned 
it could be at risk of losing its accreditation in part because it 
lacked evidence of a sustainable assessment process to evaluate 
student learning. The school was required to submit a report to the 
accrediting agency providing evidence of its process and that the 
results were being used to improve teaching, learning, and 
institutional effectiveness. According to accrediting agency 
officials, schools are given multiple opportunities to correct 
deficiencies before having accreditation revoked and can be sanctioned 
for up to 2 years.[Footnote 26] 

DOD does not currently require schools to have their substantive 
changes approved by their accrediting agency in order to receive TA 
funds. Schools may introduce new courses or programs significantly 
different from current offerings, and such changes may be considered 
substantive and outside the scope of an institution's accreditation. 
Unlike DOD, Education requires a school to obtain its accrediting 
agency's approval on any substantive change and report this 
information to Education for approval before it can disburse Title IV 
funds to students enrolled in new courses or programs considered to be 
substantive changes.[Footnote 27] Education requires accrediting 
agencies to have substantive change policies in place to ensure that 
any substantive change to an institution's educational mission or 
programs does not adversely affect its capacity to continue to meet 
its accrediting agency's standards. DOD recently proposed that tuition 
assistance funds should be available for service members participating 
in accredited undergraduate or graduate education programs and that 
approved courses are those that are part of an identified course of 
study leading to a postsecondary certificate or degree.[Footnote 28] 
According to Education, schools seeking Title IV funds generally wait 
for approval before enrolling students in such new courses and 
programs, but can collect other federal education assistance and out- 
of-pocket funds during that time. Students enrolled in unapproved 
courses or programs have less assurance that they are receiving a 
quality education, according to Education officials. On the basis of 
Education's fiscal year 2009 Program Compliance Annual Report, we 
determined that there were over 1,200 substantial changes processed in 
fiscal year 2009. 

DOD Could Better Leverage Compliance Information from Education to 
Improve Its Oversight of Schools: 

DOD coordinates with Education to some extent but does not utilize 
Education's compliance data to oversee schools receiving TA funds. The 
extent of DOD's coordination with Education has generally been limited 
to accreditation status. According to DOD officials, DOD regularly 
searches Education's Web site to verify schools' accreditation status, 
and utilizes Education's resources for counseling students on federal 
student aid. In addition, DOD reported that it invited Education 
officials to attend its Interservice Voluntary Education Working Group 
meeting in September 2010 to discuss future changes to the 
accreditation process. However, DOD does not utilize information from 
Education's monitoring reviews to inform its oversight efforts. This 
information can alert DOD to problems at schools that may affect the 
quality of education provided to students, including service members. 
Education determines schools' initial eligibility to participate in 
federal student aid programs through eligibility reviews and 
continuing eligibility through program reviews, compliance audits, and 
financial audits. The results of these oversight measures provide 
additional insight into a school's financial stability, quality of 
education, and compliance with regulations that provide consumer 
protections for students and the federal investment. See table 1 for a 
summary of these oversight activities. 

Table 1: Education's Monitoring of Schools Participating in the Title 
IV Program: 

Focus of oversight: Financial health[A]; 
Types of school monitored: Private nonprofit and for-profit; 
Activity: Financial responsibility: Education determines schools' 
financial responsibility by assessing its cash reserves and the 
school's history of meeting its past financial obligations. In 2008 
and 2009, at least 249 schools failed the financial stability test, 
and Education placed some of these schools on heightened monitoring. 

Focus of oversight: Related to quality of education; 
Types of school monitored: All schools; 
Activity: Student loan cohort default rate: According to Education 
officials, Education uses student loan cohort default rates implicitly 
as a proxy for education quality. A large number of students in 
default may indicate that a school may be poorly preparing students 
for employment. Schools with default rates above certain thresholds 
lose eligibility to participate in Title IV programs. 

Focus of oversight: Related to quality of education; 
Types of school monitored: For-profit only; 
Activity: 90/10 rule: In order to participate in Title IV programs, 
for-profit schools cannot receive more than 90 percent of their 
revenue from title IV funds.[B] Between 2003 and 2008, 7 schools lost 
eligibility for federal student aid because of noncompliance with the 
90/10 rule. 

Focus of oversight: Consumer protection related to schools' recruiting 
practices; 
Types of school monitored: All schools; 
Activity: Incentive compensation: Schools participating in Title IV 
programs are prohibited from compensating recruiters based directly or 
indirectly on their success in enrolling students or securing 
financial aid for them. Between 1998 and 2009, Education substantiated 
incentive compensation violations at 32 schools.[C]. 

