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KEEPING COLLEGE WITHIN REACH: SUPPORTING 

HIGHER EDUCATION OPPORTUNITIES FOR 

AMERICA’S SERVICEMEMBERS AND VETERANS 

HEARING 

BEFORE THE

SUBCOMMITTEE ON HIGHER EDUCATION 

AND WORKFORCE TRAINING 

COMMITTEE ON EDUCATION 

AND THE WORKFORCE 

U.S. HOUSE OF REPRESENTATIVES

ONE HUNDRED THIRTEENTH CONGRESS 

FIRST SESSION 

HEARING HELD IN WASHINGTON, DC, SEPTEMBER 11, 2013 

Serial No. 113–31 

Printed for the use of the Committee on Education and the Workforce 

( 

Available via the World Wide Web: 

www.gpo.gov/fdsys/browse/committee.action?chamber=house&committee=education 

or 

Committee address: http://edworkforce.house.gov 

CEWDOCROOM with DISTILLER

(II) 

COMMITTEE ON EDUCATION AND THE WORKFORCE 

JOHN KLINE, Minnesota, Chairman 

Thomas E. Petri, Wisconsin 

Howard P. ‘‘Buck’’ McKeon, California 

Joe Wilson, South Carolina 

Virginia Foxx, North Carolina 

Tom Price, Georgia 

Kenny Marchant, Texas 

Duncan Hunter, California 

David P. Roe, Tennessee 

Glenn Thompson, Pennsylvania 

Tim Walberg, Michigan 

Matt Salmon, Arizona 

Brett Guthrie, Kentucky 

Scott DesJarlais, Tennessee 

Todd Rokita, Indiana 

Larry Bucshon, Indiana 

Trey Gowdy, South Carolina 

Lou Barletta, Pennsylvania 

Martha Roby, Alabama 

Joseph J. Heck, Nevada 

Susan W. Brooks, Indiana 

Richard Hudson, North Carolina 

Luke Messer, Indiana 

George Miller, California, 

Senior Democratic Member 

Robert E. Andrews, New Jersey 

Robert C. ‘‘Bobby’’ Scott, Virginia 

Rube ́n Hinojosa, Texas 

Carolyn McCarthy, New York 

John F. Tierney, Massachusetts 

Rush Holt, New Jersey 

Susan A. Davis, California 

Rau ́l M. Grijalva, Arizona 

Timothy H. Bishop, New York 

David Loebsack, Iowa 

Joe Courtney, Connecticut 

Marcia L. Fudge, Ohio 

Jared Polis, Colorado 

Gregorio Kilili Camacho Sablan, 

Northern Mariana Islands 

John A. Yarmuth, Kentucky 

Frederica S. Wilson, Florida 

Suzanne Bonamici, Oregon 

Juliane Sullivan, Staff Director 

Jody Calemine, Minority Staff Director 

SUBCOMMITTEE ON HIGHER EDUCATION AND WORKFORCE TRAINING 

VIRGINIA FOXX, North Carolina, Chairwoman 

Thomas E. Petri, Wisconsin 

Howard P. ‘‘Buck’’ McKeon, California 

Glenn Thompson, Pennsylvania 

Tim Walberg, Michigan 

Matt Salmon, Arizona 

Brett Guthrie, Kentucky 

Lou Barletta, Pennsylvania 

Joseph J. Heck, Nevada 

Susan W. Brooks, Indiana 

Richard Hudson, North Carolina 

Luke Messer, Indiana 

Rube ́n Hinojosa, Texas, 

Ranking Minority Member 

John F. Tierney, Massachusetts 

Timothy H. Bishop, New York 

John A. Yarmuth, Kentucky 

Suzanne Bonamici, Oregon 

Carolyn McCarthy, New York 

Rush Holt, New Jersey 

Susan A. Davis, California 

David Loebsack, Iowa 

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(III) 

C O N T E N T S 

Page 

Hearing held on September 11, 2013 ..................................................................... 1 

Statement of Members: 

Foxx, Hon. Virginia, Chairwoman, Subcommittee on Higher Education 

and Workforce Training ............................................................................... 1 

Prepared statement of ............................................................................... 3 

Hinojosa, Hon. Rube ́n, Ranking Minority Member, Subcommittee on 

Higher Education and Workforce Training ................................................ 4 

Prepared statement of ............................................................................... 9 

Statement of Witnesses: 

Kirk, Arthur F., Jr., president, Saint Leo University ................................... 24 

Prepared statement of ............................................................................... 25 

Kitchner, Dr. Russell S., vice president for regulatory and governmental 

relations, on behalf of American Public University System ...................... 27 

Prepared statement of ............................................................................... 30 

Rhinehardt, Kimrey, the University of North Carolina ................................ 10 

Prepared statement of ............................................................................... 13 

Sauer, Ken, Ph.D., senior associate commissioner for research and academic affairs, Indiana Commission for Higher Education ........................ 71 

Prepared statement of ............................................................................... 73 

Additional Submissions: 

Chairwoman Foxx, questions submitted for the record to: 

Dr. Kirk ...................................................................................................... 88 

Dr. Kitchner ............................................................................................... 90 

Mrs. Rhinehardt ........................................................................................ 93 

Mr. Hinojosa: 

Petraeus, Hollister K., Assistant Director, Consumer Financial Protection Bureau Office of Servicemember Affairs, prepared statement of .................................................................................................... 5 

Hudson, Hon. Richard, a Representative in Congress from the State 

of North Carolina, questions submitted for the record to Mrs. 

Rhinehardt ..................................................................................................... 93 

Loebsack, Hon. David, a Representative in Congress from the State of 

Iowa, questions submitted for the record to: 

Dr. Kirk ...................................................................................................... 88 

Dr. Kitchner ............................................................................................... 90 

Mrs. Rhinehardt ........................................................................................ 93 

Dr. Sauer .................................................................................................... 95 

Response to questions submitted: 

Dr. Kirk ...................................................................................................... 89 

Dr. Kitchner ............................................................................................... 90 

Mrs. Rhinehardt ........................................................................................ 93 

Dr. Sauer .................................................................................................... 95 

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(1) 

KEEPING COLLEGE WITHIN REACH: 

SUPPORTING HIGHER EDUCATION 

OPPORTUNITIES FOR AMERICA’S 

SERVICEMEMBERS AND VETERANS 

Wednesday, September 11, 2013 

U.S. House of Representatives 

Subcommittee on Higher Education and Workforce Training 

Committee on Education and the Workforce 

Washington, DC 

The subcommittee met, pursuant to call, at 12:03 p.m., in Room 

2175, Rayburn House Office Building, Hon. Virginia Foxx [chairwoman of the subcommittee] presiding. 

Present: Representatives Foxx, Walberg, Salmon, Heck, Brooks, 

Hinojosa, Tierney, Yarmuth, Bonamici, Holt, and Loebsack. 

Also present: Representative Kline. 

Staff present: Katherine Bathgate, Deputy Press Secretary; 

Heather Couri, Deputy Director of Education and Human Services 

Policy; Amy Raaf Jones, Education Policy Counsel and Senior Advisor; Brian Melnyk, Professional Staff Member; Krisann Pearce, 

General Counsel; Nicole Sizemore, Deputy Press Secretary; Emily 

Slack, Legislative Assistant; Alex Sollberger, Communications Director; Alissa Strawcutter, Deputy Clerk; Tylease Alli, Minority 

Clerk/Intern and Fellow Coordinator; Kelly Broughan, Minority 

Education Policy Associate; Jamie Fasteau, Minority Director of 

Education Policy; Melissa Greenberg, Minority Staff Assistant; Eunice Ikene, Minority Staff Assistant; Brian Levin, Minority Deputy 

Press Secretary/New Media Coordinator; Megan O’Reilly, Minority 

General Counsel; Rich Williams, Minority Education Policy Advisor; and Michael Zola, Minority Deputy Staff Director. 

Chairwoman FOXX. A quorum being present, the subcommittee 

will come to order. Good afternoon—it is just barely afternoon—and 

thank you for joining us today for our hearing on higher education 

opportunities for veterans and servicemembers. 

Before we begin, I would like to take a moment to remember the 

thousands of American lives that were lost on this day in 2001 and 

for the Americans who lost their lives during the terror attack in 

Benghazi last year. We will never forget them. 

The men, women, and children who died will ever be in our 

thoughts and we will continue to pray for peace for their families. 

So I ask everyone to join my colleagues here for a moment of silence. 

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2 

Thank you. 

Mr. HINOJOSA. May I make a remark on that? 

Chairwoman FOXX. You certainly may. 

Mr. HINOJOSA. Thank you, Chairwoman Foxx. 

As we commemorate September 11th, I join my colleagues in the 

House and the Senate in honoring and remembering the lives of 

the victims and families of this terrible tragedy. Although it has 

been 12 years since the events of 9/11, our nation must never forget the men, the women, and children who lost their lives on that 

day. 

Chairwoman FOXX. Thank you. 

As we pause to remember the past today, it is fitting that we 

also hold this hearing to explore how we can move forward by supporting the brave men and women who serve the country, and especially those who have served in the wake of 9/11. 

America’s veterans face unique challenges as they return to civilian life. Some struggle with disabilities and combat stress injuries 

as a result of their service. Many others are older than traditional 

college students, work full time, or have a family to support. 

Beginning with the enactment of the G.I. Bill in 1944, the federal 

government has implemented a number of programs and initiatives 

to support servicemembers and veterans who wish to earn a postsecondary degree or obtain valuable job skills. This commitment to 

our men and women in uniform continues to grow with the Post9/11 G.I. Bill, which provides financial support to help cover the 

cost of tuition, fees, books, and housing at all types of colleges and 

universities. 

Since 2009 the Post-9/11 G.I. Bill has helped nearly 1 million veterans and their families access a postsecondary education, and as 

more troops return from Iraq and Afghanistan, postsecondary institutions now face the largest influx of student veterans on campus 

since World War II. The higher education community has a responsibility to tailor programs and coursework to ensure the needs of 

this unique student population are met and taxpayer resources are 

used wisely and efficiently. 

Fortunately, many schools are rising to the challenge. A growing 

number of postsecondary institutions now offer more flexible course 

schedules, the ability for veterans to earn credit for skills learned 

outside the classroom, and online coursework that can be completed on a student’s own time. Other institutions—proprietary 

schools in particular—are working with the business community to 

craft targeted programs that help veterans learn the skills necessary to compete for in-demand jobs in the local economy. 

In my home state, University of North Carolina’s Partnership for 

National Security not only coordinates with state business leaders 

but also works directly with military partners to develop a number 

of initiatives geared toward supporting our men and women in uniform, including special degree programs, pre-deployment education 

courses, internships, and fellowships. 

Additionally, the UNC SERVES program collects data to provide 

university leaders with a better understanding of the needs and 

outcomes of the active duty and veteran student population. This 

information will help prospective students make more informed decisions about their postsecondary pathway and it will also encourCEWDOCROOM with DISTILLER

3 

age institutions to establish special outreach efforts such as student groups, orientation events, and counseling offices that help 

veterans successfully transition into academic life. 

With the Higher Education Act due for reauthorization next 

year, today’s hearing provides a valuable opportunity to highlight 

institutional efforts to support veterans and servicemembers while 

also exploring potential policy changes that could strengthen the 

law. We have an excellent panel of witnesses with us today, and 

I look forward to their testimony. 

I now recognize my colleague, Mr. Ruben Hinojosa, the senior 

Democrat member of this subcommittee, for his opening remarks. 

[The statement of Chairwoman Foxx follows:] 

Prepared Statement of Hon. Virginia Foxx, Chairwoman, 

Subcommittee on Higher Education and Workforce Training 

Good afternoon, and thank you for joining us today for our hearing on higher education opportunities for veterans and servicemembers. 

Before we begin, I would like to take a moment to remember the thousands of 

American lives that were lost on this day in 2001, and for the Americans who lost 

their lives during the terror attack in Benghazi last year. We will never forget them. 

The men, women, and children who died will ever be in our thoughts, and we will 

continue to pray for peace for their families. I ask my colleagues to join me for a 

moment of silence. 

Thank you. As we pause to remember the past today, it is fitting that we also 

hold this hearing to explore how we can move forward by supporting the brave men 

and women who have served our country in the wake of 9/11. America’s veterans 

face unique challenges as they return to civilian life. Some struggle with disabilities 

and combat stress injuries as a result of their service. Many others are older than 

traditional college students, work full time, or have a family to support. 

Beginning with the enactment of the GI bill in 1944, the federal government has 

implemented a number of programs and initiatives to support servicemembers and 

veterans who wish to earn a postsecondary degree or obtain valuable job skills. This 

commitment to our men and women in uniform continues to grow with the Post9/11 GI Bill, which provides financial support to help cover the cost of tuition, fees, 

books, and housing at all types of colleges and universities. 

Since 2009, the Post-9/11 GI Bill has helped nearly one million veterans and their 

families access a postsecondary education. And as more troops return from Iraq and 

Afghanistan, postsecondary institutions now face the largest influx of student veterans on campus since World War II. 

The higher education community has a responsibility to tailor programs and 

coursework to ensure the needs of this unique student population are met and taxpayer resources are used wisely and efficiently. Fortunately, many schools are rising 

to the challenge. 

A growing number of postsecondary institutions now offer more flexible course 

schedules, the ability for veterans to earn credit for skills learned outside the classroom, and online coursework that can be completed on a student’s own time. Other 

institutions, proprietary schools in particular, are working with the business community to craft targeted programs that help veterans learn the skills necessary to 

compete for in-demand jobs in their local economy. 

In my home state, the University of North Carolina’s Partnership for National Security not only coordinates with state business leaders, but also works directly with 

military partners to develop a number of initiatives geared toward supporting our 

men and women in uniform, including special degree programs, pre-deployment education courses, and internships and fellowships. 

Additionally, the UNC SERVES program collects data to provide university leaders with a better understanding of the needs and outcomes of the active-duty and 

veteran student population. This information will help prospective students make 

more informed decisions about their postsecondary pathway, and it will also encourage institutions to establish special outreach efforts such as student groups, orientation events, and counseling offices that help veterans successfully transition into 

academic life. 

With the Higher Education Act due for reauthorization next year, today’s hearing 

provides a valuable opportunity to highlight institutional efforts to support veterans 

and servicemembers, while also exploring potential policy changes that could 

CEWDOCROOM with DISTILLER

4 

strengthen the law. We have an excellent panel of witnesses with us today, and I 

look forward to their testimony. I would now like to recognize my colleague, Mr. 

Rube ́n Hinojosa, the senior Democrat member of the subcommittee, for his opening 

remarks. 

Mr. HINOJOSA. Thank you, Chairwoman Foxx. 

I view today’s hearing as an opportunity to discuss how institutions and higher education systems are responding to the unique 

needs and services of our veterans. With this in mind, I welcome 

our distinguished group of panelists for joining us for this widely 

important discussion. 

As ranking member of this subcommittee, I am pleased that an 

increasing number of veterans are enrolling in college. In my view, 

Congress has a responsibility to support the more than 2 million 

soldiers who are returning from the wars of Iraq and Afghanistan. 

Our nation must help them transition to civilian life. 

Unfortunately, some for-profit companies and lenders are preying 

on servicemembers and veterans to cash in on their G.I. benefits. 

Veterans are especially attractive to for-profit colleges because G.I. 

Bill benefits are not Title IV funds and, therefore, allow institutions almost entirely relying on Title IV funds to meet the 90/10 

requirements—90-slash-10 requirements. 

