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82–744 PDF 2014

S. Hrg. 113–206 

THE 90/10 RULE: IMPROVING EDUCATIONAL 

OUTCOMES FOR OUR MILITARY AND VETERANS 

HEARING 

BEFORE THE

COMMITTEE ON 

HOMELAND SECURITY AND 

GOVERNMENTAL AFFAIRS 

UNITED STATES SENATE 

ONE HUNDRED THIRTEENTH CONGRESS 

FIRST SESSION 

JULY 23, 2013 

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

Printed for the use of the 

Committee on Homeland Security and Governmental Affairs 

( 
(II) 

COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS 

THOMAS R. CARPER, Delaware Chairman 

CARL LEVIN, Michigan 

MARK L. PRYOR, Arkansas 

MARY L. LANDRIEU, Louisiana 

CLAIRE MCCASKILL, Missouri 

JON TESTER, Montana 

MARK BEGICH, Alaska 

TAMMY BALDWIN, Wisconsin 

HEIDI HEITKAMP, North Dakota 

TOM COBURN, Oklahoma 

JOHN MCCAIN, Arizona 

RON JOHNSON, Wisconsin 

ROB PORTMAN, Ohio 

RAND PAUL, Kentucky 

MICHAEL B. ENZI, Wyoming 

KELLY AYOTTE, New Hampshire 

JEFF CHIESA, New Jersey 

RICHARD J. KESSLER, Staff Director 

JOHN P. KILVINGTON, Deputy Staff Director 

GOHAR SEDIGHI, Legislative Fellow, Office of Senator Carper 

WALTER S. OCHINKO, GAO Detailee 

KEITH B. ASHDOWN, Minority Staff Director 

CHRISTOPHER J. BARKLEY, Minority Deputy Staff Director 

CATHARINE A. BAILEY, Minority Director of Governmental Affairs 

LAURA W. KILBRIDE, Chief Clerk 

LAUREN CORCORAN, Hearing Clerk 
(III) 

C O N T E N T S 

Opening statements: Page 

Senator Carper ................................................................................................. 1 

Senator Coburn ................................................................................................. 4 

Senator McCaskill ............................................................................................ 22 

Prepared statements: 

Senator Carper ................................................................................................. 35 

Senator Coburn ................................................................................................. 37 

WITNESSES 

TUESDAY, JULY 23, 2013 

Curtis L. Coy, Deputy Under Secretary for Economic Opportunity, Veterans’ 

Benefits Administration, U.S. Department of Veterans’ Affairs; accompanied by Robert M. Worley, II, Director, Education Services ........................ 7 

Hollister K. Petraeus, Assistant Director, Office of Service Member Affairs, 

Consumer Financial Protection Bureau ............................................................. 9 

Hon. Steven C. Gunderson, President and Chief Executive Officer, Association 

of Private Sector Colleges and Universities ....................................................... 11 

Tom Tarantino, Chief Policy Officer, Iraq and Afghanistan Veterans of America .......................................................................................................................... 13 

Sergeant Christopher J. Pantzke, USA, Ret., Veteran ......................................... 16 

ALPHABETICAL LIST OF WITNESSES

Coy, Curtis L.: 

Testimony .......................................................................................................... 7 

Prepared statement .......................................................................................... 38 

Gunderson, Hon. Steven C.: 

Testimony .......................................................................................................... 11 

Prepared statement with attachment ............................................................. 53 

Pantzke, Sergeant Christopher J.: 

Testimony .......................................................................................................... 16 

Prepared statement with attachment ............................................................. 80 

Petraeus, Hollister K.: 

Testimony .......................................................................................................... 9 

Prepared statement .......................................................................................... 48 

Tarantino, Tom: 

Testimony .......................................................................................................... 13 

Prepared statement .......................................................................................... 77 

APPENDIX 

Chart referenced by Senator Coburn ..................................................................... 95 

Additional statements for the Record: 

American Public University System ............................................................... 101 

Education Management Corporation .............................................................. 104 

Response to request for information from ITT Technical Institute ..................... 111 

Response to testimony from the Art Institute of Pittsburgh ............................... 123 

Responses to post-hearing questions for the Record: 

Mr. Coy .............................................................................................................. 124 

Ms. Petraeus ..................................................................................................... 126 

Mr. Gunderson .................................................................................................. 128 

Mr. Tarantino ................................................................................................... 159 

(1) 

The 90/10 RULE: IMPROVING 

EDUCATIONAL OUTCOMES FOR OUR 

MILITARY AND VETERANS 

TUESDAY, JULY 23, 2013 

U.S. SENATE,

COMMITTEE ON HOMELAND SECURITY

AND GOVERNMENTAL AFFAIRS, 

Washington, DC. 

The Committee met, pursuant to notice, at 10:33 a.m., in room 

SD–342, Dirksen Senate Office Building, Hon. Thomas R. Carper, 

Chairman of the Committee, presiding. 

Present: Senators Carper, Pryor, McCaskill, and Coburn. 

OPENING STATEMENT OF CHAIRMAN CARPER 

Chairman CARPER. The hearing will come to order. I understand 

that our fifth witness, Sergeant Pantzke, is looking for parking. 

Hopefully he found it, and is on his way to join us. 

I want to welcome everybody this morning to our hearing. This 

hearing focuses on a very considerable amount of money that we 

are providing in high-quality education benefits to our 

servicemembers and to our veterans. In examining this issue, the 

Committee is asking a couple of questions. One of them is, are we 

getting the results to taxpayers that servicemembers and veterans 

deserve? 

The G.I. Bill helped me to afford the cost of getting a Masters 

of Business Administration (M.B.A.) at the University of Delaware 

(UDEL) after I transitioned off of active duty in the U.S. Navy near 

the end of the Vietnam War. And while I was grateful for that financial support—I think it was about $250 a month—those benefits pale in comparison to the very considerable taxpayer investment that the new G.I. Bill makes toward an education for our 

servicemembers and for our veterans. 

For years through the service academies and through programs 

like the Reserve Officer’s Training Corps (ROTC) and the G.I. Bill 

and tuition assistance, we have sought to raise the skill levels of 

those who serve in our armed forces as well as the skill levels of 

those who later return to civilian life. 

However, in 2008, it became clear to Congress that after years 

of multiple tours of duty in Iraq and Afghanistan, a modern day 

military needed a modern day G.I. Bill to ease soldiers’ transition 

to civilian work here at home. 

That is why we passed the post-9/11 G.I. Bill, to help our modern 

day veterans afford the cost of college and put them on a path to-
2 

ward getting a good-paying job. The modern day G.I. Bill pays for 

the tuition and housing costs of any member of the military who 

served more than 90 continuous days on active duty since September 10, 2001. 

I like to say in Delaware, you can go to the University of Delaware, Delaware State University (DSU), Wilmington University, 

Delaware Technical Community College (DTCC), and a variety of 

other schools in our State tuition-free, books, fees paid for, tutoring 

paid for, plus a $1,500 a month housing allowance. And for those 

of us who came back at the end of the Vietnam War, I think we 

got about $250 a month. So this is quite a rich benefit and I do 

not deny them it for a moment. Since it was enacted, though, $29.4 billion has been spent to 

send veterans back to school. In addition, the Department of Defense (DOD) offers military servicemembers the opportunity to pursue a high quality education through the Tuition Assistance Program (TAP). Service members and veterans taking advantage of 

the benefits available to them under the G.I. Bill are free to pursue 

the educational path of their choice. They can go to public school 

like I did when I studied at the University of Delaware, or they can 

attend a private, non-profit school, or a for-profit school. 

However, recent reports show that many veterans, too many veterans have been subjected to highly questionable recruitment practices—we have heard about those—exposed to deceptive marketing 

and substandard educational instruction in some of the schools 

they attended, particularly among the for-profit schools. Not all of 

them. Some of the for-profit schools are excellent, we know that, I 

know that, but not all. And frankly, some of the same could be true 

of the public schools and the private schools. 

But what I am interested in is uniform excellence across the 

board. I want to make sure that at least all these Federal dollars 

that we are spending on these programs, that we are going to end 

up with veterans and active duty personnel who actually have the 

skills that they need to get a job, keep a job, and be self-sufficient. 

That is what my goal is. 