Focus of oversight: Consumer protection related to schools' recruiting 
practices; 
Types of school monitored: All schools; 
Activity: Misrepresentation: Institutions participating in Title IV 
programs may not engage in substantial misrepresentation of the nature 
of the institution's educational program, its financial charges, or 
the employability of its graduates. According to Education's 
compliance data, Education found at least 16 misrepresentation 
violations between 2004 and 2009 through compliance audits and closed 
program reviews. 

Source: GAO analysis of laws and regulations, as well as testimonial 
evidence and program documents from Education. 

[A] Education considers a public institution financially responsible 
if it demonstrates legal designation as a public institution and has 
not violated past performance requirements. 

[B] DOD tuition assistance funds are counted toward meeting a 
proprietary institution's minimum of 10 percent non-Title IV funds. A 
school's revenue percentage must be calculated in accordance with 34 
C.F.R § 668.28. 

[C] GAO, Higher Education: Information on Incentive Compensation 
Violations Substantiated by the U.S. Department of Education, GAO-10-
370R (Washington, D.C. February 23, 2010). 

[End of table] 

The results of these oversight measures can provide DOD and its 
military services with additional insight into a school's ability to 
provide a quality education and services to students. Schools that are 
financially unstable or fail to comply with student loan default rate 
and 90/10 requirements may be unable to fulfill their promises to 
provide students with quality program offerings, according to 
Education. While DOD monitors default rates through SOC, it does not 
formally monitor 90/10 information. Military education center staff we 
spoke with at two military installations indicated that ensuring the 
consumer protection of service members amidst sometimes deceptive 
recruiting practices of some schools can be a challenge. Education's 
monitoring results in these areas could provide relevant information 
to help DOD and its military services to better target their oversight 
and provide additional consumer protection for service members. 

Education has recently developed additional provisions to better 
address oversight in distance education. Education has developed a 
review process and guidance for its staff to assess the integrity of 
distance learning programs, such as whether schools have a process to 
verify student attendance. DOD has proposed that distance education 
schools be subject to MVER reviews, but currently does not generally 
evaluate these courses.[Footnote 29] DOD may be able to leverage 
information from Education's ongoing efforts in this area. 

In part because of inconsistencies in states' authorization 
requirements for schools, Education recently clarified what is 
required for institutions of higher education to be considered legally 
authorized by a state. Under new regulations that will generally take 
effect in July 2011, states must, among other things, have a process 
to review and address complaints about institutions authorized by the 
state. In addition the new regulations require that if an institution 
is offering postsecondary education through distance or correspondence 
education in a state in which it is not physically located, the 
institution must meet any state requirements for it to be legally 
offering distance or correspondence education in that state.[Footnote 
30] Unlike Education, DOD does not verify that all schools receiving 
TA funds have state authorization; it only verifies state 
authorization for on-installation schools. Since DOD reported that it 
has not had the opportunity to fully review Education's new rule 
regarding state authorization, it is unclear whether it will follow 
those requirements. 

Education has partnerships with a number of other federal agencies, 
including the Department of Justice and the Federal Trade Commission. 
Education partners with these two agencies to share information on 
complaints and college scholarship and financial aid fraud. 
Additionally, Education has a Federal Agency Advisory Working Group to 
facilitate its coordination with other federal agencies and told us 
that it is willing to share information and provide guidance to DOD in 
real time. 

Conclusions: 

In fiscal year 2009, nearly 377,000 service members relied on TA funds 
to help further their academic and professional goals. Schools that 
offer distance learning courses play an ever increasing role in 
helping students achieve these goals. The amount of TA funding going 
toward distance learning programs creates new oversight challenges for 
DOD and its military services, especially since DOD oversight has 
primarily focused on schools offering traditional classroom 
instruction on military installations. 

Increased oversight is needed to remedy gaps in the accountability of 
the quality review process and the process to address complaints 
against schools. Although DOD has plans to improve its oversight of 
schools receiving TA funds, without accountability measures for its 
quality review process, DOD cannot be certain its efforts to safeguard 
TA funds will be effective. In addition, while DOD is aware of some 
concerns regarding schools' improper recruiting practices, without a 
centralized process to track complaints against schools and their 
resolution, DOD lacks the ability to accurately determine trends in 
areas requiring oversight and whether concerns have been adequately 
addressed. 

