GAO-14-855, DOD EDUCATION BENEFITS: Action Is Needed To .

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United States Government Accountability OfficeReport to Congressional CommitteesSeptember 2014DOD EDUCATIONBENEFITSAction Is Needed toEnsure Evaluations ofPostsecondarySchools Are UsefulGAO-14-855

September 2014DOD EDUCATION BENEFITSAction Is Needed to Ensure Evaluations ofPostsecondary Schools Are UsefulHighlights of GAO-14-855, a report tocongressional committeesWhy GAO Did This StudyWhat GAO FoundDOD’s military Tuition AssistanceProgram includes partnershipagreements with about 3,000 schoolsthrough which service members canpursue a postsecondary education.Through this program, servicemembers’ tuition is paid directly toparticipating schools and in fiscal year2013, the program spent 540 million.The program also provides servicemembers with education advisors, andconducts evaluations of schools toassess quality. Congress mandatedthat GAO provide information on therole of these advisors and on the DODcontractor evaluations of schoolsparticipating in the program.In fiscal year 2013, 571 Department of Defense (DOD) education advisors wereavailable to provide information and educational support to the nearly 280,000service members taking courses funded through the military Tuition AssistanceProgram. This program accommodates service members, who may regularly bereassigned to another location (including overseas), by allowing them to takeclasses online, directly on base, or at nearby schools. DOD advisors offer arange of services to service members such as helping them understand the typesof degrees and courses schools offer and helping them develop educationalgoals and plans.GAO examined (1) the number ofadvisors and the type of advice theyprovide, and (2) the informationcollected through evaluations ofschools participating in the militaryTuition Assistance Program. For thiswork, GAO analyzed DOD data on theprogram from fiscal year 2011 through2013; reviewed all DOD contractorevaluations for fiscal years 2012 and2013; and interviewed officials fromDOD and the military services,contractor staff responsible for theevaluations, and advisors at Joint BaseAndrews, Maryland. GAO visited thisbase because many of its servicemembers participate in the program,and some of the participating schoolswere evaluated by DOD’s contractor in2013.DOD used a contractor to conduct evaluations of schools participating in theTuition Assistance Program, however, according to DOD, the evaluations did notprovide the agency the information it needed to assess schools. This is becauseDOD lacked a specific plan to frame the evaluations, which according to federalstandards, should clearly define the evaluation questions and methodology andaddress the collective knowledge, skills, and experience needed by the entityconducting the evaluations. According to DOD’s contract, evaluations were toassess school quality, but the 15 areas DOD provided the contractor forevaluation were often not clearly defined and it was not clear what the contractorwas to evaluate. For example, one of the areas was the “degree of congruence”among various entities involved in delivering educational services, which DODprovided the contractor without further specificity. Further, because DOD’scontract did not specify all the skills needed by the contractor, DOD had tomodify its contract to require such skills. However, still lacking information itneeds, DOD recently decided not to renew the contract. DOD has suspended theevaluations and is exploring alternative options for evaluating schools, but doesnot yet have a plan to guide future efforts. Absent a plan, it will be difficult forDOD to have all of the information it needs to effectively evaluate schools.A Participant in a DOD Education ProgramWhat GAO RecommendsGAO recommends that DOD develop aplan for future school evaluations.DOD agreed with the recommendation.View GAO-14-855. For more information,contact Melissa Emrey-Arras, (617) 788-0534,emreyarrasm@gao.gov.United States Government Accountability Office

ContentsLetter1BackgroundIn Fiscal Year 2013, 571 Advisors Provided Information onPrograms and Educational Support to Nearly 280,000 EligibleService MembersEvaluations of Schools Participating in the Programs Do NotProvide DOD with Information Needed for AssessmentConclusionsRecommendation for Executive ActionAgency Comments and Our Evaluation13161617Selected Statistics Related to Active Duty Service Members andAdvisors for the Military Tuition Assistance Program, Fiscal Years2011 through 201319Appendix II:DOD’s Required Basic Qualifications of Military Service Advisors20Appendix III:Information on Selected Guidance the Services Provided About theRole of DOD Advisors21Appendix IV:Fifteen Areas Covered by the DOD Contractor Evaluations23Appendix V:Evaluation Contract Modifications to Address Skills Required24Appendix VI:Comments from the Department of Defense25Appendix VII:GAO Contact and Staff Acknowledgments29Appendix I:Page i37GAO-14-855 DOD Education Benefits