Under current law, in order for a for-profit school to receive Federal student aid from the Department of Education (ED), the school 

must ensure that no more than 90 percent of its revenues come 

from Federal funding. The definition of Federal funding, as it applies to this limit, is not as straight forward as one might expect. 

It turns out that under current law, Federal funding means only 

money that comes through the Department of Education. 

Other Federal funds such as G.I. Bill benefits that come from the 

Department of Veterans’ Affairs (VA) and military education benefits that are offered through the Department of Defense are excluded from the 90 percent limit that makes up the Federal share 

of a school’s revenue. 

That means that a school that maxes out on its 90 percent limit 

can bring in federally funded military and veterans’ education benefits in order to skirt the limit, and in some cases, get 100 percent 

of their funding from the Federal Government. I choke on that. The 

idea that any college or university, I do not care if they are profit, 

public, for-profit that gets 100 percent of its revenues from the Federal Government for me is troubling. It is just troubling. 
3 

As several reports have shown, this loophole has, in some cases, 

put a target on the backs of our military and veteran students, and 

then once students enroll, they are often not obtaining the knowledge and skills that they need to get a job, that will enable them 

to earn a livable wage and sound benefits. 

Clearly, the incentives at some for-profit schools are misaligned. 

These institutions are rewarded for enrolling more students, especially veterans with a fully paid-for education, but have too little 

incentive to make sure that their graduates are prepared to join 

the workforce and begin productive careers. 

Having said that, this is not an issue solely for for-profit schools, 

as I said already. There are also too many public and private nonprofit colleges and universities that experience similar issues with 

extremely low degree completion rates, high default rates, and a 

poor record of serving our veterans. And to be fair, there are also 

a number of for-profit institutions that offer quality education and 

have a history of success with placing students in well-paying jobs. 

I believe we have a moral imperative to ensure that abusive 

practices, no matter where they occur, are stopped so that those 

who have sacrificed for our country can obtain an education that 

will equip them with the skills they need to find a good job, repay 

their loans, college loans or others that they have taken out, and 

go on to live productive lives. 

Two years ago I chaired a couple of hearings on this issue in the 

Subcommittee on Federal Financial Management (FFM). Today I 

am holding this hearing to learn what is being done by the Department of Veterans’ Affairs and others, to protect our military and 

our veteran students from the predatory practices of some bad actors, not totally—but primarily in the for-profit industry. 

This hearing will also focus on what the association that represents for-profit schools has done to address concerns raised about 

the industry that it represents. My goal for today’s hearing is to 

learn how we can fix this problem by better incentivizing schools 

to deliver a higher quality education to our military and veteran 

population that will enable them to be successful in work and in 

life. 

We have a very good panel, I think a terrific panel here today, 

and we are grateful to you for joining us. Before I turn to Dr. 

Coburn, I just want to say this: When I was on active duty—I was 

on active duty for close to 5 years, and Commander Coy, you were 

on active duty for a lot longer than that. I think we had about 12 

permanent changes of station in not a very long period of time. 

I got an undergraduate degree at Navy ROTC at Ohio State 

(OSU), and 5 years later I moved to Delaware and got an M.B.A. 

with the G.I. Bill. It would have been great, all those times that 

I was traveling around the world with my squadron being deployed 

to different places, it would have been great if I could have worked 

on a Master’s degree at that time, or maybe just taking courses. 

We did not have that opportunity. 

We did not have the Internet, did not have the opportunity for 

distance learning. And it is a great tool. It is a great benefit if done 

well. For folks who are on active duty, the folks that are deployed 

or activated, Reserves, Guard, it is potentially a very valuable tool, 

not only in helping them improve their skills, but also making 
4 

1The chart submitted by Senator Coburn appears in the Appendix on page 95. 

2 Additional statements submitted for the Record appear in the Appendix on page 101. 

them more valuable to our country, to the branch of service in 

which they are serving. 

So I am not interested in the blame game here, I am not interested in demeaning any particular schools. I just want better results for less money. We have to get better results for less money 

in everything we do. It includes this area because we are spending 

a lot of money. Dr. Coburn. 

OPENING STATEMENT OF SENATOR COBURN 

Senator COBURN. Well, thank each of you for being here. As I 

think about costs for the American public, we looked at health care 

costs, and we all know that they have risen uncontrollably. They 

are somewhat slower now due to the economy and a couple of other 

factors, but there is one thing that has risen faster than health 

care costs in this country and that is the cost of a college education. 

It is the fastest growing thing. 

At the heart of today’s hearing are questions about the appropriate role of the Federal Government in higher education. In 1958, 

the National Defense Education Act (NDEA) was established and 

the Federal Government began its foray into the private sector of 

public education, higher education. 

Not everyone agreed with this bill’s passage. Some feared that it 

would lead to Federal intrusion into the halls of higher learning, 

and boy, has it. Barry Goldwater said, if adopted, the legislation 

will mark the inception of age supervision, ultimately, the control 

of the higher education in this country by Federal authorities. Fast 

forward to today and the prophecy is manifest. 

Higher education today is dramatically more expensive despite 

hundreds of billions of dollars, Federal dollars, being poured into 

the system-loans, Pell Grants, G.I. benefits, research dollars, tax 

benefits and more. More money has brought more Federal interference. Washington seemingly wants to regulate everything, even 

what constitutes a credit hour, something that is fundamentally 

the job of colleges. 

There is a lot to be said about the larger topic of the current 

state of higher education. However, when it comes to the 90/10 

Rule, it is arbitrary and government engineering at its worst. Let 

us ask ourselves a few questions, Mr. Chairman. 

If 90/10 is sound policy, why not apply this rule to all schools regardless of control type? After all, graduation rates at many nonprofit schools around the country leave much to be desired, and I 

would like to submit for the record both the public and private 

profit, non-profit education graduation rates1 for the State of Delaware and the State of Oklahoma for the record. Both are abysmal. 

Chairman CARPER. Without objection. 

Senator COBURN. I would also like to submit at this time statements2 from other individuals who would like to have their words 

as a part of the record. 

Chairman CARPER. Without objection. 

Senator COBURN. And if the 90/10 Rule is sound policy, why stop 

at 10 percent? Why not lower the threshold? How does 50 percent 
5 

sound? Fifty percent applied to all schools, all Federal dollars. We 

would see some miraculous changes, would we not? Non-profit 

schools and Congress, of course, would never agree to this. 

The truth is, the 90/10 Rule is the government picking winners 

and losers among colleges that have already proven themselves by 

being accredited, approved by State-approving agencies, eligible for 

Title IV, and by complying with a myriad forms of compliance and 

levels of compliance. 

I look forward to our hearing. The real problem is, whether it is 

in private or public, profit or non-profit, we have abysmal graduation and completion rates. We ought to take the fraud out of the 

system. Nobody would disagree with that. We ought to take the 

shysters out. There are those both in public and private, if you look 

at graduation rates. 

But we ought to be concerned about what the cost is to get an 

education, to enable somebody to have a life skill that will support 

them. And that would be where I would hope that we would focus. 

90/10 is an arbitrary rule. It is arbitrary. It causes us to focus on 

not fixing the right problem. With that, I yield back. 

Chairman CARPER. Believe it or not, Dr. Coburn and I probably 

have more agreement in this area than you might think, having 

heard his comments and mine. Neither of us like to waste money. 

We do not like to waste real money. We do not like to waste taxpayers’ money. And what we want to make sure of at the end of 

the day is we are not wasting money on the G.I. Bill, we are not 

wasting money on tuition assistance for folks on active duty. 

I am one of those people that likes to see how we can properly 

align incentives in order to get the kind of results that we are looking for. So we will work on this and we are going to keep working 

on this until we get a better result. 

Dr. Coburn asked. Mr. Coy, I said you spent like 20 years in the 

Navy, I think, Academy graduate in the Class of 1975, and I said, 

when you finished up, what was your rank? He says, he is a Commander. So he is Commander Coy and that is the way I will introduce him today. My favorite rank in the Navy was when I was a 

Commander. I loved saying to people, I am Commander Carper. 

Who are you? I am Commander Carper. 

But Commander Coy, we are grateful that you are here. We are 

grateful for all your years of active duty service in the United 

States Navy. You now serve, as I understand it, as the Under Secretary for Economic Opportunity in the Department of Veterans’ 

Affairs, overseeing all education benefits, loan guarantee service, 

and vocational, rehabilitation and employment services for America’s veterans. 

