United States Government Accountability Office

GAO Report to the Ranking Minority 

Member, Committee on Veterans’ 

Affairs, U.S. Senate 

VA STUDENT 

FINANCIAL AID 

Management Actions 

Needed to Reduce 

Overlap in Approving 

Education and 

Training Programs 

and to Assess State 

Approving Agencies 

March 2007 

 

GAO-07-384 
Contents 

Letter 1

Appendix I Briefing Slides 6 

Appendix II Comments from the Department of Veterans Affairs 34 

Appendix III GAO Contact and Staff Acknowledgments 36 

Abbreviations 

Education Department of Education 

IHL institution of higher learning 

Labor Department of Labor 

NASAA National Association of State Approving Agencies 

OJT on-the-job training 

RPO regional processing office 

SAA state approving agency 

SAC state apprenticeship council 

VA Department of Veterans Affairs 

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Page i GAO-07-384 VA Student Financial Aid
United States Government Accountability Office

Washington, DC 20548 

 

March 8, 2007

The Honorable Larry E. Craig 

Ranking Minority Member 

Committee on Veterans’ Affairs 

United States Senate 

Dear Senator Craig: 

In fiscal year 2006, the Department of Veterans Affairs (VA) paid 

approximately $2.1 billion in education assistance benefits to more than 

470,000 beneficiaries and about $19 million to state approving agencies 

(SAA) to assess whether schools and training programs offer education of 

sufficient quality for veterans to receive VA education assistance benefits 

when attending them. Qualified individuals—veterans, service persons, 

reservists, and certain spouses and dependents—receive benefits through 

a number of education assistance programs for the pursuit of various 

types of programs, such as a degree program, vocational program, 

apprenticeship, or on-the-job training. In general, these programs must be 

approved by an SAA in order for qualified individuals to receive VA 

education assistance benefits. Under contracts with the VA, SAAs ensure 

that education and training programs meet federal VA standards through a 

variety of approval activities, such as evaluating course quality, assessing 

school financial stability, and monitoring student progress. 

In fiscal year 2006, the Department of Veterans Affairs (VA) paid 

approximately $2.1 billion in education assistance benefits to more than 

470,000 beneficiaries and about $19 million to state approving agencies 

(SAA) to assess whether schools and training programs offer education of 

sufficient quality for veterans to receive VA education assistance benefits 

when attending them. Qualified individuals—veterans, service persons, 

reservists, and certain spouses and dependents—receive benefits through 

a number of education assistance programs for the pursuit of various 

types of programs, such as a degree program, vocational program, 

apprenticeship, or on-the-job training. In general, these programs must be 

approved by an SAA in order for qualified individuals to receive VA 

education assistance benefits. Under contracts with the VA, SAAs ensure 

that education and training programs meet federal VA standards through a 

variety of approval activities, such as evaluating course quality, assessing 

school financial stability, and monitoring student progress. 

