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96–134 2015

THE ROLE OF THE STATE APPROVING AGENCIES 

IN ENSURING QUALITY EDUCATION PROGRAMS 

FOR VETERANS 

HEARING 

BEFORE THE

SUBCOMMITTEE ON ECONOMIC 

OPPORTUNITY 

OF THE

COMMITTEE ON VETERANS’ AFFAIRS 

U.S. HOUSE OF REPRESENTATIVES 

ONE HUNDRED THIRTEENTH CONGRESS 

SECOND SESSION 

WEDNESDAY, NOVEMBER 19, 2014 

Serial No. 113–91 

Printed for the use of the Committee on Veterans’ Affairs 

( 

Available via the World Wide Web: http://www.fdsys.gov 


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COMMITTEE ON VETERANS’ AFFAIRS 

JEFF MILLER, Florida, Chairman 

DOUG LAMBORN, Colorado 

GUS M. BILIRAKIS, Florida, Vice-Chairman 

DAVID P. ROE, Tennessee 

BILL FLORES, Texas 

JEFF DENHAM, California 

JON RUNYAN, New Jersey 

DAN BENISHEK, Michigan 

TIM HUELSKAMP, Kansas 

MIKE COFFMAN, Colorado 

BRAD R. WENSTRUP, Ohio 

PAUL COOK, California 

JACKIE WALORSKI, Indiana 

DAVID JOLLY, Florida 

MICHAEL H. MICHAUD, Maine, Ranking 

Minority Member 

CORRINE BROWN, Florida 

MARK TAKANO, California 

JULIA BROWNLEY, California 

DINA TITUS, Nevada 

ANN KIRKPATRICK, Arizona 

RAUL RUIZ, California 

GLORIA NEGRETE MCLEOD, California 

ANN M. KUSTER, New Hampshire 

BETO O’ROURKE, Texas 

TIMOTHY J. WALZ, Minnesota 

JON TOWERS, Staff Director 

NANCY DOLAN, Democratic Staff Director 

SUBCOMMITTEE ON ECONOMIC OPPORTUNITY 

BILL FLORES, Texas, Chairman 

JON RUNYAN, New Jersey 

MIKE COFFMAN, Colorado 

PAUL COOK, California 

BRAD WENSTRUP, Ohio 

MARK TAKANO, California, Ranking 

Member 

JULIA BROWNLEY, California 

DINA TITUS, Nevada 

ANN KIRKPATRICK, Arizona 

Pursuant to clause 2(e)(4) of rule XI of the Rules of the House, public hearing records 

of the Committee on Veterans’ Affairs are also published in electronic form. The printed 

hearing record remains the official version. Because electronic submissions are used to 

prepare both printed and electronic versions of the hearing record, the process of converting 

between various electronic formats may introduce unintentional errors or omissions. Such occurrences are inherent in the current publication process and should diminish as the process 

is further refined. 


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C O N T E N T S 

Page 

Wednesday, November 19, 2014 

The Role of the State Approving Agencies in Ensuring Quality Education 

Programs for Veterans ......................................................................................... 1 

OPENING STATEMENTS 

Bill Flores, Chairman .............................................................................................. 1 

Ann Kirkpatrick ....................................................................................................... 2 

WITNESSES 

Mr. Ryan M. Gallucci, Deputy Director, National Veterans Service, Veterans 

of Foregin Wars of the United States ................................................................. 3 

Prepared Statement ......................................................................................... 26 

Mr. William Hubbard, Vice President of Government Affairs, Student Veterans of America .................................................................................................. 5 

Prepared Statement ......................................................................................... 29 

Mr. Steve Gonzalez, Assistant Director, National Veteran Employment and 

Education Division, The American Legion ......................................................... 7 

Prepared Statement ......................................................................................... 34 

Mr. Keith Glindemann, Vice President and Legislative Chair, National Association of Veterans; Program Administrators .................................................... 8 

Prepared Statement ......................................................................................... 36 

Mr. Curtis L. Coy, Deputy Under Secretary for Economic Opportunity, VBA, 

U.S. Department of Veterans’ Affairs ................................................................. 17 

Prepared Statement ......................................................................................... 42 

Accompanied by: 

MG Robert M. Worley II USAF (Ret.), Director, Education Service, 

VBA, U.S. Department of Veterans’ Affairs 

Dr. Joseph W. Wescott, President, National Association of State Approving 

Agencies ................................................................................................................ 19 

Prepared Statement ......................................................................................... 49 

FOR THE RECORD 

National Association of School Advocates for Veterans; Education and Success ........................................................................................................................ 52


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THE ROLE OF THE STATE APPROVING AGENCIES IN ENSURING QUALITY EDUCATION 

PROGRAMS FOR VETERANS 

Wednesday, November 19, 2014 

U.S. HOUSE OF REPRESENTATIVES, 

SUBCOMMITTEE ON ECONOMIC OPPORTUNITY, 

COMMITTEE ON VETERANS’ AFFAIRS, 

Washington, D.C. 

The subcommittee met, pursuant to notice, at 10:03 a.m., in 

Room 334, Cannon House Office Building, Hon. Bill Flores [chairman of the subcommittee] presiding. 

Present: Representatives Flores, Coffman, Wenstrup, Takano, 

and Kirkpatrick. 

OPENING STATEMENT OF CHAIRMAN BILL FLORES 

Mr. FLORES. Good morning. The subcommittee will come to 

order. I want to begin by welcoming everyone here this morning, 

and I look forward to hearing from both panels here today. 

Today, the subcommittee will conduct an oversight hearing entitled ‘‘The Role of the State Approving Agencies in Ensuring Quality 

Education Programs For Veterans.’’ The state approving agencies, 

or SAAs, are VA’s vital frontline partners in ensuring that veterans 

receive the quality education and training that they deserve. The 

SAAs have a long history of serving veterans dating back to when 

they were first created by Congress as part of the original GI Bill 

in the Veterans Readjustment Act of 1944. 

Although the education system has evolved over the last 70-plus 

years, the need and function of the SAAs has not diminished. It is 

important that with the billions of dollars spent on GI Bill benefits 

annually, that there is proper oversight over education and training programs so that veterans are enrolled in quality programs 

that fit their needs. 

Today, the need for correct and thorough oversight is more necessary than ever with the plethora of different programs available 

to veterans. There are now more schools, many of which have multiple campuses spread across the country. There are more training 

programs and options such as distance learning to access an extensive list of different programs. Furthermore, online education is becoming a more attractive option for veterans and many fully accredited institutions have a majority of their students participating 

through online courses. 

With all of the different avenues of education now available, I believe that today’s conversation is very important if we want to reVerDate Aug 31 2005 08:55 Dec 02, 2015 Jkt 000000 PO 00000 Frm 00005 Fmt 6633 Sfmt 6633 Y:\96134.TXT PAT

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main confident in the fact that we are doing everything we can to 

get veterans into programs that will be meaningful and useful to 

them for their future success. I want to take a minute to commend 

the current leadership of both the VA and the National Association 

of State Approving Agencies for their efforts in the past few years 

to work more collaboratively on their shared mission. 

This partnership, along with the input and assistance from other 

stakeholders, such as the veterans service organizations, the National Association of Veterans’ Program Administrators, and many 

others is what assures us all that veterans are getting the quality 

instruction they deserve from institutions that have the veterans’ 

best interest in mind. 

With the increased level of benefits under the Post-9/11 GI Bill 

over the years and the passage of the in-state provision and expanded Fry Scholarship benefits under the Veterans Access, Choice 

and Accountability Act, as well as the growing popularity of nondegree and OJT apprenticeship programs, it is important that 

these partnerships not only continue to grow, but that thorough 

oversight of education and training programs continue to be a 

focus. It is also important that, as the education sector continues 

to evolve, oversight over these programs evolves along with it. 

I am looking forward to discussing the legislative changes that 

the National Association of State Approving Agencies has proposed 

as these proposals attempt to restructure the role and mission of 

the SAAs for decades to come. I hope that we can have a fruitful 

discussion on the proposal in the preparation for the subcommittee’s legislative agenda in the 114th Congress. 

I also look forward to hearing from all of our witnesses today on 

their view of the current state of the higher education system as 

it relates to veterans’ education benefits, as well as how they view 

the current structure, duties, and mission of the state approving 

agencies, and how we can work together to improve the effectiveness and ensure quality education for all student veterans. 

With that, I recognize Ms. Kirkpatrick, and I would ask unanimous consent that the submitted testimony from the National Association of School Advocates for Veterans Education and Success 

be entered into the record. Hearing no objection, so ordered. 

OPENING STATEMENT OF HON. ANN KIRKPATRICK 

Ms. KIRKPATRICK. Thank you, Mr. Chairman. 

Today, we are here to discuss how state approving agencies help 

maintain the quality of education for our veterans using GI Bill 

education benefits. Now, we all know how important GI Bill benefits are to our Nation’s veterans. They are often critical to ensuring 

veterans’ success as they transition to civilian life. 

The education landscape has seen some major changes over the 

years with the swift growth of for-profit colleges, online programs, 

and other nontraditional forms of postsecondary education and 

training. With these changes, we must ensure that bad actors, particularly those interested solely in profit, are not taking advantage 

of our veterans in order to get their GI Bill benefits. 

Unfortunately, due to a loophole in current law, those bad actors 

are being encouraged to aggressively recruit veterans. The 90–10 

rule, which requires for-profit colleges and universities to receive at 


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least 10 percent of their revenues from sources other than Federal 

student aid, does not include GI Bill benefits as Federal student 

aid. That means the more veterans with GI Bill benefits that enroll, the more non-Federal student aid revenue they have and, in 

turn, the more Federal student aid they are allowed to take in. 

This loophole in the 90–10 rule is just one example of how ill-intentioned education corporations are taking advantage of veterans and 

other students. 

I am looking forward to hearing from our witnesses about the 

role that state approving agencies have or would like to have in ensuring that institutions of higher education are meeting the needs 

of our veterans. 

And, Mr. Chairman, I move that my colleague Mark Takano’s 

statement be submitted for the record. 

Mr. FLORES. Hearing no objection, so ordered. 

Mr. FLORES. I thank Ms. Kirkpatrick for her comments. And I 

want to recognize our first panel. It is already seated. Today we 

have Mr. Ryan M. Gallucci, who is the deputy director of national 

veterans service for the Veterans of Foreign Wars; Mr. William 

Hubbard, vice president of government affairs for Student Veterans 

of America; and Mr. Steve Gonzalez, assistant director of the National Veteran Employment and Education Division for the American Legion. 

I want to thank you for your past service and for your continuing 

service on behalf of our Nation’s veterans. 

And, then last but not least, we have Mr. Keith Glindemann, vice 

president and legislative chair for the National Association of Veterans’ Program Administrators. 

By the way, congratulations on your new position. We look forward to working with you. 

Thank all of you for being here this morning. Your complete written statements will become a part of the hearing record and each 

of you will be recognized for 5 minutes for your oral statement. 

Let’s begin with Mr. Gallucci. You are now recognized for 5 minutes. 

STATEMENT OF RYAN M. GALLUCCI 

Mr. GALLUCCI. Thank you, Mr. Chairman. 

Chairman Flores, Ranking Member Takano, and members of the 

subcommittee, on behalf of the VFW, thank you for the opportunity 

to discuss the role that state approving agencies play in ensuring 

success for today’s student veterans. 

We have made significant progress over the years to improve veteran access to education, not just by commissioning quality benefit 

programs, but also by improving access to pre-enrollment counseling and consumer resources, affording recourse to veterans who 

become victims of fraud, waste, and abuse, and most recently ensuring that no public school can hold a veteran’s military service 

against them when determining eligibility for in-state tuition. The 

subcommittee and my fellow panelists should be proud of these accomplishments, but we are not done yet. 

Today’s hearing and any resulting legislative changes should 

serve as a starting point for the broader discussion on the future 

role of the SAAs. Some in higher education insist that SAAs only 


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duplicate the effort of accreditors and the Department of Education. The VFW refutes this notion because the scope of the SAA’s 

responsibilities goes well beyond that of traditional higher ed. 

The VFW believes that we must periodically revisit oversight 

mechanisms and at times change roles and responsibilities to suit 

the needs of an ever-changing veterans community. And we encourage this committee to host future hearings to candidly discuss new 

and innovative ways to leverage a strong network of SAAs to foster 

quality outcomes for student veterans. 