And prior to that appointment in the V.A., you have had quite 

a career. Mr. Coy served in a variety of key positions at the Department of Health and Human Services (HHS), including Deputy 

Director for Operations in the Office of Consumer Information and 

Insurance Oversight. We are grateful for your service in those regards, and also in the United States Navy, where I understand you 

started off in Athens, Georgia, after you left the Naval Academy. 

I thought about going to supply school, too, and ended up taking 

a detour and went to Pensacola instead. But we are grateful for 

your service there and welcome your testimony today. 
6 

Hollister K. Petraeus, known as Holly, great to see you again, 

Assistant Director of Service Member Affairs of the Consumer Financial Protection Bureau (CFPB), which actually has a Director 

now. Our second witness, Assistant Director of the Consumer Financial Protection Bureau, is head of the Office of Service Member 

Affairs. She partners with the Pentagon to (1) help ensure that 

military families receive a strong financial education, (2) monitor 

their complaints, and (3) coordinate Federal and State consumer 

protection measures for military families. 

Prior to joining the CFPB, she was the director of a program at 

the Council of Better Business Bureaus (CBBBs) providing consumer education advocacy for military families. A military spouse 

of 37 years. We thank you for your service. And a former Department of Army civilian employee, Mrs. Petraeus also has extensive 

experience as a volunteer leader in military family programs. 

A graduate of Dickinson College, not that far from where I live, 

and a recipient of the Department of Defense Medal for Distinguished Public Service. Mother to several, including a guy named 

Steven, who is a fraternity brother of my son, Christopher, at Massachusetts Institute of Technology (MIT). So you turned out some 

pretty good kids as well, so thanks for joining us today. 

Next, Steve Gunderson, a colleague of mine. Did you serve with 

Steve in the House? 

Mr. GUNDERSON. I did. 

Chairman CARPER. A colleague of ours and someone I enjoyed. 

He is not just a colleague, he is a friend. So we welcome him as 

both. He has been President and Chief Executive Officer (CEO) of 

the Association of Private Sector Colleges and Universities since 

January 2012. Prior to his appointment, he served as President of 

the Council on Foundations where he placed a high priority on education and workforce development. 

At the age of 23, elected to the Wisconsin State legislature—I do 

not know if Tammy Baldwin is going to join us today, but I think 

she started as a pup as well. That is a pretty young age. 

Mr. Gunderson went on to serve for 16 years with a couple of us 

in the U.S. House of Representatives where education was one of 

his areas of focus. A graduate of the University of Wisconsin, a 

Badger, the Brown School of Broadcasting in Minneapolis, and we 

are delighted to see you today. Welcome. Thank you. 

Tom Tarantino, sitting alongside of Steve, is the Chief Policy Officer at the Iraq and Afghanistan Veterans of America (IAVA). As 

Chief Policy Officer, Mr. Tarantino provides strategic guidance for 

and leadership of Iraq and Afghanistan Veterans of America as the 

Legislative Research and Political Departments. 

Mr. Tarantino is a former Army captain who left after 10 years 

of service in 2007, returned from Iraq in 2006 after 1 year of deployment with the 11th Armored Cavalry Regiment where he 

served in combat as both the cavalry and mortar platoon leader. 

Awarded the Combat Action Badge and the Bronze Star. Thank 

you for all that you did in uniform and all that you have done 

since. Delighted to welcome you here. 

I will introduce Sergeant Christopher Pantzke and our expectation is that he will join us shortly. But he is our final witness, Sergeant Pantzke, who served in the Minnesota Army National Guard 
7 

1The prepared statement of Mr. Coy appears in the Appendix on page 38. 

from October 2002 until April 2004. He was promoted from Private 

First Class to Specialist after 6 months of serving in the National 

Guard. 

Sergeant Pantzke enlisted in the U.S. Army in April 2004 and 

was promoted to Sergeant in the following year. In 2005, his unit 

was deployed to Iraq. Sergeant Pantzke was medically retired from 

the Army in 2009 after serving his country for 6 years. And we 

welcome all of you. Your entire testimony will be made part of the 

record and you are invited to proceed at this time. Commander 

Coy, welcome. 

TESTIMONY OF CURTIS L. COY,1 DEPUTY UNDER SECRETARY 

FOR ECONOMIC DEVELOPMENT, VETERANS’ BENEFITS ADMINISTRATION, U.S. DEPARTMENT OF VETERANS’ AFFAIRS; 

ACCOMPANIED BY ROBERT M. WORLEY, II, DIRECTOR, EDUCATION SERVICE 

Mr. COY. Good morning, Mr. Chairman, Ranking Member 

Coburn, and other Members of the Committee. Thank you for the 

opportunity to be here today to discuss the 90/10 Rule and the Department of Veterans’ Affairs efforts to safeguard veteran students 

from questionable practices by some institutions. Accompanying me 

this morning is Mr. Robert Worley, our Director of VA’s Education 

Service. 

While VA defers to the Department of Education on the 90/10 

calculation, we recognize the argument for including post-9/11 G.I. 

Bill in the 90 percent limit on Federal funding. Modifications to the 

90/10 calculation could assist in protecting some veteran students. 

However, such a change could cause some schools to exceed the 90 

percent threshold and be at risk of losing eligibility. 

Our concern is to ensure that veterans are not adversely affected 

by any proposed changes or, if so, to mitigate them to the extent 

possible. VA is happy to work collaboratively with the Department 

of Education and the Committee as it considers changes in this 

area. 

VA is acutely aware of concerns raised regarding for-profit institutions and potential fraudulent activities, and in VA’s oversight of 

for-profit institutions they are held to the same standards and criteria as non-profit institutions for the purpose of approval for use 

of VA education benefits. 

Since testifying on this issue in 2011, VA has done significant 

work to ensure veteran students are informed consumers when 

using their well-deserved and hard-earned G.I. Bill benefits. In conjunction with the Veteran Employment Initiative Task Force 

(VEIT) directed by the President, along with the Vow to Hire Heroes Act of 2011, we have collaborated with multiple agencies to redesign the Transition Assistance Program (TAP) for departing 

servicemembers. The redesigned TAP transforms the previous 

VEIT powerpoint presentation into a truly informative session for 

servicemembers. 

During the day-long VA benefits overview, we provide 

servicemembers with detailed information on VA education benefits, Federal financial aid programs, and factors to consider when 
8 

applying for school. We are also piloting a 2-day special session 

called Accessing Higher Education dedicated to providing information on education and training opportunities. 

The new TAP program is truly transformative. The Veterans Opportunity to Work (VOW) Act mandates that TAP be a mandatory 

requirement now reaching all departing servicemembers and that 

will be over one million in the next several years. 

Through our Integrated Disability Evaluation System (IDES) 

program, we are placing 200 vocational rehabilitation counselors at 

over 75 military installations across the country to provide a full 

range of vocational, rehabilitation, and employment counseling and 

benefit services to members during earlier in their transition process, including counselors counseling those wounded warriors and 

disabled veterans on their educational benefits. 

Of particular importance to the Committee, VA has greatly increased oversight of all schools, including for-profit schools. Some 

specific actions include, but are not limited to, in fiscal year (FY) 

alone, our State Approving Agency (SAAs) completed over 38,000 

approvals of for-profit schools. In fiscal year 2, we completed 2,418 

compliance reviews of for-profit institutions representing over 

96,000 students. 

We should note that these reviews also survey students and review marketing material of those institutions. Overall, with our 

SAA partners, we completed over 4,700 reviews last year. This year 

through the end of May, we have already conducted over 3,000 

compliance reviews. We have withdrawn approval for nine institutions representing 177 veteran students due to erroneous or misleading practices. 

We continue to work to improve our oversight, including work 

groups with our SAA partners, hotlines, et cetera. VA is also undertaking significant efforts to implement the provisions of the 

Principles of Excellence, Executive Order (EO) and Public Law 

112–249, Improving Transparency of Education Opportunities Act. 

As part of the Executive Order, VA, with Department of Education, Defense, in consultation with the Department of Labor and 

the Consumer Financial Protection Bureau, we are in the process 

of implementing the Principles of Excellence. I am pleased to report 

that over 6,300 schools have already voluntarily agreed to comply 

with the Principles. 

