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DOD Education Benefits: Increased Oversight of Tuition Assistance Program Is Needed

GAO-11-300 Published: Mar 01, 2011. Publicly Released: Mar 01, 2011.
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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.

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. 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.


Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Defense To improve its oversight of schools receiving TA funds and to improve the accountability of DOD, its military services, their installations, and participating postsecondary schools in developing its new third-party review process, the Secretary of Defense should direct the Undersecretary of Defense for Personnel and Readiness to (1) require all schools, installations, and the military services to formally respond in writing to related recommendations pertaining to them, and (2) develop a process to track and document the status of all recommendations for improvement.
Closed – Implemented
DOD established a new policy requiring all educational institutions participating in the Tuition Assistance (TA) program to have a Memorandum of Understanding (MOU) articulating their commitments prior to receiving TA funds by September 2014. By signing this MOU, institutions agree to participate in the Third Party Review, resolve any findings, and provide corrective actions taken within six months to DOD. Similarly, DOD policy now instructs all installations to communicate the resolution to the third-party assessment recommendations to the DOD Voluntary Education Chief. If participating institutions and installations cannot complete corrective actions within this timeframe, they must submit status reports every three months to DOD. The third party will track and document the status of recommendations, and the DOD Assessment Advisory Board will review findings and monitor trends.
Department of Defense To improve its oversight of schools receiving TA funds, the Secretary of Defense should direct the Undersecretary 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.
Closed – Implemented
DOD developed an automated tracking system to document complaints. The system can be access through a link on the DOD Voluntary Education Web site. GAO staff reviewed DOD's website and tested the link; it appears to be operational.
Department of Defense To improve its oversight of schools receiving TA funds, the Secretary of Defense should direct the Undersecretary of Defense for Personnel and Readiness to 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: (1) developing a more systematic risk-based approach to oversight by utilizing information from accrediting agencies and Education to better target schools, (2) modifying its proposed standard MOU to include an explicit prohibition against school conduct that may adversely affect service members, such as misrepresentation, and (3) 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.
Closed – Implemented
The Department of Defense (DOD) has made multiple, systematic changes to strengthen its oversight of schools receiving tuition assistance funds. Specifically, all participating schools are now required to sign a memorandum of understanding (MOU) that they will adhere to certain standards in order to receive tuition assistance funds. These standards are designed to address issues with accreditation, recruiting practices, and policy disclosures that would help protect service members while allowing for judicious oversight of taxpayer dollars. In addition, DOD has developed two working groups with Education, the Department of Veterans Affairs, the Department of Justice, and the Bureau of Consumer Financial Protection. The working groups are intended to strengthen enforcement of student protections, and one result of this collaboration is a new system to register student complaints that will be accessible across agencies in the coming months. In the meantime, DOD has recently implemented its own complaint tracking system that will feed into the interagency system when it becomes fully operational. Moreover, DOD has decided to shift its oversight strategy to a risk-based assessment of participating schools, which will consider school sector and location in addition to leveraging information from the interagency complaint system. With regard to reviewing Education's requirements for state authorization of schools, the policy has changed since GAO originally recommended this action in March 2011, but DOD's collaboration with the agency offers opportunities to stay informed of relevant requirements.
Department of Defense To improve its oversight of schools receiving TA funds, the Secretary of Defense should direct the Undersecretary of Defense for Personnel and Readiness to 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.
Closed – Implemented
In a July 2014 policy update, DOD required that schools participating in the Tuition Assistance (TA) program be accredited by agencies recognized by the Department of Education (Education), and schools must obtain the approval of their accrediting agency for any substantively new course or program offering. Approval must be obtained before the enrollment of a Service member into the new course or program offering. In addition, DOD signed a memorandum of understanding (MOU) to share data with Education, the Department of Veterans Affairs, and the Bureau of Consumer Financial Protection with the purpose of increasing oversight of participating schools, which includes a commitment to notify the other parties of any federal action that could result in a school losing its program eligibility. Building on the new policy and MOU, DOD's compliance review process now includes accessing Education's Database of Accredited Postsecondary Institutions and Programs, along with the individual accrediting agency websites to confirm a school's accreditation. DOD also uses data from Education?s Postsecondary Education Participants System to get updated and detailed information concerning accreditation status and changes. When a student submits a tuition assistance request, DOD reviews and confirms the information in the school's record to ensure the degree program and course is approved.
Department of Defense To improve its oversight of schools receiving TA funds, the Secretary of Defense should direct the Undersecretary of Defense for Personnel and Readiness to require and verify that all schools receiving TA funds are authorized by their state.
Closed – Implemented
In 2014, DOD established a policy requiring its leadership staff to ensure that schools providing education programs are in compliance with state authorization requirements.

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