In fact, Holly Petraeus, of the Consumer Financial Protection Bureau, has accused certain for-profit colleges of viewing veterans as 

nothing more than dollar signs in uniform. In 2011 for-profit colleges collected 1 of every 2 dollars in the military assistance program. For-profit colleges enroll 13 percent of all students receiving 

Title IV aid but account for almost half of all federal loan defaults. 

It is also worth noting that national veterans organizations, including the American Legion, are concerned that some for-profit 

colleges utilize federal education aid to pay for recruiting and for 

marketing. The American Legion has correctly pointed out that the 

core educational programs suffer when a disproportionate percentage of tuition is used towards marketing expenses. 

While my colleagues on the other side of the aisle may insist that 

federal regulations are burdensome and that they discourage innovation, I strongly believe that Congress must have federal regulations in place to protect veterans and servicemembers from unscrupulous companies and institutions and lenders. We owe veterans 

and servicemembers nothing less. 

And while I applaud President Obama for issuing an executive 

order establishing principles of excellence for educational institutions serving our servicemembers, veterans, spouses, and other 

family members, Congress and the administration, in my opinion, 

must do more to ensure that these principles are enforced and that 

servicemembers and veterans are well served by these federal benefits and programs. 

A critically important issue that some of our panelists will address today is the issue of credentialing of veteran experience. As 

you know, there are national organizations such as the American 

Council on Education, known as ACE, and state collaboratives that 

help institutions translate military experience into credit hours. 

With more than 2 million servicemembers returning from combat, colleges can do more to award credit hours for their past servCEWDOCROOM with DISTILLER

5 

ice experience. Improved articulation agreements can also help 

servicemembers transfer credits from community colleges to 2-year 

colleges with more ease. 

In closing, I want to recognize the veterans and servicemembers 

in my congressional districts—veterans like Harry Brunell, who 

served in World War II, who served in Korea, and he also served 

in Vietnam. I want to thank them for their courage and dedication 

to the nation. 

At this time I would like to enter into the record a copy of Hollister K. Petraeus’ recent testimony before the U.S. Senate Committee on Veterans Affairs on July 31, 2013. 

[The information follows:] 

Prepared Statement of Hollister K. Petraeus, Assistant Director, 

Consumer Financial Protection Bureau Office of Servicemember Affairs 

Before the U.S. Senate Committee on Veterans’ Affairs, July 31, 2013 

Chairman Sanders, Ranking Member Burr, and distinguished Members of the 

Committee, thank you for the opportunity to speak with you today about the Office 

of Servicemember Affairs at the Consumer Financial Protection Bureau (Bureau). 

Many of you already know me as I’ve testified before you on other committees, 

and I’ve also had the opportunity to visit with some of you in your home states. But 

for those of you who are not familiar with my office, I’d like to take a few moments 

to tell you what we do. 

As defined in the Dodd-Frank Act, the Office of Servicemember Affairs at the Bureau is responsible for: 

• Developing and implementing initiatives to educate and empower 

servicemembers and their families to make better-informed decisions regarding consumer financial products and services; 

• Monitoring military complaints about consumer financial products and services, 

including the Bureau and other federal or state agency responses to those complaints; and 

• Coordinating the efforts of Federal and State agencies regarding consumer protection measures relating to consumer financial products and services offered to, or 

used by, servicemembers and their families. 

Concerning our education mission, in an effort that I think would be of interest 

to this committee, my team worked with the Department of Defense (DoD) to create 

a financial module to be included in the recently revised Transition Assistance Program for those departing the military. 

And, in a logical follow-on, this year we’re working on an initiative to offer financial coaching services to recently-transitioned veterans, to ensure they have some 

professional financial-planning support during the economically vulnerable time 

after they leave the service. 

As for our complaint monitoring, from July 21, 2011 through July 6, 2013, the 

Bureau received approximately 4,516 complaints from veterans and their family 

members. The complaint volume from veterans has steadily increased over time, 

with 262 complaints received in 2011, 2,315 in 2012, and 1,939 complaints in the 

first six months of 2013. About 49 percent of the complaints from veterans have 

been mortgage complaints, followed by 18 percent credit card complaints, and 13 

percent bank account or service complaints. We only started accepting complaints 

about credit-reporting companies in October 2012, but credit reporting is already the 

4th highest complaint category for veterans at 8 percent, and is trending upward. 

We have helped veterans who filed complaints secure hundreds of thousands of 

dollars in monetary relief. We’ve also assisted many others to obtain non-monetary 

relief, for example having errors on a credit report corrected, which helps them resolve problems that may have been affecting them for months or even years. 

But these complaint statistics aren’t just numbers to us: they represent military 

and veteran families and we know the impact consumer financial issues can have 

on their quality of life. In one complaint, a veteran from North Carolina was struggling with his bank for months over a fee of nearly 2,000 that should have been 

waived because he was disabled. Within weeks of his filing a complaint with the 

Bureau, the bank removed the fee and refunded the veteran for the interest that 

was charged in error. Although we can’t promise specific results, I encourage 

servicemembers, veterans, retirees, and military spouses to go to 

consumerfinance.gov and file a complaint if they are having problems with a mortCEWDOCROOM with DISTILLER

6 

gage, credit card, student loan, or other consumer financial product. And I think it’s 

fair to say that our Consumer Response team is making a real difference for many 

veterans and their families. 

As to my office’s third mission—coordinating with other federal and state agencies—I have spent a significant amount of time doing just that. Our Office of Servicemember Affairs has worked with federal agencies such as the Department of the 

Treasury and the Federal Housing Finance Agency on mortgage issues, with the Department of Justice (DOJ) on Servicemembers Civil Relief Act issues, and with the 

Department of Veterans Affairs (VA) concerning veterans’ issues. And obviously, my 

staff and I talk all the time with DoD. 

In the states, I’ve had great support from the Attorneys General, with 16 of them 

personally joining me at events in military communities. In fact, on July 1st I was 

at MacDill Air Force Base in Florida at the invitation of Attorney General Pam 

Bondi to watch Governor Scott sign a bill to provide enhanced penalties for those 

who use deceptive or unfair trade practices in their dealings with servicemembers, 

veterans, and their families. 

I’ve also had a very good relationship with the state directors of Veterans Affairs, 

meeting with almost a dozen of them in their home states as well as addressing 

their national conference in May. And I work with the veterans’ service organizations (VSOs), as well. I’ve done presentations to the Iraq and Afghanistan Veterans 

of America, the Vietnam Veterans of America, and the American Legion. We have 

also had a couple of town halls specifically for VSOs and intend to do more. 

Speaking of town halls, I participated in a telephone town hall last year with Senator Manchin and Senator Rockefeller that reached thousands of veterans in the 

state of West Virginia, and I am eager to engage with veterans through initiatives 

such as these whenever I have the opportunity to do so. I should add that I have 

just added a veterans’ outreach specialist to my staff so we can do more work on 

consumer protections and financial education for veterans. 

Now, let me talk specifically about the issues that have come up during my travels to 28 states and about 60 military communities, where I have heard directly in 

the past two years from servicemembers, veterans, military retirees, and their families. 

One issue that has been raised consistently throughout my travels is concern over 

aggressive marketing to military personnel, veterans, and their families by certain 

institutions of higher education seeking to attract individuals with access to GI Bill 

benefits. These institutions are pushing not only their educational programs, but 

also, in many cases, expensive private student loans to pay for the amount of tuition 

and fees not covered by the GI Bill. 

There is an extra incentive for for-profit colleges, in particular, to chase after military students because of the 90-10 proprietary college federal funding cap—a requirement that for-profit colleges get at least 10 percent of their revenue from 

sources other than Title IV federal education funds administered by the Department 

of Education (ED). Military GI Bill and Tuition Assistance benefits are not Title IV 

funds, so they fall into the 10 percent category that these colleges need to fill—and 

we have heard of some very aggressive tactics to put GI Bill recipients into classes. 

For example, a year ago when I was out in Nevada with Attorney General Catherine Cortez Masto, I spoke with a woman from the VA Regional Office there who 

was overseeing vocational rehabilitation for veterans. She told me that she had patients with traumatic brain injury (TBI) and post-traumatic stress disorder (PTSD) 

who had been persuaded to sign up for college classes, and didn’t even remember 

doing so. That didn’t stop the colleges from pressing them for full payment, even 

though they were not regularly attending classes. She said that some schools were 

also pushing her patients to enroll in master’s degree programs even though she believed they were not capable of doing the work at that time. Their tactics were aggressive enough that she described it as ‘‘tormenting veterans.’’ Obviously it distressed her to see her patients pressed to spend their GI Bill benefits in this manner. 

On the same topic, in April 2012 I went to Fort Stewart, Georgia to watch the 

President sign an Executive Order 13607, ‘‘Establishing Principles of Excellence for 

Educational Institutions Serving Service Members, Veterans, Spouses, and Other 

Family Members.’’ The order directed the Departments of Defense, Veterans Affairs, 

and Education, in consultation with the Bureau and the attorney general, to take 

steps to enable servicemembers, veterans and their families to get the information 

they need about the schools where they spend their education benefits. The order 

also strengthened oversight and accountability within the federal military and veterans’ educational benefits programs. 

I am pleased to report that there has been real progress since then, with DoD, 

ED, VA, DOJ, the Federal Trade Commission, and the Bureau working together to 

CEWDOCROOM with DISTILLER

7 

better protect and inform servicemembers, veterans, and military families about 

their education benefits. For example: • The term ‘‘GI Bill’’ has now been trademarked by the VA; • DoD has updated their rules to protect against aggressive commercial solicitation on military installations by educational institutions; and • ED has finalized the ‘‘Know Before You Owe Financial Aid Shopping Sheet,’’ enabling veterans to make better-informed decisions about paying for college and 

choosing a school. 

The state attorneys general have been active, too, filing suit against certain colleges for deceptive marketing and aggressive recruiting tactics. And 19 of them 

joined Kentucky Attorney General Jack Conway in filing suit against a company 

called Quin Street that had a number of lead-generation websites marketing to GI 

Bill recipients. In addition to paying a monetary settlement and changing misleading content on their sites, Quin Street agreed as part of the settlement to give 

the URL www.gibill.com to the VA. 

Certainly there is more work to be done, but I believe these and subsequent steps 

will help protect against some of the most egregious abuses we’ve seen in the past. 

That said, we intend to keep working with groups from the above agencies to see 

that the order is implemented in a way that best serves our military and veterans. 

Another area of concern that has arisen fairly frequently, both on my trips and 

via our complaint system, is that of financial institutions failing to provide 

Servicemembers Civil Relief Act (SCRA) protections to those who qualify for them. 

DOJ has explicit enforcement authority under SCRA, so we coordinate frequently 

with the DOJ Civil Rights Division and DoD concerning the SCRA-related components of the military complaints that we receive. In fact, my first testimony before 

Congress in this job was in February 2011 before the House Committee on Veterans’ 

Affairs and the subject of the hearing was the failure of the largest banks to provide 

SCRA entitlements to their military customers—both the interest-rate reduction to 

six percent and foreclosure protection. I also had the opportunity to take part in a 

panel hosted by Senator Rockefeller and Congressman Elijah Cummings discussing 

the impact on military readiness when SCRA protections are violated. 

Since then the state AGs, the Department of Housing and Urban Development 

(HUD) and DOJ have aggressively pursued this issue, resulting in a national mortgage settlement with the five largest mortgage lenders that was in part spurred by 

the lenders’ failure to comply with the provisions of the SCRA. While I commend 

the settlement and their continued vigilance, we do continue to see compliance concerns in the complaints that military/veteran consumers file with the Bureau. 

SCRA compliance problems are not limited to mortgage servicing; we’ve now identified other markets with similar problems. Most notably, in the student-loan servicing market, we’ve heard of lenders giving out incorrect or misleading information 

or even refusing to grant SCRA protections. Some examples: 

• Servicemembers being told (incorrectly) that they must provide a letter from 

their commanding officer or ‘‘certified’’ orders in order to receive the interest-rate 

reduction to six percent; 

• Officers being told to provide orders with an end date in order to receive the 

interest-rate reduction (officers’ orders usually don’t have end dates—they are indefinite); 

• The lender terminating the interest-rate reduction at the end of one year because the servicemember does not provide proof of continuing active-duty service 

(proof that is not required under the SCRA); 

• The lender placing the servicemember in forbearance automatically when SCRA 

rights are invoked, rather than simply providing the requested interest-rate reduction; and 

• The lender failing to comply with a servicemember’s request that the lender refund all the interest charged above 6 percent from the point of entry into activeduty military service. As long as the servicemember requests this SCRA protection 

within 180 days of leaving active duty, the lender must comply and issue a refund, 

no matter how long has passed since the servicemember entered active duty, even 

if it’s been months or years. 

We put out a report on this topic with the Bureau’s student loan ombudsman, 

along with an action guide for servicemembers. In the report we also raised concerns about an issue that arises when servicemembers attempt to replace older, preservice student loans with a new direct consolidation loan (to take advantage of federal student loan repayment options such as Income-Based Repayment or Public 

Service Loan Forgiveness). Unfortunately, the law as currently written does not convey the ‘‘pre-service obligation’’ status of the old loans to the new direct loan, which 

has the unfortunate result of forcing some servicemembers to choose between the 

SCRA protection of a lower interest rate on their old loans or the prospect of inCEWDOCROOM with DISTILLER

8 

come-based repayment and eventual loan forgiveness with a consolidated Direct 

Loan. 

And although it is not an SCRA issue, while we’re on the topic of student loans 

I wanted to raise a concern about veterans with private student loan debt who have 

been very severely injured during combat or at any time during their military service. It’s a sad fact that some veterans with the most severe disabilities will never 

be capable of obtaining or performing a job that will enable them to repay that private student loan debt. However, as the law now stands, it is very difficult for them 

to discharge those debts despite the reality of their medical condition. It seems a 

shame that federal student loans have such a provision for those with 100 percent 

disability, but there is currently no such relief for those who have private student 

loans. 

Another issue that I have heard about frequently on my trips throughout the U.S. 

concerns abuses connected with the veterans’ benefit known as Aid and Attendance, 

which I know this group is familiar with. I have heard from a number of State Veterans Affairs directors, starting with my trip to Montana at the invitation of Senator Tester in January 2012, that they are concerned about the increasing number 

of individuals and companies that use Aid and Attendance as a hook to sell their 

services to elderly veterans. I’d like to note a recent settlement by the Attorney General of Washington with three financial planning companies that were doing just 

that. These companies were offering help with obtaining Aid and Attendance but 

were requiring their customers to sign up for financial services first,—and then 

moving the veterans’ assets into irrevocable trusts but not fully informing the veterans of the risks of doing so. 

Aid and Attendance offers can take a variety of forms: 

• It may be an offer from a lawyer or ‘‘veterans’ advisor’’ to get the Aid and Attendance benefit for you—for a fee. In reality claims processing should be free, but 

in some cases veterans are being charged a ‘‘consultation fee’’ before the claim paperwork is begun. • It may be a claim from a paid advisor that they can get the benefit for you more 

quickly than anyone else. But all VA benefits claims have to go through the standard VA evaluation process, and no one can bypass the system to get your claim approved faster than usual. • It may involve offering to help you qualify for Aid and Attendance, if you have 

too much money, by taking control of your assets and moving them into a trust 

where you can’t access them, as in the case in Washington State. This, in turn, may 

disqualify you for other assistance such as Medicaid, and it also means that you 

can’t get at your money. In one outrageous example I was told about an advisor who 

locked one veteran’s money into an annuity that wouldn’t start paying out until he 

was well into his nineties! • Also, some retirement homes are now using the lure of Aid and Attendance to 

get veterans to move in on the premise that they will get Aid and Attendance and 

it will pay for everything. In cases where the claim is denied after the veteran has 

already spent money to move in, this leaves the veteran in the untenable position 

of being unable to afford to remain in the facility. 