In conjunction with DOD, Education, CFPB, and the Department 

of Justice (DOJ), we are also developing student outcome measures 

that are comparable, to the extent possible, across Federal educational programs and institutions. With our agency partners, we 

continue to work on the development of a centralized complaint 

system for veteran servicemembers and family members to submit 

complaints about schools that are engaged in deceptive or fraudulent practices. 

We expect this tool to be available by late summer. However, veteran students are always able to use our toll-free G.I. Bill hotline 

or our G.I. Bill website to report complaints to us. Additionally, we 

have successfully registered the term G.I. Bill as a trademark to 

help prevent its use in a deceptive or fraudulent manner. 

VA provides a wealth of resources and guidance on our G.I. Bill 

website. For example, the site contains our Choosing the Right 
9 

1The prepared statement of Ms. Petraeus appears in the Appendix on page 48. 

School handbook which provides potential veteran students with 

factors to consider when choosing a school. We have also integrated 

the Department of Education’s College Navigator onto our G.I. Bill 

website. Since integrating the tool in May 2013, it has already received over 27,000 hits. 

VA also plans to pilot an online assessment tool called 

CareerScope that allows veterans or servicemembers to assess 

whether he or she is ready to engage in post-secondary education 

and determine his or her likely vocational aptitude. In addition, we 

are promoting our Chapter 36 program, resources that emphasize 

sources of financial aid and other choices. 

Finally, VA has strengthened our on-campus presence. Started in 

2008, our VetSuccess on Campus program placed an experienced 

Vocational Rehabilitation and Employment (VR&E) counselor at 

colleges and universities. This program has grown from 8 to 32 

campuses, and by the end of this fiscal year, counselors will be on 

more than 90 campuses across the country. 

With our partner agencies, VA is working hard to ensure veterans are informed consumers and that schools meet their obligations in training this generation’s next greatest generation. Mr. 

Chairman, this concludes my statement. Thank you for the opportunity to appear before you today and we would certainly be 

pleased to respond to any questions you or other Members of the 

Committee may have. 

Chairman CARPER. Good. Well, that was a much welcomed bit of 

testimony and encouraging testimony. 

Mr. COY. Thank you, sir. 

Chairman CARPER. We are appreciative of the effort that is going 

in, his report he shared with us and we are anxious to find out all 

that we are doing, all that you are doing, what is actually working, 

what is actually working the best, what do we need to do more of. 

Thank you. Welcome. 

Mrs. Petraeus, please proceed. It is great to see you. 

TESTIMONY OF HOLLISTER K. PETRAEUS,1 ASSISTANT DIRECTOR, OFFICE OF SERVICE MEMBER AFFAIRS, CONSUMER 

FINANCIAL PROTECTION BUREAU 

Ms. PETRAEUS. Chairman Carper, Ranking Member Coburn, and 

distinguished Members of the Committee, thank you for the opportunity to testify before you today concerning higher education for 

our Nation’s servicemembers and their families. 

The government has provided a number of benefit programs to 

assist servicemembers and, in some cases, their family members to 

gain a post-secondary education, most significantly the G.I. Bill 

and the Military Tuition Assistance program. 

Today’s servicemembers and veterans are eager to earn advanced 

degrees, and many for-profit colleges are eager to enroll them as 

students, due in no small part to the 90/10 Rule created by the 

1998 amendments to the Higher Education Act (HEA). Put simply, 

the Rule says that a for-profit college has to obtain at least 10 percent of its revenue from a source other than Title IV Federal education funds. 
10 

Although tuition assistance (TA) and the G.I. Bill are federally 

funded, they are not Title IV, and that puts them squarely into the 

10-percent category of the 90/10 Rule. 

This has given some for-profit colleges an incentive to see 

servicemembers as nothing more than dollar signs in uniform, and 

to use some very unscrupulous marketing techniques to draw them 

in. 

A military spouse at Fort Campbell, Kentucky, told me that she 

was attending a ‘‘military-affiliated college.’’ It was not. It was a 

for-profit school with no official military status, but she had been 

given this impression by the recruiter. After she filled out an interest form, she was called multiple times per day until she enrolled. 

But when she had trouble logging on to her online class, she could 

not get anyone from the college to help her. She failed the class due 

to lack of access, but was charged the full fee anyway. 

National Guard education officers in Ohio and North Carolina 

told me that they are besieged by for-profit colleges desiring access 

to the troops. If they hold a job fair, over half the tables may be 

for-profit colleges, an implied promise that you are likely to get a 

job if you graduate from that school. 

In Nevada, a woman from the VA overseeing vocational rehabilitation for veterans told me that she had patients with traumatic 

brain injury (TBI) and post-traumatic stress disorder (PTSD) who 

had been persuaded to sign up for classes at for-profit colleges, and 

did not even remember doing so. That did not stop the colleges 

from pressing them for full payment, even though they were not 

regularly attending classes. Some of the schools were also pushing 

her patients to enroll in Master’s Degree programs even though 

they were not capable of doing the work. Their tactics were aggressive enough that she described it to me as ‘‘tormenting veterans.’’ 

The overall cost to the government of the G.I. Bill and TA has 

soared in recent years. While the number of individuals using VA 

education benefits has roughly doubled since 1998, the monetary 

cost has grown ten-fold, and the cost of TA has also grown exponentially, with for-profit colleges taking an increasing share. In 

2011, for-profit colleges collected one of every two TA dollars. 

President Obama has taken an interest in the issue, signing Executive Order 13607 in April 2012, ‘‘Establishing Principles of Excellence for Educational Institutions Serving Servicemembers, Veterans, Spouses, and Other Family Members.’’ Pursuant to the 

order, the VA, DOD, and Education, in consultation with the CFPB 

and the Department of Justice, are poised to launch a centralized 

complaint system for students receiving TA and G.I. Bill benefits. 

They are also working on a crosswalk system to share data about 

schools, improve consumer information for beneficiaries, and track 

outcomes. 

At CFPB, we have developed products for our website, 

consumerfinance.gov, that give useful information about student 

loan issues. They include a financial aid shopping sheet and an online G.I. Bill benefits calculator. 

So there are some very worthwhile efforts underway to help military personnel, veterans, and their families learn more about the 

schools where they may spend their hard-earned education benefits. However, it also seems prudent for Congress to examine the 
11 

1The prepared statement of Mr. Gunderson appears in the Appendix on page 53. 

90/10 Rule. As long as it adds a significant extra incentive for forprofit colleges to enroll military students, concerns will remain. 

Although there may be some for-profit colleges with solid academic credentials and a history of success for their graduates, others have low graduation rates and a poor gainful employment history. They also tend to have a higher-than-average student loan default rate, which can be an indicator that students are being recruited with little concern for their ability to do the course work, 

graduate, and repay their loans. Although the Association of Private Sector Colleges and Universities recently convened a blue ribbon task force to make recommendations for best practices for military and veteran students, one of the recommended best practices 

was simply that schools ‘‘consider assessing academic readiness 

prior to enrollment,’’ which indicates that there is still plenty of 

room for improvement. 

The G.I. Bill and TA are supposed to provide the opportunity to 

build a better future. The wonderful education benefits provided to 

our military and their families should not be channeled to programs that do not promote and may even frustrate this outcome. 

Thank you for the opportunity to testify before the Committee. 

Chairman CARPER. Thank you so much for testifying before the 

Committee. Congressman Gunderson, welcome. 

TESTIMONY OF THE HON. STEVEN C. GUNDERSON,1 PRESIDENT AND CHIEF EXECUTIVE OFFICER, ASSOCIATION OF 

PRIVATE SECTOR COLLEGES AND UNIVERSITIES 

Mr. GUNDERSON. Chairman Carper, Ranking Member Coburn, 

Members of the Committee, thank you for this opportunity. We 

share your commitment to ensuring that every post-secondary institution provides the highest level of service to every student, especially active duty military, veterans and their families. We take 

great pride in our institutions that they are designing and delivering education in ways that meets the needs of today’s military 

and veteran students. 

According to the Department of Defense, 762 of our institutions 

have been approved to offer courses to active duty military. The 

Department of Veterans’ Affairs reports that more than 325,000 

veterans and their families have been served by our institutions 

using the post-9/11 G.I. benefits. 