The VFW proudly serves as constructive partner with the National Association of State Approving Agencies, as well as VA, in 

ensuring student veterans have access to quality training programs. With this in mind, much of our testimony will focus on 

NASAA’s recommendations on ways to improve the effectiveness of 

SAAs. 

For the past few years, NASAA has expressed frustration at the 

inability of SAAs to inspect and approve noncollege degree programs at nonprofit schools which were considered ‘‘deemed approved’’ through Public Law 111–377. After the law went into effect, the SAAs found that some schools started to develop NCD programs of questionable value. When SAAs sought to inspect these 

programs, they were denied access until VA intervened. However, 

SAAs still lack the statutory authority to properly approve NCD 

programs at nonprofit schools, meaning some programs continue to 

operate as deemed approved until SAAs learn about and inspect 

them. This is why the VFW supports extending statutory authority 

so SAAs can inspect NCDs to evaluate quality. 

NASAA has also reported that public institutions of higher learning have started the commissioned flight training programs as free 

electives, targeting veterans for enrollment. According to the SAAs, 

schools are adding such programs because of the uncapped reimbursement offered by VA through the Post-9/11 GI Bill. 

The fact that these programs have sprouted up in the few years 

since the new benefit ramped up is a clear indication that SAAs 

must have greater authority to inspect and approve these programs. Moreover, the VFW agrees with NASAA’s recommendation 

to establish a reimbursement cap for flight programs commensurate with the private institution cap already established for the 

Post-9/11 GI Bill. 

These new criteria are not an indictment of the quality of these 

new flight programs, but instead are a quality control measure to 

ensure that benefits are equitably administered for veterans who 

choose to enroll. 

Next, under current law, VA must conduct annual compliance 

surveys on all facilities with at least 300 student veterans enrolled. 

The VFW agrees with NASAA’s assertion that this is an impossible 

mission and one that neglects institutions that may face significant 

compliance issues. The current statutory requirement can mean 

that some schools will go years without a compliance survey as VA 

and the SAAs struggle to survey schools with large veteran populations. Such a requirement can hinder the response to at-risk programs that may enroll far fewer veterans while wasting significant 

time on inspecting perennial top performers. 


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The VFW agrees with NASAA that statutory requirements 

should change to ensure the VA can conduct compliance surveys at 

all institutions at least once every 3 years. VA and the NASAA 

should also be given flexibility in determining priorities in conducting annual compliance surveys. In the past, this kind of collaboration may have been difficult, but thanks to the new GI Bill 

complaint system, the VA is confident the VA and the SAAs have 

access to information through which they can identify trends and 

conduct risk-based reviews. 

Finally, after shopping around and speaking to school officials, 

the VFW could not identify a single preparatory course through 

which a veteran could use his or her GI Bill benefits. The ability 

to use benefits to prepare for complex entrance exams like the 

LSAT, GMAT, or GRE is a major selling point for veterans and a 

benefit readily discussed on VA’s GI Bill FAQ. The VFW believes 

that the law is unclear about how these programs are to be treated 

for GI Bill approval, and we seek clarification on how VA should 

approve such courses so that veterans can take advantage of the 

opportunity. 

The VFW firmly believes that the SAAs remain a valuable partner in ensuring quality for veterans in higher education. We agree 

with many of NASAA’s recommendations. However, we also reiterate our call for periodic discussions on how to better leverage the 

SAAs to ensure veterans’ success in higher education. 

Chairman Flores, Ranking Member Takano, members of the subcommittee, this concludes my testimony, and I am happy to answer 

any questions you may have. 

[THE PREPARED STATEMENT OF MR. GALLUCCI APPEARS IN THE AP- PENDIX] 

Mr. FLORES. Thank you, Mr. Gallucci. 

Mr. Hubbard, you are recognized for 5 minutes. 

STATEMENT OF WILLIAM HUBBARD 

Mr. HUBBARD. Thank you, Mr. Chairman. 

Chairman Flores, Ranking Member Takano, and members of the 

subcommittee, thank you for inviting Student Veterans of America 

to testify today. With this opportunity to discuss the state approving agencies and the National Association of State Approving Agencies, we will discuss their mission, effectiveness, and recent legislative proposal. 

With only 230 staff across 49 States, the SAA are responsible for 

over 7,000 facilities and more than 100,000 programs—this, in addition to over 1 million annual users of GI Bill benefits. 

Congress effectively established the SAA in 1945 when they 

passed Public Law 79–268, authorizing State governors to appoint 

their own approval agencies. As a mechanism to prevent so-called 

fly-by-night schools from taking advantage of returning veterans, 

the SAA became the frontline defense to ensure that those veterans 

receive a quality education. 

Recent changes to the role of the SAA has affected the allocation 

of finite resources, shifting them from areas where those resources 

are needed most. Then, in 2011, Public Law 111–377 impacted how 

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provals was split to include the Secretary of VA, while the SAA 

were to increase their role in compliance measures. 

This shift in resources away from the significant duty to perform 

approvals has diverted specialized resources away from missioncritical functions. The SAA bring an implicit capability which 

should be given greater emphasis: the capacity for judicious discretion. 

For student veterans, the SAA across the country have the ability to call for a review of a school, even if no specific standards are 

triggered. The goal of the SAA, in our view, should be to have their 

success go unseen by the student veteran. If the SAA perform their 

job well, the true beneficiaries should remain unaware. Those that 

benefit from the due diligence of these professionals are the student veterans on campuses nationwide. 

Student veterans who successfully transition serve as a demonstration of the important work performed by the SAA, that these 

student veterans can count on receiving a quality education for the 

GI Bill benefits they earned. Indeed, they do not have to question 

whether or not their GI Bill benefits will be well spent as the SAA 

provide necessary oversight to ensure their education will be one 

of quality. 

To further advance the effectiveness of the SAA, several things 

should be addressed regarding the authorities and resources. Despite the general effectiveness of the SAA, we believe there are 

some areas that require attention. SVA agrees with NASAA that 

the assumed approval of schools is risky for student veterans. Implicit approval is not always a safe assumption. Additionally, VA 

being included in the state approval process is also an issue worth 

reviewing. The responsibility is no longer the primary duty of the 

SAA. This authority should be returned to the SAA, given their 

subject matter expertise in the field. 

Lastly, we have serious concerns about the potential abuse of GI 

Bill benefits. While no specific cases have been yet addressed, the 

ability of schools to contract out certain programs for exorbitant 

fees is a serious issue. For some flight programs or electives, the 

results of the government covering these costs of these programs is 

well beyond the market norm. With the intent of creating a clear 

and reasonable solution, SVA accepts the NASAA proposal to reasonably cap such programs. 

Ultimately, we believe the approval process to be the preventative medicine for issues which would otherwise stem from low-quality programs underserving the interest of student veterans. SVA 

accepts the legislative proposal presented by NASAA, and it encourages the body to empower the SAA to pursue their mission 

with the original intent of Congress. 

We thank the chairman, ranking member, and the subcommittee 

members for your time, attention, and devotion to the cause of veterans in higher education. As always, we welcome your feedback 

and questions. And we look forward to continuing to work with this 

subcommittee, the House Committee on Veterans’ Affairs, and the 

entire Congress to ensure the success of all generations of veterans 

through education. Thank you. 

[THE PREPARED STATEMENT OF MR. HUBBARD APPEARS IN THE APPENDIX] 


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Mr. FLORES. Mr. Hubbard, thank you for your testimony. 

Mr. Gonzalez, you are recognized for 5 minutes. 

STATEMENT OF STEVE GONZALEZ 

Mr. GONZALEZ. Thank you, sir. 

Good morning, Chairman Flores, Ranking Member Takano, and 

distinguished members of the subcommittee. On behalf of the national commander, Mike Helm, and the 2.4 million members of the 

American Legion, we thank you and your colleagues for the work 

you do in support of our servicemembers, veterans, and their families. We thank you especially for holding this hearing. 

With the constantly shifting economic and social landscapes 

faced by veterans, it is important to continually evaluate, reevaluate, and, if needed, revise the roles of the state approving agencies 

in order to protect veterans and taxpayers. The American Legion 

is proud to work with the National Association of State Approving 

Agencies in order to provide veterans with the best education and 

training opportunities possible. 

In December 2010, Congress passed Post-9/11 Veterans Education Assistance Improvement Act of 2010, which was signed into 

law in January 2011. That bill contained language that impacted 

the role of the SAAs in terms of program approval authority. Due 

to the expansion of the GI Bill, eligible programs, to include many 

for-profit vocational training programs, nonregistered apprenticeships, and on-the-job training establishments, the law deemed approved many programs that were otherwise accredited or approved 

by other institutions, such as the Department of Education recognized accrediting bodies. That was done in order to relieve some of 

the workload of the SAAs and to avoid redundancies between the 

work done by the SAAs and other accrediting bodies. 

While the American Legion applauds the expansion of the GI Bill 

applicability, we find it problematic that SAAs have been removed 

from a large portion of the approval process. SAAs focus specifically 

on the GI Bill and serve to protect it, and, by extension, the veterans using it. Furthermore, as federally authorized arms of their 

respective State governments, SAAs are in a unique position to 

evaluate programs that are offered in their State, given the proximity. This arrangement also maintains the federalism required by 

the Constitution. Therefore, the American Legion supports the 

SAAs and believes that they should have a role in the reviewing, 

evaluating, and approving all educational and training programs 

for GI Bill use. 

While some may argue that the work that the SAAs do is redundant to the work of accrediting bodies, the American Legion believes that the SAA’s approval is, in fact, unique. This is because 

the charge of the SAAs is to specifically focus on protecting GI Bill 

funds, while traditional accreditation provided by the Department 

of Ed-recognized accrediting bodies does a significant portion of 

work toward ensuring quality programs. SAA approval should work 

in tandem with that accreditation, rather than the stark division 

that is represented in the current statute. However, under current 

law, SAAs lack the statutory authority to inspect many questionable programs that have sprung up since the passage of the Post9/11 GI Bill at not-for-profit institutions. 


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The American Legion supports the portion of the legislation proposed by the NASAA that would statutorily make SAAs the primary approving body for all programs approved for GI Bill use. 

Programs may still be deemed approved, but at the discretion of 

the SAAs, not the Secretary of VA. 

The American Legion agrees with the NASAA recommendation 

regarding changes to flight training. Not-for-profit institutions 

would take advantage of the GI Bill by charging exorbitant tuition 

and fees for this training is disheartening. Fixing this loophole 

helps to protect the GI Bill by ensuring that the costs are kept low 

while still allowing beneficiaries to pursue such training, if required or desired. Furthermore, in cases where the institution contracts with a third party to provide the training, the American Legion believes that the SAA should still have approval authority. 

Additionally, the American Legion supports a proposed shift in 

the statutory requirement for SAA compliance surveys. As NASAA 

has indicated, the current mandate is needlessly burdensome, and 

it is frankly impossible, given the limited resources available. In 

light of this, the American Legion believes that their funding 

should be increased to ensure that they are able to adequately perform their crucial role. Even if SAA’s compliance service requirement is reduced, an increased role as primary approving body 

seems likely to require the resources. 

The American Legion supports SAAs and recognizes the crucial 

role they play in ensuring quality programs for veterans using the 

GI Bill benefit. This hearing should serve as a starting point for 

an ongoing conversation regarding the role that SAAs currently 

playing in quality assurance. How SAAs’ approvals interact with 

accreditation remains somewhat unclear. This legislation would 

make strides toward clarify and codifying the terms of that interaction. 

Chairman Flores, Ranking Member Takano, we thank the subcommittee for looking into this issue, and it is crucial to veterans, 

and look forward to your questions. 

[THE PREPARED STATEMENT OF MR. GONZALEZ APPEARS IN THE

APPENDIX] 

Mr. FLORES. Mr. Gonzalez, thank you for your testimony. 

Mr. Glindemann, you are recognized for 5 minutes. 

STATEMENT OF KEITH GLINDEMANN 

Mr. GLINDEMANN. Thank you. 