DOD could further enhance its oversight efforts by leveraging 
resources and information that accrediting agencies and Education 
already collect. For example, the additional consumer protections 
provided by Education's regulations on schools' substantive changes 
could provide DOD with additional assurance that TA funds are going 
toward courses and programs that have been properly vetted by the 
schools' accreditors. Without leveraging these additional oversight 
tools, DOD and its military services may lack key information that 
could help strengthen and inform future program oversight. Targeted 
improvements in these areas may help DOD and its military services to 
better ensure that TA funds are being properly utilized and services 
members are receiving quality education. 

Recommendations for Executive Action: 

We recommend that the Secretary of Defense direct the Undersecretary 
of Defense for Personnel and Readiness to take the following 5 actions 
to improve its oversight of schools receiving TA funds: 

1. To improve the accountability of DOD, its military services, their 
installations, and participating postsecondary schools in developing 
its new third-party review process, 

* require all schools, installations, and the military services to 
formally respond in writing to related recommendations pertaining to 
them, and: 

* develop a process to track and document the status of all 
recommendations for improvement. 

2. Evaluate ways to develop a centralized process to record and track 
the status and outcomes of complaints. This should be done in a way 
that balances the need for a comprehensive tracking system with, to 
the extent possible, minimizing the reporting burden placed on 
education center staff at military installations. 

3. Undertake a systematic review of its oversight of schools receiving 
TA program funds. In doing so, the Undersecretary of Defense for 
Personnel and Readiness should consider the following: 

* developing a more systematic risk-based approach to oversight by 
utilizing information from accrediting agencies and Education to 
better target schools, 

* modifying its proposed standard MOU to include an explicit 
prohibition against school conduct that may adversely affect service 
members, such as misrepresentation, and: 

* reviewing Education's recently promulgated requirements for state 
authorization of schools and coordinate with Education to determine 
the extent to which these requirements are useful for overseeing 
schools receiving TA funds. 

4. Prohibit TA funds from being used to pay for courses and programs 
that are not included within the scope of an institution's 
accreditation. This could include leveraging Education's knowledge and 
expertise to determine the extent to which other substantive changes 
listed in Education's regulations are applicable to the military 
education programs. 

5. Require and verify that all schools receiving TA funds are 
authorized by their state. 

Agency Comments: 

We provided a draft of this report to DOD and Education. DOD's written 
comments are reproduced in appendix III. DOD agreed with our 
recommendations and noted steps it would take to address them. 
Additionally, DOD and Education provided technical comments on the 
draft. We incorporated each agency's comments as appropriate. 

We are sending copies of this report to relevant congressional 
committees, the Secretary of Defense, the Secretary of Education, and 
other interested parties. In addition, this report will be available 
at no charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made key contributions to 
this report are listed in appendix IV. 

Sincerely yours, 

Signed by: 

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

[End of section] 

Appendix I: Scope and Methodology: 

To address our objectives, we reviewed and analyzed relevant federal 
laws, regulations, and program documents and data, including program 
participation and expenditure data from the Department of Defense 
(DOD) and its military services. We also reviewed the Department of 
Education's (Education) monitoring results to report on cases where 
schools were not in compliance with Title IV requirements. 

We interviewed officials from DOD, its military services, and 
contractors--Servicemembers Opportunity Colleges (SOC) and the 
American Council on Education. We conducted site visits to education 
centers located at military installations of the four military 
services to gain a better understanding of how the program is 
implemented. We selected these sites based on whether the sites had a 
mix of public, private nonprofit, and for-profit schools offering 
classes or held office hours at the installations. We visited one 
installation per military service--Joint Base Andrews, Fort Carson, 
Marine Corps Base Quantico, and Naval Station Norfolk. During our site 
visits, we toured the education facilities and interviewed education 
center staff and representatives from 16 schools across the four 
installations that we visited. (See appendix II.) 

We interviewed Department of Education officials to determine the 
extent to which they coordinate with DOD as part of DOD's efforts to 
oversee its Military Tuition Assistance (TA) program. Finally, we 
interviewed representatives from an association of colleges and 
universities (Council for Higher Education Accreditation) and selected 
accrediting agencies (the Distance Education and Training Council and 
the Higher Learning Commission) in order to obtain information about 
the extent to which they coordinate and provide information to DOD and 
its military services for monitoring schools. Overall, we assessed the 
reliability of these data by reviewing existing information about the 
data and the system that produced them and interviewing agency 
officials knowledgeable about the data. We determined the data to be 
sufficiently reliable for the purposes of this report. 