We have also seen a flood of advertising in the past year urging those with VA 

home loans to refinance their homes. Veterans on my staff and elsewhere at the Bureau have received a torrent of these offers in the mail. We were concerned enough 

that the Bureau and the FTC did a joint sweep of the mortgage ads which resulted 

in letters to a number of lenders concerning potential violations of the Mortgage 

Acts and Practices—Advertising (MAP) Rule, with the potential for future enforcement actions by the Bureau and FTC. 

On a related note, I commend the FTC for its first enforcement action under the 

MAP Rule, announced June 27th, in which Mortgage Investors Corporation, a large 

refinancer of veterans’ home loans, must pay a $7.5 million penalty for allegedly 

calling consumers on the Federal Trade Commission’s National Do Not Call list, 

failing to remove consumers from its company call list upon demand, and misstating 

the terms of available loan products during telemarketing calls. 

One last area of concern is pension advances—offers to pay military retirees a 

lump-sum payout in return for their monthly retirement payments. These offers 

usually amount to pennies on the dollar, and may be in violation of the law regarding assignment of pension benefits, even though they are disguised as loans. If you 

go on the internet you will find them—often with patriotic-sounding names and the 

American flags on the website to match, but with a high cost for the retiree who 

takes them up on the offer. 

The Bureau has an Office of Financial Protection for Older Americans and my office is working with them on these issues. They have recently reported to Congress 

on the wide array of ‘‘elder financial advisor’’ designations that are in use and 

CEWDOCROOM with DISTILLER

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spotlighted the fact that many of them are not based on any sort of academic rigor 

or significant training—but may sound official to elderly consumers. 

To conclude, the Office of Servicemember Affairs is working hard to fulfill its mission to work on consumer financial education and consumer-protection measures for 

military personnel and their families, and we certainly want to include retirees and 

veterans in that number. We will press on to work with you and the states on existing problems and also address new issues as they arise. Our veterans and their families have done extraordinary service for our country, and, in return, it’s an honor 

for me and my staff to serve them through our work at the Office of Servicemember 

Affairs. 

Thank you for the opportunity to testify before the Committee. 

Chairwoman FOXX. Without objection. 

Mr. HINOJOSA. And I thank you. I yield back. 

[The statement of Mr. Hinojosa follows:] 

Prepared Statement of Hon. Rube ́n Hinojosa, Ranking Member, 

Subcommittee on Higher Education and Workforce Training 

Thank you, Chairwoman Foxx. 

As we commemorate September 11th, I join my colleagues in the House and Senate in honoring and remembering the lives of the victims and families of this terrible tragedy. Although it has been twelve years since the events of 9/11, our nation 

must never forget the men, women, and children who lost their lives on that day. 

Chairwoman Foxx, I view today’s hearing as an opportunity to discuss how institutions and higher education systems are responding to the unique needs and services of veterans. With this in mind, I welcome our distinguished group of panelists 

for joining us for this vitally important discussion. 

As Ranking Member of this subcommittee, I am pleased that an increasing number of veterans are enrolling in college. In my view, Congress has a responsibility 

to support the more than two million soldiers who are returning from the wars of 

Iraq and Afghanistan. Our nation must help them transition to civilian life. 

Unfortunately, some for-profit companies and lenders are preying on service members and veterans to cash in on their GI benefits. Veterans are especially attractive 

to for-profit colleges because GI Bill benefits are not Title IV funds, and, therefore, 

not affected by the 90/10 rule. In fact, Holly Petraeus of the Consumer Financial 

Protection Bureau (CFPB) has accused certain for-profit colleges of viewing veterans 

as nothing more than ‘‘dollar signs in uniform.’’ In 2011, for-profit colleges collected 

one of every two dollars in the Military Assistance program. 

For-profit colleges enroll 13 percent of all students receiving Title IV aid but account for almost half of all federal loan defaults. It is also worth noting that national veteran organizations, including the American Legion, are concerned that 

some for-profit colleges utilize federal education aid to pay for recruiting and marketing. The American Legion has correctly pointed out that core educational programs suffer when a disproportionate percentage of tuition is used toward marketing expenses. 

While my colleagues on the other side of the aisle may insist that federal regulations are burdensome and discourage innovation, I strongly believe that Congress 

must have federal regulations in place to protect veterans and service members 

from unscrupulous companies, institutions, and lenders. We owe veterans and service members nothing less. 

And while I applaud President Obama for issuing an executive order establishing 

principles of excellence for educational institutions serving service members, Veterans, Spouses, and other family members, Congress and the Administration must 

do more to ensure that these principles are enforced and that service members and 

veterans are well-served by these federal benefits and programs. 

A critically important issue that some of our panelists will address today is the 

issue of credentialing of veteran experience. As you know, there are national organizations such as the American Council on Education (ACE) and collaboratives that 

help institutions translate military experience into credit. With more than two million service members returning from combat, colleges can do more to award credit 

hours for their past service experience. 

Improved articulation agreements can also help service members transfer credits 

from community colleges to two year colleges with more ease. 

In closing, I want to recognize the veterans and service members in my congressional district—veterans like Harry Brunelle who served in WWII, Korea and Vietnam—for their courage and dedication to the nation. 

CEWDOCROOM with DISTILLER

10 

At this time, I would like to enter into the record a copy of Hollister K. Petraeus’s 

testimony before the U.S. Senate Committee on Veterans’ Affairs on July 31, 

2013.Thank you. 

Chairwoman FOXX. Thank you, Mr. Hinojosa. 

Pursuant to committee rule 7(c), all subcommittee members will 

be permitted to submit written statements to be included in the 

permanent hearing record, and without objection the hearing 

record will remain open for 14 days to allow statements, questions 

for the records, and other extraneous material referenced during 

the hearing to be submitted in the official hearing record. 

It is now my pleasure to introduce our distinguished panel of witnesses. 

Mrs. Kimrey Rhinehardt is the vice president for federal and 

military affairs at the University of North Carolina, where she 

serves as the primary liaison between the university and the university’s 17 campuses and the federal government. Dr. Arthur Kirk 

is the president of Saint Leo University in Saint Leo, Florida, 

where he has served since he was appointed to the position in 

1997. 

Dr. Russell Kitchner serves as vice president for regulatory and 

governmental relations for the American Public University System. 

Dr. Ken Sauer has been with the Indiana Commission for Higher 

Education since 1985, currently holds the position of senior associate commissioner for research and academic affairs. 

Before I recognize you to provide your testimony individually, let 

me briefly explain our lighting system. 

You will have 5 minutes to present your testimony. When you 

begin, the light in front of you will turn green; when 1 minute is 

left, the light will turn yellow; when your time is expired, the light 

will turn red. At that point I ask that you wrap up your remarks 

as best as you are able. 

After you have testified, members will each have 5 minutes to 

ask questions of the panel. 

I now recognize Mrs. Kimrey Rhinehardt for 5 minutes. 

And, Kimrey, wait one second—and Kimrey has her daughter, 

Tyler, with her today, and she is getting a lesson in good representative government. And we are glad to have Tyler with us here 

today. 

Kimrey? 

STATEMENT OF KIMREY W. RHINEHARDT, VICE PRESIDENT 

FOR FEDERAL MILITARY AFFAIRS, THE UNIVERSITY OF 

NORTH CAROLINA 

Mrs. RHINEHARDT. Madam Chair, thank you. You know well that 

North Carolina is a proud state. We are proud that Revolutionary 

War patriots fought for and established the University of North 

Carolina, the nation’s first public university. 

Today the University of North Carolina is a multi-campus university. We have 220,000 students, 55,000 faculty and staff, and 

our budget is approximately $9 billion. 

North Carolina is also proud of our military family, and it is a 

very large military family: 11 percent of North Carolinians are in 

some way directly connected to the military. My father proudly 

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11 

served as a citizen soldier for 29 years. My sister, two uncles, an 

aunt, my grandparents—including my grandmother—all served 

this nation in uniform. 

Our state’s military family includes those who have served, are 

serving, and will serve in the future. 

This culture of prideful acceptance and support of the military is 

a North Carolina core value. After the Post-9/11 G.I. Bill became 

law in 2008, UNC institutions experienced a surge in applications 

from military students. The surge continues. 

In 2010, Congress again changed the Post-9/11 G.I. Bill. In parallel, the Department of Defense asked institutions participating in 

a tuition assistance program to sign new MOUs in 2011 and then 

again in 2012. We are working on our third MOU as we speak. 

Concurrent to these changes, President Obama issued an executive order establishing principles of excellence. Shortly thereafter, 

the V.A. asked institutions of higher education to commit to certain 

principles of excellence consistent with the president’s executive 

order. 

To be clear, we agree with the spirit of and the intent behind 

these requirements. But honestly, we are ahead of the curve. 

In October 2010, a UNC system working group of faculty, staff, 

and students was appointed to take a closer look at how well we 

serve these students. The working group known as UNC SERVES, 

as Dr. Foxx referenced, established the baseline for where we were 

and where we wanted to go. 

President Ross and the 16 chancellors are implementing UNC 

SERVES. The university’s governing board is equally engaged. 

They established a special committee to focus on military affairs 

and approved a military student success policy that applies systemwide. 

Under this new policy, the university considers a student having 

completed at least 2 years of active duty service a transfer student. 

We are also collecting better data so that we may identify and 

track the academic progress of these students—specifically their retention and graduation rates and length of time to degree. 

Veterans are not your typical students. They come to us from a 

highly structured bureaucratic environment and become frustrated 

with the loosely structured bureaucratic environment of the university. 

One of our top priorities is to centralize information-sharing by 

using technology. The university system has a website that serves 

as the virtual front door for all military. 

Another resource and development is the North Carolina Military Educational Positioning System. This website, a partnership 

with the Aurora Foundation, is designed to help veterans explore 

their educational options, navigate to their college of choice, and 

then graduate and transition into the workforce. 

For active duty servicemembers, the university has academic advisors at Fort Bragg, Camp Lejeune. We work with the community 

colleges to create specialized programs just for this service—just for 

the servicemember. 

At President Ross’ direction, I lead and manage the system-wide 

UNC Partnership for National Security, an initiative that coordiCEWDOCROOM with DISTILLER

12 

nates all of our efforts with the military across the system. The 

one-stop shop approach works very well. 

At UNC we care deeply about the whole soldier. We care about 

providing them with access to a high quality, affordable education. 

We care about the families that they leave behind when they deploy. We care about the equipment that they carry down range. 

We care about providing them with a sharp civilian workforce to 

support their mission. And when they decide to retire or separate 

from service, we care about getting them a good paying job in 

North Carolina. 

We commit ourselves to the UNC Partnership for National Security because of that deeply embedded prideful acceptance and support that I referenced earlier. A servicemember’s education is critical because the most important weapon that they have is their 

mind. 

The equipment they need must be the most advanced technology 

imaginable because they need to execute their mission and return 

home safely. And when the servicemember makes the transition to 

veteran in the civilian world, we want that veteran to remain in 

North Carolina for the long term. 

Finally, the University of North Carolina system commits itself 

to partnering with the military because national security should be 

a priority for us all, not just for the less than half of one percent 

of us that serve in the armed forces. We can all do something to 

contribute. 

The faculty, staff, and students of the University of North Carolina stand ready to do our part, Madam Chair. Thank you, and this 

concludes my testimony. 

[The statement of Mrs. Rhinehardt follows:] 

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Chairwoman FOXX. Thank you very much. 

I now recognize Dr. Arthur Kirk for 5 minutes. 

STATEMENT OF DR. ARTHUR F. KIRK, JR., PRESIDENT, 

SAINT LEO UNIVERSITY 

Mr. KIRK. Chairwoman Foxx, Ranking Member Hinojosa, members of the subcommittee, I appreciate the opportunity to discuss 

programs that assist our nation’s servicemembers and veterans in 

obtaining a higher education. I am Art Kirk, president of Saint Leo 

University. 

Saint Leo University, a Catholic university founded in 1889, offers over 40 undergraduate and graduate programs on a residential 

campus in Florida; on 16 military bases in Florida, Virginia, South 

Carolina, Mississippi, Texas, California, and Georgia; to students 

everywhere online; on community college campuses; and at other 

locations near bases. 

G.I. Jobs and Military Advanced Education rank us among the 

most military-friendly institutions. But we understand that we 

must be more than just military-friendly. We must be military and 

veteran supportive. 

We are celebrating 40 years of serving military students. The 

university began offering degree programs on bases at the height 

of the Vietnam War, becoming the first college in the nation to 

grant the bachelor’s degree on an Air Force base, when members 

of the military found it very difficult to complete their education 

while on active duty. We adopted online offerings for the military 

in 1997. We partner with GoArmyEd, eArmyU, Navy College Distance Learning, Air Force Academic Institution Portal, Air University, the Marine Corps Lifelong Learning Program, 

Servicemembers’ Opportunity Colleges, and more. 

Saint Leo offers credit for prior learning, military training, and 

Air Force and ROTC opportunities. Today, seven Saint Leo ROTC 

candidates are in the Army Green to Gold program for veteran 

non-commission officers. Last year we enrolled 5,697 veterans, 79 

percent of whom were post-9/11 vets, while educating 4,886 active 

duty military, representing 39 percent of our student body. 

The university provides our military students outstanding academics and personal attention in small classes. These qualities 

characterize the National Association of Independent Colleges and 

Universities, which I also represent today. 

With more than 1,000 members, NAICU reflects the diversity of 

private, not-for-profit higher education in the U.S. Over half of our 

colleges educate fewer than 5,000 students; a quarter enroll fewer 

than 2,000. Many veterans choose to attend these smaller institutions. 

To support our military and veterans mission, the Saint Leo Office of Veteran Student Services opened in 2011 to work with all 

university departments and community organizations to meet the 

needs of our veterans. Dr. Jose Coll, who came to the U.S. as a boy 

when his parents fled Cuba, leads the office. 

The first American Coll encountered was a Marine. Coll later 

served with the 1st Force Reconnaissance Company Marines. Regarding Saint Leo’s support of vets, he noted, ‘‘It takes the entire 

university to do what we do so well.’’ 

CEWDOCROOM with DISTILLER

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Our efforts to create a proactive veteran-supportive environment 

include extensive training programs. Our 52 veteran certifying officials, our academic advisors, faculty, and staff receive training in 

identifying and addressing issues that veterans may face, including 

post-traumatic stress. We take staff through scenarios so they 

know where to refer students for the needed support on and off 

campus. 

We also offer training to public schools and law enforcement 

agencies as well as to our students and faculty in those majors. We 

believe social support is critical and continue to identify ways for 

veterans to connect on our campus and education centers. 

Employee veterans play a critical role, mentoring Saint Leo student veterans. We educate the university community about military culture and build an inclusive community that benefits our entire student body. 

All our military and veteran students receive a roadmap to graduation. We determine what credits the student brings to college 

and develop a clear sequence of courses towards the degree of their 

choosing. Their plan is updated each term. 