Chairman Flores, Ranking Member Takano, and members of the 

Subcommittee on Economic Opportunity, my name is Keith 

Glindemann. I am the vice president of the National Association of 

Veterans’ Program Administrators, NAVPA. I appreciate and thank 

you for the opportunity to appear before you today to discuss 

NAVPA’s view on the role of state approving agencies in ensuring 

quality education programs for veterans. I am accompanied on this 

trip by Marc Barker, who is our current NAVPA president. 

It is my hope to help provide some insight on this topic from the 

viewpoint of the individuals that are charged to implement the 

policies and procedures on veterans’ education benefits at our colleges and universities across this great Nation. 


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NAVPA was founded in 1975 and it is a nationally recognized 

nonprofit organization of institutions and individuals who are involved in the operation of veterans affairs programs and/or the delivery of services to veterans as school-certifying officials. We are 

devoted to promoting professional competency and efficiency 

through our association’s membership and with others involved in 

veterans education assistance programs. We believe that the development, improvement, and extension of opportunities to any veteran or their dependent for their personal growth or development 

to be a noble cause. 

Relationship with the SAAs. NAVPA has worked hand in hand 

with our Nation’s state approving agencies for many years. They 

have been instrumental in helping our organization provide our 

members with comprehensive training sessions at national and regional conferences, offering technical assistance with complex 

issues regarding the certification of GI Bill benefits, as well as providing subject matter expertise on policies and procedures. 

We, as an organization, have seen the state approving agencies 

always assist in a timely manner. This is especially beneficial as 

it is often hard to get a quick response from our overburdened VA 

education liaison representatives. 

Compliance surveys. Current statutory requirements require that 

any institution with at least 300 GI Bill recipients have a compliance survey conducted annually. This requirement is mandated regardless of the results of the prior year’s survey. This requirement 

results in overburdened inspectors revisiting schools that have 

proven to be good stewards and in full compliance. The negative effect of this requirement results in many smaller institutions with 

less than 300 GI Bill recipients to go years between surveys. This 

creates an inequity among schools where benefits are being applied. Within NAVPA, we have been told of institutions that have 

not had a compliance survey since the inception of the Chapter 33 

Post-9/11 GI Bill. 

By relooking at the 300 mandated inspection rule, a more favorable one could be determined that would allow institutions to be on 

more equal footing in regards to compliance surveys. This could 

also allow SAAs to be freed up to provide additional technical assistance and training. Potential compliance issues could be avoided 

by having better-trained SCOs on the front end of the process. This 

would reduce issues of noncompliance and help to preserve benefits. 

Deemed approved. Section 203 of Public Law 111–377 deemed 

certain programs of education to be approved for VA educational 

benefits. NAVPA’s membership supports the current deemed approved language in 38 U.S.C. 3672 for accredited standard college 

degree programs offered at public or not-for-profit proprietary IHLs 

that are accredited by an agency or association recognized by the 

Secretary of Education. 

NAVPA respectfully asks the legislature and the Department of 

Veterans Affairs to clarify and define ‘‘deemed approved’’ relative 

to what the interpretation of a standard college degree program is. 

In the absence of a clear definition of standard college program, our 

member institutions are being inundated with proposals and requests from training programs to enter into third-party contracted 


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training agreements so that the nonapproved programs can operate 

under the umbrella of ‘‘deemed approved’’ as standard college degree programs without actually going through the approval process, 

be it the VA or the SAA. 

In closing, NAVPA’s membership institutions strive to always be 

in compliance with all regulations when assisting our students in 

utilizing their VA educational benefits. As an organization, NAVPA 

looks forward to a continued strong relationship with the state approving agencies, the VA, and others charged with assisting our 

veterans in achieving their educational goals. 

Chairman Flores, Ranking Member Takano, and members of the 

committee, thank you, and I look forward to your questions. 

[THE PREPARED STATEMENT OF MR. GLINDEMANN APPEARS IN THE

APPENDIX] 

Mr. FLORES. Thank you, Mr. Glindemann, for your testimony. I 

thank the panel for your testimony. And I now yield myself 5 minutes for questions. 

For each of you—and we will start with you, Mr. Gallucci—what 

is your position on the SAA’s proposed legislative changes to the 

GI Bill as it pertains to flight schools? 

Mr. GALLUCCI. As we laid out in our testimony, we support establishing a cap and allowing SAAs broader authority to inspect 

these programs and evaluate them for quality. The reason we support establishing that cap is because what the SAAs have reported 

and what VA seems to have confirmed is that these schools seem 

to just be charging whatever they want. It is not commensurate 

with what the economy would reflect the cost of that program 

should be. 

So our concern is they are basically optimized to what the Post9/11 GI Bill will pay out right now. And unless we get that under 

control, they are going to continue to charge exorbitant fees for 

that, which VA will have to reimburse for. 

Mr. FLORES. Okay. 

Mr. Hubbard. 

Mr. HUBBARD. Thank you for your question. Similarly, we support NAVPA’s proposal, more from a standpoint of the concerns 

over waste of the GI Bill. As money goes out the door way beyond 

market norms, this is ultimately decreasing the return on investment with the GI Bill, which is of serious concern to us. 

Mr. FLORES. Okay. 

Mr. Gonzalez. 

Mr. GONZALEZ. Yes, Chairman. I will echo the same sentiment as 

my two colleagues. We support SAA’s recommendation on flight 

school. Just like Will and Ryan have indicated, it is also ensuring 

that we are fiscally responsible in how the GI Bill is being applied, 

what is the return on investment, and ensuring that the SAAs can 

actually review the actual programs that are being offered, regardless of where they are being offered. 

Mr. FLORES. Okay. 

Mr. Glindemann. 

Mr. GLINDEMANN. Thank you, Chairman Flores, for the question. 

Our position at NAVPA would be that we support the State Approving Agencies’ recommendation on this. Fee caps are necessary 

to help preserve the whole program as we look at the use of the 


VACREP180 with DISTILLER
11 

Post-9/11 GI Bill. The other piece would be that we need to ensure 

that people aren’t taking flight classes in an open elective status 

and therefore burning through the benefit. 

Mr. FLORES. Okay. Thank you. 

Mr. Hubbard, throughout your written statement you referred to 

your belief that the SAAs need to return to their core competency. 

Can you expand on that recommendation? 

Mr. HUBBARD. Yes. And thank you for the question. 

The SAAs, their original role—and it is an approval body—has 

been somewhat mitigated by additional expectations placed on 

them, in particular their performance of compliance measures. We 

believe compliance measures are more of an audit function and 

could be done in other entities. For them to take their subject matter expertise and place it toward activities that are not their core 

competency is ultimately denigrating their comparative advantage 

in the space. 

Mr. FLORES. Okay. 

Mr. Glindemann, one of the biggest challenges that arises when 

it comes to veterans’ education, as I understand it, is the high 

turnover rate and the need for enhanced training for school-certifying officials. Can you comment on these issues—you touched on 

it a little bit—and how we can work collaboratively to address the 

retention and turnover and training of these individuals? 

Mr. GLINDEMANN. Thank you. 

Yes. The main thing with our school-certifying officials are that 

they often could be at a college where they wear many hats. They 

are not only a school-certifying official. They could also be an admissions person, evaluations personnel. The other thing is that 

school-certifying officials who only do that duty also may move 

within the structure of their college, therefore having a high turnover. 

Currently, we have the School Certifying Official Manual that 

the VA updates and puts out to us every 6 months, which is a great 

tool. It is approximately 280 pages. The Quick Reference Guide for 

Certifying VA Benefits is 120 pages. 

Mr. FLORES. Wow. 

Mr. GLINDEMANN. Sometimes that can be like drinking from the 

fire hose when you are just trying to do that. 

The best types of training are physical training where the people 

can actually be in front of the system. When being certified to be 

able to certify benefits, the VA once system offers a training program prior to being able to enter stuff. That is a great first step. 

However, something more thorough and that could be offered, 

whether regionally trained or SAAs actually in the schools, would 

be beneficial. 

Mr. FLORES. Okay. So you believe there should be some sort of 

standardized training with a certification for this position at 

schools? 

Mr. GLINDEMANN. Absolutely. 

Mr. FLORES. Okay. 

Approaching the end of my 5 minutes, I am going to release the 

rest of my time. And I will recognize the ranking member, Mr. 

Takano, for 5 minutes for his questions. 


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Mr. TAKANO. Thank you, Mr. Chairman. I thank you for holding 

the hearing on this really important topic. 

Mr. Gonzalez, can you elaborate a bit more about how you perceive the difference between what SAAs do and what an accrediting 

body does? 

Mr. GONZALEZ. Yes, sir. The accrediting body that is usually recognized by the Department of Education, they look at the whole institution, and that is sometimes done within a 1-year to 10-year 

time span, where the SAAs, of course, work in tandem with the accreditation body. But what they do is they accredit the actual programs that are being offered to the actual beneficiary, and that is 

an ongoing process where, again, they are different in their scope 

and their bandwidth and what their actual jobs and role is. 

And to be honest, SAAs, when they were created, were totally 

created—like my colleague Will has stated—out of the first GI Bill 

and then, of course, leading into the second GI Bill in the 1950 for 

the Korean War vets where it actually helped create the regional 

accreditation body to help ensure that these public institutions that 

were being created to absorb the returning veterans, that they had 

quality programs and the institutions had the right faculty and the 

institutions had the right type of policies in place. And, again, the 

accreditation body is really a peer-to-peer, once every 10 years type 

of evaluation, where the SAAs is an ongoing process. 

And they continue to have an ongoing process because for individual institutions to continue to have their programs approved, 

they have to resubmit any time a course is changed. So the course 

catalogues always have to be resubmitted to the SAAs to make 

sure that those programs are meeting the standards. 

Mr. TAKANO. And that happens ongoingly and more frequently? 

Mr. GONZALEZ. Yes, sir. 

Mr. TAKANO. Do you believe the VA, as a fiduciary, should still 

play a role in the approval process or that SAAs should be entrusted to make the decision on their own? 

Mr. GONZALEZ. We think that the SAA, being that they are the 

primary, they are actually on the ground, they know the schools 

that they are working with, they have the knowledge and institutional knowledge, that they should be the primary approval authority when looking at programs. 

And if you take it one step further, that is the whole purpose of 

being approved. You have everything, roughly, 137 to 140 SAAs, individuals throughout the 50 States and, I think, U.S. territories, 

and you have 7,000 programs. That is the whole reason why 

‘‘deemed approved’’ was put into play. 

Now, that shouldn’t say that an SAA shouldn’t be able to go, as 

an example, go to Harvard and not look at their program. Granted, 

I wouldn’t think Harvard would not have a great program. But it 

shouldn’t take away that the SAA should not be able to still go to 

Harvard and say, I want to at least inspect to make sure that you 

are still meeting the standards we need to protect the GI Bill, and 

by that to protect the veteran themselves. 

Mr. TAKANO. But should the VA still play a role in the process 

or—— 

Mr. GONZALEZ. Yes, sir. 

Mr. TAKANO. Okay. 


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Mr. GONZALEZ. I mean, we shouldn’t take VA out completely neither. 

Mr. TAKANO. Well, VA should be the primary. 

Mr. GONZALEZ. Yes, sir. 

Mr. TAKANO. VA should be the primary. 

Mr. Hubbard, do you think that the SAAs—on a little bit probably different track—do you think that the SAAs are successfully 

weeding out programs that lead to essentially worthless degrees, 

like those that promise to prepare student veterans for entry in a 

particular profession but do not qualify them for the necessary license or exam? 

Mr. HUBBARD. Thank you for the question. In short, yes. They 

are the best option for quality that we have right now. There are 

a lot of different measures in conversation to try and approach that 

level of quality. But right now the SAAs for student veterans are 

the best option we have. Again, they have that judicious ability to 

look at the program and if something doesn’t quite look right they 

can ask for a review. I think that is a very valuable quality that 

they bring to the table, and it is something that just hasn’t been 

achieved otherwise. 

Mr. TAKANO. But are they—I mean, you say they are the best option—but are they successfully able to weed out these programs? 

Mr. HUBBARD. I will give you an example. In Virginia there were 

a couple schools that were performing some questionable activities. 

Strong SAA there. They were able to review the program, and the 

end result was convictions and jail time for those who were taking 

advantage of the system and really at the end of the day harming 

student veterans. 