Although veterans make up less than 10 percent of our students, 

we are proud to serve those who choose our schools. Why do veterans and active duty military choose to attend our schools? The 

answer lies in our customer service to veterans. Returning from 

duty, most veterans do not want to live in a dorm and take five 

different three-credit courses at a time. They want a focused and 

accelerated delivery of academic programs that can support their 

transition from the front lines to full-time employment as soon as 

possible. 

Because of our longer school days and year-around academic programming, our students can often complete an associate’s degree in 

18 months, or a bachelor’s degree in just over 3 years. As Mr. Coy 
12 

said in his opening testimony, of their 3,000 compliance reviews, 

they have identified only nine problem schools. 

But we take the position that one veteran who is mis-served is 

one veteran too many. And that is why we created this set of best 

practices on veteran’s education. I do want to followup with Mrs. 

Petraeus’s suggestion on the comments on enrollment because I 

want you to hear the whole section. 

To ensure students are appropriately placed and prepared for the 

programs in which they enroll, consider employing any of the following practices: Access academic readiness prior to enrollment, 

offer appropriate remediation if necessary, offer limited course 

loads, offer a reasonable trial period for enrollment, offer penaltyfree drop/add periods upon enrollment. So I want the total story to 

be understood in terms of our best practices. 

Because the government’s Integrated Postsecondary Education 

Data Systems (IPEDS) systems only follows first-time, full-time 

students right out of high school, last year we invested in a survey 

of our institutions to better understand the path of our veteran students. In this survey, we looked at 16,500 veteran graduates and 

found 24 percent are single parents, 50 percent attend part-time, 

80 percent are over 25 and independent, 33 percent are female, 46 

percent have dependents, 29 percent are African-American, and 12 

percent are Hispanic. 

As for what they pursued, we found that 75 percent earned certificates and/or associate degrees, while 25 percent earned bachelor’s or higher. 40 percent of the veterans graduated, earned credentials in the health care field; 20 percent in the skilled trades 

such as construction, maintenance, and engineering; 10 percent 

earned credentials in computer information programs. 

Just as important as the programs we offer is the spending on 

instruction by institutions of higher education. According to the latest Department of Education data, instruction expenses are a percent of total expenses. It is 32 percent for public institutions, 33 

percent for private non-profit institutions, and 27 percent for our 

institutions. 

Considering that our schools have fewer tenured and research 

faculty, our spending on instruction is very comparable to our postsecondary colleagues. Today we now see the majority of post-secondary students attend more than one institution before completing their education. When students transfer, they often face the 

nerve-wracking and uncertain task of having their credits accepted 

by a new institution. 

All too often, institutions will simply not accept credits earned at 

an institution accredited by a different organization, especially 

when that sending institution happens to be a nationally and not 

a regionally accredited school. 

We encourage the Congress to examine policies that facilitate 

credit transfer so that completion is not delayed and extra debt 

massed as a result of repeating course work, especially when it 

comes to our active duty military and veterans. 

Finally, Mr. Chairman, I would like to comment specifically on 

90/10 in the context of today’s student veterans attending our 

schools and the skill demands of our future workers. The 90/10 

Rule is not a measure of institutional quality. It is a financial cal-
13 

1The prepared statement of Mr. Tarantino appears in the Appendix on page 77. 

culation that is a measure of the socioeconomic position of the student population served by that institution. 

An institution that is close to the 90 percent threshold is enrolling low-income students in the need of post-secondary education, 

but simply dependent upon Title IV funding to make that dream 

a reality. The government should be encouraging this behavior, 

rather than penalizing those institutions that serve a majority of 

low-income students. This metric simply undercuts the very reason 

we have Federal loan and grant programs. 

Further, across this country, because of cuts in public funding for 

public institutions like community colleges, they have reached their 

capacity and simply cannot accept more students for post-secondary 

education, especially in the skilled trades like I was discussing earlier. 

Imposing changes that make 90/10 more punitive endangers student access and choice because schools will be forced to limit enrollment of low-income students. We should judge all schools, including private sector colleges and universities (PSCUs), based on outcomes, retention, graduation, employment; based on appropriate 

metrics that look at those students. But we should not judge any 

institution on the financial net worth of the students they serve. 

Mr. Chairman, thank you for this opportunity to testify. I look 

forward to answering your questions and discussing the important 

issues later. 

Chairman CARPER. Good. Thanks for your testimony and for joining us today. Mr. Tarantino. 

TESTIMONY OF TOM TARANTINO1 CHIEF POLICY OFFICER, 

IRAQ AND AFGHANISTAN VETERANS OF AMERICA 

Mr. TARANTINO. Chairman Carper, Ranking Member Coburn, 

distinguished Members of the Committee, on behalf of Iraq and Afghanistan Veterans of America (IAVA), I would like to extend our 

gratitude for being given the opportunity to share with you our 

views and recommendations regarding this issue that affects the 

lives of thousands of servicemembers and veterans. 

My name is Tom Tarantino. I am the Chief Policy Officer for 

IAVA and I proudly served 10 years in the Army. Although my uniform is now a suit and tie, I am proud to work with this Congress 

to continue to have the backs of America’s servicemembers, veterans, and military families. 

The World War II G.I. Bill was one of the most successful government programs in our Nation’s history, doubling the number of 

degrees awarded by colleges and universities from 1940 to 1950, 

and resulting in a fivefold increase in the percentage of Americans 

with bachelor’s degrees. It is estimated that for every dollar invested in America’s veterans through the World War II G.I. Bill, 

the government took in $7 in increased tax revenue. 

And much of the success can be traced to Congress wisely protecting the World War II G.I. Bill from predatory actors in education by enacting what was called the 85/15 Rule that allowed the 

free market to weed out bad actors in the education sector. 
14 

As the student population changed, the protections offered by the 

85/15 Rule lived on in the current 90/10 Rule as the 85/15 was a 

head count model that existed when 50 percent of all college students were G.I.s. Now with an all-volunteer force and a head count 

that is much lower, the 90/10 Rule is a revenue-based model. But 

there is one major exception between the spirit of the 85/15 and the 

90/10 Rule is that tax dollars that fund the G.I. Bill are counted 

under private funds that are supposed to allow the market to regulate the for-profit industry. 

The proposed reforms that IAVA strongly support seek to make 

educational institutions accountable to free market principles by 

counting the post-9/11 G.I. Bill funds as government-sourced funds 

under the 90/10 Rule. The intent of Congress with regard to the 

90/10 Rule and its predecessor was not only to decrease instances 

of fraud and predatory targeting of veterans by educational institutions, but also to ensure that these institutions provided a quality 

product to students by making them accountable to free market 

forces. 

Unfortunately, due to a loophole in the law, or the fact that the 

G.I. Bill just simply did not exist when they wrote the 90/10 Rule, 

military and veteran’s benefits are counted as part of the 10 percent of revenue that is supposed to come from private sources. 

This ends up putting a target on every single veteran’s back. Because of this loophole, every veteran that a for-profit school recruits 

is worth nine additional students on Federal financial aid, potentially raising revenue up to $125,000 per veteran recruited. 

IAVA believes that in order to protect the future of the post-9/ 

11 G.I. Bill, Congress must act to classify G.I. Bill dollars as government funds subject to the 90 percent restrictions, if for any 

other reason than because the G.I. Bill are unquestionably government funds. The goal of the proposed reform is not to penalize educational institutions, but to ensure that America’s veterans are receiving a quality education that will help them transition successfully from military to civilian life. 

Unfortunately, as a result of the actions of some bad actors in 

the system, this transition is being made more difficult for too 

many of our Nation’s veterans. Although less than 20 percent of 

veterans are attending a for-profit school, a lot of these schools are 

taking over a third of all G.I. Bill dollars. Drop-out rates at forprofit schools are above 60 percent on average, and even though 

they account for 13 percent of all college students in the country, 

they produce half of all student loan defaults. 

In this period of deficit cutting and waste reduction that we are 

seeing in Congress, the failures of the handful of bad actors in the 

for-profit school industry with regard to providing quality job training and education programs to servicemembers represents an unacceptable threat to the future of the G.I. Bill. 

One IAVA member, Maggie Crawford, expressed frustration with 

a for-profit school on IAVA’s Defend the New G.I. Bill web page. 