FiguresFigure 1: Number of Advisors and Service Members Participatingin the Tuition Assistance Program, Fiscal Year 2013Figure 2: Sources of Information Available to Service Members inthe Tuition Assistance PAMOUVADefense Activity for Non-Traditional Education SupportDepartment of DefenseDepartment of EducationFree Application for Federal Student AidFull Time Equivalentgrade point averagememorandum of understandingDepartment of Veterans AffairsThis is a work of the U.S. government and is not subject to copyright protection in theUnited States. The published product may be reproduced and distributed in its entiretywithout further permission from GAO. However, because this work may containcopyrighted images or other material, permission from the copyright holder may benecessary if you wish to reproduce this material separately.Page iiGAO-14-855 DOD Education Benefits

441 G St. N.W.Washington, DC 20548September 8, 2014Congressional CommitteesThrough the Department of Defense’s (DOD) Tuition Assistance Program,active duty service members can pursue a postsecondary education andimprove their skills. In fiscal year 2013, DOD spent 540 million on theprogram, which allows service members to take courses from more than3,000 participating schools. 1 Service members can attend classes onlineor, in some cases, at schools located on the military base or in closeproximity to the base. As part of this program, education advisors withineach of the military services are made available to service members tohelp them with decisions regarding their education. DOD uses acontractor to evaluate the quality of participating schools and submit toDOD reports of schools with recommendations to improve the educationalservices.Congress mandated 2 that GAO provide information on the role andfunction of the services’ advisors and the nature of the findings from theschool evaluations. This report addresses (1) the number of advisors andthe type of advice they provide, and (2) the information collected byDOD’s contractor in assessing and reporting on the schools participatingin the Tuition Assistance Program.For our first objective, we analyzed, for each of the four services, trenddata from fiscal years 2011 through 2013 on the number of advisorsavailable (full-time equivalents or FTEs). 3 We collected these data directly1The authorizing statute uses the term “educational institutions” (10 U.S.C. § 2007(a))and various additional terms are used in other contexts, but for ease of readabilitythroughout this report we generally use the term “schools.”2Senate Report No.113-85 at 35 (2013).3We analyzed DOD data for the Air Force, Army, Navy, and Marine Corps. Because dataon the Coast Guard is not collected by DOD, we did not include them in our study. We areusing “advisors” to refer to three types of positions that provide some type of advisorysupport to service members—Education Specialists, Counselors (or Advisors), andEducation Service Officers.Page 1GAO-14-855 DOD Education Benefits

from each service. 4 For the same time period, we also analyzedinformation from DOD’s Voluntary Education Management InformationSystem on the number of service members enrolled in the TuitionAssistance Program. To assess the reliability of the data on advisors andservice members, we reviewed relevant documents and interviewedprogram officials. We determined that they were sufficiently reliable forthe purposes of this report. Further, for each service, we met with officialsto discuss the advisors’ role and any guidance provided to advisors andmethods of delivering advice to service members (i.e., in person, and onwebsites). In addition, we visited Joint Base Andrews, Maryland—with7,134 service members assigned to the base during fiscal year 2013, ofwhich 2,223 were enrolled in classes under the Tuition AssistanceProgram—where we met with advisors to better understand the nature ofthe advice they provide service members and how education services aredelivered. We selected this installation because (1) a large number of itsservice members were enrolled in classes, (2) five schools offeredclasses on base, and (3) the schools providing classes to servicemembers on the base and the installation were recently evaluated byDOD’s contractor.For our second objective, we reviewed the 23 evaluations of schoolsconducted for DOD under the current contract, covering fiscal years 2012through 2013. 5 We also reviewed the information that DOD provided tothe contractor and interviewed the contractor’s staff, and reviewed theevaluation contract and related contract documentation. We alsocompared the contract and related documentation to federal evaluationstandards and principles established by the American Evaluation4We collected these data directly from each military service because we determined thatdata on advisors from DOD’s Voluntary Education Management Information System werenot sufficiently reliable for the purposes of this report.5At the time of our review, only three evaluations from fiscal year 2014 had beencompleted, which we included in our review of evaluations.Page 2GAO-14-855 DOD Education Benefits