Mr. TAKANO. Could we do this better? I mean, could the SAAs 

be doing a better job? I mean, I don’t dispute that you think they 

are the best option now. But I have got a sense that there are a 

lot of programs that still are out there that are wasting our veterans’ money—— 

Mr. HUBBARD. Right. 

Mr. TAKANO [continuing]. And wasting the Federal Government’s 

money. How could we do this better? If you would take that. 

Mr. GALLUCCI. Oh, Mr. Takano, I would like to jump in there, 

if I could, quickly. 

Mr. TAKANO. Please. 

Mr. GALLUCCI. I think that is one of the reasons we are here 

today, to talk about the way that they conduct compliance surveys. 

And I think this is one of the reasons why we support changing the 

statutory requirement that they only go to schools that have more 

than 300 veterans every year. 

With the commissioning of the complaint system, we now have 

access to a lot more information. We have seen the SAAs do it. It 

was brought to our attention about the expansion of noncollege degree programs, about the flight school issue. They are aware that 

this is happening. But giving them the authority to go in and conduct more audits will strengthen their ability to do it. 

I agree with Will that they are the best option we have right 

now, and I think the proposals that we are discussing today would 

only strengthen their ability to serve as that frontline defense. 


VACREP180 with DISTILLER
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Mr. TAKANO. Mr. Chairman, I am sorry I went over my time, but 

I thought it was an important question. But I yield back. 

Mr. FLORES. Thank you, Mr. Takano. 

Mr. Coffman, you are recognized for 5 minutes for questions. 

Mr. COFFMAN. Thank you, Mr. Chairman. 

First of all, I want to thank you all for your service, those who 

have served in the military, and thank you so much for what you 

do on behalf of veterans in achieving their educational goals. 

I think that the fundamental mistake made by the Congress— 

and I was an Army veteran, I went to the University of Colorado 

under the Vietnam-era GI Bill, which gave veterans an amount of 

money in order to pay for room and board and tuition based on 

pretty much the average cost of going to a public university in the 

country. And then, we made decisions. We were the ones, empowered to make decisions based on cost and quality. 

I think after Congress tried to save money in post-Vietnam by 

going to this VEAP program, that I don’t think was very effective. 

That was a matching program. Then we have the Post-9/11 GI Bill, 

that I think was pretty much written by institutions, educational 

institutions, for educational institutions, whereby it was bifurcated 

from living expenses to tuition and with tuition is uncapped. 

I think you get the spiralling of inflation of tuition where there 

is no shopping around, where the veteran is in the marketplace. I 

think that was a big mistake, and I think we ought to look at going 

back to that Vietnam-era plan where we give an amount of money 

to a veteran and let the veteran shop for what program. If they 

want to go to a private school. They pay the difference, as we did. 

My decision then was to go to the University of Colorado where my 

costs were covered. 

Secondly, I am very concerned in our discussion today about proprietary schools. Granted, there are abuses. This administration 

has a gainful employment rule on proprietary schools, and I think 

there are certainly bad ones, as there are bad programs in public 

institutions that don’t lead to jobs. 

My father retired as a master sergeant from the United States 

Army. He had no more than a GED. Started out at a community 

college where he wanted to learn heating and air conditioning repair, but he was forced to take electives. He dropped out of that 

college, went to a proprietary trade school under the GI Bill, 

learned the specific trade that he wanted, heating and air conditioning, and eventually had a successful small business that did 

that. 

I am very concerned that it is more that this whole attack on 

proprietary trade schools is really focused on the working class 

Americans in terms of their ability to advance to the middle class. 

My father could have gone to where I went to school and studied 

anything that didn’t lead to a job, taken a major that wouldn’t lead 

to a job, and that would have been okay. But to go to a proprietary 

trade school to try and better himself, that is not okay. There has 

got to be a balance. 

The problem I have in asking a question is I am so opposed to 

the existing system we have, because I think it doesn’t serve veterans, it doesn’t serve taxpayers, and we need to abandon it and 

go back to Vietnam-era plan. 


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Let me ask you, what you all are evaluating in terms of these 

folks that go out and evaluate programs that are available under 

the GI Bill. Do these same personnel look at apprenticeship and 

on-the-job training for veterans? Do they help in that process? And 

what can we do to make more opportunities available to veterans 

who come back and want jobs? 

Mr. GALLUCCI. Well, thank you, Mr. Coffman. And, again, thank 

you for your service as a fellow veteran. Always good to have fellow 

veterans in Congress. 

But, again, to your question about evaluating quality of OJT and 

apprenticeship programs, this is one of the other primary functions 

of the state approving agencies. 

Mr. COFFMAN. Okay. Good. 

Mr. GALLUCCI. This is one of the reasons that we each, I believe, 

outlined in our testimony, that we feel they play a critical role. 

These are underutilized programs and for veterans who don’t want 

to pursue traditional higher ed, they are certainly a viable career 

path and it is something that we fully support. 

Mr. COFFMAN. Okay. 

Mr. Chairman, may I have an extension of my time so they can 

answer the question? 

Mr. FLORES. Give you another 30 seconds. 

Mr. COFFMAN. Thank you, Mr. Chairman. 

Anybody else have anything? 

Mr. HUBBARD. If I can just add to that. I do like the point that 

you made originally about being able to shop around with your 

benefit. To the credit of the VA, the GI Bill comparison tool is getting closer to that. It allows veterans to see the benefits that they 

have and then compare that at different schools. So I think that 

is getting closer to that ability to shop around in that sense, and 

I think that is something that is worth exploring in more detail. 

Mr. COFFMAN. Okay. Thank you, Mr. Chairman. I yield back. 

Mr. FLORES. Okay. We will offer my colleagues a second round 

of questions so that we can wrap that one up if that is okay with 

Mr. Coffman. 

Ms. Kirkpatrick, you are recognized for 5 minutes. 

Ms. KIRKPATRICK. Let me first say that I really appreciate the 

work you are doing as representatives of the veterans service organizations. You are the eyes and ears of this committee as we try 

to craft policy that is going to really help our veterans. So I appreciate your coming to the Hill today to our committee and having 

this discussion with us. It is very important. So I just want to 

thank you. 

Mr. Glindemann, I have a question with respect to the compliance survey rules. How many institutions actually have less than 

300 GI Bill recipients? Any idea about that? 

Mr. GLINDEMANN. I couldn’t answer that right now. I know 

through our membership over 50 percent of our schools are under 

300. And the biggest worry for us is that I think the VA originally 

maybe or the intent of the rule was to get the big recipients of GI 

Bill dollars. So when they came into a college with over 300, if they 

could identify compliance issues there, they could have more cost 

savings. 


VACREP180 with DISTILLER
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Unfortunately, then we look at the smaller schools. I actually 

help oversee veterans services for over 35 campuses, and one of my 

campuses only has about a dozen veterans at it. So in theory it has 

its own facility code, so it would be under a separate inspection. 

Those are kind of what you would think of as the nickels and 

dimes because it is a lot smaller amounts of money from the Post9/11 GI Bill coming into that school. However, they still have the 

same issues with training and the same issues with just trying to 

make sure the program is straight and with high turnover rates of 

their personnel. 

Ms. KIRKPATRICK. What do you think would be a better number 

then, than 300? Should there be no number or should everyone go 

through the compliance review? I mean, what are your thoughts 

about that? 

Mr. GLINDEMANN. I would expand it that for your schools that 

pass that don’t have any major compliance issues, a 36-month rule. 

I think if you could visit every school within 36 months, you would 

really get a true vision of what is out there, stop issues as soon as 

they happen, and have cost savings for the program as a whole. 

Ms. KIRKPATRICK. Mr. Hubbard, could you describe for me a 

model SAA that you envision or that is actually out there just so 

we can know really what works well for our veterans? 

Mr. HUBBARD. Sure. So I think the biggest thing is to be able to 

have a full spectrum of review. If an SAA is not able to look at all 

the programs, it is going to be an incomplete picture. So having 

that off the bat is a really important part. 

In addition, the communication between the SAA and VA is critical. With the JAC, the Joint Advisory Committee that is set up 

and set to continue conversations, I think that is also a critical aspect in that process. If they are not talking, the benefits coming 

and going, it is not going to be clear how that is working. So to 

have that Joint Advisory Committee, we do look forward to seeing 

the work come from that and think that will support that process 

quite well. 

Ms. KIRKPATRICK. Mr. Gallucci, I introduced a bill that would say 

if a veteran has a skill in the military, such as EMT, that they can 

easily get certification without having to go through all of the EMT 

training. And so my question is for you, do you think that there 

should be an easier path for approval of GI Bill benefits in noncollege degree programs such as EMTs? 

Mr. GALLUCCI. This is a really good question, and I may defer 

to my colleague Steve to comment on this a little as well. 

Ms. KIRKPATRICK. Okay. That is fine. 

Mr. GALLUCCI. Absolutely, as far as an easier path to approving 

these kinds of programs. What I think the concern is, though, is 

that the SAAs still have to play a role in that to ensure the validity 

of these kinds of programs. 

We have seen a lot of positive steps in improving the transferability of military-acquired skills to the civilian job market over the 

last few years, and it is still efforts that my colleagues at the table 

and I still push for. But it is something that, absolutely, if there 

is a way that a servicemember can translate their skills to a job 

set and then find a job, that is something we absolutely support. 


VACREP180 with DISTILLER
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Ms. KIRKPATRICK. I have about 40 seconds. Anybody else want to 

comment on that? 

Mr. GONZALEZ. Ma’am, I will make even a lot easier. SAAs, 

again, approve the program itself. Now, if you want to take it one 

step further, the question now becomes—and this is a question that 

might be for this committee, but also for the Education and Workforce Committee—because the institution bodies themselves are accredited by a totally different accreditation body, that if you actually get some type of credential irrespective of the credential from 

an institution of higher learning and yet you cannot sit for a license at a state board, then that is greater than just an SAA issue. 

It is an actual accreditation and SAAs of that respective state, 

ma’am. 

Ms. KIRKPATRICK. Thank you very much. I yield back. 

Mr. FLORES. Thank you, Ms. Kirkpatrick. 

We thank the first panel for your testimony. You are now excused. 

Mr. FLORES. And I would invite the second panel to the table. On 

our second panel, we welcome back both Mr. Curtis L. Coy, deputy 

under secretary for economic opportunity at the Department of Veterans Affairs. And he is accompanied by Major General Robert 

Worley, director of the Education Service at the Department of Veterans Affairs. 

I thank both of you for your prior service, and it is nice to have 

you back in front of this committee. 

And we also have Dr. Joseph Wescott, president of the National 

Association of State Approving Agencies, who has been a large subject of the testimony of today’s hearing. 

We thank you for your prior service as well, Dr. Wescott, and it 

is great to have you here. 

Mr. Coy, as soon as you get situated, we will recognize you for 

5 minutes for your testimony. Sorry to rush you guys. 

STATEMENTS OF MR. CURTIS L. COY, DEPUTY UNDER SECRETARY FOR ECONOMIC OPPORTUNITY, VETERANS BENEFIT ADMINISTRATION; U.S. DEPARTMENT OF VETERANS 

AFFAIRS, ACCOMPANIED BY MAJOR GENERAL ROBERT M. 

WORLEY II, USAF (RET.), DIRECTOR, EDUCATION SERVICE, 

VETERANS BENEFIT ADMINISTRATION; U.S. DEPARTMENT 

OF VETERANS AFFAIRS 

STATEMENT OF CURTIS L. COY 

Mr. COY. Thank you and good morning, Mr. Chairman, Ranking 

Member Takano, and other members of the subcommittee. I certainly appreciate the opportunity to appear before you today to discuss the Department of Veterans Affairs’ education benefit program 

and the role of state approving agencies. Accompanying me this 

morning, as you indicated, is Rob Worley, our director of education 

service at VA. 

I would like to start by acknowledging and thanking NASAA for 

its leadership and all SAAs for their continuing commitment to 

work with their respective educational institutions and VA to ensure the accurate and timely delivery of high-quality educational 

benefits to our veterans. 


VACREP180 with DISTILLER
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I would specifically like to thank Dr. Joe Wescott, president of 

NASAA, for his exceptional leadership. The last several years have 

been a collaborative journey for his with our SAA partners. I would 

also like to thank and acknowledge the other members and organizations testifying here today. I respect and admire their passion 

and advocacy of veterans. 