The Departments of Education (Education) and Labor (Labor) also assess 

education and training programs for various purposes, primarily for 

awarding student aid and providing apprenticeship assistance. These 

assessments are based, in part, on evaluations against standards set by 

laws and regulations, such as those applicable to accrediting agencies. In 

2006, under Title IV of the Higher Education Act, Education provided 

nearly $77 billion in student aid in the form of both grants and loans. The 

Department of Education assesses and certifies postsecondary institutions 

for participation in Title IV programs through various oversight functions 

to ensure that these schools meet federal administrative and financial 

requirements and that they are accredited and licensed. Similarly, under 

the National Apprenticeship Act of 1937, the Department of Labor is 

authorized to formulate and promote the furtherance of labor standards to 

safeguard the welfare of apprentices. To ensure programs comply with 

federal standards, Labor directly registers and oversees apprenticeship 

programs in less than half of the states and has given state apprenticeship

The Departments of Education (Education) and Labor (Labor) also assess 

education and training programs for various purposes, primarily for 

awarding student aid and providing apprenticeship assistance. These 

assessments are based, in part, on evaluations against standards set by 

laws and regulations, such as those applicable to accrediting agencies. In 

2006, under Title IV of the Higher Education Act, Education provided 

nearly $77 billion in student aid in the form of both grants and loans. The 

Department of Education assesses and certifies postsecondary institutions 

for participation in Title IV programs through various oversight functions 

to ensure that these schools meet federal administrative and financial 

requirements and that they are accredited and licensed. Similarly, under 

the National Apprenticeship Act of 1937, the Department of Labor is 

authorized to formulate and promote the furtherance of labor standards to 

safeguard the welfare of apprentices. To ensure programs comply with 

federal standards, Labor directly registers and oversees apprenticeship 

programs in less than half of the states and has given state apprenticeship

Page 1 GAO-07-384 VA Student Financial Aid
agencies or councils in the remaining states such authority over their own 

programs. 

Given each agency’s role, the potential of duplicative efforts among federal 

agencies has been a congressional concern. In 1995, GAO reported on this 

matter and concluded that there was a substantial amount of overlap 

between the efforts of SAAs and the other federal agencies.1

 In light of 

continued congressional interest in this issue, we have now answered the 

following questions: (1) What changes have occurred in state approving 

agencies’ duties and functions since 1995? (2) To what extent does the 

SAA approval process overlap with efforts by the Departments of 

Education and Labor? (3) What, if any, additional value do the SAA 

approval activities bring to VA education benefit programs? 

To address all three questions, we reviewed legislation, regulations, 

federal guidance, and other documents relevant to the approval processes 

for education and training programs. We also interviewed officials from 

each of the entities involved in the approval processes of VA, Education 

and Labor. Specifically, we interviewed federal officials from VA, 

Education, and Labor as well as officials representing three SAAs, three 

institutions of higher learning (IHL), and state apprenticeship councils in 

Connecticut, Maryland, and Washington. We also interviewed officials 

from one IHL that operates in multiple states and officials from the 

National Association of State Approving Agencies (NASAA), an accrediting 

agency (Accrediting Commission of Career Schools and Colleges of 

Technology), the Connecticut state licensing agency, and three 

apprenticeship programs (in Connecticut, Illinois, and Maryland). We 

selected Connecticut, Washington, Illinois, and Maryland based on VA’s 

recommendation of knowledgeable SAA officials, to include both state and 

federally monitored states for apprenticeship programs, and geographic 

diversity. To identify the programs that were approved by the Departments 

of Veterans Affairs, Education, and Labor, we compiled and analyzed data 

on approved programs from each of the three agencies. To assess the 

reliability of the data, we talked with knowledgeable officials in each of 

the agencies, reviewed relevant documentation, and performed electronic 

testing of files. We determined that the data we have included in this 

briefing were sufficiently reliable for this purpose. We conducted our work 

 1

GAO, VA Student Financial Aid: Opportunity to Reduce Overlap in Approving 

Education and Training Programs, GAO/HEHS-96-22 (Washington, D.C.: Oct. 30, 1995). 

Page 2 GAO-07-384 VA Student Financial Aid
from October 2006 to January 2007 in accordance with generally accepted 

government auditing standards. 

On February 1, 2007, we briefed your office on the results of our analysis.

This report formally conveys information provided during that briefing, 

which is contained in appendix I. In summary, we reported the following 

findings: 

• Since 1995, legislative changes effective in 2001 created additional 

responsibilities for SAAs, including promoting the development of 

apprenticeship and on-the-job training programs, providing outreach 

services, and approving tests for occupational licensing.2

 From fiscal 

years 2003 to 2006, SAA funding increased from $13 million to 

$19 million to expand services and support the additional 

responsibilities. However, funding is scheduled to decrease beginning 

in fiscal year 2008. 

• Many education and training programs approved by SAAs have also 

been approved by Education or Labor, and VA and SAAs have taken 

few steps to coordinate approval activities with these agencies. In 

addition, information is not available to determine the amount of 

resources spent on SAA duties and functions, including those that may 

overlap with other agencies and programs. 

• SAAs reportedly add value to the approval process for education and 

training programs through (1) a focus on student services for veterans 

and on the integrity of VA benefits, (2) more frequent on-site 

monitoring of education and training programs than provided by 

Education or Labor, and (3) assessments and approval of a small 

number of programs that are not reviewed by other agencies. However, 

VA’s lack of outcome-oriented performance measures for evaluating 

SAAs makes it difficult to assess the significance of these efforts. 