Saint Leo maintains a retention alert system so that advisors can 

intervene when a student misses classes or receives failing midterm grades. Veterans and servicemembers attending Saint Leo receive critical financial support, including the financial aid programs 

under the jurisdiction of this committee and programs supported by 

the Departments of Defense and Veterans Affairs. We are grateful 

for the commitment and support the federal government provides 

for those who serve the nation. 

Saint Leo works to do our share by participating in the Yellow 

Ribbon program and raising money for private scholarships. Saint 

Leo also initiated a two-step certification process for V.A. benefits 

that makes the process much quicker and more manageable for the 

veteran but adds work for us. 

All this support results in success. Saint Leo awarded 1,485 associate, bachelor’s, and graduate degrees to just veterans last year— 

more than double two years ago. 

On our campus stands a 30-foot bronze sculpture of a soldier, 

sailor, airman, Marine, and guardsman upholding Lady Liberty— 

a tribute to all of our military and veteran students and graduates 

and a daily reminder that their service allows us the freedom to 

live, learn, and teach in peace and security. We take great pride 

in serving those who serve. 

[The statement of Mr. Kirk follows:] 

Prepared Statement of Arthur F. Kirk, Jr. President, Saint Leo University 

Chairwoman Foxx, Ranking Member Hinojosa, and members of the Subcommittee, I appreciate having the opportunity to appear today to discuss programs 

that assist our nation’s servicemembers and veterans in obtaining a higher education. I am Art Kirk, president of Saint Leo University. 

Saint Leo University is an independent Catholic university founded in 1889. The 

University offers over 40 undergraduate and graduate degree programs on its residential campus in Florida, and to adult students on 16 military bases in Florida, 

Virginia, South Carolina, Mississippi, Texas, California, and Georgia; to students in 

all states and overseas through our center for online learning; on 15 Florida community college campuses; and at several other locations near military bases. 

Saint Leo is ranked among the nation’s most military-friendly institutions by G.I. 

Jobs and Military Advanced Education magazines. It is one of only 10 institutions 

nationwide to be approved by the U.S. Coast Guard for participation in its new MarCEWDOCROOM with DISTILLER

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itime Law Enforcement College Partnership Program. But we understand that we 

must be more than just military and veteran friendly, we must be military and veteran supportive. 

We are currently in a year-long celebration of 40 years of serving those who serve. 

The University began offering full degree programs on military bases in 1973, and 

became the first college or university in the nation to grant the bachelor’s degree 

on an Air Force base. We started with 176 students at the Avon Park Bombing 

Range and 13 at MacDill Air Force Base. 

This was at the height of the Vietnam War. At the time, many members of the 

armed forces found it difficult to complete their education while on active duty. 

Some were stationed in conflict zones. Some served at military installations in isolated areas. Many performed shift work and could not attend regular daytime classes. Often servicemembers were transferred before they could complete their degree 

programs. My University’s mission, to provide opportunities for people of good character regardless of their religion, compelled us to respond to these needs. 

We were an early adopter, in 1997, of online offerings for the military. In efforts 

designed to fit the mobile lifestyle of military personnel worldwide, we partner with: • GoArmyEd • eArmyU • Navy College Program Distance Learning Partnership (CPDLP) • The Air Force Academic Institution (AI) Portal • Air University Associate to Baccalaureate Cooperative Program • The Marine Corps Lifelong Learning Program’s Academic Explorer (AeX) • Servicemembers’ Opportunity Colleges program and its Degree Networking System 

Saint Leo also offers our students credit for prior learning experiences and maintains a partnership with University of South Florida that allows University Campus 

students to participate in Air Force and Army ROTC programs at USF. ROTC provides the tools, training and experiences for students to become officers in the 

United State military, while earning money toward their college education. This 

year seven Saint Leo ROTC candidates are from the Army Green to Gold program 

for veteran non-commission officers who can choose any ROTC program to complete 

their BA degree and receive their commission. 

Saint Leo University enrolled 5,697 veterans during the past academic year, 4,477 

(78.5%) of whom were Chapter 33 or Post-9/11 veterans. The University also educated 4,886 active duty military and reservists during the course of the last academic year. All told, this equals nearly 39% of the students who took at least one 

course with us during the year. 

The University is proud of its military students and is committed to providing 

them with outstanding academic programs and personal attention in small classes. 

I might add that these are qualities that characterize the member institutions of 

the National Association of Independent Colleges and Universities, which I am also 

representing today. With more than 1,000 members nationwide, NAICU reflects the 

diversity of private, non-profit higher education in the United States. Over half of 

our nation’s private, non-profit colleges have fewer than 5,000 students, and a quarter have fewer than 2,000. Many veterans choose to attend these smaller institutions. 

To further support our military and veterans mission, the Saint Leo University 

Office of Veteran Student Services opened in 2011. The Office works collaboratively 

with all university departments and community organizations to best meet the 

needs of our student veterans in order to ensure them every opportunity to accomplish individual goals. 

This office is headed up by Jose Coll, who came to the United States as a young 

boy when his parents fled Cuba. The first American Coll encountered in Key West 

was a Marine, a meeting that triggered his own desire to join the Marine Corps. 

Coll served with the 1st Force Reconnaissance Company at Camp Pendleton where 

he supervised combat parachuting operations and training. Due to the positive experience and mentorship he received at Saint Leo, Coll decided to enter academia. 

Commenting on the role that all departments at Saint Leo University have played 

in supporting veteran education, Coll noted ‘‘It takes the entire university to do 

what we do so well.’’ 

Our efforts to create a proactive ‘‘veteran-supportive environment’’ at Saint Leo 

include relevant training for faculty, staff, and students. In particular, our 52 veteran certifying officials (VCOs) (up from 20 a few years ago), academic advisors, 

many faculty and staff receive extensive training in identifying and addressing 

issues that veterans are likely to face in pursuing their education. These training 

programs take them through a series of ‘‘what-if’’ scenarios to assure that our staff 

know where students can be referred to to receive the support they need—both onCEWDOCROOM with DISTILLER

27 

and off-campus. Our faculty and staff are also trained to identify signs of post-traumatic stress and how to respond to it on the spot. 

This training is conducted by our Office of Veteran Student Services, which also 

offers training in nearby public schools and to our education majors and faculty in 

dealing with the particular issues faced by children of veterans. Likewise, the office 

conducts training sessions with law enforcement agencies and criminal justice students and faculty regarding issues they may encounter with veterans in their communities. 

We believe that social support is also critical and continue to look for new ways 

for veteran students to connect on campus and at our education centers. We recognize the critical role that faculty and staff veterans can play in mentoring veteran 

students and have encouraged these interactions. We also look for ways to educate 

the Saint Leo University community about military culture and veterans’ issues. 

The sense of community that these efforts build on campus benefits our entire student body—veterans and non-veterans alike. 

There are a number of things we’re doing that offer important academic support. 

For example, we provide all our military and veterans students with what I think 

of as a ‘‘road map to graduation.’’ Essentially, at the outset, we determine what 

credits the student is already bringing to college and then develop a clear sequence 

of courses towards the degree of their choosing. 

This plan is updated each term so that the student clearly understands what is 

needed to graduate. 

Saint Leo also has a retention alert system so that advisors can take a closer look 

when a student misses classes or receives failing grades and see that appropriate 

remediation is provided. 

This is by no means a one-way street. Our veteran students, who now comprise 

just under 5% of our campus residential students, have had a tremendously positive 

influence on campus. 

In addition, veterans and servicemembers attending Saint Leo receive critical financial support from a variety of sources—including the financial aid programs 

under the jurisdiction of this committee as well as programs supported by the Departments of Defense and Veterans Affairs (VA). Those of us involved with military 

and veterans’ education are grateful for the commitment and support the federal 

government has provided in offering opportunities for those who serve our nation. 

We work to do our share as well, through participation in the Yellow Ribbon program and support for private scholarships. At Saint Leo, we have also initiated a 

two-step certification process for VA benefits that has made the process much 

quicker and more manageable for the veteran. It does involve extra work on the 

part of our staff, but the improved help to veterans is well worth the investment. 

All of this support results in success. The University awarded 311 associate degrees, 884 bachelors, and 290 graduate degrees to veterans last year (1,485 total: 

more than double than two years ago). Our veterans maintained a grade point average of 3.31 in their undergraduate studies. 

At the center of our campus, stands a 30 foot bronze sculpture by artist Dexter 

Benedict of a soldier, sailor, airman, marine and guardsmen upholding lady liberty 

as a tribute to all of our military and veteran students and graduates and a daily 

reminder to all of us on campus that their service allow us the freedom to live, learn 

and teach in peace and security. We take great pride in serving those who serve. 

Chairwoman FOXX. Thank you very much. 

I now recognize Dr. Kitchner for 5 minutes. 

STATEMENT OF DR. RUSSELL S. KITCHNER, VICE PRESIDENT 

FOR REGULATORY AND GOVERNMENTAL RELATIONS, AMERICAN PUBLIC UNIVERSITY SYSTEM 

Mr. KITCHNER. Chairwoman Foxx, Ranking Member Hinojosa, 

members of the committee and staff, I have the privilege of joining 

you today and representing American Public University System, 

which consists of American Military University and American Public University. Originally chartered as American Military University in 1991, its history and legacy reflect one of the unique 

strengths of our nation’s approach to higher education: the ability 

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of one person’s vision to be transformed into a distinguished center 

for teaching and learning. 

Marine Corps Major James Etter had experienced the frustrations of obtaining the academic credentials necessary for advancement in grade and rank that resulted from frequent deployments, 

and he recognized the emerging potential of the Internet to mitigate the reliance upon on-the-ground instruction. 

From an initial cohort of 18 students, American Military University now enrolls over 70,000 military students and veterans, and its 

APU counterpart serves approximately 50,000 more civilians, each 

of them taking advantage of more than 90 programs of study. The 

university is regionally accredited by the Higher Learning Commission of the North Central Association. In 2011, its accreditation 

was reaffirmed for an additional 10 years. 

In the brief comments to follow I will focus on four qualities that 

I believe are critical to our conversation this afternoon: academic 

quality, institutional transparency, affordability, and what it 

means to be military-friendly. 

I would offer just a few indicators related to academic quality. 

First, APUS is a recognized leader in assessing online learning, as 

evidenced by it being cited in 2009 by the Sloan Consortium with 

its Ralph Gomory Award for Quality Online Education. 

Second, on the 2011 Educational Testing Service proficiency profile, APUS graduates exceeded the national norms in every academic category. Furthermore, 16 APUS students were designated 

as Presidential Management Fellows in 2012, which placed the university in the top 10 institutions nationally. 

On the matter of transparency, the university has an extraordinarily robust institutional research division, supported by a 

president who is committed to using data to measure institutional 

performance and to identify indicators of the university’s success 

and fulfilling its mission on behalf of the students’ educational objectives. The university publishes the results of this data analysis 

on its public website. 

It should be noted in this context that regulatory compliance has 

become an essential dimension of ensuring that servicemembers 

and veterans obtain the full value of their academic efforts and investments. APUS has successfully accommodated the rules and 

regulations of institutional and program-specific accreditors; presidential executive orders; the Departments of Defense, Veterans Affairs, and Education; and the appropriate authorizing agency in 

each of the 50 states. This is both time- and resource-intensive, and 

while the university embraces the principle of accountability, the 

increasing scope and number of regulatory hurdles has the potential to negatively affect institutional efficiency and limit educational options for military students and veterans. 

With regard to affordability, the university has not raised undergraduate tuition since 2001, and it is approximately 20 percent less 

than the average in-state tuition at public institutions and 34 percent less than private nonprofit institutions. Also, it offers a book 

grant for undergraduate students that in most cases underwrites 

the full cost of instructional materials. Consequently, relatively few 

military and veteran students need to apply for loans, and even 

fewer need to do so to cover instructional-related expenses. 

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29 

I would like to state in this regard that, while no one questions 

the importance of the current national discussion related to college 

affordability, America’s military and veteran students do not deserve to be caught in its crosshairs, nor should their earned benefits be held hostage to that debate. 

Finally, the university’s military culture continues to reflect the 

vision of its founder, but I believe that there are a number of other 

factors that underscore our commitment to serving military students and veterans well, and that can be applied and those factors 

can be applied elsewhere. 

In addition to the accessibility afforded by our robust online 

learning platform and the other attributes noted earlier, the university has implemented monthly rather than quarterly or semiannual course starts. We also have a very liberal leave policy that 

takes into account deployments, personal bereavement for fallen 

comrades, and other unforeseen circumstances that often affect students serving on active duty. 

A generous approach to accepting American Council on Education-certified military credits and transfer work from other accredited institutions enables our students to complete their programs of study without duplicating earned coursework, thus limiting their expenses, unnecessary taxpayer investment, and a timeto-degree completion. These and other policies and practices largely 

explain why nearly 70 percent of our newly admitted military and 

veteran students indicate they heard about AMU from a friend. 

We sincerely appreciate the willingness of this committee to recognize the dedication of our students and the efforts of those who 

are committed to their success. Together we can continue to advance Major Etter’s vision to educate those who serve. 

Thank you. 

[The statement of Mr. Kitchner follows:] 

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Chairwoman FOXX. Thank you very much. 

Dr. Sauer, you are now recognized for 5 minutes. 

STATEMENT OF DR. KEN SAUER, SENIOR ASSOCIATE COMMISSIONER FOR RESEARCH AND ACADEMIC AFFAIRS, INDIANA 

COMMISSION FOR HIGHER EDUCATION 

Mr. SAUER. Chairwoman Foxx, Ranking Member Hinojosa, and 

members of the subcommittee, thank you for this opportunity to 

testify. I serve as chief academic officer of Indiana’s coordinating 

board for higher education, but I am also one of the leaders of a 

multi-state collaborative focused on maximizing ways 

servicemembers can translate their military training and experience into college credit, and it is in this capacity that I offer some 

remarks. 

The Multi-State Collaborative on Military Credit began 18 

months ago with a meeting of representatives from Illinois, Indiana, and Ohio. Since then, four other states—Kentucky, Michigan, 

Minnesota, and Missouri—have been added. 

The collaborative embraces several key premises. 

First, states, if they work together, can better meet the needs of 

returning servicemembers. And second, the federal government 

needs to work in close partnership with states to make progress in 

this area. States play an important role in identifying and publicizing institutional best practices and can coordinate statewide efforts to adopt these best practices. 

The third premise is that we support the recommendations on 

military credit that have been developed by the American Council 

on Education under contract with the Department of Defense. ACE 

has a long history of making these recommendations and we believe the approach they use of making site visits with faculty to 

military bases has integrity. Our interest is in having the recommendations used more and in developing feedback mechanisms 

for further enhancements. 

To that end, the collaborative urges ACE to reveal more of the 

information that is garnered from these site visits, more importantly—most importantly—the specific competencies and skills or 

learning outcomes acquired through the military training so that 

institutions can better award credit for the right course. This will 

help to ensure that veterans are earning credit for courses that will 

count toward the degree program they are pursuing and will permit them to complete their studies within the time limit allowed 

by the Post-9/11 G.I. Bill. 

The collaborative would also like to have the complete data file 

of all military occupational specialties and ratings and the corresponding ACE credit recommendations to be made public for inclusion in widely-used software that is designed to facilitate transfer of credit among institutions. At least 17 states, including Indiana and four other states in the collaborative, as well as hundreds 

of individual institutions and campuses, license software that 

makes it easier for institutions to determine and store transfer 

equivalencies: ‘‘This course at this institution is equivalent to that 

course at that institution.’’ 