As you know, VA administers educational benefits to eligible veterans and dependents, while SAAs work to ensure the quality of 

educational and vocational programs. SAAs are charged with approving courses, including apprenticeship programs, and ensure 

that education and training programs meet approval requirements 

through a variety of approval activities. 

With the implementation of Public Law 111–377, VA was given 

the authority to use the services of the SAAs to assist VA in conducting compliance surveys. That has been an incredibly valueadded partnership. SAAs also conduct outreach to veterans and 

other eligible persons about available education and training benefits. We believe SAAs add significant value to the VA’s educational 

benefit programs. 

As I mentioned, in the past 2 or 3 years VA and our SAA partners have worked collaboratively. Two quick examples. This past 

September, VA and NASAA conducted a joint summer training conference to provide essential training to both NASAA and VA compliance and liaison staff. One primary goal of the training was to 

ensure a comprehensive and consistent understanding of all aspects of compliance surveys. Another example, VA and NASAA recently chartered a Joint Advisory Committee to serve as a standing 

forum for resolution of issues related to the mutual responsibilities 

of SAAs. 

Today, we are here to talk about legislative proposals submitted 

to the committee by NASAA in three broad areas: compliance reviews, flight training programs, and program approval. 

With respect to changing the current statutory requirements for 

conducting compliance surveys, VA believes it may be necessary to 

review the frequency and types of schools at which compliance surveys are conducted. Currently, there are about 16,000 approved domestic and international institutions of higher learning and noncollege degree institutions. Of the 16,000, 11,260 were active institutions in calendar year 2013. During the last 2 fiscal years, VA 

and SAAs have completed over 10,000 compliance surveys. This 

work was split roughly in half between VA and SAAs. 

VA believes that it would be valuable to review the criteria for 

compliance survey requirements, and we believe there should be 

enough flexibility to allow for the time and resources to conduct 

scheduled surveys, as well as unscheduled surveys and risk-based 

surveys. We look forward to working with NASAA and the committee on this. 

NASAA also has put forward proposed changes to the flight 

school aspect of the GI Bill. Like NASAA, VA is concerned about 

high tuition fee payments for enrollment in degree programs involving flight schools. VA wants to ensure that we are good stewards of the taxpayer money and we are open to discussing possible 

changes in how benefits are paid. 


VACREP180 with DISTILLER
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There has been a significant increase in flight training centers, 

specifically those that offer helicopter training, which have contracted with public IHLs to offer flight-related degrees. Sometimes 

these programs charge higher prices than those that would have 

been charged if the student had chosen to attend a vocational flight 

program, which is currently capped at about $11,000. We are, also, 

concerned about the growing number of VA beneficiaries that are 

taking flight school courses as an elective. 

Finally, the NASAA proposal would clarify and codify state approval authority and oversight to all non-Federal facilities. VA is 

not opposed to this proposal and to clarify SAA approval authorities within the context of the other key functions SAAs perform, including compliance, training, outreach, and technical assistance. 

However, the VA believes that the Secretary should maintain the 

approval-related authorities currently reflected in the statute. 

Mr. Chairman, this concludes my statement. I would be happy 

to answer any questions you may have. 

[THE PREPARED STATEMENT OF MR. COY APPEARS IN THE APPEN- DIX] 

Mr. FLORES. Thank you, Mr. Coy. 

Dr. Wescott, you are recognized for 5 minutes for your testimony. 

STATEMENT OF JOSEPH W. WESCOTT 

Dr. WESCOTT. Mr. Chairman, Ranking Member Takano, and 

members of the subcommittee, I am pleased to appear before you 

today on behalf of the National Association of State Approving 

Agencies to discuss the role of state approving agencies in ensuring 

quality education. I am accompanied by our legislative director, 

Tim Freeman. 

Soon after the GI Bill became law, Congress, recognizing that it 

was the responsibility of the States within our Federal system of 

government to oversee the education of their citizens, required that 

each State establish a state approving agency. Thus evolved a truly 

cooperative Federal-State effort that maintains the rights of the 

States while monitoring and protecting a federally sponsored program administered under the terms and conditions of Federal law. 

And I would say that VA has strived, particularly under the 

leadership of Deputy Under Secretary Curt Coy, to both support 

and enhance that historic partnership. I sincerely thank him for 

that commitment. And I thank my other partners here today as 

well as who share both our passion and our purpose. 

Today 55 SAAs in 49 States and Puerto Rico, composed of nearly 

175 professional and support personnel, are supervising over 7,000 

active facilities with approximately 100,000 programs. NASAA believes strongly that the primary responsibility and focus of the 

SAAs is and should continue to be to review, evaluate, and approve 

programs at schools and training facilities utilizing State and Federal criteria and to provide training and technical assistance to 

school officials. For that reason, it is critically important, as Congress intended, that each State have a state approving agency. 

In 2011, with the implementation of Section 203 of Public Law 

111–377, we began assisting VA with their requirement to perform 

compliance surveys at SAA-approved institutions. Over the course 

of the next 3 years, SAAs conducted over 60 percent of the compliVerDate Aug 31 2005 08:55 Dec 02, 2015 Jkt 000000 PO 00000 Frm 00023 Fmt 6633 Sfmt 6633 Y:\96134.TXT PAT

VACREP180 with DISTILLER
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ance survey visits performed. Last year alone we conducted 51 percent of those visits. 

NASAA has submitted legislative proposals to the committee 

which would serve to improve the service and protection provided 

to our veterans while enhancing the administration of the GI Bill. 

Our legislative proposals to the committee are in the area of approval authority, payment for flight programs, and compliance reviews. 

NASAA seeks to clarify and codify state approval authority and 

oversight over all non-Federal facilities. 

Dr. WESCOTT. We wish to clarify the Federal code in regard to 

the role of SAAs, by identifying SAAs as the primary entity responsible for approval, suspension, and withdrawal. In addition, since 

the passage of the Public Law 111–377, there has been no statutory authority for the approval of accredited NCD programs at public or private not-for-profit institutions, a situation our recommendation would correct. 

NASAA is seeking measures to improve cost control for flight 

programs offered by colleges and universities. Some public higher 

education institutions have instituted higher costs for flight fees, 

and in some cases benefits have been paid for aviation degree programs at public IHLs provided by a third-party flight contractor 

with no approval issued by the governing SAA. NASAA suggests 

limiting Chapter 33 payments for flight programs and public institutions to the prevailing cap. 

Finally, NASAA seeks appropriate changes to 38 U.S. 3693 to 

improve the manner in which we and our VA partners perform 

compliance surveys. We would like to see changes in the law to 

allow VA, with the assistance of the SAAs, to respond quickly to 

risks identified through the new complaint system. To accomplish 

this, Mr. Chairman, our legislative proposal is to amend the law 

to provide that the Secretary will conduct a compliance survey at 

least once every 2 years at each facility offering one or more approved programs with at least 20 veterans or eligible persons enrolled. 

Mr. Chairman, NASAA remains strongly committed to working 

closely with our VA partners, our VSO stakeholders, and school officials to ensure that veterans have access to quality educational 

programs delivered in an appropriate manner by reputable providers. This concludes my statement and, I look forward, Mr. 

Chairman, to answering any questions you or other members may 

have. 

[THE PREPARED STATEMENT OF MR. WESCOTT APPEARS IN THE AP- PENDIX] 

Mr. FLORES. Dr. Wescott, thank you for your testimony. And also 

thank you for the work that you and your colleagues and your affiliated organizations do to further veterans’ education in our country. 

I am going to begin, I am going to recognize myself for 5 minutes 

for questioning. The first question is for you, Mr. Coy. What is the 

Department’s position on the flight school changes that have been 

proposed by the SAAs? 

Mr. COY. Thank you, Mr. Chairman, for that question. There are 

two or three comments with respect to flight schools. Right now 


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flight schools, as we break it down, are basically in three general 

areas. 

The first is the vocational flight school, and as I mentioned, that 

is currently capped at $11,500 and a little bit more. And we believe 

that is fine as is to some degree. 

The second is flight school programs at institutions of higher 

learning that for the most part have been contracted out. And we 

have seen an alarming increase in the dollars that are spent on 

that. 

And then finally, there are flight course electives that veterans 

are taking, that again is somewhat alarming in that. Capping them 

at the current national maximum of $20,235.02 probably makes 

good sense in terms of being able to manage those programs and 

looking at this from a standpoint of being good stewards of the taxpayer money. 

Mr. FLORES. Okay. Thank you. Another question, Mr. Coy. What 

is the Department’s position on the legislative changes proposed by 

the SAAs regarding the number of compliance surveys completed 

over the course of a year? 

Mr. COY. Another great question, sir. And I would suggest that 

as we stand back and look at compliance surveys as a whole, currently, as you know, it is all schools over 300 students. I have some 

numbers here that are somewhat interesting. 

Right now, as I think I mentioned, there are about 11,260 schools 

that were active schools in 2013. Interestingly, of those 11,260 

schools, 15 percent of them have one veteran attending. And then 

if you look overall, the number of schools that have 20 or more attending is 5,100 schools. So you see we would essentially capture 

well over 50 percent of those active schools should we drop that 

down to 20. We have also heard testimony today that there are 

some schools that don’t necessarily are required to have compliance 

surveys because they drop below that 300 cap. 

So doing it for 20 schools or more probably is an appropriate 

number every 2 years, because what we think would be valued is, 

as we stand back and look at our compliance survey process in the 

past few years, as I mentioned, we have done 10,000 over the last 

2 years or 15,000 over the last 3 years. 

And so if we stand back and look at being able to do in round 

numbers 5,000 surveys a year, and being able to schedule a certain 

amount of surveys so the schools over 20 would be in round numbers about 2,500 schools or so every 2 years, that allows us some 

flexibility to do unscheduled visits, which we want to increase, but 

as well do risk-based reviews of schools based upon whether they 

are complaints from our complaint system or getting them from 

other quarters. So the over 20 probably provides enough flexibility. 

Mr. FLORES. The next question is for both of you, Dr. Wescott 

and Mr. Coy. In Mr. Gallucci’s testimony and in his written statement he alerted the subcommittee to the fact that many college 

prep courses—or actually I would say post-undergrad courses—offered at institutions of higher learning are not approved for use 

under the GI Bill. Can you tell me, A, is the assertion correct? And 

B, if it is, do you see this as a problem, and what steps can the 

VA and the SAAs take to address this issue? 


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Mr. WESCOTT. Mr. Chairman, certainly there is regulatory ability 

to approve those courses. There are certain limitations about what 

courses can be approved. For instance, they must be offered by an 

IHL. 

So normally what happens in the approval process, if a student 

takes a course, wants reimbursement, he will go to that institution 

and then that institution would come to the SAA. Certainly we can 

work within our States to promote more knowledge about these 

courses and can work with IHLs to see what they are offering so 

that we can have more of those courses approved. But it is somewhat driven by the needs of the veterans themselves. 

Mr. FLORES. Mr. Coy, anything to add? 

Mr. COY. I would agree with Dr. Wescott. I would add one or two 

other pieces. There is some flexibility to provide for some of those 

thing like LSAT prep courses, and SAT prep courses and that sort 

of thing for the GI Bill. 

I think one of the challenges that we see more anecdotally or not 

is remedial course for veterans coming onto campus. And so when 

they first get to campus, they may require, for example, a no-credit 

course, but it is English 101 revised or revisited, in other words, 

or Math 101, that would help a veteran get reacquainted to the 

academic environment. 

Generally, those courses are not credit courses. So those are the 

kinds of things that I think Ryan was also alluding to in his oral 

testimony. 

Mr. FLORES. Okay. Thank you, Mr. Coy. 

And I apologize to the ranking member for overrunning my time, 

and so I will give you 7 minutes for questions. 

Mr. TAKANO. Mr. Chairman, that was a very important dialogue 

you were having toward the end and I don’t begrudge you in the 

least. 

Dr. Wescott, can you please explain to me some of the criteria 

SAAs use to evaluate programs? What I am getting at is, do you 

see noticeable differences between for-profit and nonprofit or public 

schools? Do you think the criteria are stringent enough for the 

evaluation? 

Dr. WESCOTT. Well, certainly that would be part of a conversation we would love to have with the committee, is how we might 

change criteria. SAAs are devoted to looking at the quality of programming, and of course that is what we would do as educators. 