In conclusion, while VA spends $19 million (less than 1 percent of the total 

benefit amount) to fund SAA duties and functions, it does not track the 

amount it spends on specific SAA activities, especially those that may also

be performed by other agencies. Without knowing the amount of 

resources spent on specific duties and functions, VA does not have all 

relevant information for making resource allocation decisions and cannot 

determine if it is spending its federal dollars efficiently and effectively. In 

addition, VA, Education, and Labor have various standards and processes 

 2

Veterans Benefits and Health Care Improvement Act of 2000, Pub. L. No. 106-419 (2000); 

and Veterans Education and Benefits Expansion Act of 2001, Pub. L. No. 107-103 (2001). 

Page 3 GAO-07-384 VA Student Financial Aid
in place, in part to ensure that federal funds are being spent on quality 

education and training programs. While we have identified some overlap in

approval efforts across agencies, the full extent of the overlap between 

SAA duties and other agencies’ oversight efforts is unknown. It is 

important that VA work with other federal agencies to determine how the 

scope of the approval process could be streamlined to reduce overlap and

ensure that federal dollars are spent efficiently. Finally, it is difficult to 

assess the effectiveness of SAA activities, in part because VA does not 

have outcome measures in place to fully evaluate SAA performance. 

Evaluating the effectiveness of VA’s approval process is vitally important 

in order to manage the program and improve program results. 

To help ensure that federal dollars are spent efficiently and effectively, we

are recommending that the Secretary of the Department of Veterans 

Affairs take steps to monitor SAA spending and identify whether any 

resources are spent on activities that duplicate the efforts of other 

agencies. The extent of these actions should be in proportion to the total 

resources of the program. Specifically: 

• VA should require SAAs to track and report data on resources spent on 

approval activities such as site visits, catalog review, and outreach in a 

cost-efficient manner; and 

• VA should collaborate with other agencies to identify any duplicative 

efforts and use the agency’s administrative and regulatory authority to 

streamline the approval process. 

In addition, we are recommending that the Secretary establish outcomeoriented performance measures to assess the effectiveness of SAA efforts. 

We provided a draft of this report to officials of the U.S. Department of 

Veterans Affairs for review and comment. In addition, we provided a draft 

of this report to officials of the U.S. Departments of Education and Labor 

for their technical review. In written comments on a draft of this report, 

VA agreed with our findings and recommendations and stated that it will 

(1) establish a working group with the SAAs to create a reporting system 

to track and report data for approval activities with a goal of 

implementation in fiscal year 2008, (2) initiate contact with appropriate 

officials at the Departments of Education and Labor to identify any 

duplicative efforts, and (3) establish a working group with the SAAs to 

develop outcome-oriented performance measures with a goal of 

implementation in fiscal year 2008. While VA stated that it will initiate 

contact with officials at Education and Labor to identify duplicative 

efforts, it also noted that amending its administrative and regulatory 

Page 4 GAO-07-384 VA Student Financial Aid
authority to streamline the approval process may be difficult due to 

specific approval requirements of the law. We acknowledge these 

challenges and continue to believe that collaboration with other federal 

agencies could help VA reduce duplicative efforts. In addition, VA may 

wish to examine and propose legislative changes needed to further 

streamline its approval process. 

Labor provided technical comments and we incorporated them into this 

report where appropriate. 

We are sending copies of this report to relevant congressional committees 

and other interested parties and will make copies available to others upon 

request. In addition, this report will be available at no charge on GAO’s 

Web site at 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 that made 

major contributions to this report are listed in appendix III. 

Sincerely, 

George A. Scott 

Acting Director 

Education, Workforce, and Income Security Issues 

Page 5 GAO-07-384 VA Student Financial Aid
Appendix I: Briefing Slides Appendix I: Briefing Slides 

1

VA Student Financial Aid: Management

Actions Needed to Reduce Overlap in

Approving Education and Training Programs

and to Assess State Approving Agencies

Briefing for Staff of 

Senator Larry Craig, Ranking Minority Member

Committee on Veterans’ Affairs

United States Senate

February 01, 2007

Page 6 GAO-07-384 VA Student Financial Aid
Appendix I: Briefing Slides 

Page 7 GAO-07-384

2

Objectives

Since the 1940s, the Department of Veterans Affairs (VA) and its predecessor agencies 

have contracted with state approving agencies (SAA) to assess whether schools

and training programs offer education of sufficient quality for veterans to receive

VA education assistance benefits. SAAs are created or designated by state

governments but are federally funded and responsible for enforcing federal law.