After serving a tour of duty in Afghanistan, Maggie, a member of 

the Army National Guard, enrolled in ITT Tech to study nursing. 

It was not until the second quarter of her program that they informed her that she was not eligible for the Yellow Ribbon Scholar-
15 

ship that she was told she was originally eligible for and she could 

not cover the full cost of her degree. 

According to Maggie, ITT was also dishonest about its nursing 

accreditation, first telling her that they were an accredited program, and then later telling her, as she was going through her program, that the accreditation was still pending. She quit ITT and 

is still to this day working to pay off the debt she incurred. She 

is actually enrolled at another for-profit school in a nursing program and is extremely pleased with her experience thus far. 

Another IAVA member, Howard Toller, expressed a similar frustration. He enrolled in ITT in 2010 for a degree in computer networking services, and later admits that he was ‘‘duped’’ by their 

high pressure recruiting tactics. A couple of months after his enrollment, he learned that ITT was not properly accredited for him 

to get a job in the field that they were training him for, thereby, 

rendering his degree completely worthless. 

The experiences of these veterans and thousands like them demonstrate the need for more effective policies to protect military and 

veterans’ education benefits from the practices of a handful of predators in the higher education system. And I agree with the rest of 

my panel. We do have to increase outcome-based metrics, but the 

90/10 Rule is one piece of that puzzle. 

Many for-profit institutions, I would argue most, are valued participants in education, and as has been pointed out earlier, they actually provide veterans with a service that is not widely available 

by traditional non-profit universities, including online vocational 

programs that offer highly technical degrees. 

Unfortunately, it is difficult to separate the good actors from the 

bad actors in for-profit education without closing the 90/10 loophole. This loophole undermines the spirit and intent of the G.I. Bill 

and should be closed this year. IAVA stands ready to assist Congress in closing a loophole that virtually every veterans’, educational, and consumer advocacy group agrees should be closed. 

Thank you for your time and attention. 

Chairman CARPER. Mr. Tarantino, thanks so much. It is good to 

see you. Thank you for joining us on this occasion. 

We have been joined as well by Sergeant Christopher—is it 

Pantzke? 

Sergeant PANTZKE. Yes, sir. 

Chairman CARPER. We are happy that you are here and appreciate the time and effort you have made to get here. Welcome. Your 

whole testimony will be made part of the record. If you would like 

to summarize that, feel free. Thanks. We are just delighted that 

you could join us. 
16 

1The prepared statement of Mr. Pantzke appears in the Appendix on page 80. 

TESTIMONY OF SERGEANT CHRISTOPHER J. PANTZKE,1 USA, 

RET., VETERAN 

Sergeant Pantzke. Greetings to the Committee and panel Members. My name is Christopher James Pantzke, formerly known as 

Sergeant Pantzke. I am a 100 percent disabled Iraq combat veteran. In 2005, one of the convoys that I was in was attacked by 

a vehicle-borne improvised explosive device (IED). After coming 

back to the States, I found I had trouble adjusting to everyday life. 

From 2006 to 2008, I received intensive therapy. 

In 2008, I was placed in the Wounded Warrior Transition Unit 

at Fort Lee, Virginia, to heal and make the transition back into civilian life. In March 2009, I was medically retired and placed on 

temporary disability retired list (TDRL) status. And this is my 

story. 

To begin with, I believe that anyone can take a picture, but a 

photograph is created. I wanted to learn how to take a photograph. 

So in March 2009, I contacted an enrollment advisor at the Art Institute of Pittsburgh (AIP) and I informed her that I was a disabled 

veteran, and I specifically mentioned what my disabilities were. I 

started their enrollment process right away and within 48 to 72 

hours later, I was notified that I was accepted into school. 

I believe it was July 2009 when I started my classes. Almost immediately I started having trouble with my classes and I started 

to fall behind. I struggled with my classes on a daily basis, especially my math classes. I was forced to find an alternative source 

to help me with my math assignments. 

I notified the academic advisor and told her that I was having 

trouble in keeping up with my classes and I asked her if there was 

any type of face-to-face tutoring or remedial classes that I could 

take to help me. She told me that tutoring services were not available for me because I had not applied for disability services 

through the Art Institute. I was livid. 

Why was I not referred to or informed of disability services when 

I first enrolled into the school? So I was granted accommodations 

for my disabilities. The accommodations granted me one extra day 

to submit my assignments. That was it and I still struggled. 

During my attendance at the Art Institute of Pittsburgh online, 

my post-traumatic stress disorder was raging. I was so frustrated 

with the Art Institute Online (AIO). Anyone and everything was a 

target. The Art Institute of Pittsburgh had placed me on academic 

probation several times and withdrew me twice, once because I had 

a bought with depression, and the second time because of my grade 

point average (GPA), which I disputed. I was readmitted both 

times. 

I did several written and televised interviews hoping to effect 

change on how for-profit colleges dealt with and treated veterans. 

While I was being interviewed by Natalie Morales from the National Broadcasting Company (NBC), she asked me why I had not 

withdrawn from school because it was causing such suffering and 

pain for myself and my family. 

So in late October 2011, I officially withdrew from the Art Institute of Pittsburgh online, stating that I felt that the Art Institute 
17 

had failed to provide me with proper disability services and that 

they were unable to provide me with an education to become a viable and credible photographer. And topping it all off was that they 

were overcharging my G.I. Bill benefits for a worthless degree. 

After doing the interview, Educating Sergeant Pantzke, I believe 

it was my digital image management class that I did one of my assignments in 3 hours and submitted it, knowing that it was a sloppy job, but I did not have time to do the assignment properly. To 

my amazement, I received an A for this assignment. 

When I last checked my account for the breakdown of the costs 

of my tuition, which was on February 18, 2011, it was roughly 

$91,000. And just the other day, on July 17, 2013, I rechecked the 

tuition costs again. The costs went down to $34,000. I would like 

to know what happened to the rest of the $57,000. I also have 

$26,000 in student loan debit. 

In closing, I learned more about photography on my own than I 

did while I was in attendance at the Art Institute. Also, education 

should never be for sale or traded on the public market. The only 

person that should profit from education should be the student who 

is striving for a better life for themselves and/or their family. I 

thank you for your time. 

Chairman CARPER. Sergeant Pantzke, thank you for sharing that 

sad story with us. 

Let me just ask, Commander Coy, talk about—what was that, 4 

years ago? Was it roughly 4 years ago where you went through the 

ordeal that you just described? Commander Coy, what is in place 

today to better ensure that other G.I.s coming home, whether it is 

from Afghanistan or other places around the world, enrolling in a 

college or post-secondary education, what do we have in place today 

to better ensure that this kind of story is not going to be told and 

retold again and again? 

Mr. COY. Yes, sir, Senator. And I feel for Sergeant Pantzke’s 

plight, and we certainly would like to help in any of those kinds 

of instances. What we have in the VA is our Vocational Rehabilitation and Employment Service. In that service, we provide case 

management for individual veterans. As you might imagine, with 

respect to G.I. Bill benefit payments, we have done close to a million post-9/11 G.I. Bill payments, but none of that is done on a case 

management basis. 

But for our disabled veterans or wounded warrior veterans, we 

provide, when they come into our office at Case Management—I 

would further suggest that for those students like the sergeant that 

was in need of some additional help or counseling, we would be 

able to provide that as well. So I do not know if the sergeant is 

or continues to be in our VR&E program. 

Chairman CARPER. I am going to ask you to go back in your testimony, Commander, and to talk a little bit more about some of the 

changes that have been adopted in the last year or two within the 

VA to address some of the abuses that I think most of us are aware 

have existed. I said in my comments, and Dr. Coburn has said, we 

have problems, not just with for-profit colleges. We have problems 

with a quality education and preparation for jobs, job readiness, in 

public schools and in private schools as well. 
18 

But just talk to us about, again, some of the changes that you 

mentioned earlier in your testimony, safeguards in place to reduce 

the likelihood they are going to be wasting money for veterans and 

helping ensure that we do not waste their lives. 

Mr. COY. Yes, sir. We work very hard in the VA to ensure or 

hopefully ensure that veterans are informed consumers, and we try 

and provide them with as much information as possible. We have 

also initiated a number of things in the last year or two that I related in my oral testimony, and I will sort of flip through some of 

those as well. 