Association. 6 In addition, for fiscal years 2012 through 2013, we reviewedthe contractor’s recommendations resulting from these evaluations. Todetermine how the evaluations and recommendations were used, weinterviewed DOD officials and officials for the four services and reviewedrelevant federal laws and regulations, as well as other relevantdocuments.We conducted this performance audit from April through August 2014 inaccordance with generally accepted government auditing standards.Those standards require that we plan and perform the audit to obtainsufficient, appropriate evidence to provide a reasonable basis for ourfindings and conclusions based on our audit objectives. We believe thatthe evidence obtained provides a reasonable basis for our findings andconclusions based on our audit objectives.BackgroundDOD’s military Tuition Assistance Program helps active duty servicemembers—some of whom may regularly be reassigned to anotherlocation, including overseas—pursue an education. 7 Through partnershipagreements between DOD and more than 3,000 schools, during off-dutyhours, service members are able to take undergraduate, graduate,vocational, licensure, certificate, and language courses. They may alsocomplete their high school education, if necessary. 8 The majority ofservice members who participate in the program are enrolled inundergraduate courses.The Undersecretary of Defense for Personnel and Readiness within DODis responsible for implementing the Tuition Assistance Program, which6See American Evaluation Association Guiding Principles for Evaluators, July 2004. TheAmerican Evaluation Association is an international professional association of evaluatorswhose mission is to improve evaluation practices and methods, increase evaluation use,and promote evaluation as a profession. Also, see Quality Standards for Inspection andEvaluation, Councils for the Inspectors General on Integrity and Efficiency, 2011; Centersfor Disease Control and Prevention, Program Performance and Evaluation Office,Program Evaluation Steps, Aug. 3, 2011; GAO, Designing Evaluations: 2012 Revision,GAO-12-208G (Washington, D.C.: Jan. 2012); and GAO, Internal Control Standards:Internal Control Management and Evaluation Tool, GAO-01-1008G (Washington, D.C.:Aug. 2001).7Service members who are deployed overseas are able to participate in the TuitionAssistance Program by, for example, taking classes online.8Voluntary education programs are authorized by 10 U.S.C. §§ 2005 and 2007.Page 3GAO-14-855 DOD Education Benefits

includes the provision of educational counseling for service members. 9However, each military service is responsible for establishing andoperating its own program. Through 195 education centers located onU.S. military bases, advisors are available to provide assistance andinformation to service members pursuing their education. These basesalso make classroom space available for service members to takeclasses on base, although the majority of service members enroll inonline classes.To participate in the program, service members must meet certainrequirements. In consultation with an advisor, they must develop aneducation goal and education plan, and maintain a 2.0 grade pointaverage (GPA) for undergraduate-level courses and a 3.0 GPA forgraduate-level courses. Service members can receive up to 250 intuition assistance per credit hour, with a maximum of 4,500 each year. Ifthe cost of tuition exceeds the amount that the program provides, servicemembers are eligible for other federal financial aid, such as federal grantsand loans, to cover their expenses. Tuition is paid directly to the schoolsby DOD, and if a service member fails to complete a course or receives afailing grade, the student must pay back the money for those courses.Schools participating in the military Tuition Assistance Program must signDOD’s Voluntary Education Partnership memorandum of understanding(MOU), 10 which requires, among other things, that the schools (1) beaccredited by a national or regional accrediting agency recognized by theDepartment of Education (Education); 11 (2) comply with state932 C.F.R. § 68.4(c).10The MOU requirement was introduced through a final DOD instruction on March 15,2011. DoDI 1322.25, Voluntary Education Programs. The instruction was then included ina final regulation published December 7, 2012 (Voluntary Education Programs, 77 Fed.Reg. 72,941), but participating schools with an MOU under the March 2011 instructionscould continue to operate under it or sign a new MOU. Participating schools without anMOU under the March 2011 instructions that wished to participate in the program wereultimately given until March 1, 2013 to sign a new MOU. On May 15, 2014, DODpublished another final regulation revising the MOU, and all schools wishing to participatein the program were generally given 60 days to sign a revised one. Voluntary EducationPrograms, 79 Fed. Reg. 27,732.11Institutional accreditation is a peer review evaluative process that compares a schoolagainst its accrediting agency’s standards regarding such matters as school resources,admissions requirements, and student achievement. Institutions must be accredited by anaccrediting agency recognized by the Secretary of Education in order to participate infinancial aid programs administered by Education.Page 4GAO-14-855 DOD Education Benefits