Concerns have been raised about whether SAA approval activities are duplicative 

of efforts conducted under other federal programs.

Key questions

• What changes have occurred in State Approving Agencies’ duties and functions 

since 1995?

• To what extent does the SAA approval process overlap with efforts by the 

Departments of Education and Labor?

• What, if any, additional value do the SAA approval activities bring to veterans’ 

education benefit programs?

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 8 GAO-07-384

3

Scope and Methodology

To address our key questions, we:

• Reviewed legislation, regulations, federal guidance, and other documents relevant to

the approval processes for education and training programs.

• Compiled and analyzed data on approved programs from the Departments of

Veterans Affairs, Education, and Labor.

• Interviewed federal officials from VA, Education, and Labor.

• Interviewed officials representing three SAAs, three institutions of higher learning 

(IHL), and state apprenticeship councils in Connecticut, Maryland, and Washington. 

We also interviewed one IHL that operates in multiple states.

• Interviewed officials from the National Association of State Approving Agencies 

(NASAA), an accrediting agency (Accrediting Commission of Career Schools and

Colleges of Technology), Connecticut state licensing agency, and three

apprenticeship programs (in Connecticut, Illinois, and Maryland).

• Our work was performed from October 2006 to January 2007 in accordance with

generally accepted government auditing standards.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 9 GAO-07-384

4

Summary of Findings

• Since 1995, legislative changes effective in 2001 created additional 

responsibilities for SAAs, including promoting the development of

apprenticeship and on-the-job training programs, providing 

outreach services, and approving tests for occupational licensing.

• Many education and training programs approved by SAAs have 

also been approved by Education or Labor, and VA and SAAs have 

taken few steps to coordinate approval activities with these 

agencies.

• SAAs reportedly add value to the approval process for education 

and training programs, but the lack of outcome-oriented

performance measures makes it difficult to assess the significance

of their efforts.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 10 GAO-07-384

5

VA Funding for Education Assistance

Programs and SAAs

• In fiscal year 2006, VA provided

over $2.1 billion in educational

assistance benefits to more than

470,000 beneficiaries.

• In the same year, SAAs received 

$19 million to assess the quality of

schools and training programs for

veterans.

Reserve Educational 23,747 $151,397,610

Assistance Program

(Chapter 1607)

Total 477,765 $2,147,974,691

Veterans Educational 575 $59,113

Assistance Program

(Chapter 32)

Dependents and 74,532 $38,787,332

Survivors Educational 

Assistance Program

(Chapter 35)

Educational 65,145 $48,716,031

Assistance for the 

Selected Reserve 

(Chapter 1606)

Montgomery GI Bill 313,766 $1,909,014,605

(Chapter 30)

Programs * Beneficiaries Expenditures

Background

*No payments for the National Call to Service program were made in fiscal year 2006. Source: VA.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 11 GAO-07-384

6

VA Education Assistance Programs

• Benefits are designed to assist individuals in gaining access

to postsecondary education or training for a specific

occupation. Benefits can be used to pursue a degree

program, vocational program, apprenticeship, and on-the-job 

training.

• Qualified individuals include veterans, service persons, 

reservists, and certain spouses and dependents.

Background

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 12 GAO-07-384

7

Veteran Enrollment by Program Type in Fiscal 

Year 2006

Background

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 13 GAO-07-384

8

Agencies Responsible for the Approval 

Process for Education and Training Programs

Background

Source: GAO Analysis. 

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 14 GAO-07-384

9

VA’s Approval Process: Purpose and 

Responsible Entities 

• Purpose – To ensure education and training programs meet VA standards for receipt of veteran 

education assistance benefits.