The contract that the Department of Defense has with ACE does 

not allow the vendor I am referring to, CollegeSource in this case, 

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as well as other vendors from freely downloading that file and 

making it available for institutions to access. This makes it more 

difficult for institutions to make full use of the ACE credit recommendations and it prevents metrics from being developed that 

would give the Department of Defense, ACE, and other stakeholders data on how the ACE credit recommendations are actually 

being used by institutions. 

I would also add that as a result of the collaborative bringing 

this problem to the attention of the Department of Defense, our 

contact at the department is now working on this issue. 

The Multi-State Collaborative is also interested in identifying examples of how institutions are translating military credit and experience into substantial progress toward earning a degree or acquiring a license. In Illinois, community colleges have developed a transition program that allows Basic Medical Corpsmen to take a specially-designed course, completion of which qualifies them to become a licensed practical nurse. In Indiana, Ivy Tech Community 

College has identified relevant military training and experience 

that can equate to about half of the major coursework needed to 

complete associate degrees in criminal justice and construction 

technology. 

These examples benefit all parties. They save money for both the 

veteran and the taxpayer; they help ease the transition from military to civilian life; and they also contribute toward a better-educated workforce. 

Members of the Multi-State Collaborative have more recently 

identified two other areas that need attention: data and communications. In the interest of time I will simply say that we need to 

collect better data on veterans enrolled in our colleges, and we need 

to develop better communication tools to let veterans know about 

what opportunities are available to them. 

I am grateful to the members of the subcommittee for convening 

this important hearing, and thank you for the opportunity to contribute testimony. 

[The statement of Mr. Sauer follows:] 

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Chairwoman FOXX. Thank you very much. 

And I think everybody here knows this, but just in case, I will 

say all the testimony you have submitted will be put in the record, 

and some of you have very extensive testimony and very excellent 

testimony. 

I would now like to recognize the chairman of the full committee 

for his—give him an opportunity to ask questions. 

Chairman Kline? 

Mr. KLINE. Thank you, Madam Chair, for the hearing. 

Thanks to the witnesses for coming. Excellent testimony. You 

can see your dedication to helping our men and women in uniform—those in uniform now and those who have been and those 

who will be. 

A special thank you to Ms. Rhinehardt for bringing Tyler. She 

is sitting back there taking notes. It is an example for all my colleagues up here. I hope you are paying attention. 

I think we share a common goal up here. This is one of those 

hearings where I think every single person sitting up here and 

every person in the room wants to do the very best we can to help 

our veterans, our men and women in uniform, get the education 

they need to enhance their opportunities for a good job, better life, 

all those things that a good education brings. 

I am going to yield the remainder of my time to one of those veterans, my friend and colleague, medical doctor, because I know this 

is an issue of great personal importance to him. 

Dr. Heck? 

Mr. HECK. Thank you, Mr. Chairman. 

Thank you all for taking the time to be here to address this important issue. And we heard in some of the opening statements 

about, for instance, the 90/10 rule and the concerns that some colleges have about potentially including military assistance—educational assistance programs within the 90/10 rule. 

I have traveled and visited many of the proprietary schools within my district. It certainly is an area of concern for them, and one 

of the things that they consistently bring up is how this 90/10 rule 

actually results in them having to artificially inflate their tuition 

costs in order to maintain that 90/10 ratio, and they have said that 

without that 90/10 ratio they could probably lower tuition across 

the board for everyone. 

With that as an example, and realizing the need for reasonable 

regulation to protect the students as well as the taxpayer, what are 

some examples of the regulations that you have faced that have either helped you in delivering services to veterans or hindered you 

in delivering services to veteran students? 

Let’s start with you, Mrs. Rhinehardt? 

Mrs. RHINEHARDT. I would say it is the preponderance of regulation that has been difficult. You know, with an influx of so many 

servicemembers, both active duty and veterans, coming into the 

UNC system, you know, we already—we were down our path and 

we had a well laid out plan, and it—over the course of several 

years it felt like the rules kept changing and that was difficult, 

particularly for offices on campus that aren’t used to dealing with 

the rules and regulations of the Department of Defense and the 

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V.A. So I—my answer would be that it is the totality and not any 

one rule or regulation in specific. 

Mr. HECK. Dr. Kirk? 

Mr. KIRK. I would concur. We have been trying to inventory all 

of the regulations, and I know, and from all the offices of government, from Internal Revenue to Veterans to DOE, and we are well 

beyond 176 in our inventory and they seem to just keep growing. 

So it is the preponderance. 

Mr. HECK. Dr. Kitchner? 

Mr. KITCHNER. Thank you. In addition to concurring in general 

with my colleagues, I would offer one different perspective, and 

that is that the regulations themselves are often helpful in providing institutions with benchmarks and opportunities to gauge the 

effectiveness and how well they are meeting the needs that have 

been identified by various agencies. 

So in that regard I can say that there is a benefit, a value added, 

to having a body of appropriate regulations, and it really becomes 

incumbent upon Congress and the various agencies that work with 

veterans to be conscious of the fact that there is such a thing as 

too much of a good thing. 

Mr. HECK. Thanks. 

Dr. Sauer? 

Mr. SAUER. Yes, I would concur with the remarks made previously but I would add one item that specifically relates to online 

education, and Dr. Kitchner had mentioned this. There is a new 

way of looking at interstate regulation of online education—the 

State Authorization Reciprocity Agreement, or SARA, as it is 

known by its acronym. And I think this holds great promise for 

striking a balance between ensuring that there is some basic adequate oversight of online education, which would perhaps keep the 

bad actors out, but also give the good actors—and most of our colleges and universities do provide very strong online education—it 

would free them from some of the regulations and costs that are 

currently associated with delivering online education. 

Mr. HECK. Great. Thank you. 

Thank you all very much. 

I yield back, Madam Chair. 

Chairwoman FOXX. Thank you. 

Mr. Hinojosa, you are recognized for 5 minutes. 

Mr. HINOJOSA. Thank you. 

I want to thank the panel because your statements are very informative and something that is greatly needed as we are trying 

to re-deploy and bring back the active soldiers from Afghanistan by 

the end of 2014. So I think that members of Congress are all anxious to learn about this information that is working and how they 

can use them in their respective congressional districts. 

So I am going to ask my first question of Ken Sauer. 

Dr. Sauer, licensure is typically done through state boards. Is 

there any way to make progress on getting veterans licensed other 

than by state basis? 

Mr. SAUER. Yes, Representative Hinojosa, I believe there is. I 

think it is important—as you correctly point out, most of the licenses are state-based in individual states and individual boards, 

and that is the way the licensure process is carried out. However, 

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and I do believe, and members of the Multi-State Collaborative believe, that we do have to work within our own states to try to make 

it easier for veterans to apply some of their training and experience 

toward obtaining a license, either directly or indirectly through a 

program of study that would prepare one to be a license. 

But I think we can also work at the national level as well. Most 

state boards have associations, so we have an association of state 

boards of nursing, for example. And I think it is important to try 

to work at the national level as well, and I think if we attack the 

problem, if you will, from both a state level and from a national 

level I think we can make some progress on this issue. 

Mr. HINOJOSA. Good. 

Mr. Sauer, the last question to you is, can you give us a couple 

of recommendations on how we can get more states involved in the 

work of the collaborative? 

Mr. SAUER. Well, the collaborative is happy to involve other 

states in its work. This is very much a grassroots effort. It started 

by several states that have a lot of contact with one another simply 

recognizing that we had a lot of common ground and common interest in trying to make it better for our servicemembers to make the 

transition to college. 

It has grown very quickly, and really the only thing we ask of 

a state is that they actively participate in the work of the collaborative. We have three work groups that tackle different problems, 

and we simply ask that a state be active in at least one of those 

work groups and really contribute toward the work that is going 

on. 

Mr. HINOJOSA. Would you be willing to receive some delegations 

from our congressional district to visit with you and talk about 

this? 

Mr. SAUER. We would be delighted to. 

Mr. HINOJOSA. Thank you. 

My next question is to Mr. Kitchner. 

In working with veterans, what services do they need, what do 

they desire that may be different than traditional students? 

Mr. KITCHNER. Representative Hinojosa, you are asking what different services as an online student would they need, that would 

differ from on the ground? 

Mr. HINOJOSA. Yes, because you all talked about veterans being 

different than the regular college students. 

Mr. KITCHNER. Well, in many cases their needs are comparable. 

The difference between veteran students is they are typically working adults as opposed to immediate graduates of high school, so 

they have workload and family-load considerations that are factors. 

And in those cases where they are veterans who may suffer from 

PSTD or other military-related challenges, we have to accommodate the needs they might have in terms of their health—their 

emotional and physical health—and the online environment is a 

great leveler of the playing field to some extent, but it also offers 

its own challenges for those people, so we have to be sensitive to 

those challenges and accommodate them. 

Mr. HINOJOSA. What in your system is helping veterans integrate 

back into civilian life? 

Mr. KITCHNER. I am sorry. Would you repeat that? 

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79 

Mr. HINOJOSA. Your system is very—is a successful system. Tell 

us how yours is helping veterans integrate back into civilian life. 

Mr. KITCHNER. Well, I am not sure that I would say that is part 

of our core mission is to integrate them. We hope that as a result 

of their integration in a classroom with other students, both civilian and military, which is quite often the case, that they will find 

avenues for integration, but— 

Mr. HINOJOSA. The reason for my question is that we are finding 

that jobs are sometimes difficult because we can’t seem to match 

educated persons or trained individuals that can fill allied health 

and information technology, which are two sectors where we do 

have jobs to fill. So we have got to integrate them into the civilian 

life and explain to them that if they could just take some additional 

hours and add it to the training they received in the military they 

would probably be hired. 

Mr. KITCHNER. That is an excellent point, and I think the best 

that we can—the best that we can offer—is a wide variety of programs that are career-related and vocationally relevant to their interest and backgrounds, and that is why we have as many programs as we do, many of them sort of on demand because veterans 

have asked for them or military students have asked for them. 

Mr. HINOJOSA. Thank you. 

I yield back. 

Mr. KITCHNER. Thank you. 

Chairwoman FOXX. Thank you very much. 

Dr. Heck, you are now recognized. 

Mr. HECK. Thank you, Madam Chair. 

I would ask, you know, there certainly are several different programs currently available for both active duty and veteran members in trying to seek higher education, whether it is the Montgomery G.I. Bill, the Selected Reserve Montgomery G.I. Bill, the 

Reserves Educational Assistance Program, Post-Vietnam Education 

Assist, Post-9/11—I mean, there is a whole host of possibilities for 

veterans and active duty members to take advantage of, including 

tuition assistance. What are the potential advantages and disadvantages of streamlining and simplifying the different benefits 

and programs that currently serve servicemembers and veterans 

pursuing higher education? 

Mrs. Rhinehardt? 

Mrs. RHINEHARDT. I am not sure I am qualified to answer that 

question, but I do think that you raise an important point that 

there are so many different ways that a servicemember or a veteran can financially pay for their college experience, that one of the 

things that we are doing as a UNC system is we are building the 

Military Educational Positioning System Portal so that—essentially 

it has a decision tree so the veteran can enter in personal information about whether they have invested in the Montgomery G.I. Bill, 

whether they have the Post-9/11 G.I. Bill, and at the end it spits 

out, you know, ‘‘You are most likely to want to use the following 

as your benefit first;’’ because, you know, there is a chemistry between the programs and you can be on the losing end if you are 

not very well aware of how each of those programs work together. 

Mr. HECK. Well, I applaud you and the university system for developing that, because I know several members that as they go 

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through their transition assistance program as they out-process 

and they watch their two-day slideshow talking about some of the 

potential benefits that they don’t quite understand what is truly 

out there and available to them and would best meet their needs, 

so congratulations. 

Dr. Kirk, anything? 

Mr. KIRK. Yes. We have actually increased the number of veterans’ counselors from 20 to 52 over the last several years and, as 

I mentioned in my testimony, have done a tremendous amount of 

training. Simplification will be better for the veterans. Sorting 

through all that is very difficult for them, and I think can be a barrier. 

And the other thing is stabilizing the requirements. We are constantly training our people because things are constantly changing, 

and the vet can get caught in that. 

Several summers ago we actually paid the rent for a number of 

veterans because they hadn’t enrolled full time in summer school 

and the rules had changed and somehow they missed it and they 

couldn’t get their housing allowances because they weren’t enrolled 

full time. We stepped up and paid their rent so they didn’t get 

evicted, but those kinds of changes can throw them way off course. 

Mr. HECK. Dr. Kitchner? 

Mr. KITCHNER. Dr. Kirk is exactly on target in at least two respects. Number one, the availability of capable, knowledgeable advising staff is absolutely critical—people that can help navigate the 

myriad of rules and regulations through the Department of Defense 

or the Veterans Administration both, coupled with some support 

for that process that you articulated, where individuals are about 

to be discharged and they go through that one-or two-day orientation to the civilian life that is somewhat out of context. 

And I think what we need to be thinking about is implementing 

a transition that involves the colleges, universities in that process 

and bring some of the resources that we are striving to develop— 

bring those resources to bear in the context of those pre-discharge 

events and counseling. And I think it could smooth that transition 

remarkably. 

Mr. HECK. Great. Thank you. Very helpful. 

Dr. Sauer? 

Mr. SAUER. Yes. Just picking up on the point about academic advising, which I very much agree with, I think we need to work on 

making the academic advising much more consistent to try to develop tools that can be widely used so that veterans have access to 

the same information and that they are getting it in an easily understandable form. 

Dr. Kitchner also mentioned the time period just—involving the 

discharge. I think it would be helpful if we could work with base 

education officers prior to that time to try to get veterans, as they 

begin to think about the transition, to think about their opportunity to have information to evaluate much before that week in 

which they are making the transition itself. 

Mr. HECK. Great. 

Again, thank you all very much for being here. 

And thank you. 

Mr. KIRK. May I add, Congressman— 

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81 

Mr. HECK. I am out of time but I will yield to the chair if—yield 

back. 

Chairwoman FOXX. You yield back. Okay. 

Mr. Loebsack? 

Mr. LOEBSACK. Thank you, Madam Chair. 

It is great to have all you folks here today. I really appreciate 

what you are trying to do for our veterans. I think it is maybe particularly appropriate that we are having this discussion today on 

9/11, the anniversary of the terrible terrorist attacks on our country in 2001. 

I am also on the Armed Services Committee. I am also a military 

parent. I have two kids I saw last night, my stepson and his wife, 

who are in the Marine Corps; they have been deployed. They are 

a little more fortunate in the sense that, I mean, they are at the 

Command and Staff school at the moment at Quantico, so they are 

kind of with folks, you know, who have had some similar experiences. They are not at a traditional university or a traditional college where they have to go and try to fit in and have differential 

experiences and that kind of thing. Although, I taught, myself, at 

a small college in Iowa for 24 years prior to 2006 and I did my best 

as a professor to try to deal with folks who were coming back from 

these wars, but it was not always easy, not having served in the 

military myself and had that experience. 

So I understand and I really, really appreciate all the things that 

folks are trying to do to get these folks back—get them on the 

ground, keep them as healthy as possible, especially psychologically 

for a lot of those folks who come back. I think it is really critical. 