authorization requirements consistent with Education regulations; 12 (3) becertified to participate in federal student aid programs authorized underTitle IV of the Higher Education Act of 1965; 13 (4) disclose basicinformation about the school’s programs and costs, including tuition, fees,and other charges to service members; and (5) undergo, when requested,an evaluation of the quality of the education programs it is providing toservice members. 14DOD contracts with an independent entity to assess the quality ofpostsecondary educational programs and services used by servicemembers to assist in the improvement of these educational programs andservices. In accordance with contract requirements, the contractor was toconduct evaluations of individual postsecondary schools. Also, forselected military bases that have a school on the base, the contractorwas to evaluate all of the schools located on a single base and thefacilities and operations of that base that support these schools and thedelivery of education services to service members. Specifically, each yearDOD required: four evaluations of military bases (with limited scopeevaluations of the schools located on the base); two evaluations ofdistance learning (or online) schools; and four evaluations of schoolslocated in close proximity to the base.12In order to participate in Title IV federal student aid programs, schools must be legallyauthorized within a state to provide postsecondary education. 20 U.S.C. § 1001. OnOctober 29, 2010, Education published final regulations describing the statutoryrequirements for state authorization. Program Integrity Issues, 75 Fed. Reg. 66,832.These regulations generally provide, among other things, that schools are legallyauthorized in a state where they are located if the state has a process to review andappropriately act on complaints concerning the school, including enforcing applicable statelaws. 34 C.F.R. § 600.9. The original effective date was July 1, 2011, but it was laterdelayed until July 1, 2014, for any school whose state authorization does not meet therequirements of the regulations but is taking steps to meet them. Institutional EligibilityUnder the Higher Education Act of 1965, as Amended; Delay of Implementation Date, 78Fed. Reg. 29,652. Finally, on June 24, 2014, Education further delayed implementation forthose schools until July 1, 2015. Institutional Eligibility Under the Higher Education Act of1965, as Amended; Delay of Implementation Date, 79 Fed. Reg. 35,692.1320 U.S.C. §§ 1070-1099d and 42 U.S.C. §§ 2751 – 2756b. This particular requirementwas added by the final rule published May 15, 2014. Voluntary Education Programs, 79Fed. Reg. 27,732. While schools were generally given 60 days to sign revised MOUs,those with current MOUs that are not certified to participate in federal student aidprograms authorized under Title IV of the Higher Education Act, but have initiated theirapplications with the Department of Education, were given 18 months to meet thisrequirement.1432 C.F.R. pt. 68, appendix A.Page 5GAO-14-855 DOD Education Benefits

Education is responsible for the administration of all federal student aidunder Title IV 15 of the Higher Education Act of 1965. Under that act,Education has oversight of the more than 7,200 postsecondary schools 16that participate in federal student aid programs, including those thatparticipate in DOD’s Tuition Assistance Program (but not with respect tocompliance with DOD’s requirements). Specifically, Education mustcertify a school’s eligibility to participate in federal student aid bydetermining that the school is accredited by an accrediting agency itrecognizes, is authorized to operate within a state, and meets certainadministrative and financial requirements. 17 In addition, postsecondaryschools that provide federal student aid are subject to program reviews byEducation, which are made available on its website. Education alsomaintains websites that provide publicly available information aboutschools that participate in federal student aid programs authorized underTitle IV of the Higher Education Act of 1965, including graduation rates,default rates, and costs. 18 In addition to Education reviews, these schoolsare subject to compliance and financial audits by independent auditors.Lastly, the Department of Veterans Affairs’ (VA) Post-9/11 VeteransEducational Assistance Program (Post-9/11 GI Bill) is similar to DOD’sprogram, but l

September 2014 GAO-14-855 . standards, should clearly define the evaluation questions and methodology and address the collective knowledge, skills, and experience needed by the entity . DOD reports of schools with recommendations to improve the educational services. 2:

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