At present, we do have criteria that allows us look at things like 

standards of progress, instructor qualification, the curriculum 

itself. It is very important to us that institutions grant prior credit 

if that credit has been earned at other places. We look at the ability to administer the program. And with recent changes by the 

Congress, we also are starting to look at inducements and making 

sure that institutions are not offering those. 

We believe in one standard. We believe that standard should be 

the same for both the profit and the nonprofit. We believe it should 

be a high standard. And certainly I think we have evolved to the 

point that we do need to have a look at the present criteria and 

possibly strengthen them. 

Mr. TAKANO. Mr. Coy, that conversation you had with the chairman toward the end of his line of questioning, I know from my 


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years on community college boards that up to 80 percent of the students coming to California’s community colleges were not college 

ready. Can you give me an idea of how many of our veterans who 

are seeking a return to college face remediation issues? Do you 

have a number on that? 

Mr. COY. The short answer is, no, sir, I do not have an answer 

on how many require that sort of remedial training. And part of 

the reason that we don’t have that kind of information is, is that 

we, number one, have not collected that information. 

But number two is, as I am often fond of saying, that veterans 

are sort of like fingerprints and each one is a little bit different. 

And some may need remedial courses in English, and some may 

need remedial courses in math, and some may need remedial 

courses on study habits, and the list goes on and on and on. 

So, no, sir, I don’t have a number or percentage, but what we do 

know, I go out and talk at schools and universities all the time, 

and it is something that is going on. 

I would also like to suggest that SVA has done something that 

is really unique, Student Veterans of America, and they are developing a mentoring program and a tutoring-type program. We also 

have tutoring available to certain aspects of veterans. 

Mr. TAKANO. I want to get on to my next question, but I would 

like to pursue this issue with you further. 

Mr. Coy, the issues that we have been discussing today are so 

important because they help us understand what we all need to do 

to ensure that veterans’ education benefits aren’t being exploited, 

and that veterans are receiving the education they need and deserve. In light of that, I would like to raise another issue. Today 

the Center for Investigative Reporting published a story about the 

VA’s response to student veterans complaints against colleges. 

The story is going to show that the VA investigated only 324 of 

the roughly 2,400 complaints that veterans have filed against colleges for alleged deceptive marketing, financial fraud, or poor quality education. Can you tell me why so few complaints have been 

investigated and what the VA plans to do to address the remaining 

complaints? 

Mr. COY. Yes, sir, absolutely. I did read the article this morning 

as well, and we have had several conversations with the author of 

that particular article. I will just stand back and take a look at the 

complaint system or feedback tool that we have. It was born out 

of the President’s Principles of Excellence and that executive order. 

We created this system and it came online about 10 months ago. 

Since it has come online, there have been over 33,000 views of 

the tool and 2,298 complaints that have been submitted. We have 

about 48 percent of them that are pending. In other words, we 

haven’t sent them out. There are about 1,000 active complaints or 

less than half. 

And what we do with these complaints is, is when we get them 

and we validate them in terms of an applicable complaint with respect to the Principles of Excellence, because about, I want to say 

36 percent, have nothing do with the Principles of Excellence. They 

are complaints ranging from I don’t like my professor to any number of sort of non-POE-type complaints. 


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We take these complaints, we send them to the school, ask for 

their response. They have 60 days. After 60 days, if we don’t respond, we generally try and give them another 30 days. So we have 

completed 366 of them. As a result of these complaints, we have 

done 42 risk-based compliance reviews. They have resulted in four 

suspensions and one withdrawal. 

And so we think this feedback tool is incredibly valuable in terms 

of transparency for veterans that are looking at these various 

schools, and we think it is so powerful that just last week we released an update to our comparison tool that includes that school’s 

complaints that have been submitted through the system. 

The only other piece I would suggest in this is, is each one of 

these complaints is handled manually. So in other words, there is 

not a neat digital system that ships them from here to there. We 

take each one, we read each one. Where it is appropriate, we send 

them out to the school, we get responses. Schools have been incredibly responsive. 

Interestingly, I brought this, just as an example. This is a 30- 

page response to one of the complaints, of which 5 pages of it is 

pure verbiage talking about that particular complaint. So each one 

of these is taken very, very seriously. And part of the reason for 

that is, is, A, it is manual, and, B, each one is taken a look at individually. 

Mr. TAKANO. Mr. Chairman, my time is up and I yield back. 

Mr. FLORES. Okay. Thank you. 

Mr. Coy, we will probably want to come back and revisit that. 

As you know, Chairman Miller of the entire VA Committee has 

issued a request to the agency to respond to some of these issues. 

So probably revisit this sometime next year. 

Dr. Wenstrup, you are recognized for 5 minutes for questions. 

Mr. WENSTRUP. I have no questions. 

Mr. FLORES. Okay. Ms. Kirkpatrick, you are recognized for 5 

minutes. 

Ms. KIRKPATRICK. Dr. Wescott, I have a question about the Joint 

Advisory Committee. How often does it meet? 

Mr. WESCOTT. Well, actually, we just chartered that in September and the plan is to have our first meeting in January. There 

will be six members, six from the state approving agencies, six 

from the VA. Myself and the education service director will chair 

that group. Our expectation is probably that it would meet on a 

monthly basis or a bimonthly basis and that we would deal with 

issues that would impact both of our institutions, and particularly 

those where we are looking at changing policies or requirements 

vis-α-vis education programming. 

So we are excited about that. We think it is yet another avenue 

where we can work on these problems together. And we think it 

is also important that we work not only with the VA, but we are 

also excited about working with accreditors, those channels of communication as well, as have been mandated by law. We look forward to doing that as well. 

Ms. KIRKPATRICK. The last panel suggested that every approved 

program be audited so we do away with having 300 recipients of 

the GI Bill enrolled. Basically, if the program has one, they would 

be reviewed every 3 years. What do you think about that idea? 


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Mr. WESCOTT. Well, I certainly am in agreement with our proposal that we would be looking at schools who have at least 20 veterans, and let me add to that, every 2 years. And then we suggest 

no school should go without some kind of visit every three years. 

We believe that certainly we can, by visiting those schools, SAAs 

can help our partners with compliance surveys. But we also think 

that there is a great deal of value in us making training and technical assistance visits, that we are able to help schools that we 

have become aware of that are struggling, maybe they have a new 

SCO that has questions. So when there is an opportunity, we 

would like to visit those institutions as well. 

But you are right, we do need to adjust away from the 300-plus. 

Many of those institutions having 300 or more veterans enrolled 

are adequately staffed, they are adequately trained, and possibly 

don’t even have as much turnover as some of the other institutions 

that we need to go and visit. 

Ms. KIRKPATRICK. Well, according to Mr. Coy’s testimony, it is 

over 50 percent of the programs that are deemed approved fall 

within that category. So it seems like a lot are falling through the 

cracks. 

Mr. Coy, can you describe for me how a program becomes 

deemed approved? What is the criteria for that? 

Mr. COY. Well, according to 111–377, if you are an accredited institution of higher learning and a degree-granting institution, you 

could be considered deemed approved. What the SAAs do when 

they look at each of those schools or apprenticeship programs is 

going in—and I have a list of things, if you will give me a second 

I can talk through some of the things that our SAAs do. They go 

out and—— 

Ms. KIRKPATRICK. Excuse the interruption, but could you focus 

on the for-profit schools that don’t fall into that category of a higher education institution? How do you apply your criteria to get 

those programs deemed approved? 

Mr. COY. I will defer to my colleague Dr. Wescott. He is probably 

more of an expert in terms of the exact things that they go in and 

do. I can certainly talk generally, but I think you would prefer 

something more specific. 

Ms. KIRKPATRICK. Okay. Dr. Wescott. 

Mr. WESCOTT. Certainly, I would be delighted to respond to that, 

ma’am. Deemed-approved degree programs are at public and notfor-profit private institutions. So for-profit institution degree programs are not deemed approved. So we still look at those, as well 

as the NCD programs. 

At the deemed-approved institutions, we look at primarily the 

noncollege degree programs there, and that is where our legislation 

seeks to correct the deficiency in the present code to give us the 

criteria to do that. So we are still looking closely at the for-profits. 

Ms. KIRKPATRICK. Okay. 

Mr. Coy, you described the complaint system and how that is 

done manually. Do you have plans to digitalize that and is it possible for the veterans to monitor the progress of their case? 

And I only have about 4 minutes, can I allow the witness to at 

least answer that question? Thank you, Mr. Chairman. 


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Mr. COY. It is a great question, Congresswoman, and the short 

answer is, is yes, we are looking at doing more automation. We 

wanted to get this tool on the street as quickly as possible. So the 

front end is automated, the back end is not. We are working with 

our IT folks to automate that as much as we can. 

Ms. KIRKPATRICK. Thank you, Mr. Chairman, for your indulgence. I yield back. 

Mr. FLORES. Thank you, Ms. Kirkpatrick. 

Thank you, Mr. Coy, Major General Worley, and Dr. Wescott. 

You are now excused. 

I want to thank everyone for your attendance today and the 

frank discussion on the state approving agencies. And I appreciate, 

Dr. Wescott, the recommendations of your group and I think they 

are very helpful. 

Finally, I ask unanimous consent that all members have 5 legislative days to revise and extend their remarks and include any extraneous material in the record of today’s hearing. Hearing no objection, so ordered. 

Mr. FLORES. If there is nothing further, this hearing is adjourned. 

[Whereupon, at 11:25 a.m., the subcommittee was adjourned.] 

f 

APPENDIX 

PREPARED STATEMENT OF RYAN M. GALLUCCI

Chairman Flores, Ranking Member Takano and members of the Subcommittee, 

on behalf of the men and women of the Veterans of Foreign Wars of the United 

States (VFW) and our Auxiliaries, I want to thank you for the opportunity to 

present the VFW’s thoughts on the role that State Approving Agencies (SAAs) can 

play in ensuring quality in education for today’s student veterans. As advocates for 

the success of student veterans in higher education, the VFW has long been concerned about the role the SAAs can play as the front-line quality assurance resource 

for GI Bill programs. This committee, along with partners in the veterans’ advocacy 

community, played a major role in commissioning the Post-9/11 GI Bill, and the 

VFW has always been willing to serve as an advisor on ways to ensure success for 

our student veterans in higher education. 

Together we have made significant progress over the years, not just by commissioning landmark benefit programs, but also by ensuring resources are in place to 

help college-bound veterans make informed educational choices; ensuring veterans 

have access to quality, unbiased pre-enrollment counseling options; affording veterans recourse should they become victims of fraud, waste, and abuse; and most recently, ensuring that no public institution of higher learning can hold a veterans’ 

military service against them when determining eligibility for in-state tuition. This 

Subcommittee and my fellow panelists should be proud of these recent accomplishments, but we must also acknowledge that we are not done yet. 

The SAAs were designed under the original Veterans Readjustment Act of 1944 

to serve as each state’s steward of quality educational programs for veterans. The 

VFW credits both the Department of Veterans Affairs (VA) and the SAAs with fostering a boom in higher education for America’s middle class, ultimately leading to 

further investment in civilian higher education opportunities. With this in mind, the 

VFW believes it is important that we consistently revisit the SAAs’ role in providing 

for the quality education our veterans have earned, like we are doing today. 

However, I must also remind the Subcommittee that today’s hearing, and any resultant legislative changes, should only serve as a starting point for the broader discussion on the future role of SAAs. Some in today’s higher education space insist 

that SAAs only duplicate the modern role of independent accreditors and the Department of Education. The VFW refutes this notion, and must remind the Subcommittee that the SAAs’ scope of responsibilities is well beyond the kinds of programs approved for participation in the Department of Education. SAAs also serve 

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tion, as well as VA On-the-Job Training and Apprenticeship programs – two GI Bill 

programs that are currently underutilized, but can serve as gateways to quality careers for veterans who do not want to pursue a traditional college education. 

The VFW also understands that it is responsible governance to periodically revisit 

oversight mechanisms and at times change roles and responsibilities to suit the 

needs of an ever-changing veterans’ community, which is why we encourage this 

committee to host future hearings to candidly discuss new and innovative ways to 

leverage a strong network of SAAs to foster quality outcomes for student veterans. 