The University of Iowa has a wonderful program—I represent 

the University of Iowa in my district and I was just at an event 

at the Military and Veteran Student Services Center there. They 

are doing a great job. I know a lot of universities, lot of colleges, 

lot of folks are trying to do the best that they can to make sure 

that these folks can make this transition. 

I do want to just make sure, if I could—I want to request from 

those who have concerns about regulations but were either unable 

or whatever to specify specific regulations that are concerns—I understand the totality argument, but for the record, if folks could 

submit to me specific regulations that get in the way, that you 

have concerns about, that sort of thing, I would like you to do that 

in writing if you could, please. I would appreciate that. 

Beyond that, I do want to talk—ask about the credentialing process. 

And in particular, Dr. Sauer, you mentioned this. I mean, we 

have the federal level and we have the state level. Lot of different 

states have—do this in a different sort of way. Do you think there 

is any role to play on the part of the Department of Defense in all 

of this to coordinate more closely with the states when that transition process occurs? 

Mr. SAUER. Yes, I certainly do. And in fact, there is an academic 

credentialing task force which has just been formed and we were 

pleased that when this task force was being put together we had 

a representative of the Department of Defense who found out about 

the work of the Multi-State Collaborative and participated via conference call in one of our meetings— 

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Mr. LOEBSACK. By the way, Iowa is not part of that collaborative. 

Is that correct? 

Mr. SAUER. That is correct. 

Mr. LOEBSACK. Unfortunately, but we will look into that. But go 

ahead. 

Mr. SAUER. So I think we do now have an opportunity to work 

with the Department of Defense on some of these issues. But the 

short answer is yes, I certainly believe that a real partnership between the states and the federal government—and I would say, actually, not just the Department of Defense, but I would include also 

the Department of Education and the Veterans Administration. 

And in fact, all three of those federal agencies that I mentioned are 

part of this academic credentialing task force, so there—it is really 

a joint effort on the part of those three departments. 

So I think if we could have a more, a closer relationship between 

states, and in our case the Multi-State Collaborative and federal 

agencies that are involved in this, I think we could make some 

progress. 

Mr. LOEBSACK. Okay. 

Mrs. RHINEHARDT. Sir, may I add a follow up? 

Mr. LOEBSACK. Please, go ahead. 

Mrs. RHINEHARDT. I don’t want folks to leave thinking that there 

is no effort going on between the DOD and states because, you 

know, we are home to a very large Marine Corps contingent— 

Mr. LOEBSACK. I am aware of that. 

Mrs. RHINEHARDT [continuing]. That we are very proud of. And 

the Marine Corps actually is—you know, has designed a very 

elaborate educational process where the day that you enlist you 

start your educational plan. So we work closely with Marine Corps 

Base Camp Lejeune and their base education office, so those Marines—the new Marines when they come in, they are already starting their educational pathway. 

We do that in North Carolina, and we are proud of the relationship that we have with them. 

Mr. LOEBSACK. Thank you. 

Thanks to all of you. 

And thank you, Madam Chair. 

Chairwoman FOXX. Mr. Loebsack. 

Congresswoman? 

Mrs. BROOKS. Thank you, Madam Chair, and thank you for convening this very important hearing. And I must share that I have 

worked with Dr. Sauer because I was at Ivy Tech Community College as some of these, prior to coming to Congress, as some of these 

initiatives began. 

And I would like to continue on that discussion and I am glad 

that you, Mrs. Rhinehardt, talked about what North Carolina is 

doing and I am curious to hear from each of you to build on what 

is happening in Indiana and with the other states. 

What are our colleges and universities doing with respect to prior 

learning assessments and ensuring that we take the skills and the 

training and—the incredible skills and training that our men and 

women receive in the military and give them either credit or go 

through a prior learning assessment by our faculty and staff to give 

them credit? What is happening in your institutions, particularly 

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if we don’t have yet, it sounds like, a completely clear path from 

the Defense Department to transfer through either a certification 

process directly to your institutions? 

And if you would like to just expand, and then I would like to 

hear from everyone else. 

Mrs. RHINEHARDT. Absolutely. I would like to reiterate that the 

ACE guide is a recommendation only and our faculty always reserve the right to look under the hood of that military learning that 

the servicemember received when they were in service, and we 

have done that. 

Let’s take, for example, you know, we are home to the U.S. Army 

Special Operations Command, where they train all of the Special 

Operations medics. These folks are probably more skilled in medicine than most allied health professionals in the civilian world. 

And so our faculty at UNC Chapel Hill who work in emergency 

medicine and at the Jaycee Burn Center started a dialogue with 

them about these Special Forces medics instructors coming up and 

doing rotations with the faculty at UNC Chapel Hill. That led to 

a discussion about, ‘‘Hey, I would like to come down and see your 

curriculum.’’ It was clear to them, to the faculty, that the folks 

are—these Special Operations medics are, you know, a quarter of 

the way down the road toward a P.A. degree. 

So UNC Chapel Hill didn’t have a physician’s assistant’s program. They are in the process of establishing one, after a fight with 

the nursing program. But we are establishing a P.A. program because the faculty recognized the unparalleled military learning that 

these folks received, and so they will receive credit when they come 

in and hopefully we are going to be able to transition some of the 

most amazing medical professionals into the rural parts of our 

state that we need more emergency medicine professionals in and 

counties that don’t even have an emergency room doctor, that— 

Mrs. BROOKS. Well, and thank you. I am glad that they have acknowledged that. I am curious, though, what will it take to move 

us further rather than program by program, you know, a faculty 

member or a program—what can we do to have the much stronger 

collaboration between the Defense Department and our colleges 

and universities so it is much more seamless rather than what 

sounds to be a bit more happenstance right now? 

And maybe Dr. Kirk or others, I mean—and I appreciate and applaud what is happening, but yet it seems like it just is not systematic at this point and I think we are missing an opportunity, and 

I would like to find out what your ideas are about how we can fix 

that. 

Mr. KIRK. We do accept all ACE credit for military training and 

experience and all of those credits. Took some doing many, many 

years ago to keep the faculty from wanting to do a second take on 

that, but we have crossed that bridge and accept that all. 

We also do provide opportunities for prior learning assessment 

through the Council for Adult and Experiential Learning 

LearningCounts system, and we have a robust testing program, 

CLEP and others, that will speed the way to a degree. In fact, 

many of our military centers’ classrooms serve as testing services— 

testing centers, and we monitor those tests. So we are trying to do 

all we know and adopt all the best practices to facilitate that. 

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Mrs. BROOKS. Thank you, doctor. 

I am sorry. My time is expired. 

I yield back. 

Chairwoman FOXX. Ms. Bonamici? 

Ms. BONAMICI. Thank you very much, Madam Chairwoman. 

Thank you all for your testimony today. I agree with my colleagues who have pointed out how fitting it is that we are having 

this discussion on the anniversary of September 11th. 

I really appreciate all your testimony. 

Mrs. Rhinehardt, I especially wanted to acknowledge your testimony and appreciate everything that you are doing in North Carolina. I especially want to point out where you talk about the UNC 

Partnership for National Security, and I think you raised a very 

poignant point here where you say that, you know, the soldier that 

deploys may be our family member, friend or neighbor; the family 

that they leave behind is our family. 

The education that the servicemember needs is crucial to the 

mission because the most important weapon that he or she has is 

not an assault rifle but their mind. And you talk about the ability 

to adapt to changing environments, use critical thinking skills, 

learn a foreign language, employ negotiation skills, apply conflict 

management lessons. 

I think that is a good reminder of how important this education 

is to those who are serving our country. So I appreciate that very 

much, wanted to point that out and thank you for all you are doing 

in North Carolina. 

I also wanted to thank my colleague, Congresswoman Brooks, for 

asking the question that I was going to ask about what we can do 

to make sure that our servicemembers get credit hours for their 

past service. And I have had people who have served come into my 

office and tell me about everything that they did and they are a 

little frustrated about why they can’t get credit for that work that 

they have already done. 

So I am going to explore a different issue and I wanted to talk 

a little bit about this 90/10 rule. Now, I wasn’t here when it was 

implemented and passed. My assumption is that it was designed to 

ensure that students have some skin in the game and probably to 

crack down on some of the abuses. 

But I wanted to talk about what appears to be sort of the unintended consequence that has resulted in what appears to be more 

of an incentive to recruit servicemembers to for-profit institutions, 

and I know that there are examples that were raised in the articles 

in the testimony—prior testimony of Ms. Petraeus in another committee. So I would like to talk a little bit about that. 

I know that the Department of Defense has recently updated its 

rules against aggressive solicitation by educational institutions on 

military installations and finalized the Know Before You Owe shopping sheet for veterans. So will you please all address this issue 

of—none of us want the abuses that we have heard about—people 

being recruited who shouldn’t be recruited, misinformation provided. 

So can you talk about how we can make sure that those abuses 

are stopped? And if you would address whether you believe these— 

what appear to be fairly new rules - 

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are really going to do what they are designed to do and crack 

down on that overly aggressive solicitation of our veterans? 

Thank you. 

And, Dr. Kitchner, you look like you are ready to start. 

Mr. KITCHNER. Well, I think I am probably the poster child for 

a 90/10 issue in the sense that I represent a for-profit university, 

and we are currently—our mix of students currently puts us well 

underneath that 90/10 issue. What we find disconcerting about the 

conversation around changing 90/10 and folding T.A. and V.A. into 

that formula is it could have the perverse effect of restricting the 

students from attending a university that they really want to attend and where there may be programs that are unique to their interests and they would be excluded from that. 

There is also the potential for, you know, an increase in cost to 

offset 90/10. I am not sure I want to speculate on the degree of relevance of that. I think there is some relevance to it, but I wouldn’t 

want to overstate it. 

I think the more important question, really, is what effect changing it would have on redlining, in a sense—that institutions would 

stop serving the very populations that need our services the most, 

that need education the most. I would hate to see institutions that 

are doing a very good job being held back from fulfilling that mission simply because of a regulatory provision that had that perverse effect on restricting their ability to do that. 

Ms. BONAMICI. And do you think that the new rules, the updated 

rules from the Department of Defense, are going to crack down on 

the overly aggressive solicitation? 

Mr. KITCHNER. I honestly believe they have great potential for 

doing that. I think it is going to depend on how well the terms are 

defined and how well they are implemented but I—because I think 

some of the regulations and the rules that have been discussed talk 

about graduation rates and employment rates and those are terms 

that even the Department of Education has not yet fully established concrete definitions for them. 

And so there is a lot of work yet to be done in terminology and 

measurement—appropriate statistics for measuring the concepts, 

but I think the Department of Defense is headed in the right direction, and I think that the MOUs and other initiatives that relate 

to making sure that veterans and military students in general are 

being well served have potential as long as they are not overlapping and contradictory. 

Ms. BONAMICI. Thank you very much. 

And I see my time is expired. Thank you, Madam Chairwoman. 

Chairwoman FOXX. Thank you. 

I will now recognize myself for 5 minutes. 

Mrs. Rhinehardt, in your written testimony and you briefly 

touched on the initiatives put forward by the Obama administration in your spoken testimony—in early August the president gave 

a speech outlining eight keys to success for higher education institutions to follow as they serve servicemembers and veterans. When 

this initiative was unveiled, the president noted 250 institutions 

had already agreed to push these efforts on campus. 

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Was the UNC system asked to join the Eight Keys to Success effort? Do you know the criteria that the Department of Education 

used to recruit colleges in this effort? 

Mrs. RHINEHARDT. No, we were not asked. I learned about it— 

a colleague of mine forwarded a press release to my e-mail and I 

was—you know, the secretary of the V.A. had just been to UNC 

system and commented that we were the most coordinated system 

of higher education in the country that he had ever seen, so you 

can imagine our disappointment that we weren’t asked because we 

are very—we feel proud of what we are doing and want to communicate to all veterans that we support them. 

Chairwoman FOXX. Thank you very much. 

Now I would like to ask all of the witnesses—and, Dr. Kitchner, 

perhaps I will start with you since you have gotten left out a couple 

of times and we will try to get you and Dr. Sauer in and go the 

other way. 

In your experience in educating the student veteran population, 

what are two best practices done at your institution that you think 

could be adapted to other universities, and have you shared these 

best practices with other colleges and universities? 

Mr. KITCHNER. I will take my cue and respond. One of the things 

that I think is absolutely essential is to prepare our faculty to work 

with veteran students, understanding that they come to the classroom with some special challenges and in all likelihood have life 

situations and experiences that differ from your traditional collegeage student. So I think we need to make sure that faculty are oriented and prepared to address that population effectively and to 

make accommodations for their circumstances. 

And it happens that we have a retired colonel on our faculty who 

is a—who teaches a seminar on preparing faculty to teach veterans 

and military students, and he teaches that seminar for faculty all 

over the country and it is a very successful one. I think that is a 

very important part of it. 

Chairwoman FOXX. Okay. A second one very quickly, or do you 

want to stop with that one? 

Mr. KITCHNER. I will yield to my colleagues. 

Chairwoman FOXX. Okay. 

Dr. Sauer? 

Mr. SAUER. Well, in the spirit of representing a multi-state collaborative, I am going to point to— 

Chairwoman FOXX. Sure. 

Mr. SAUER [continuing]. One of our members states, Minnesota, 

that I haven’t mentioned before. Minnesota has developed a really 

terrific website and it is very veteran-friendly and provides a lot of 

information, and I think communication and academic advising is 

so critical. I think it is really important to pay attention to this 

area, and the Minnesota State Colleges and Universities, in particular, have developed this website. 

This is a variation of that, but it is a second—you called for 

two—you asked for two practices, and I will again point to the Minnesota State Colleges and Universities. They really have made very 

good use of the data file of the military occupational specialties and 

the ACE credit recommendations. And it was unfortunate that for 

reasons that I am not quite sure about the access to that was cut 

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off through the Department of Defense, and this is why I mention 

the need to try to work on the contract to make that information 

available. 

Chairwoman FOXX. Dr. Kirk? 

Mr. KIRK. Beyond training faculty, the staff advisors, and community, law enforcement, recognizing post-traumatic stress, teachers—because the children of veterans, certainly those that went 

through multiple deployments, exhibit many of the characteristics 

of foster children, and recognizing and dealing with that. And then 

our mentorship program—we have many faculty and staff who are 

themselves veterans, and having them, whether they are in administrative technology positions outside and away from students, 

mentoring student vets has been very, very important to them. 

Chairwoman FOXX. Thank you. 

Mrs. Rhinehardt? 

Mrs. RHINEHARDT. Thank you, Dr. Foxx. 

I would say that the one-stop shop concept is very important. 

Folks want to go to one place for information with clearly articulated steps for each process that they need. And that could be virtual, that could be a physical location on campus. That is the most 

important thing that we can do. 

I also think it is very important for leadership of a college or university to really signal to the rest of the campus how important 

this population is, so I think leadership from the top—that commitment from the president, the commitment from the chancellor— 

makes a huge difference in how that campus responds, because 

from every faculty member I have ever talked to who have had 

these students in their classrooms, they say that by far these students make a huge difference in the conversations that occur—they 

add value, and frankly, they are some of our very best students. 

Chairwoman FOXX. Thank you all very much. Thank you again, 

for the distinguished panel, for taking your time today. 

Mr. Hinojosa, do you have closing remarks? 

Mr. HINOJOSA. Thank you, Madam Chair. 

I would like to thank you all—each and every one of the panelists for sharing your insights and expertise on these very important 

issues that we discussed today. This has been very informative and 

will be very helpful to all members of Congress. 

