June 11, 2012

Our country's military and veteran students have a right to choose the school and education that best meets their needs and goals.  They deserve the right to make informed choices based on transparent disclosure of information, including providing access to critical data about educational programs and outcomes.  All institutions of higher education, regardless of their tax status, should be held accountable to high standards in this regard.  To this end, APSCU supports the following Five Tenets of Veterans Education:


As part of the Chapter 38 vocational and education counseling process, the Department of Veterans Affairs (VA) should be required to provide counseling to all prospective students, including unbiased, comprehensive educational disclosures before the individual receives their education benefit, except in cases where an individual declines such services.  Further, Chapter 38 counseling should include at a minimum, but not be limited to, information on the federal and state educational benefits and aid available, financial literacy and student loan debt counseling, and the importance of developing an academic plan with the institution.  The VA should provide the counseling to eligible individuals in a clear, easily accessible format to assist prospective students in making sound postsecondary education choices.


Prior to student enrollment or the incurrence of any financial obligation, all institutions of higher education should disclose and make readily available through their catalogs, websites, and other resources that specifically pertain to all individuals eligible for military or veteran education benefits the following information:

  • If the institution participates in the Yellow Ribbon Program;
  • If the institution is a Servicemember Opportunity Colleges (SOC) Consortium Member;
  • If the institution signed the Department of Defense (DoD) Memorandum of Understanding (MOU);
  • If any student veteran organizations have been created;
  • If the institution offers reduced tuition rates to military students;
  • Military-specific scholarships or programs provided by the institution; 
  • Leave of absence and refund policies that apply to military and veteran students;
  • A comprehensive description of academic and student support services available to military and veteran students, including job placement and career counseling services;  
  • Number of degrees and certificates conferred to military and veteran students in each of the three  most recent academic years; 
  • Percent of military and veteran students enrolled in degree or certificate programs who complete within normal, 150 percent, or 200 percent of the normal time for each of the three most recent academic years;
  • Placement rates for individuals eligible for military and veteran education benefits and available for placement;
  • State licensure program passage rates, to the extent states make such data publicly available; and
  • An explanation that transfer of academic credit is at the discretion of the receiving institution.


The VA's centralized complaint system should be developed with input from other veteran-education stakeholders to assist in ensuring that student complaints are addressed effectively and in a timely manner.  The complaint system must ensure that there is accountability and transparency for all parties involved (i.e. complaints should not be anonymous), and that the due process rights of institutions are appropriately balanced with respecting the privacy and expediency of the veteran students’ complaints.  Creation of such a system should also be implemented through a public rulemaking process by the VA.

In addition, APSCU believes that all institutions of higher education enrolling military and veteran students should have a clearly defined process for military and veteran students to communicate grievances and to discuss other concerns.  This process should be outlined in public documents such as the university catalog, website or other appropriate vehicles accessible to military and veteran students and should include a point of contact at the institution.


The Government Accountability Office (GAO) currently has two studies underway examining a number of issues related to VA education programs, including what is known about student outcomes. However, before a clear picture has been provided about the academic outcomes of our veteran population, the recent Executive Order requires use of the Consumer Financial Protection Bureau's (CFPB), “Know Before You Owe” form as a resource for both military and veteran populations to understand the academic and student outcomes of an institution, all derived from the Department of Education’s Integrated Postsecondary Education Data System (IPEDS). All sectors of higher education, and the military and veteran education communities, are in strong agreement that IPEDS does not adequately reflect the unique, nontraditional, military and veteran student population.  Additionally, the “Know Before You Owe” form is not sufficiently nuanced to reflect the complexity of military and veteran educational assistance, nor does it reflect crucial student demographics, such as Pell-eligibility.  In fact, the “Know Before You Owe” prototype sheet does not reference military or veteran benefits at all.  Rather than providing the resources and information prospective students would need to make sound educational decisions, they will instead receive incomplete, misrepresentative data that will likely cause more confusion than assistance.  Following the conclusion of the GAO study, APSCU extends an invitation to the Administration, Capitol Hill, and the higher education and veteran education communities to work collaboratively to fix the current data-collection system and then create a form that is representative, accurate, and serves as a true resource for all prospective students.


APSCU would lead an initiative to convene a series of panels—inviting other stakeholders to participate—to identify, collect, discuss, and document practices and programs that meet the unique needs of veteran students, foster persistence, and enable them to meet their academic and professional goals.  The agreed-upon information would be condensed into a clear, practical set of “best practices” and guidelines for all institutions of higher education to consider and adopt as a “good housekeeping-like” seal of approval for their school.


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PSCUs open doors to many of the 9 million unemployed and 90 million undereducated Americans by providing a skills-based education. To remain competitive over the next decade, we must identify between 8 and 23 million new workers with postsecondary skills. PSCUs are a necessary part of that solution, having produced over 800,000 degrees last year alone.