We conducted this performance audit from August 2010 to February 2011 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Selected Postsecondary Institutions GAO Interviewed at 
Selected Education Centers: 

For-profit: 

1. American Military University:
2. Ashford University:
3. DeVry University:
4. ECPI College of Technology:
5. Strayer University:
6. University of Phoenix: 

Private nonprofit: 

7. Embry Riddle Aeronautical University:
8. Park University:
9. Webster University: 

Public: 

10. Colorado State University-Pueblo:
11. Pikes Peak Community College:
12. Northern Virginia Community College:
13. Tidewater Community College:
14. Troy University:
15. University of Colorado at Colorado Springs:
16. University of Maryland University College: 

[End of section] 

Appendix III: Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
Personnel and Readiness: 
41130 Defense Pentagon: 
Washington, DC, 20301-4000: 

February 22, 2011: 

Ms. Janet St. Laurent: 
Managing Director, Defense Capabilities and Management: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, DC 20548: 

Dear Ms. St. Laurent: 

This is the Department of Defense (DoD) response to the GAO Draft 
Report, GAO-11-300, "DOD Education Benefits: Increased Oversight of 
Tuition Assistance Program is Needed," dated February 3, 2011(GAO CODE 
131025). 

In the enclosure we provide the DoD responses to the GAO 
recommendations. We concur with all recommendations. 

Signed by: 

Robert L. Gordon III: 
Deputy Assistant Secretary of Defense (Military Community and Family 
Policy): 

Enclosure: As stated: 

[End of letter] 

GAO Draft Report Dated February 3, 2011: 
GA0-11-300 (GAO Code 131025): 

"DOD Education Benefits: Increased Oversight of Tuition Assistance
Program is Needed" 

Department Of Defense Comments To The GAO Recommendations: 

Recommendation 1: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
take the following actions to improve the accountability of the DOD, 
its Military Services, their installations, and participating 
postsecondary schools in developing its new third party review process: 

* require all schools, installations, and the Military Services to 
formally respond in writing to related recommendations pertaining to 
them; 

* develop a process to track and document the status of all 
recommendations for improvement. 

DoD Response: Concur. The new third party review process will require 
all schools, installations and the Services to formally respond in 
writing to recommendations and show actions taken for improvement. OSD 
will track to ensure compliance and monitor all corrective actions to 
ensure there is continuous quality improvement. (Estimated completion 
date is Oct. 11) 

Recommendation 2: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
evaluate ways to develop a centralized process to record and track the 
status and outcomes of complaints. This should be done in a way that 
balances the need for a comprehensive tracking system with, to the 
extent possible, minimizing the reporting burden placed on Education 
Center staff at military installations. 

DoD Response: Concur. Currently, DoD is developing an automated 
tracking system to document all concerns and complaints. The system 
will track the complaint, status and record resolutions. The system 
will allow students, DoD personnel and schools to submit complaints 
and will be located on DoD Voluntary Education Partnership MOU web 
page: www.dodmou.com or as a link under the DoD Voluntary Education 
Web site at www.volcd.dodcd.mil . (Estimated completion date is June 
11). 

Note: The Army has already established a process to record/track 
complaints through the GoArmyEd's Customer Relationship Management 
(CRM) resource available to all Soldiers who use Federal tuition 
assistance. Soldiers can create a CRM case either on-line (in 
GoArmyEd) or use toll-free phone numbers to the GoArmyEd's helpdesk. 
Once a CRM case is resolved/closed, the Soldier may use the available 
"Customer Satisfaction Survey" to rate the course and/or provide 
candid comments concerning the level of service provided to resolve 
their case. 

Recommendation 3: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness take 
the following actions to undertake a systematic review of its 
oversight of schools receiving Tuition Assistance (TA) program funds. 
In doing so, the Undersecretary of Defense for Personnel and Readiness 
should consider the following: 

* developing a more systematic risk based approach to oversight by 
utilizing information from accrediting agencies and Education to 
better target schools; 

* modifying its new standard MOU to include an explicit prohibition 
against school conduct that may adversely affect service members, such 
as misrepresentation; 

* reviewing Education's recently promulgated requirements for state 
authorization of schools and coordinate with Education to determine 
the extent to which these requirements arc useful for overseeing 
schools receiving TA funds. 