As this committee moves forward with the reauthorization of the 

Higher Education Act I look forward to working with my colleagues 

on this committee to support higher education opportunities for our 

nation’s servicemembers and veterans. I believe that this committee must ensure that veterans and servicemembers are protected from predatory practices and can fully benefit from federal 

higher education programs. 

I thank you. 

Chairwoman FOXX. Thank you, Mr. Hinojosa. 

I wanted to recognize one other person who is here with me 

today, and that is Jason Harvey, who is doing an internship in my 

office. Jason is a Marine veteran and took advantage of the programs we have been talking about here today, got his degree from 

George Washington, and is interested in the public policy arena. 

And we are absolutely delighted to have him with us. 

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I want to again thank all of you all for being here. We had actually a hearing yesterday on research and how best to use research 

in application in education, and I said that I felt like it was deja 

vu all over again because these conversations have been going on 

for a long time. 

As someone who used to be full time in the education arena, I 

think about the things that I was involved with when I was there. 

I actually set up a transfer, a program at Appalachian State University when I was there, to ease the transition for transfer students coming to Appalachian. We had always had a very vibrant 

transfer population and we were doing everything that we could to 

make it possible for the students to get the credit that they needed. 

So this issue about transfer of credit has gone on, I guess, as 

long as we have had higher education. It boils down to the issue 

of academic freedom and faculty and departments being very jealous of their programs and wanting to make sure of the integrity 

of the programs that their graduates have. 

So it isn’t something that has just recently cropped up; it is out 

there and has been out there for a long time. And I say, you know, 

it is—Ms. Bonamici asked the question, ‘‘How do we guarantee that 

more of this is done?’’ Other people have gone at that issue. 

And it is a tough one, and I don’t think it is where the federal 

government should be involved, and I think the higher ed community would rise up in arms if the—if we do. But I think what is 

being done to honor the experiences that are gained through the 

military is very important. 

And, Mrs. Rhinehardt, I really am very proud of the University 

of North Carolina system and my alma mater for all that you are 

doing there and for the leadership that you are providing. And we 

know that you understand about working with the military when 

you say Camp Lejeune. That got my attention because most people 

do not say that and the Marines know that that is the appropriate 

term to use. 

But I think progress is being made and it is obvious, again, from 

the things that you are saying that progress is being made to help 

our veterans and help our active duty military. And I appreciate 

all that you all are doing and I just hope that the good practices 

that are being utilized in your institutions and by other institutions 

are going to be spread out and that we do honor these people in 

an appropriate way. 

And, as I said, as we work to reauthorize the higher education 

legislation next year we will be keeping your testimony in mind. 

And as other people have said, we all have the same commitment— 

all of us here, whatever our party is, and most of the people in this 

country—to honor our veterans and our military people. 

So, there being no further business, the subcommittee stands adjourned. 

[Questions submitted for the record and their responses follow:] 

U.S. CONGRESS, 

Washington, DC, November 6, 2013. 

Dr. ARTHUR F. KIRK, JR., President, 

Saint Leo University, Office of the President—MC2187, P.O. Box 6665, Saint Leo, FL 

33574-6665. 

DEAR DR. KIRK: Thank you for testifying before the Subcommittee on Higher Education and Workforce Training at the hearing entitled, ‘‘Keeping College Within 

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Reach: Supporting Higher Education Opportunities for America’s Servicemembers 

and Veterans,’’ on Wednesday, September 11, 2013. I appreciate your participation. 

Enclosed are additional questions submitted by members of the subcommittee 

after the hearing. Please provide written responses no later than November 22, 2013 

for inclusion in the final hearing record. Responses should be sent to Amy Jones 

or Emily Slack of the committee staff who can be contacted at (202) 225-6558. 

Thank you again for your important contribution to the work of the committee. 

Sincerely, 

VIRGINIA FOXX, Chairwoman, 

Subcommittee on Higher Education and Workforce Training. 

CHAIRWOMAN VIRGINIA FOXX (R-NC)

In your written testimony, you mention that Saint Leo provides academic credit 

for the prior learning experiences of student veterans. Could you provide us a few 

examples where that has taken place? Also, is this benefit provided for just student 

veterans or all students? 

REPRESENTATIVE DAVE LOEBSACK (D-IA)

In your view, what are the specific regulations that institutions of higher education must comply with pertaining to veterans and servicemembers that are overly 

burdensome? 

Dr. Kirk’s Response to Questions Submitted for the Record 

In you written testimony, you mention that Saint Leo provides academic credit for 

the prior learning experiences of student veterans. Could you provide us a few examples where that has taken place? Also, is this benefit provided for just student veterans or all students? 

This benefit is provided to all students, but through the American Council of Education (ACE) program of evaluating military training and assigning, where appropriate, course credit equivalencies, active-duty military and veterans generally can 

earn more credits, more easily. The university uses LearningCounts to help students 

develop substantive portfolios of prior, non-academic learning other than ACE evaluated training and then assess the amount of credit to be awarded. We, of course, 

also encourage students to avail themselves of CLEP, DANTES and other testing 

opportunities to earn credits. We operate ‘‘testing centers’’ at many of our locations 

for any active-duty military or veteran interested in earning credits this way regardless of what college they are attending or intend to enroll in. 

In your view, what are the specific regulations that institutions of higher education 

must comply with pertaining to veterans and servicemembers that are overly burdensome? 

The VA requires schools to report graduation data when the VA works with the 

National Student Loan Clearinghouse and has the graduation information already. 

This is a duplication of efforts. 

The net payer regulation put into effect in 2011 put an additional strain on Florida certifying officials who have to reduce for FRAG (The Florida Resident Access 

Grant). This has caused many problems with overpayments and unhappy students. 

The current Post 9/11 GI Bill regulation regarding (withdrawals) is counterintuitive. A student who is failing a class is typically advised by his/her advisor to withdraw minimizing the impact of their GPA. Unfortunately, for student veterans the 

VA will only cover the cost of a repeated course if he/she received an ‘‘F’’. 

The proactive student is penalized and is then required to pay out-of-pocket for 

the repeated course. Although, this may not be an institutional burden, it does have 

larger implications such as GPA, retention, and employment. However, the VA will 

allow veterans to fail a class multiple times and continue to pay 100% for the class. 

This hurts the student’s progress to their degree and costs the VA extra. 

Determining term certification eligibility of Active Duty students on Page 85 of 

the book defines ‘‘Tuition Assistance (TA) as a DoD program. Rules for this program 

vary by branch of service and can even vary between components within the 

branches * * * If a student receives education benefits from VA and receives TA 

benefits from the military, duplication of benefits may be an issue.’’ Determining if 

there is an issue tends to fall on the school. Two pages of the Handbook attempt 

to define potential duplication issues. Compiling information from the student, 

branch unit, and VA on a case by case situation is definitely burdensome. (It involves crucial work hours, questioning students who often don’t have a clue whether 

their funds are Federal or State-funded, and sometimes even education unit EduCEWDOCROOM with DISTILLER

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cation Service Officers (ESO’s) who are telling the military personnel they CAN use 

TA and Post 9/11 benefits together. While technically true, only Net Tuition can be 

reported to the VA (often resulting in a waste of the serviceperson’s educational benefits). 

U.S. CONGRESS, 

Washington, DC, November 6, 2013. 

Dr. RUSSELL S. KITCHNER, Vice President, 

Regulatory and Governmental Relations, American Public University System, 111 W. 

Congress Street, Charles Town, WV 25414. 

DEAR DR. KITCHNER: Thank you for testifying before the Subcommittee on Higher 

Education and Workforce Training at the hearing entitled, ‘‘Keeping College Within 

Reach: Supporting Higher Education Opportunities for America’s Servicemembers 

and Veterans,’’ on Wednesday, September 11, 2013. I appreciate your participation. 

Enclosed are additional questions submitted by members of the subcommittee 

after the hearing. Please provide written responses no later than November 22, 2013 

for inclusion in the final hearing record. Responses should be sent to Amy Jones 

or Emily Slack of the committee staff who can be contacted at (202) 225-6558. 

Thank you again for your important contribution to the work of the committee. 

Sincerely, 

VIRGINIA FOXX, Chairwoman, 

Subcommittee on Higher Education and Workforce Training. 

CHAIRWOMAN VIRGINIA FOXX (R-NC)

In your testimony, you’ve detailed the tremendous support and services that 

APUS provides to student veterans. Have you worked with other institutions to 

share these best practices or help other institutions develop their own set of veteran-friendly policies on campus? 

REPRESENTATIVE DAVE LOEBSACK (D-IA)

In your view, what are the specific regulations that institutions of higher education must comply with pertaining to veterans and servicemembers that are overly 

burdensome? 

Dr. Kitchner’s Response to Questions Submitted for the Record 

Please accept the following in response to your letter of November 6, 2013 in 

which you and Rep. Loebsack sought additional information subsequent to the Subcommittee hearing on September 11, 2013. You stated your specific question as follows: 

‘‘In your testimony, you’ve detailed the tremendous support and services that 

APUS provides to student veterans. Have you worked with other institutions to 

share these best practices or help other institutions develop their own set of veteran-friendly policies on campus?’’ 

Indeed, one of the key dimensions of our culture and values as an institution of 

higher education is to be a resource to other colleges and universities. To that end 

our staff makes it a point routinely and regularly to attend national conferences, 

and to actively engage with our educational colleagues. The following examples are 

a good indication of the degree of our engagement with the higher education community: 

• DOD Worldwide Education Symposium 

• The Council for College and Military Educators 

• The Conference on Distance Learning Administration 

• The Sloan Consortium’s Conference on Distance Learning 

• American Association of Collegiate Registrars and Admissions Officers 

In addition to our attendance at these and other meetings and conferences, our 

faculty and staff have given countless presentations and served as panelists in the 

context of programs designed to help other institutions effectively respond to the 

personal and educational needs of their military students and veteran students, including the following: 

• ‘‘Wounded Warriors: The New Transfer Students of America’’—AACRAO Annual Meeting 

• ‘‘So What Are You Gonna Give Me?: A Transfer Credit Award Comparison’’— 

CCME Annual Meeting 

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• ‘‘Prior Learning Assessment: Balancing Academic Quality and Enrollment 

Goals’’—Academic Impressions Webinar • Presentation titled ‘‘Students with PTSD: Is Your Faculty Prepared?’’—CCME • ‘‘Organizational Structures for Military Transfer Students’’—DoD Worldwide • ‘‘So What Are You Gonna Give Me?: A Transfer Credit Award Comparison’’— 

AACRAO Annual Meeting • ‘‘Awarding Credit for Non-Traditional Education and Training’’—AACRAO Annual Meeting Workshop • ‘‘Awarding Credit for Non-Traditional Education and Training’’—AACRAO 

Transfer Conference Workshop • ‘‘Organizational Structures for Transfer Students’’—AACRAO Annual meeting • ‘‘Transfer 101’’—AACRAO Annual Meeting • ‘‘How to Better Serve Military Students’’—Sloan Consortium • APUS also hosted a VA Certifying Official’s Workshop in Spring 2013 for the 

colleges and universities located in the eastern region of West Virginia 

In an effort to reach even wider audiences, our faculty and staff have published 

a number of articles, contributed to numerous publications and engage in a wide 

variety of social media related to educating servicemembers and veterans, such as: • ‘‘Finding Success as a Returning Veteran or Military Student,’’ published as 

part of Pearson’s ‘‘Identity’’ series • LinkedIn group titled ‘‘PTSD and Online Faculty:’’ Group contains almost 400 

members from all over the world • Although APUS is not a member of the Association of Public Sector Colleges 

and Universities (APSCU), the university was asked to serve on a Blue Ribbon 

Taskforce for Military and Veteran Education. The results of that task force was the 

publication of a comprehensive guidebook that established best practices and indicators of program integrity to which all colleges and universities in America could embrace and implement. 

In addition to providing written testimony and serving as a witness at the Subcommittee hearing that is the focus of this letter, I was invited to testify on September 22, 2011 before the Federal Financial Management, Government Information, Federal Services, and International Security Subcommittee of the Senate Committee on Homeland Security and Governmental Affairs on the topic of ‘‘Improving 

Educational Outcomes for Our Military and Veterans.’’ 

APUS has a dedicated Veteran’s office, which supports the needs of Veterans 

working toward a degree within the university system. Some of the operational dimensions that APUS has established in the context of that office, and in support 

of military and veteran students generally include the following: • Dedicated teams within the Enrollment Management department, Student Advising department, Career Services department, and Finance department to assist 

military and veterans with answers to questions specific to their culture and needs 

• The Student Services office has developed and implemented programs to assist 

Veterans’ with resume writing, translating military jargon into civilian terminology, 

mock interview processes, and expectations for civilian employment 

• Mandatory faculty orientation programs to aid in better understanding the military and veteran culture 

• APUS also has a generous transfer credit policy which equates to more earned 

college credit for life experience 

• APUS is the ‘‘largest online, Student Veteran’s Chapter in the Country,’’ recognized and stated by the parent Student Veterans of America organization 

Finally, APUS has worked with the National Association of Veteran’s Program 

Administrations (NAVPA) to prove compliance with Executive Order 13607, and it 

was invited by the GAO to participate in discussions to help improve educational 

processes and academic support services for veteran students. 

Representative Dave Loebsack (D-IA) asked the following question: 

In your view, what are the specific regulations that institutions of higher education must comply with pertaining to veterans and servicemembers that are overly 

burdensome? 

With regard to the notion of regulatory burden, it should be noted at the outset 

that institutions that endeavor to serve military and veteran students should be 

prepared to accept reasonable standards of regulatory oversight. Given that the 

term ‘‘overly burdensome’’ is relative, some institutions are likely better equipped 

than others to accommodate such oversight, depending on mission, resources, and 

institutional culture. That qualifier aside, the challenges associated with the current 

regulatory environment are generally focused on the Departments of Defense and 

Veterans Administration. One example worth noting is the labor-intensive processes 

associated with compliance with various VA and State Approving Agency policies. 

For instance, one of the biggest inhibitors to the ability of institutional certifying 

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officials to correctly report enrollment information to the VA is that such officials 

do not have access to a students’ VA data. There have been discussions in the past 

around the possibility of establishing stakeholder access rights to the eBenefits 

website, and access to that site would provide certifying officials with specific data 

regarding a student’s benefit entitlements. It would also make the university’s task 

of accurately reporting data to the VA much less complex if it could view specific, 

relevant data, such as the number of entitlements remaining, the percentage of eligibility, where and when other schools submitted benefits for the student, etc. Given 

the current state of affairs, it is not unusual for the university to submit a benefit 

report for a student to the VA, only to be subsequently informed by the VA that 

the student had exhausted eligibility, thus creating an unnecessary burden on the 

student to find other means to pay for his/her courses. If colleges and universities 

had a VA-regulated database, many of these issues could be resolved before the student is allowed to enroll in courses and later be expected to provide the necessary 

funds from alternative sources. 

There is sound reason to believe that this issue and others could be addressed as 

a result of a re-structuring of the VAOnce system to allow for greater reporting from 

school officials. Frankly, the current system is very archaic and is primarily useful 

only as a data entry tool. Fairly commonplace technological upgrades to this system 

(ability to export student data, more robust reporting of student data, and the ability to accept a mass batch of VA enrollment certifications for students rather than 

input each enrollment for each term for each student) would greatly increase the 

efficiencies of both the VA Regional Office processors and school officials. Both cohorts are increasingly taking on roles that were previously the responsibilities of VA 

Regional Processing Office personnel. 