The VFW proudly serves as a constructive partner with the National Association 

of State Approving Agencies (NASAA) as well as VA in ensuring student veterans 

have access to quality educational and vocational training programs. With this in 

mind, much of our testimony will focus on NASAA’s recommendations to the Subcommittee on ways to improve the effectiveness of today’s SAAs. 

Statutory Authority on Non-College Degree Program Approval 

For the past few years, NASAA has expressed frustration at the inability for 

SAAs to inspect and approve non-college degree (NCD) programs at not-for-profit institutions of higher learning which became ‘‘deemed approved’’ through the Post-9/ 

11 Veterans Educational Assistance Improvements Act of 2010 (P.L. 111–377). 

Through P.L. 111–377, all programs at not-for-profit schools accredited by a Department of Education-recognized accreditor were to be ‘‘deemed approved’’ for GI Bill 

purposes. However, what the SAAs found in subsequent years was that not-for-profit schools started to develop NCD programs of questionable value. When SAAs started to question the marketplace validity of these programs, SAAs were denied access 

to inspect them. In the subsequent years, NASAA caught the attention of VA’s Office of Economic Opportunity, which issued guidance allowing the SAAs to once 

again inspect NCD programs. 

However, SAAs still lack the statutory authority to properly approve NCD programs at non-profit schools—meaning some programs continue to operate under the 

‘‘deemed approved’’ umbrella, unless SAAs learn about them and inspect them for 

validity. The VFW supports extending the statutory authority to the SAAs to inspect 

these kinds of programs to validate their quality. 

NASAA also requested that the SAAs once again retain primary approval authority for GI Bill programs—another change ushered in through P.L. 111–377, through 

which the Secretary of Veterans Affairs was also given the authority to approve or 

disapprove programs. One goal of this initiative is to ensure that every state fully 

staffs its SAA, as four currently have eliminated their SAA position. While the VFW 

understands the intent of this provision, we believe that as the fiduciary of the benefit, VA must retain some authority over the approval and disapproval of programs. 

Statutory Authority on Flight Program Approval at Public Institutions 

NASAA also has reported that public institutions of higher learning have started 

to commission flight training programs or free electives specifically targeting veterans for enrollment. According to the SAAs, the reason schools are adding these 

programs is because of the uncapped reimbursement offered by VA for flight programs at public institutions through the Post-9/11 GI Bill. VA has corroborated this 

report, acknowledging that several flight programs at public intuitions have been 

suspended for GI Bill eligibility for violating the long-standing 85/15 headcount rule, 

through which no more than 85 percent of students enrolled in an academic program can be receiving VA education benefits. In years past, the VFW believed that 

VA’s 85/15 rule had become obsolete, since veterans comprised such a small cohort 

in the higher education population. We were surprised to learn that programs—particularly programs at public institutions—could violate this seemingly irrelevant 

rule by recruiting veterans for newly-commissioned flight programs. 

However, the fact that these programs have sprouted up in the few years since 

the Post-9/11 GI Bill was signed into law are a clear indication that SAAs must 

have greater authority to inspect and approve flight programs at public institutions. 

Moreover, the VFW agrees with NASAA’s recommendation to establish a tuition and 

fees cap for flight programs commensurate with the cap for private institutions of 

higher learning already established for the Post-9/11 GI Bill. 

These new criteria are not an indictment of the quality of flight programs at public institutions, but instead are a quality control measure to ensure that the benefit 

is administered in a fair and equitable way for veterans who choose to enroll. 

Consistency and Flexibility for Compliance Surveys 

Finally, NASAA has also expressed serious concerns over current statutory requirements on how VA and the SAAs must conduct compliance surveys every year. 

Under current law, VA must conduct compliance surveys annually on all facilities 

reporting at least 300 enrolled GI Bill recipients. The VFW agrees with NASAA’s 


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assertion that this is an impossible mission, and one that neglects institutions that 

may face significant compliance issues. 

The current statutory requirement can mean that some schools will go years without a compliance survey, as VA and the SAAs struggle to satisfy the requirement 

to survey schools with large veteran populations. Such a requirement can hinder 

both VA’s and the SAAs’ response to at-risk programs that may enroll far fewer veterans, while wasting significant time and resources inspecting perennial top performers who happen to have large student veteran populations. 

The VFW agrees with NASAA that the statutory requirements should change to 

ensure that VA can conduct compliance surveys on all institutions at least once 

every three years. VA and the SAAs should also be given flexibility in determining 

priorities in conducting annual compliance surveys. 

In the past, this kind of collaboration may have been a difficult task, but thanks 

to the GI Bill Complaint System commissioned by this Committee through the Improving Transparency in Education for Veterans Act of 2012, the VFW is confident 

that VA and the SAAs now have access to a clearinghouse of information through 

which they can identify trends that would lead to risk-based program reviews. 

Approval of Preparatory Courses 

In the past year, the VFW has learned that no preparatory courses offered by institutions of higher learning have been approved for use by GI Bill beneficiaries for 

chapters 33, 30, 1606, 1607 and 35. The ability to use these benefits to prepare veterans for complex entrance exams, like the LSAT, GMAT or GRE, is a major selling 

point for veterans, and a benefit readily discussed on VA’s GI Bill FAQ website. Unfortunately, we have found that some college administrators, VA employees and 

SAA officials are unaware that the GI Bill will pay for preparatory courses and, 

therefore, are denying veterans the ability to use their benefits for such programs. 

In fact, after shopping around, the VFW failed to identify a single preparatory 

course through which a veteran could use his or her benefits. 

In discussions with VA and NASAA on the ability to approve preparatory courses, 

both VA and the SAAs have admitted that the law is unclear about how these programs are to be treated for GI Bill approval. The VFW seeks clarification on how 

VA should approve preparatory courses offered by institutions of higher learning to 

ensure that veterans can start taking advantage of this opportunity. 

The VFW firmly believes that the SAAs remain a valuable partner in ensuring 

quality for veterans in higher education. We agree with many of NASAA’s recommendations to change the current framework under which the SAAs operate to 

ensure they can continue serving in this role. However, we also reiterate our call 

for periodic discussions on how to better leverage the SAAs and their resources to 

ensure veteran success in higher education. 

Chairman Flores, Ranking Member Takano, this concludes my testimony and I 

am happy to answer any questions you may have. 

Information Required by Rule XI2(g)(4) of the House of Representatives 

Pursuant to rule XI2(g)(4) of the House of Representatives, VFW has not received 

any federal grants in Fiscal Year 2013, nor has it received any federal grants in 

the two previous Fiscal Years. 


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PREPARED STATEMENT OF STEVE GONZALEZ

Chairman Flores, Ranking Member Takano and distinguished Members of the 

Subcommittee, on behalf of National Commander Mike Helm and the 2.4 million 

members of The American Legion, we thank you and your colleagues for the work 

you do in support of our service members and veterans as well as their families. 

The hard work of this Subcommittee in creating significant legislation has left a 

positive impact on our military and veterans’ community. 

We thank you especially for holding this hearing that aims to examine the current 

role of State Approving Agencies (SAAs) in ensuring that veterans have access to 

quality educational and job training programs. With the constantly shifting economic and social landscape faced by veterans, it is important to continually reevaluate and—if needed—revise the role of these SAAs in order to protect veterans 

and taxpayers. 

The American Legion is proud to work with the National Association of State Approving Agencies (NASAA) in order to provide veterans with the best educational 

and training opportunities possible. 

Background 

State Approving Agencies (SAAs) are responsible for approving and supervising 

programs of education for the training of veterans, eligible dependents, and eligible 

members of the National Guard and the Reserves. SAAs grew out of the original 

GI Bill of Rights that became law in 1944. Though SAAs have their foundation in 

Federal law, SAAs operate as part of state governments. SAAs approve programs 

leading to vocational, educational or professional objectives. These include vocational certificates, high school diplomas, GEDs, degrees, apprenticeships, on-the-job 

training, flight training, correspondence training and programs leading to required 

certification to practice in a profession. 

In December 2010, Congress passed the Post 9/11 Veterans Educational Assistance Improvements Act of 2010 (P.L. 111–377), which was signed into law in January 2011. That bill contained language that impacted the role of the State Approving Agencies in terms of program approval authority. Due to the expansion of GI 

Bill-eligible programs to include many for-profit vocational training programs, nonregistered apprenticeships, and on the job training establishments, the law ‘‘deemed 

approved’’ many programs that were otherwise accredited or approved by other institutions such as Department of Education-recognized accrediting bodies. This was 

done in order to relieve some of the work load of the SAAs, and to avoid redundancy 

between the work done by SAAs and other accrediting bodies. This had the effect 

of shifting the role of the SAAs from being the primary entity responsible for approving all GI Bill eligible programs to examining only those that were not deemed 

approved for the purposes of the legislation (viz. programs at for-profit institutions, 

non-registered apprenticeships, on the jobs training establishments, non-accredited 

institutions, non-public licensure/certification examinations, and new institutions). 

Our Position 

While The American Legion applauds the expansion of the GI Bill applicability, 

we find it problematic that SAAs have been removed from a large portion of the approval process. SAAs focus explicitly on the GI Bill and serve to protect it, and, by 

extension, the veterans using it. They ensure that programs meet certain eligibility 

criteria, in order to see that the funds are not wasted, but are put to the best use 

possible. Their unique focus on how GI Bill funds are spent makes their mission 

distinct from all other oversight and approving bodies. Furthermore, as federally authorized arms of their respective state governments, SAAs are in a unique position 

to evaluate programs that are offered in their state, given their proximity. This arrangement also maintains the federalism required by the Constitution. 

Therefore, The American Legion supports the SAAs, and believes that they should 

have a role in reviewing, evaluating, and approving all educational and training programs for GI Bill use. 

While some may argue that the work that the SAAs do is redundant to the work 

of accrediting bodies, The American Legion believes that SAAs approval is, in fact, 

unique. This is because the charge of the SAAs is to specifically focus on protecting 

GI Bill funds. While traditional accreditation provided by Department of Educationrecognized accrediting bodies does a significant portion of work toward ensuring 

quality programs, SAA approval should work in tandem with that accreditation, 

rather than the stark division that is represented in the current statute. 

However, under P.L. 111–377, SAAs lack the statutory authority to inspect many 

questionable programs that have sprung up since the passage of the Post 9/11 GI 

Bill at not-for-profit institutions. Given that the original mandate of the SAAs was 

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sonable that SAAs should be allowed to inspect all suspicious programs, even if they 

are housed in not-for-profit institutions. 

As such, The American Legion supports the portion of the legislative proposal submitted by NASAA that would statutorily make SAAs the primary approving body 

for all programs approved for GI Bill use. Programs may still be deemed approved, 

but at the discretion of the SAAs, not the VA secretary. 

The American Legion agrees with the NASAA recommendations regarding 

changes to flight training. That not for profit institutions would take advantage of 

the GI Bill by charging exorbitant tuition and fees for this training is disheartening. 

Fixing this loophole helps to protect the GI Bill by ensuring that its costs are kept 

low, while still allowing beneficiaries to pursue such training, if required or so desired. Furthermore, in cases where the institution contracts with a third party to 

provide the training, The American Legion believes that the SAAs should have approval authority. 

Additionally, The American Legion supports the proposed shift in the statutory 

requirement for SAA compliance surveys. As NASAA has indicated, the current 

mandate (annual surveys for every institution offering anything other than nonstandard degrees, and any institution that enrolls more than three hundred GI Bill 

beneficiaries is needlessly burdensome, and is, frankly impossible given the limited 

resources available. 

In light of this, The American Legion believes that their funding should be increased to ensure that they are able to adequately perform their crucial role. Even 

if SAAs compliance survey requirement is reduced, an increased role as primary approving body seems likely to require more resources. 

Conclusion 

The American Legion supports SAAs, and recognizes the critical role they play in 

ensuring quality programs for veterans using their GI Bill benefit. This hearing 

should serve as a starting point for an ongoing conversation regarding the role that 

SAAs currently play in quality assurance. 

How SAA approvals interact with accreditation remains somewhat unclear. This 

legislation would make strides toward clarifying and codifying the terms of that 

interaction. That said, The American Legion believes that more insight into how the 

process works is needed in order to ensure that veterans receive the highest quality 

education and training, while preventing redundancy and wasting resources. 