DoD Response: Concur. DoD has contacted the Department of Education 
and is developing a partnership sharing agreement to utilize 
information from Education's 1) requirements reports from accrediting 
agencies, 2) school monitoring reviews, and 3) requirements for state 
authorization of schools. This information will be used to assist is 
targeting its review process. In addition, DoD will revise directives 
to more explicitly address adverse conduct by a school that may 
negatively impact Service members. (Estimated completion date is 
August 11) 

Recommendation 4: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
take the following action to prohibit TA funds from being used to pay 
for courses and programs that arc not included within the scope of an 
institution's accreditation. This could include leveraging Education's 
knowledge and expertise to determine the extent to which other 
substantive changes listed in Education's regulations are applicable 
to the military education programs. 

DoD Response: Concur. DoD has contacted the Department of EdUcation 
and is developing a partnership sharing agreement to utilize 
information from Education's requirements reports from accrediting 
agencies to include substantive change reports. As part of this, we 
will be determining which of Education's regulations are applicable to 
DoD Voluntary Education programs and apply to the military tuition 
assistant program policies. (Estimated completion date is August 11) 

Recommendation 5: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness take 
action to require and verify that all schools receiving TA funds are 
authorized by their state. 

DoD Response: Concur. DoD has contacted the Department of Education 
and is developing a partnership sharing agreement to utilize the 
tracking and documentation of a school's state authorization. The 
information will be used, prior to issuing tuition assistance funds, 
to ensure schools are in compliance with Education's new requirement 
for all schools to have state authorization to offer distance or 
correspondence learning. (Estimated completion date to begin receiving 
audit reports from the Department of Education is August 11; a 
comprehensive tracking system will be developed by the Department of 
Education but will require additional time) 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

In addition to the above contact, Tranchau (Kris) Nguyen (Assistant 
Director), Raun Lazier (Analyst-in-Charge), James Bennett, Jessica 
Botsford, Susannah Compton, Catherine Hurley, Edward (Ted) Leslie, 
Katya Melkote, and Luann Moy made significant contributions to this 
report. 

[End of section] 

Footnotes: 

[1] DOD defines "off-duty time" as the time when service members are 
not scheduled to perform official duties. 

[2] TA funds may be used for educational activities such as (1) 
completion of an associate's degree, bachelor's degree, or master's 
degree; (2) for courses leading to technical, vocational, or 
professional certificate or license; (3) building academic foreign 
language skills when not part of a degree program; and (4) pursuing 
prerequisite courses for academic skill development or preparation for 
a degree program, according to the Joint Service Uniform Tuition 
Assistance Policy. 

[3] DOD defines "distance education" as the delivery of education or 
training through electronically mediated instruction, including 
satellite, video, audio graphic, computer, multimedia technology, and 
other forms of learning at a distance, such as correspondence and 
independent study. 

[4] Voluntary education programs are authorized by 10 U.S.C. §§ 2005 
and 2007. 

[5] DOD Directive 1322.08E (May 3, 2010) and DOD Instruction 1322.25 
(April 23, 2007). 

[6] Education centers located on military installations are equipped 
with office space, classrooms, laboratories, and other features to 
conduct voluntary education programs and provide on-installation 
classes. 

[7] According to DOD, TA funds are paid directly to schools, and if 
service members do not meet GPA requirements or complete their 
courses, service members are responsible for paying back the money for 
these courses. 

[8] The term "academic residency requirement" pertains to the required 
number of course credits students must take from their home 
institution to be eligible for a degree. 

[9] Servicemembers Opportunity Colleges, SOC Principals and Criteria 
2011-2013. 

[10] The most recent MIVER contract was a 4-year contract (January 1, 
2007, to December 31, 2010) with a total value of $3,743,440. 

[11] Voluntary Education Programs, 75 Fed. Reg. 47,504 (Aug. 6, 2010) 
(to be codified at 32 C.F.R. pt. 68). 

[12] Title IV of the Higher Education Act of 1965 (HEA), as amended, 
authorizes financial assistance to help students and families pay for 
postsecondary education through student grants and loans, such as Pell 
Grants for low-income students, loans to parents and graduate 
students, and Stafford loans. 