On our G.I. Bill website, we have a wealth of information that 

is on there and we continue to build on that. We have a handbook 

that is a wonderful handbook called Choosing the Right School, and 

it talks about things like employment, graduation rates, credit 

transfer, military credit. It asks a whole realm of questions that 

the veteran should consider when they are choosing a school. 

As well, we put together, as I mentioned in my oral testimony, 

we have put up the Department of Education’s College Navigator 

which provides a wealth of information about schools. Across the 

board, we work very close with our partners at Department of Education, Department of Defense, CFPB, Department of Justice to implement a number of things. 

Just to go through some of those, we have developed an increased partnership with out State approving agencies in just the 

last couple of years. We have launched a 64-hour training module 

on compliance reviews. We have rewritten our School Certifying Official (SCO) manual. The School Certifying Official is really the 

front line on most schools that deal with veteran issues. 

And so, we have rewritten our entire School Certifying Official 

manual. We have established a School Certifying Official hotline 

that is just for them, that they can call in and do those kinds of 

things. 

I mentioned the compliance reviews. Last year we did over 2,400 

compliance reviews of for-profit schools, but we also did overall 

about 4,700 compliance reviews. We, by the end of May, have done 

over 3,000 compliance reviews this year alone. So just the rampup of the number of compliance reviews we do. Just to give a perspective, in fiscal year 2011 we did about 1,900 compliance reviews. 

Last year we did over 4,700, and our target this year is over 6,300. 

So we really have ramped up our compliance review process with 

our SAA partners. 

I mentioned the withdrawals that we talked about, but with respect to the Principles of Excellence, working with our colleagues, 

we have trade-marked the G.I. Bill and added College Navigator. 

We are developing outcome measures. I would be happy to talk in 

depth about those. But those outcome measures were developed 

with our partners at Department of Education, DOD, and CFPB. 

We are developing a comparison tool for schools that sort of racks 

and stacks whether or not a school is veteran-friendly or not. We 

have also been working very hard in the TAP program. 

Chairman CARPER. I am going to ask you just to hold just for a 

moment, if you would. 

Mr. COY. Yes, sir. 
19 

Chairman CARPER. I want to give Mrs. Petraeus an opportunity 

during this round just to comment, if you would. We have heard 

from Commander Coy some of the changes that have been made, 

adopted at the VA, that are being implemented at the VA. My dad 

used to talk to my sister and me a lot about common sense, and 

said, You just use some common sense. Which of these measures 

that he has described do you think meet, if you will, a common 

sense test, which is likely to give us a better result for the veterans 

and for the taxpayers, in your judgment? 

Ms. PETRAEUS. Well, I think we need to take a multifaceted approach, really. I certainly applaud the work that is being done at 

this point by the VA, the Department of Defense, and the Department of Education in concert to see if they can address these issues 

to some degree. I think it is important that while Congress may 

look at the 90/10 Rule, that the VA and the Department of Education work to make it easier really for servicemembers, veterans, 

and their families to see what they are getting when they go to 

apply for a school. 

I think there are a number of steps in place to do that. I also 

think the single complaint portal is going to be very helpful because it will allow folks to go to one place to complain, to have 

their issues addressed in a systemic way, and, for those of us who 

take an interest in this, to see what the trends are, to really be 

able to have some metrics about complaints. 

It has been kind of on an informal basis by each agency. So I 

think that is a very important step. We are also trying to do some 

common sense things at the CFPB. We have a financial aid shopping sheet that tries to make it easier for someone to see what it 

is actually going to cost, where can I get the money to pay for 

school, and we have a G.I. Bill calculator as well on our side, and 

I know we are working with the VA who are also going to design 

one. 

I think we also need to work together to stop some of the very 

aggressive marketing tactics. One thing I was pleased to see was 

the copyrighting of the term G.I. Bill. So you no longer have 

websites that are able to give the misleading impression that they 

are an official source of G.I. Bill information when they are not. 

So I think there are a lot of ways we can approach this. I think 

accreditation is another important one. Mr. Gunderson mentioned 

that there are different types of accreditation and some of them 

will not get you the job you want or get your credits transferred. 

That is another thing, I think, that is very important, that the accreditation process be looked at as well. 

So there are a number of steps that can be taken, basically, so 

students choose schools not based on which one has the best marketing, but on which one has the best potential for them to have 

a positive outcome. 

Chairman CARPER. Thanks very much. Dr. Coburn. 

Senator COBURN. Thank you. Mr. Tarantino, I think you testified 

a moment ago that the other veteran service organizations have endorsed this? 

Mr. TARANTINO. Yes, they have. 
20 

Senator COBURN. I checked with the American Legion and the 

Veterans for Foreign War (VFW) and they did not endorse it this 

last year, so would you want to correct your testimony? 

Mr. TARANTINO. No, I am happy to talk with them again, but the 

three of us were all working together, along with Small Business 

Administration (SBA), and we had endorsed Senator Carper’s bill 

from last year. 

Senator COBURN. There was no letter of endorsement from the 

American Legion or the VFW on that bill. 

Mr. TARANTINO. Well, I will check with our staff, but I was sitting in multiple meetings with them. 

Senator COBURN. One of the things you testified about is a quality education. And so, one of the things I try to do as a Senator 

is try to fix the right problem. We now have nine schools that have 

been deleted based on the 90/10 Rule. I think that was Commander 

Coy. Or was that through your assessment of—— 

Mr. COY. It was through compliance reviews, sir, not 90/10. 

Senator COBURN. OK. But since 2007, I think three schools have 

been eliminated. The question I would ask is, what if the three 

schools that were eliminated under the 90/10 Rule had an 80 percent graduation rate and an 80 percent job placement rate? Which 

is higher than every other institution, on average, in this country. 

What would we do then? 

I mean, they are doing the job. They are giving a quality education, have great placement, but because they do not meet the 

rule, they no longer qualify. If we are looking for quality education, 

we ought to be looking for different metrics, much like Ms. 

Petraeus had testified. It ought to be quality. 

And so, when we get hung up, whether it be the 85/15 Rule that 

we had before, or the 90/10 Rule now or the expanded 90/10 Rule 

that we are going to make, it does not direct us toward the problem. It may solve one problem of taking pressure off recruiting of 

veterans, and I agree that is something we ought to look at, but 

do we really solve the problem? 

And so, our whole hearing focusing on the 90/10 Rule, as long as 

we focus on that, we are not focusing on what is really going to 

make a difference for our veterans. What we ought to be saying is, 

across the board, if you are going to get government help and government payment, you ought to perform. 

There ought to be a metric. We ought to know how well you do 

in terms of graduating students, what your matriculation rate is, 

what your job placement rate is, what is the quality of your education? And we are talking about everything except that. We are 

talking about the symptoms of the problem instead of the problem. 

The other thing that concerns me, Mr. Tarantino, in your testimony, ITT, although accredited, was not accredited for the things 

they marketed. That is fraud. 

Mr. TARANTINO. Yes. 

Senator COBURN. And so, where is the Justice Department in 

terms of going after fraud? If, in fact, they are marketing something that is accredited when it is not, that is deception. And so, 

we ought to be talking about it. We should have somebody from the 

Justice Department saying, ‘‘Why have you not gone after this? ’’ 
21 

Congressman Gunderson, do you all have a sanction procedure 

within your organization for bad actors? 

Mr. GUNDERSON. Any school that is not licensed by the State, approved for Title IV by the Department of Education, and accredited 

is not allowed to be a member of our association. So you have to 

meet all three standards to be eligible for membership in the Association of Private Sector Colleges and Universities. 

When we take the issue of veterans and, specifically, our veterans’ education best practices, people ask me, Do you have an enforcement measure in there? And I said, We endorse the President’s Executive Order. We supported the Bilirakis legislation last 

year. We drafted these, our best practices, and we believe that the 

VA and the complaint process will determine whether or not we are 

meeting that standard. 

If the records show that there is a disproportionate number of 

complaints targeted at our schools, then we have work to do. 

Senator COBURN. Can any of you think of any untoward event if 

we were to incorporate the TA and new G.I. Bill in this 90/10? It 

seems to me there might be an economic incentive for people not 

to participate with the new G.I. Bill and tuition assistance, and 

force people who have a good program to say go student loan rate. 