Chairman Flores, Ranking Member Takano, we thank the subcommittee for looking into this issue that is crucial to veterans and look forward to your questions. 


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PREPARED STATEMENT OF DR. JOSEPH W. WESCOTT

Introduction 

Chairman Flores, Ranking Member Takano and members of the Subcommittee on 

Economic Opportunity, I am pleased to appear before you today on behalf of the National Association of State Approving Agencies (NASAA) and appreciate the opportunity to provide comments on ‘‘The Role of the State Approving Agencies in Ensuring Quality Education Programs for Veterans’’. I am accompanied today by Timothy 

Freeman, NASAA Legislative Director, We also will provide some additional comments that may be helpful to the Committee as it addresses concerns about maintaining the effectiveness and integrity of the administration of educational assistance programs administered by the Department of Veterans Affairs under Title 38, 

U.S.C., particularly in regard to safeguarding educational quality. 

Role of the State Approving Agencies: Past and Present 

State Approving Agencies were established by Congress with the passage of the 

Veteran’s Readjustment Act of 1944, or the GI Bill of Rights, signed into law by 

President Franklin D. Roosevelt. That legislation changed forever the face of higher 

education in the United States and much has been written on the social, economic 

and cultural return on that investment. 

Congress, recognizing that it was the responsibility of the states within our federal system of government to oversee the education of its citizens, required that 

each state establish a ‘‘State Approving Agency’’ and the governor of each state designated a state bureau or department as the SAA. The SAA was to be supported 

by reimbursement of its expenses by the US Department of Veterans Affairs (VA). 

Thus evolved a truly cooperative federal-state effort that maintains the rights of the 

states while monitoring and protecting a federally-sponsored program administered 

under the terms and conditions of federal law. And I would say that the present 

leadership of the VA has strived, particularly in the person of the Deputy Undersecretary and the Education Service Director, to both support and enhance that historic 

partnership. 

From a role of simply advising VA as to which educational and training programs 

were state-approved, State Approving Agencies evolved to become the primary 

source of assuring institutional accountability. With specialized authorization under 

the Code of Federal Regulations and state statues, they exercise the state’s authority to approve, disapprove and monitor education and training programs. SAAs also 

assist the states and VA with exposing fraudulent and criminal activity involving 

the payment of veteran’s benefits. 

In 1948, SAA representatives met to form a professional organization to promote 

high professional standards, create a forum for the exchange best practices, and to 

promote uniformity of purpose and practice. For almost seventy years now, NASAA 

has worked with our VA partners, the VSOs, and all agencies to ensure that the 

greatest numbers of quality programs are available to those eligible for education 

and training programs. We do this through our primary mission of program approval and out related efforts; compliance, training, liaison and outreach. We would 

like to briefly discuss these in turn. 

Practice and Partnership 

Today, fifty-five SAAs in 49 states (some states have two) and the territory of 

Puerto Rico, composed of around 175 professional and support personnel, are supervising over 7,000 active facilities with approximately 100,000 programs (includes 

those considered ‘‘deemed approved’’). The Subcommittee is no stranger to our fundamental role as it is the same today as when we were created by Congress. SAAs 

and NASAA work in collaboration with the VA and our other partners to promote 

and safeguard quality education and training programs for veterans and other eligible persons AND assist VA in preventing fraud, waste and abuse in the administration of the GI Bill. NASAA believes that the primary responsibility and focus of the 

SAAs is, and should continue to be, to review, evaluate, and approve programs at 

schools and training facilities, utilizing state and federal criteria. For that reason 

alone, it is important, as Congress intended, that each state have an SAA. Last year 

alone, SAAs across our nation approved over 39,000 education and training programs at universities, colleges, training institutions, flight schools, and correspondence schools. We also approved around 1000 licensing and certification exams providing for reimbursement of exam fees. We do this through an approval process that 

allows us to carefully evaluate many factors including curriculum, instructors, policies, facilities, equipment and advertising. After a careful review of the completed 

application, we schedule an inspection visit to the facility to ensure that the institution understands requirements and has the capability to oversee and administer the 

program. If we find that they do, we provide training on the approval process and 


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our continuing expectations. And we continue to review the approvals on a recurring 

basis as schools add or change programs and policies. Also as a part of this approval 

process, where appropriate, we ensure that schools are in compliance with Public 

Law 112–249 and are not providing any ‘‘commission, bonus, or other incentive payment based directly or indirectly on success in securing enrollments or financial aid 

to any persons or entities engaged in any student recruiting or admission activities.’’ 

And for schools who are signatories of the ‘‘Principles of Excellence (POE),’’ we provide training and information to them as well. 

In 2011, with the implementation of Section 203 of Public Law 111–377, the Post911 Veterans Educational Assistance Improvements Act, we began assisting VA 

with their requirement to perform compliance surveys at SAA-approved institutions. 

Over the course of the next three years, FY 12 through14, SAAs conducted over 

sixty (60) percent of the compliance survey visits performed throughout the nation. 

Last year alone, we conducted 2,589 visits, or some fifty-one (51) percent of the visits accomplished. During those visits we ensure that schools are conducting the GI 

Bill educational program in compliance with state and federal requirements, talk to 

veterans (if possible) and if appropriate, review POE requirements with institutions. 

We are proud to have worked with our partners at VA on the joint Compliance Survey Redesign Work Group (CSRWG) to change for the better the way that compliance surveys are conducted. We believe there is more work to be done in that area 

and we look forward to addressing those needs (and others) through the recently 

chartered Joint Advisory Forum (JAC), made up of NASAA and VA leadership. And 

we are suggesting as a part of our legislative proposal, a further refinement of the 

federal requirement for compliance surveys. 

We consider an important part of our mission to be the training and professional 

development of our newly hired SAA personnel (and in recent years our VA Educational Liaison Representatives (ELRs)). As such, each year we offer our National 

Training Institute (NTI) at conveniently located sites around the nation utilizing 

our National Training Curriculum, which provides information on policies and procedures relating to the SAA mission. Last month, we trained a total of 54 students, 

36 SAA personnel and 18 VA personnel, in Cincinnati, Ohio and the previous year, 

29 SAA professionals were trained in Atlanta, GA. We consider equally important 

the opportunity to train school certifying officials, and we work closely with our National Association of Veteran’s Program Administrators (NAVPA) partners to do so 

on a national level. In our individual states we work with the ELRs to provide training to SCOs at conferences and workshops each year. SAAs also provide training 

to school officials during our official visits (inspection and compliance) and when resources and time allow, we schedule training and technical assistance visits to 

schools that need additional training. 

As State agencies working with a Federal program, SAAs are uniquely situated 

to network with stakeholders in education and training to coordinate the improved 

delivery of veterans’ benefits. 

State Approving Agencies work with others to exchange information, facilitate the 

increased approval of programs and raise awareness of the veteran, their educational needs and benefits. SAAs have forged links with State Agencies such as Departments of Veterans Affairs, Departments of Education, Higher Education Governing Boards, Departments of Labor and other licensing boards. We meet with representatives of accreditation associations, the National Guard and the Reserve, apprenticeship councils, union boards, and veterans service organizations. In the past, 

some SAAs have also participated on accreditation visits. At a national level, contacts are made with the Departments of Defense, Education, and Labor, as well as 

the Federal Aviation Administration. State Approving Agency activities often complement what is being done at the state level and since not all states have program 

review offices, those SAAs become the de facto review entity for the State. 

Legislative Proposals 

Given the evolution of the role of SAAs over the past decade, NASAA has submitted legislative proposals to the committee which would serve to improve the service and protection provided to our veterans while enhancing the administration of 

the GI bill educational program. Our legislative proposals to the Committee are in 

the area of approval authority, payment for flight programs, and compliance reviews. 

NASAA seeks to clarify and codify State approval authority and oversight over all 

non-Federal facilities. We wish to clarify 3672 in regards to the role of the SAAs 

by identifying SAAs as the primary entity responsible for approval, suspension, and 

withdrawal. These proposed changes would ensure that an actual process for approval, suspension, and withdrawal will be adhered to (as opposed to our current 

scenario under the present ‘‘deemed approved’’ idea). However, we are not seeking 


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to do away with the idea that accredited degree programs at public and not for profit private institutions of higher education (IHLs) may be ‘‘deemed approved’’ 

.Rather, we seek to maintain the intent of the statute by adhering to an expeditious 

list of approval criteria for those programs that have been reviewed and/or endorsed 

by another appropriate entity. Furthermore, these changes would lessen the opportunity for third-party contracted training programs to be ‘‘deemed approved’’ with 

no review. 

In addition, since the passage of the Post 9/11 Veterans Educational Assistance 

Improvements Act of 2010 (111–377) in January of 2011, there has been no statutory authority for the approval of accredited NCD programs at public or private notfor-profit institutions. Our recommendations expand 3675 to cover all accredited 

programs not already covered under 3672, while maintaining all previous approval 

criteria for private-for-profit institutions. 

NASAA is seeking measures to improve cost control for flight programs offered 

by colleges and universities. These programs frequently involve a contracted flight 

school. Some public higher education institutions have instituted extreme costs for 

flight fees as there are presently no caps in place for public IHLs. In some cases, 

benefits have been paid for aviation degree programs at public IHLs provided by a 

third-party flight contractor with no approval issued by the governing SAA. This 

was exacerbated by the implementation of 3672. And some students are taking 

flight classes as electives with no cost cap for flight fees. In those cases, students 

could foreseeably take flight classes as an ‘‘undeclared’’ student for up to two years. 

NASAA suggests limiting Chapter 33 payments flight programs at public institutions to prevailing cap, producing immediate cost-savings. There would be no impact 

on the institutions ability to access Yellow Ribbon funds. This would also eliminate 

the need to further investigate and micro-manage flight programs areas including 

the number of flight hours in addition to those minimally required or the types of 

aircraft used. 

Finally, NASAA seeks appropriate changes to 38 US 3693 ( Compliance Surveys) 

to maximize the opportunity to protect the G I Bill while changing the manner in 

which we perform these surveys to reflect the changes that have occurred in higher 

education and training in the past three decades. The current statutory requirements for VA to conduct Compliance Surveys represents an impossible mission, 

given present resources. The statute requires an annual survey be conducted at 

each and every facility that offers anything other than a standard college degree as 

well as each and every institution enrolling at least 300 GI Bill recipients. We would 

like to see changes in the law to allow for a manageable mission in which VA, with 

the assistance of SAA partners, can conduct compliance surveys on a regular scheduled basis at the majority of approved institutions, while allowing for continued 

waiver of those institutions with a demonstrated record of compliance. At the same 

time, we feel strongly that no school should go without a visit of some kind for 

longer than three years. Such compliance surveys should be designed to ensure that 

the institution and approved courses are in compliance with all applicable provisions 

of chapters 30 through 36 of this title, but should also allow for limited program 

review, interviews with veteran students and training for school officials. Plus, the 

changes should allow for flexibility to adjust resources towards specific high-risk 

educational institutions as specific needs arise, allowing both VA and SAAs to be 

nimble and proactive in response to risks identified through the new complaint system and will allow SAAs to provide needed technical assistance and training visits 

to schools. To accomplish this, Mr. Chairman, our legislative proposal is to amend 

the law to provide that ‘‘the Secretary will conduct a compliance survey at least once 

every two years at each institution or facility offering one or more courses approved 

for the enrollment of eligible veterans or persons if at least 20 veterans or persons 

are enrolled in such course or courses.’’ 

Conclusion 

Mr. Chairman, we remain strongly committed to working closely with our VA 

partners, VSO stakeholders and educational institutions to ensure that veterans 

have access to quality educational programs delivered in an appropriate manner by 

reputable providers. For we all share one purpose, a better future for our veterans 

and their dependents. As I told another gathering of NASAA and VA personnel in 

Washington over a year ago, while attempting to define who are the SAAs, ‘‘We are 

not mere clerks or bureaucrats. We are not just state employees drawing a federally 

funded check. We are educators. We are the engineers of excellence and the gatekeepers of quality. We will not fail in our commitment to safeguard the public trust, 

to protect the GI Bill and to defend the future of those who have so nobly defended 

us.’’ Mr. Chairman, thank you again for this opportunity and I look forward to answering your questions. 


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