• Entities, Roles and Responsibilities

• VA national office oversees the four regional processing offices (RPO) and national

contract with SAAs.

• RPOs administer the education assistance programs and process benefits for veterans.

• SAAs review education and training programs to determine which programs should be

approved and ensure schools and training providers are complying with VA standards.

• Duties and functions – SAAs have six core duties: (1) approval of programs,

(2) visits to facilities, (3) technical assistance to individuals at facilities,

(4) outreach, (5) liaison with other service providers, and (6) contract management.

• Structure – 60 SAAs exist in the 50 states, the District of Columbia, and Puerto Rico. 

Eight states have two SAAs. SAAs are usually part of a state’s department of

education (31 SAAs). In some states, SAAs are organizationally located in other 

departments such as labor (9 SAAs) or veterans’ services 

(19 SAAs).*

Background

* The Washington, D.C. SAA office is overseen by VA.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 15 GAO-07-384

10

Education’s Approval Process: Purpose and 

Responsible Entities 

• Purpose –To ensure schools meet federal Education standards to participate in the student 

financial aid programs. As part of Education’s approval process, the state licensing agencies, 

accrediting agencies, and certain offices within Education are responsible for various approval

activities.

• Entities, Roles and Responsibilities

• State licensing agencies grant legal authority to postsecondary institutions to operate in the 

state in which they are located. Each of the states has its own agency structure, and each 

state can choose its own set of standards.

• Accrediting agencies develop evaluation criteria and conduct peer evaluations to assess 

whether or not those criteria are met by postsecondary institutions. Institutions and/or

programs that meet an agency's criteria are then "accredited" by that agency. As of 

November 2005, there are 60 recognized private accrediting agencies of regional or 

national scope.

• Office of Postsecondary Education evaluates and recognizes accrediting agencies based 

on federal requirements to ensure these agencies are reliable authorities as to the quality 

of education or training provided by the institutions of higher education and the higher

education programs they accredit.

• Office Federal Student Aid determines the administrative and financial capacity of schools 

to participate in student financial aid programs, conducts ongoing monitoring of participant 

schools, and ensures participant schools are accredited and licensed by the states.

Background

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 16 GAO-07-384

11

Labor’s Approval Process: Purpose and 

Responsible Entities

• Purpose – To establish and promote labor standards to safeguard the 

welfare of apprentices.

• Entities, Roles and Responsibilities

• Department of Labor establishes standards and registers programs

that meet the standards. Labor directly registers and oversees 

programs in 23 states but has granted 27 states, the District of

Columbia, and 3 territories authority to register and oversee their own 

programs, conducted by State Apprenticeship Councils (SACs). Labor 

reviews the activities of the SACs. 

• SACs ensure that apprenticeship programs for their respective states

comply with federal labor standards, equal opportunity protections, and

any additional state standards.

Background

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 17 GAO-07-384

12

Legislative Changes Effective in 2001 Created Additional 

Responsibilities for SAAs, Including Promoting the Development of

Apprenticeship and On-the-Job Training Programs, Providing Outreach 

Services, and Approving Tests for Occupational Licensing

In 2001, SAAs received additional responsibility for:

• Actively promoting the development of apprenticeship and on-the-job training 

programs.

• Conducting more outreach activities to eligible persons and veterans to increase

awareness of VA education assistance.

• Approving tests used for licensing and certification, such as tests to become a

licensed electrician. (For those tests that have been approved, veterans can use 

VA benefits to pay for testing fees.) 

From fiscal years 2003 to 2006, SAA funding increased from $13 million to $19 million

to expand services and support the additional responsibilities. Funding will begin to

decrease in fiscal year 2008.

Objective One: Changes in SAA duties and functions

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 18 GAO-07-384

13

• Many education and training programs approved by SAAs have also been 

approved by Education and Labor.

• Similar categories of approval standards, such as student achievement

and institutional capacity (e.g., fiscal stability), exist across agencies, but 

the specific standards within each category vary and the full extent of the 

overlap is unknown.

• VA and SAAs have made limited efforts to coordinate approval activities 

with other federal agencies.

• Information is not available to determine the amount of resources spent on 

SAA duties and functions, including those that may overlap with other 

agencies.