The issue above notwithstanding, I would respectfully rephrase Rep. Loebsack’s 

question to reflect the fact that regulations are not simply a function of burden, but 

also one of constraints. The President’s call for increased access to higher education, 

and by clear implication, increased persistence to graduation without incurring 

undue financial burden, is a mandate that seems to be contradicted by Department 

of Education and Congressional initiatives that would have the effect of limiting access and increasing costs. Considering that recent budget cuts have eroded tuition 

assistance benefits for servicemembers, it is regrettable that in March, 2013, the Department of Defense added insult to injury by issuing Instruction 1322.19—‘‘Voluntary Education Programs in the Overseas Area.’’ Specifically, Enclosure 3, paragraph 4d of that policy stipulates that ‘‘Overseas Servicemembers who initiate postsecondary programs after the Servicemembers’ arrival in the overseas duty location 

may not receive military TA for courses offered by non-approved program institutions overseas. This limitation will apply to the first postsecondary course requested 

and successfully completed by the Service member.’’ 

This provision, combined with language contained in the ‘‘Performance Work 

Statement (PWS) for Post-Secondary Programs of the U.S. Army, U.S. Air Force and 

U.S. Navy in Europe’’ issued by the Department of the Army, Europe on June 25, 

2013 that prohibits non-contract schools from displaying educational materials in 

military education centers, limits choice for servicemembers and creates a virtual 

monopoly for a small handful of academic institutions. Specifically, the PWS states, 

‘‘Non-contract academic institutions will not be permitted on installations, and their 

coursework and programs will not be marketed on the installations. Only the contracted academic institutions shall participate in education fairs on military installations.’’ 

The spirit and intent of the DoD Voluntary Education Program is to provide freedom of choice to servicemembers desiring to pursue their educational goals. Restrictive policies such ‘‘Instruction 1322.19—‘‘Voluntary Education Programs in the 

Overseas Area’’ have the real and regrettable effect of limiting educational opportunities for servicemembers by forcing them to enroll in programs provided by a selected group of institutions that do not necessarily offer the desired programs. It 

should be further stipulated that these recent polices implemented by DoD contradict long-standing policy as codified in DoD Instruction 1322.08, to wit: 

It is DoD policy, under Section 2005 and 2007 of title 10 United States Code that: 

4.1. Programs shall be established and maintained in the Department of Defense 

that provide servicemembers with educational opportunities that they may participate voluntarily during their off-duty time or at such other times as authorized by 

Military Services’ policies. 

4.2. Voluntary education programs shall provide educational opportunities comparable to those available to citizens outside the military, be available to all active 

duty personnel regardless of their duty location, and include courses and services 

provided by accredited postsecondary vocational and technical schools, colleges, and 

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universities. Programs may be provided as traditional classroom instruction or 

through distance education. 

I have no doubt that the Department’s intentions were honorable, but I am equally convinced that in issuing this policy, it did not take into full account the best 

interests of America’s military personnel, nor does its policy support the President’s 

national vision for an educated society. I believe that those of us who strive to provide educational opportunities, the various branches of government, and all military 

agencies can do a better job of acknowledging our indebtedness to servicemembers 

and veterans by respecting their ability to make sound decisions, and affording 

them the prerogative to attend the institutions of their choice. 

As stated during my oral comments to your Committee, I consider it a distinct 

privilege to be asked to represent APUS in the context of that hearing, and I remain 

willing to provide additional testimony upon request. 

U.S. CONGRESS, 

Washington, DC, November 6, 2013. 

Mrs. KIMREY W. RHINEHARDT, Vice President, 

Federal and Military Affairs, the University of North Carolina, 910 Raleigh Road, 

Chapel Hill, NC 27514. 

DEAR MRS. RHINEHARDT: Thank you for testifying before the Subcommittee on 

Higher Education and Workforce Training at the hearing entitled, ‘‘Keeping College 

Within Reach: Supporting Higher Education Opportunities for America’s 

Servicemembers and Veterans,’’ on Wednesday, September 11, 2013. I appreciate 

your participation. 

Enclosed are additional questions submitted by members of the subcommittee 

after the hearing. Please provide written responses no later than November 22, 2013 

for inclusion in the final hearing record. Responses should be sent to Amy Jones 

or Emily Slack of the committee staff who can be contacted at (202) 225-6558. 

Thank you again for your important contribution to the work of the committee. 

Sincerely, 

VIRGINIA FOXX, Chairwoman, 

Subcommittee on Higher Education and Workforce Training. 

CHAIRWOMAN VIRGINIA FOXX (R-NC)

In your written testimony, you talked about the university’s transfer of credit policies. Can you elaborate more about that and how those policies help student veterans? 

REPRESENTATIVE RICHARD HUDSON (R-NC)

1. Mrs. Rhinehardt, by my count you must contend with five separate federal 

agencies in trying to serve student veterans and military students: the Department 

of Education, the Department of Veterans Affairs, the Department of Defense, the 

Consumer Financial Protection Bureau and the Department of Justice. Is that correct or are there other agencies that have regulations with which you must also 

comply? 

2. In the President’s Executive Order he directs the Secretary of Education to collect information on the amount of funding received pursuant to the Post-9/11 GI Bill 

and the Tuition Assistance Program. I am aware that the department, through 

IPEDS, has started the process of requiring this information of institutions of higher 

education. Is this correct? 

3. Part of the UNC SERVES initiative is to evaluate best practices for improving 

access, retention, and graduation of student veterans on campus. What are some of 

those best practices and do these differ from what the campuses are doing to improve outcomes for all students? 

REPRESENTATIVE DAVE LOEBSACK (D-IA)

In your view, what are the specific regulations that institutions of higher education must comply with pertaining to veterans and servicemembers that are overly 

burdensome? 

Mrs. Rhinehardt’s Response to Questions Submitted for the Record 

CHAIRWOMAN FOXX

In your written testimony, you talked about the university’s transfer credit policies. 

Can you elaborate more about that and how those policies help student veterans? 

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A: The University of North Carolina recognizes the value of the education, training, and experience that military students bring to the university. The university 

and its constituent campuses are working to establish a process by which this learning can be evaluated for possible course credit. Such learning may include, but will 

not be limited to, recruit training, military occupational specialty (MOS) training 

and education, Defense Language Institute foreign language and coursework exams, 

Community College of the Air Force (CCAF) coursework, College-Level Examination 

Program (CLEP), and DANTES Standardized Subject tests. 

The American Council on Education (ACE) credit equivalency recommendations 

serve as the standard reference for recognizing the learning acquired through military service. Constituent campuses, however, reserve the right to evaluate military 

learning independent of ACE recommendations and evaluation. 

HON. RICHARD HUDSON

By my count, you must contend with five separate federal agencies in trying to 

serve student veterans and military students: the Department of Education, the Department of Veterans Affairs, the Department of Defense, the Consumer Financial 

Protection Bureau, and the Department of Justice. Is that correct, or are there other 

agencies that have regulations with which you must also comply? 

A: Yes, but actually within the DOD we are also required to work with each 

branch of service on addenda to the MOUs so that adds the US Army, Navy, Air 

Force and Marines in addition to the five agencies that you mentioned. Other than 

for the Department of Education, education is not the primary mission of the federal 

agencies. These other agencies don’t always understand higher education or the diversity of schools and practices, so their regulatory efforts are typically misguided 

and problematic for schools. 

In the President’s Executive Order, he directs the Secretary of Education to collect 

information on the amount of funding received pursuant to the Post-9/11 GI Bill and 

the Tuition Assistance Program. I am aware that the department, through IPEDS, 

has started the process of requiring this information of institutions of higher education. Is this correct? 

A: Yes, IPEDS will require that institutions of higher education report a number 

of new data points as it relates to veterans and active duty service members. We 

will report the number of undergraduate and graduate students receiving Post 9/ 

11 benefits as well as the total dollar amount of tuition and fee benefits awarded 

to them through the institution. We will also be required to do this for active duty 

service members using tuition assistance. The ‘‘preview year’’ is the 2013-2014 academic year with the full requirement beginning in the 2014-2015 academic year. Additionally, IPEDS will collect additional data for the Institutional profile such as 

whether or not the institution participates in the Post-9/11 GI Bill and Yellow Ribbon Programs, offers credit for military training, provides a dedicated point of contact for support services for veterans, military service members, and their families, 

has a recognized student veteran organization, is a Member of Servicemembers Opportunity Colleges (SOC), as well as the URL for tuition policies specifically related 

to veterans and military service members. 

Both the VA and the DOD should be able to provide this information to the Department of Education without requiring new data from institutions of higher education. It would be great if both agencies issued an annual demographic report that 

outlined this information. It would be beneficial to institutions and the taxpayer to 

have access to this data. 

Part of the UNC SERVES initiative is to evaluate best practices for improving access, retention, and graduation of student veterans on campus. What are some of 

those best practices and do these differ from what the campuses are doing to improve 

outcomes for all students? 

A: Although UNC system campuses seek to provide the utmost quality education 

and assistance necessary to improve outcomes for all students, the system recognizes that military and student veterans often have needs different to their civilian 

student counterparts. The UNC system seeks to fulfill those needs through the UNC 

SERVES initiative, which includes a multitude of best practices recommendations. 

Some of the best practices recommendations include a Student Affairs Liaison 

specifically for military-affiliated students, military or veteran orientation sessions, 

operational tracking of active-duty military and veteran student populations, admissions counselors for military-affiliated students, classification of military students as 

transfer students, and a dedicated web presence for military-affiliated students. 

Please see the full table (attached) for a more comprehensive list and as each item 

pertains to the individual campuses. 

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HON. DAVE LOEBSACK

In your view, what are the specific regulations that institutions of higher education 

must comply with pertaining to veterans and servicemembers that are overly burdensome? 

A: Other than for the Department of Education, education is not the primary mission of the federal agencies. These agencies don’t always understand higher education or the diversity of schools and practices, so their regulatory efforts are typically misguided and problematic for schools. The MOU is an example for DoD. The 

VA has numerous examples, but the debt offset problem comes to mind, as well as 

the fact that the VA does not have a way to communicate with institutions. Instead, 

it often sends notices by postal mail and sometimes one location will get notices for 

several campuses since the VA identifies institutions with a very different system 

than the Department of Education’s OPEID number. 

It would be helpful to have a webpage similar to IFAP that would post all the 

regulatory and sub-regulatory guidance for GI bill benefits, so institutions have one 

place to look. Finding letters outlining VA policies is difficult and burdensome. 

U.S. CONGRESS, 

Washington, DC, November 6, 2013. 

Dr. KEN SAUER, Senior Associate Commissioner for Research and Academic Affairs, 

Indiana Commission for Higher Education, 101 W. Ohio Street, Suite 550, Indianapolis, IN 46204-1984. 

DEAR DR. SAUER: Thank you for testifying before the Subcommittee on Higher 

Education and Workforce Training at the hearing entitled, ‘‘Keeping College Within 

Reach: Supporting Higher Education Opportunities for America’s Servicemembers 

and Veterans,’’ on Wednesday, September 11, 2013. I appreciate your participation. 

Enclosed is an additional question submitted by a member of the subcommittee 

after the hearing. Please provide a written response no later than November 22, 

2013 for inclusion in the final hearing record. Responses should be sent to Amy 

Jones or Emily Slack of the committee staff who can be contacted at (202) 225-6558. 

Thank you again for your important contribution to the work of the committee. 

Sincerely, 

VIRGINIA FOXX, Chairwoman, 

Subcommittee on Higher Education and Workforce Training. 

REPRESENTATIVE DAVE LOEBSACK (D-IA)

In your view, what are the specific regulations that institutions of higher education must comply with pertaining to veterans and servicemembers that are overly 

burdensome? 

[Response to questions submitted to Dr. Sauer follow:] 

May 9, 2014. 

Hon. VIRGINIA FOXX, Chairwoman, 

Subcommittee on Higher Education and Workforce Training, U.S. House of Representatives, 2181 Rayburn House Office Building, Washington, DC 20515. 

Dear Representative Foxx: I write about your request to respond to the following 

question posed by Representative Loebsack: 

‘‘In your view, what are the specific regulations that institutions of higher education must comply with pertaining to veterans and servicemembers that are overly 

burdensome?’’ 

To help craft my answer, I sent a request to the academic officers of all of our 

public two- and four-year institutions to solicit their reactions to Representative 

Loebsack’s question. The majority of our colleges and universities responded, and in 

a few cases, with considerable detail. 

Most institutions identified problems that in one way or another focused on burdens associated with supplying detailed information about students to the Veterans 

Administration and on inefficiencies in accessing related information so benefit 

claims could be processed in a timely manner. Other concerns identified by the institutions included: the frequency with which the Department of Defense changed the 

requirements of the MOUs institutions sign with the Department; lack of consistency in definitions used by different federal agencies with respect to veterans; the 

requirement to upload extensive information about the institution, such as course 

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catalogs, class schedules, and tuition rate charts; and confusion in communicating 

to veterans the differences among various federal and state benefit programs. 

In reflecting on the institutional responses, Indiana Commission colleagues and 

I have identified some potential ways for addressing the problems identified above. 

Though we offer these as conversation starters, we believe that each of the following 

is rooted in a sound idea that deserves further consideration: 

1. Have the Veterans Affairs Certifying Official (VACO) at each institution be a 

certified user of the VA’s VETRECS computer system, which would enable them to 

more efficiently access information needed to carry out their responsibilities; 

2. Integrate the billing systems of the VA so that information about each veteran 

and each course they take only needs to be entered once by the VACO, rather than 

entering duplicate information for each benefit, for which the veteran is eligible. Not 

only would this reduce the possibility for data entry errors, but it would also enable 

better access to this information by VACOs at other institutions across the country, 

should the veteran transfer to another institution anywhere in the country; 

3. Rather than having the VACOs tediously enter data on each course taken by 

each veteran—including course titles, grades, start dates, and end dates, as currently required by GoArmyEd, for example—have the VA accept this information 

through a college transcript, which could be transmitted electronically, ideally in a 

standardized format, via commercial vendors widely used by institutions and states; 

and 

4. Consider modifying the contracts between the VA and the State Approving 

Agencies (SAAs), such that SAA Directors can play a more active role in educating 

servicemembers and their families about their eligibility for educational benefits. 

We would be happy to provide additional information about the problems that our 

institutions have identified and constructive suggestions about potential ways these 

problems might be addressed. 

Last September, I had the privilege of providing testimony before the Subcommittee on the Multi-State Collaborative on Military Credit. I am pleased to report that the Collaborative now has eleven member states and that a meeting of 

state representatives will be held on May 27–28. The gathering, which will be held 

in Indianapolis, will also include in-person representation from the Department of 

Defense, Veterans Administration, DANTES, Servicemembers Opportunity Colleges, 

Council of College and Military Educators, Council for Adult and Experiential 

Learning, CollegeSource, National Governors Association, Midwest Higher Education Compact, and State Higher Education Executive Officers. The Collaborative’s 

commitment to better meeting the needs of our servicemembers and veterans remains firm and we pledge our best efforts to carry through on this commitment. 

Thank you for the opportunity to provide testimony to the Subcommittee and to 

respond to Representative Loebsacks’s question. 

Sincerely, 

KEN SAUER, PH.D., 

Senior Associate Commissioner and Chief Academic Officer. 

[Whereupon, at 1:23 p.m., the subcommittee was adjourned.] 

Æ 

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