[13] Under the HEA, institutions must meet certain requirements to 
participate in Title IV student aid programs. In general, an 
institution of higher education is required to (1) be authorized by 
the state in which it is located to provide higher education, (2) be 
deemed eligible and certified to participate by the Department of 
Education, and (3) be accredited by an accrediting agency recognized 
by the Secretary of Education. Although Education's regulations 
provide that accrediting agencies may not accredit institutions that 
lack state authorization, accreditation does not establish that an 
institution is authorized by a state for purposes of the Title IV 
program. 

[14] Institutions that receive Title IV funds must submit an annual 
audit to Education prepared by a certified independent auditor. 

[15] As part of the resolution process, Education generally sends a 
program review or audit determination letter to the school describing 
the violations found and any corrective actions the school must take 
to address the finding. In certain circumstances, Education may fine a 
school or suspend, limit, or terminate a school's participation in 
Title IV programs. 

[16] According to the GAO's standards for internal control in the 
federal government--GAO, Internal Control: Standards for Internal 
Control in the Federal Government, [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C. 
November 1999)--to better achieve their missions and improve 
accountability, federal agencies are required to employ certain 
internal controls, including assessing the risk agencies face from 
both external and internal sources. Applying the federal risk 
assessment standard to the TA program suggests that DOD needs to 
consider all significant interactions between its entity and other 
parties, as well as internal factors at both the entitywide and 
activity level. Risk identification methods may include qualitative 
and quantitative ranking activities, and consideration of findings 
from audits and other assessments. 

[17] SOC follows Education's definition of loan default limits for its 
membership eligibility. Generally, a school loses eligibility to 
participate in Title IV programs when its cohort default rate exceeds 
25 percent for 3 consecutive years or 40 percent in any one year. 34 
C.F.R. § 668.187. 

[18] The Air Force is the only service that does not require 
membership of SOC for institutions located on its installations. This 
is because the Air Force operates the Community College of the Air 
Force (CCAF), which is a regionally accredited, 2-year college open to 
Air Force enlisted on active duty, or enlisted in reserve or guard 
services. As with the SOC program, credits toward a CCAF degree can be 
accumulated through Air Force training and credit from examinations. 

[19] All on-installation schools and installations are subject to a 
MIVER review but may not be selected for one. 

[20] Between 1994 and 2004, Air Force policy was to use MIVER at 
overseas locations only. In 2005, the Air Force changed that policy 
and began MIVER at stateside locations. 

[21] The Marine Corps has a MIVER follow-up procedure, which involves 
filing an action plan in response to MIVER findings and reviewing the 
plan to determine if an additional MIVER site visit is necessary. 

[22] The military services also had the option to request a MIVER 
revisit. During a revisit, a MIVER team would return to the 
installation to determine the extent to which the recommendations had 
been implemented. The revisits usually occurred in cases where the 
original MIVER visit resulted in many negative findings and 
commensurate recommendations. 

[23] The military services established call centers to handle issues 
such as complaints related to the TA Program, according to DOD 
officials. 

[24] ICE is an online portal operated by DOD to collect feedback on 
DOD products and services, including educational programming. 

[25] According to a report by Education's Office of Inspector General, 
an accrediting agency allowed a school to remain accredited even 
though it had determined the school's credit hour policy was 
"egregious and not in the best interest of the students." 

[26] Accrediting agencies may also be challenged in their decisions to 
revoke a school's accreditation, and legal proceedings may take a 
number of years to be finalized. 

[27] In order to be recognized by Education, accrediting agencies must 
require an institution to obtain the agency's approval of a 
substantive change, and have a definition of substantive change, which 
includes such changes as any change in the established mission or 
objectives of the institution; any change in the legal status, form of 
control, or ownership of the institution; the addition of courses or 
programs that represent a significant departure from the existing 
offerings of educational programs, or method of delivery, from those 
that were offered when the agency last evaluated the institution; or 
the addition of programs of study at a degree or credential level 
different from that which is included in the institution's current 
accreditation or pre-accreditation. 

[28] Voluntary Education Programs, 75 Fed. Reg. 47,508 (Aug. 6, 2010) 
(to be codified at 32 C.F.R. pt. 68). 

[29] A school on a military installation selected for a MIVER review 
may be subject to questions MIVER has developed for distance education 
providers, such as how to verify the identity of students enrolled in 
online courses. 

[30] 34 C.F.R. § 600.9(c), as added by final regulations published on 
October 29, 2010, at 75 Fed. Reg. 66,832. 

[End of section] 

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