Objective Two: Overlap in Approval Efforts

Many Education and Training Programs Approved by SAAs Have

Also Been Approved by Education or Labor, and VA Has Taken Few 

Steps to Coordinate Approval Activities with These Agencies.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 19 GAO-07-384

14

Many Education and Training Programs Approved by SAAs Have

Also Been Approved by Education and Labor

69% of all programs approved by SAAs are offered by institutions that

have been certified by Education. 

• 78% of SAA approved programs in institutions of higher learning 

(e.g., colleges and universities) have been certified by Education. 

• 64% of SAA approved non-college degree programs are in 

institutions that have been certified by Education. 

Less than 2% of all programs approved by SAAs are apprenticeship

programs. VA and SAA officials reported that many of these 

programs have also been approved by Labor.

Objective Two: Overlap in Approval Efforts

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 20 GAO-07-384

15

Similar Categories of Standards Exist Across Agencies,

but the Specific Standards within Each Category Vary and 

the Full Extent of Overlap is Unknown

Similar categories of standards exist across agencies.1

Objective Two: Overlap in Approval Efforts

Source: GAO analysis of VA, Education, and Labor Standards

Note: GAO constructed these categories to encompass the numerous and broad range of standards used by agencies.

1SAA has different sets of standards for each program type (e.g. IHL and NCD). Education’s approval process involves different sets of

standards used by different entities, such as accrediting agencies. Labor has one set of standards that is applicable to apprenticeship

programs. 2By statute, courses must meet certain criteria. These relate to: (1) record-keeping of student progress; (2) record-keeping of

students’ previous education; (3) quality, content and length of courses; (4) qualifications of administrators and instructors; and (5)

equipment, space, and instructional materials. We categorized the first two criteria as student achievement, criteria (3) and (4) as Curricula,

Program Objectives and Faculty, and criterion (5) as Institutional objectives, capacity, and administration. 3SAA approval requirements for 

non-accredited courses encompass a number of additional criteria, such as having a tuition refund policy and enrollment limitations. 4

Connecticut’s standards may not be representative of standards across the country.

Categories of approval standards SAA23 Education4 Labor IHL/NCD accredited IHL/NCD non-accredited apprenticeship On the job training

Education’s certification Federal Standardsfor AccreditingAgencies Connecticut statelicensing agency

Apprenticeship

Student achievement X X X X X X X 

Curricula, program objectives, and faculty X X X X X X X X 

Facilities, equipment, and supplies X X X X X X X 

Institutional objectives, capacity, and 

administration 

X X X X X X 

Student support services X X 

Recruiting and admissions practices X X X X X X 

Record of student complaints X X 

Process related requirements (e.g. application 

requirements)

X X X X X X X 

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 21 GAO-07-384

16

Similar Categories of Standards Exist Across Agencies, 

but the Specific Standards within Each Category Vary and 

the Full Extent of Overlap Is Unknown

Specific standards within each category vary across agencies.

• For example, while VA and Education’s approval standards 

have requirements for student achievement, the New England 

Association of Schools and Colleges, an accrediting agency,

requires that students demonstrate competence in various 

areas such as writing and logical thinking, and VA does not 

have this requirement. 

• Also under student achievement, VA requires schools to give 

appropriate credit for prior learning while Education does not

have such a requirement.

Objective Two: Overlap in Approval Efforts

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 22 GAO-07-384

17

Similar Categories of Standards Exist Across Agencies, 

but the Specific Standards within Each Category Vary and 

the Full Extent of Overlap Is Unknown

While agencies have the same standards in some instances, the 

interpretation and application of these standards may differ. 

For example:

• VA, accrediting agencies, and Labor require that facilities have

adequate space, equipment and instructor personnel to provide 

quality training, but the definition of adequacy differs in the level 

of specificity.

• VA and accrediting agencies require that schools have policies 

related to student achievement such as minimum satisfactory 

grades, but the requirements differ in level of specificity.

Objective Two: Overlap in Approval Efforts

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 23 GAO-07-384

18

VA and SAAs Have Made Limited Efforts to

Coordinate Approval Activities with Education and

Labor

• VA reported that while it has coordinated with Education and Labor on

issues related to student financial aid and apprentices’ skill requirements, 

it believes increased coordination is needed for approval activities in order 

to determine the extent of duplicative efforts.

• Most of the SAA officials we spoke with reported that they have

coordinated with SACs to register apprenticeship programs in their states. 

• Labor reported that it coordinated with VA’s national office in several 

instances, including providing a list of registered apprenticeship programs.

• Education reported that it does not have formalized coordination with VA 

but has had some contacts to inform VA of its concerns regarding specific 

institutions.

Objective Two: Overlap in Approval Efforts

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 24 GAO-07-384

19

• VA does not require SAAs to collect information on the amount 

of resources they spend on specific approval activities. 

• The SAA officials we spoke with said that their most time 

consuming activity is conducting inspection and supervisory

visits of schools and training facilities. 

• Lack of data on resource allocation prevented us from 

determining what portion of funds spent by SAAs were for

approval activities that may overlap with other agencies.

Objective Two: Overlap in Approval Efforts

Information Is Not Available to Determine the Amount of Resources 

Spent on SAA Duties and Functions, Including Those That May Overlap

with Other Agencies

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 25 GAO-07-384

20

SAAs Reportedly Add Value to the Approval Process for Education and 

Training Programs, but the Lack of Outcome-oriented Performance 

Measures Makes It Difficult to Assess the Significance of Their Efforts

• SAA and other officials reported that SAA activities add value

because they provide enhanced services to veterans and 

ensure program integrity.

• VA uses output measures rather than outcome-oriented

performance measures to evaluate SAA performance and 

progress.

Objective Three: Value of SAA Services

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 26 GAO-07-384

21

SAA and other Officials Reported that SAA Activities Add Value 

because They Provide Services to Veterans and Ensure Program 

Integrity 

SAA and other officials reported SAAs’ added value includes:

• A focus on student services for veterans and on VA benefits; 

• More frequent on-site monitoring of education and training 

programs than Education and Labor; and 

• Assessments and approval of a small number of programs 

that are not reviewed by other agencies.

Objective Three: Value of SAA Services

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 27 GAO-07-384

22

SAA approval activities:

• Ensure that veterans are taking courses consistent with occupational goals 

and program requirements.

• Ensure that schools and training programs have evaluated prior learning

and work experience and grant credit as appropriate.

• Ensure that school or program officials know how to complete paperwork 

and comply with policies required by VA educational assistance through 

technical assistance.

States, schools, and apprenticeship officials we spoke with reported that

without SAAs, the quality of education for veterans would not change;

however, their receipt of benefits could be delayed and the time required to

complete their education and training programs could increase.

Objective Three: Value of SAA Services

The SAA Approval Activities Focus on Student 

Services for Veterans and on VA Benefits

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 28 GAO-07-384

23

SAAs Generally Conduct More Frequent On-Site Monitoring of 

Education and Training Programs Than Education and Labor

Oversight of veterans assistance is generally

more frequent than oversight by Education 

and Labor, which may prevent fraud, waste,

and abuse.

• Some officials reported that SAAs’ frequent

visits were beneficial because they ensure

schools properly certify veterans for benefits,

ensuring that benefits are distributed

accurately and quickly.

• Officials from one school reported that SAAs’

visits were unnecessary because many

schools are sufficiently monitored by their

accreditors and Education.

1 Education also performs ongoing monitoring by reviewing schools’ 

annual compliance audits and financial statements.

2 Accrediting agencies’ frequencies vary depending on whether the

agency is a national or regional agency.

3 Labor –See Registered Apprenticeship Programs: Labor Can 

Better Use Data to Target Oversight , GAO-05-886

(Washington D.C.: August 29, 2005).

Objective Three: Value of SAA Services

SAA 1-3 years

1-3+ years Labor 3

2-10 years Ac 2 crediting

agencies

Only schools that 

have performance 

issues are visited1

Education

VA’s RPOs 3 years

Frequency of site

visits to each

school

Entity

Source: GAO analysis.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 29 GAO-07-384

24

SAAs approve a small number of programs that are not

reviewed by other agencies:

• Programs, such as cosmetology and massage training, offered 

by unaccredited schools.

• On-the-job training programs.

• Apprenticeship programs not approved by Labor.

SAAs Approve a Small Number of Programs That Are 

Not Reviewed by Other Agencies

Objective Three: Value of SAA Services

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 30 GAO-07-384

25

VA Uses Output Measures Rather Than Outcome 

Measures to Evaluate SAA Performance and Progress

Although VA does have some output

measures in place, such as the 

number of supervisory visits SAAs 

conduct, it does not have outcomeoriented performance measures to

evaluate the overall effectiveness

and progress of SAAs.

Completion rates of 

beneficiaries

Number of approved facilities 

with approved programs

Error rate of certification 

transactions identified by 

SAAs

Number of times technical

assistance provided to 

interested parties such as

individuals and schools

Amount of benefit

adjustments resulting from 

SAAs’ review of school 

certification transactions 

Percentage of visits to 

facilities for supervisory and

inspection purposes 

completed within VA specified 

timeframes

Examples of

Potential Outcome 

Measures

Examples of Existing

VA output Measures

Objective Three: Value of SAA Services

Source: GAO analysis.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 31 GAO-07-384

26

Conclusions

• While VA spends $19 million (less than 1% of total benefit amount) to fund

SAA duties and functions, it does not track the amount it spends on specific 

SAA activities, especially those that may be performed by other agencies. Without knowing the amount of resources spent on specific duties and 

functions, VA does not have all relevant information for making resource 

allocation decisions and cannot determine if it is spending its federal dollars 

efficiently and effectively.

• VA, Education, and Labor have various standards and processes in place, 

in part to ensure that federal funds are being spent on quality education and 

training programs. While we have identified some overlap in approval

efforts across agencies, the full extent of the overlap between SAA duties

and other agencies’ oversight efforts is unknown. It is important that VA 

work with other federal agencies to determine how the scope of the 

approval process could be streamlined, such as to determine the extent to

which SAAs could rely on recognized accreditors’ assessments of

institutions’ policies on student achievement to reduce overlap and ensure

that federal dollars are spent efficiently.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 32 GAO-07-384

27

Conclusions (Cont’d)

It is difficult to assess the effectiveness of SAA activities, in part 

because VA does not have outcome measures in place to fully

evaluate SAA performance, such as the outcomes of site visits. 

Under the Government Performance Results Act, federal agencies

must report on their results in achieving their agency program 

goals. Outcome-oriented performance measures are should be

used to assess program activity. Evaluating the effectiveness of 

VA’s approval process is vitally important in order to manage the 

program and improve program results.

VA Student Financial Aid
Appendix I: Briefing Slides 

Page 33 GAO-07-384

28

Recommendations for Executive Action

To help ensure that federal dollars are spent efficiently and effectively, we are

recommending that the Secretary of the Department of Veterans Affairs take 

steps to monitor its spending and identify whether any of its resources are 

spent on activities that duplicate the efforts of other agencies. The extent of 

these actions should be in proportion to the total resources of the program. 

Specifically:

• VA should require SAAs to track and report data on resources spent on 

approval activities such as site visits, catalog review, and outreach in a 

cost-efficient manner.

• VA should collaborate with other agencies to identify any duplicative 

efforts and use the agency’s administrative and regulatory authority to

streamline the approval process.

In addition, we are recommending that the Secretary establish outcomeoriented performance measures to assess the effectiveness of SAA efforts.

VA Student Financial Aid
Appendix II: Comments from the Department Appendix II: Comments from the Department of Veterans Affairs 

of Veterans Affairs 

Page 34 GAO-07-384 VA Student Financial Aid
Appendix II: Comments from the Department 

of Veterans Affairs 

Page 35 GAO-07-384 VA Student Financial Aid
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 36 GAO-07-384

Appendix III: GAO Contact and Staff 

Acknowledgments 

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

In addition to the contact named above, Heather McCallum Hahn, 

Assistant Director, Tranchau T. Nguyen, Jacqueline Harpp, Cheri 

Harrington, Richard Burkard, Susannah Compton, John Mingus, and Jim 

Rebbe made key contributions to this report. 

VA Student Financial Aid

GAO Contact 

Staff 

Acknowledgments 

(130609) 
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