In other words, a perverse incentive to not use what is available 

and send people in another direction because of the 90/10 Rule. 

Any worries about that? 

Mr. GUNDERSON. Mr. Coburn, we have a number of schools that 

fit the description you discussed earlier, and let me just name one 

of them for you. It is called Praxis Institute, Miami, Florida, 100 

percent Hispanic student body, graduation rate is 86 percent, default rate is 9.5 percent; yet, they receive 89.8 percent of their 

funding from Title IV because of the economic circumstances of 

that Hispanic community. 

If you were to move this into the 90/10 ratio, that school would 

simply have to turn away every veteran who applied. 

Senator COBURN. Any comments, Holly? 

Ms. PETRAEUS. I would just suggest that one alternative idea 

might be not to move the military money into the 90 percent, but 

just take it off the table altogether so it is not part of the calculation, take it out of 10 percent, but do not put it in the 90 percent. 

That could address the issue you have mentioned. 

Senator COBURN. OK. I want to go back. Mr. Tarantino, did you 

want to comment on that? 

Mr. TARANTINO. No, I am good. 

Senator COBURN. OK. I want to go back to what I mentioned earlier. Does anybody here disagree that what we really ought to do 

is change it to outcomes-based? Anybody disagree with that? 

Mr. TARANTINO. Senator, I do not think the two are mutually exclusive, though, but I absolutely agree. I think we should have outcomes-based. I think that should be the first thing. The problem is, 

is that we should be talking largely about how the Department of 

Education does not measure graduation rates properly. 

There is a large argument about community colleges having a 

low graduation rate. That is because community colleges have five 

different types of students, from guys who take adult education to 

people who get vocational and transfer degrees. Not one of those 
22 

students are technically graduates. According to the Department of 

Education, I have dropped out of college twice because I deployed 

to Bosnia and transferred from community college to the University 

of California. 

Senator COBURN. I agree. That is a good point. Well, my time is 

up. 

OPENING STATEMENT OF SENATOR MCCASKILL 

Chairman CARPER. Senator McCaskill. 

Senator MCCASKILL. Mr. Gunderson, is the online Video Game 

Developer School a member of your association that is advertised 

so frequently? Become a video game developer online. 

Mr. GUNDERSON. I have to plead guilty that I do not follow the 

media advertising at all. We have schools that are accredited, that 

are members of our association that provide instruction in the gaming skill set, but I do not know that particular school. 

Senator MCCASKILL. I will send you a clip—— 

Mr. GUNDERSON. Yes. 

Senator MCCASKILL [continuing]. And I would like to find out if 

it is a member, and I would also like to find out if it qualifies for 

this G.I. Bill money. What percentage of the revenue do your members get from taxpayers, of their overall revenue, Mr. Gunderson? 

What percentage is provided by taxpayers? 

Mr. GUNDERSON. Very small, because we have no public subsidies. If you compare community college to one of our schools, 

there is no public subsidy in that regard. 

Senator MCCASKILL. But of all the revenue that is taken in, what 

percentage of that—if you are worried about 90/10—— 

Mr. GUNDERSON. Yes. 

Senator MCCASKILL. I mean, what—— 

Mr. GUNDERSON. It varies by school. 

Senator MCCASKILL. Right. 

Mr. GUNDERSON. There is no one set. 

Senator MCCASKILL. But if you took them all together, all of your 

members. 

Mr. GUNDERSON. I do not know that we have ever done that calculation because it rotates by year. 

Senator MCCASKILL. Well, it seems to me it is really relevant. 

One, because if more than half of the money that your schools are 

realizing is coming from the public sector, then I think Congress 

has a right to be more aggressive in terms of oversight. If it is a 

smaller percentage, then I think the argument that many of my 

colleagues might make, that it is none of our business, might apply. 

And it is interesting to me that is a figure that you do not know, 

because if we are worried about 90/10, what does that tell us? 

Mr. GUNDERSON. Well, the problem, Senator, is there are schools, 

as I mentioned, that are right at that 90 percent criteria. 

Senator MCCASKILL. Which means 90 percent of their revenue is 

coming from that. 

Mr. GUNDERSON. That means that exactly 90 percent would come 

from Title IV. 

Senator MCCASKILL. Right. So how can it be very small if you 

are worried about 90/10? 
23 

Mr. GUNDERSON. There are also schools that are well below 50 

percent. What? 

Senator MCCASKILL. How could the percentage of revenue you receive be very small if you are worried about 90/10? 

Mr. GUNDERSON. I am worried about 90/10 for the same reason 

a Senator from Missouri would be worried about 90/10. I come from 

rural Wisconsin. If you look at rural America and if you look at the 

inner city, you will find a population that, based on economics, is 

dependent upon financial aid in order to pursue their education. 

We need to be very careful. The reality is, my schools, because 

they are for-profit, they are private sector schools, they can move 

where they want, they can move where the enrollment is best 

available to their mission. I had a conversation with the president 

of a college in one of our large inner cities in the Midwest. I said 

to him exactly what you are saying to me. 

I said, You have very high Federal financial numbers. You have 

low graduation rates. You have high default rates. What is going 

on? What he said to me? He said, Steve, I can fix that tomorrow. 

I said, You can fix it tomorrow? Why do you not do that? He said, 

Well, I would fix it tomorrow by closing the school and moving to 

the suburb and dealing with upper middle-income students and I 

would not have any issue at all. But the students that I am serving 

in this inner city school would have no opportunity for the very career skills I am trying to provide. 

Senator MCCASKILL. Well, listen, I am sure that there are many 

altruistic people among your members, and I am sure there are 

many of them that are answering a calling. But it is interesting to 

me that we are arguing about 90/10, and I would make the argument, if graduation rates were high, if the metrics were high, they 

would not worry about 90/10 because they would not have any 

problem with 10. 

If this was a quality school, they would not have any problem attracting at least 10 percent of their revenue from something other 

than the government. What is the average—first of all, I would like 

to get the number of what the overall percentage of your schools, 

how much of it is public money. And then I would like the average 

salaries of these folks that are in the inner city because they are 

worried about that. 

I mean, I am not usually one to care about salaries in the private 

sector, and everybody has the right to make a profit. This is a free 

market economy. 

Mr. GUNDERSON. Sure. 

Senator MCCASKILL. But when the taxpayers are footing the bill, 

there becomes a requirement of a level of accountability that I do 

not sense is there. It is like all these institutions want our money. 

Would you support your institutions not getting their money from 

veterans until the veteran graduates? 

Mr. GUNDERSON. The reality is, Senator, that if you will look at 

that survey we did of our 16,500 veterans, we had a graduation 

rate on 2-year certificates of 63 percent—— 

Senator MCCASKILL. So would you accept—— 

Mr. GUNDERSON [continuing]. For our veterans. 

Senator MCCASKILL. Then—— 
24 

Mr. GUNDERSON. If you would look at the Department of Education statistics on 2-year institutions, we are at 62.7 percent graduation rate. The public schools are at a 21.9 percent graduation 

rate. We do incredibly well in the career certificate in 2 years program, but because we are dealing with an adult population coming 

back to school that often has—— 

Senator MCCASKILL. Let me ask you this question. 

Mr. GUNDERSON [continuing]. To drop out and go back and startup again—— 

Senator MCCASKILL. I understand. 

Mr. GUNDERSON [continuing]. The 4-year program—— 

Senator MCCASKILL. Believe me, I understand. My son is—— 

Mr. GUNDERSON [continuing]. Graduation rates are not great. 

Senator MCCASKILL [continuing]. My son is back in school at 25. 

I get it. 

Mr. GUNDERSON. But the 2-years are incredibly good. 

Senator MCCASKILL. Let me ask you this: Would you tell us, 

what would be the metrics—let us assume that Senator Carper decides to draft a different bill, a bill that maybe Senator Coburn has 

in mind in his testimony. What are the metrics that your association would endorse today as a requirement that you must achieve 

before you can receive VA benefits? What would that metric be? 

Mr. GUNDERSON. The best set of metrics that I have seen is probably the National Governors’ Association (NGA) in their development of what is called Complete to Compete. And they have set up 

a series of metrics that look at outcomes based on those particular 

metrics. I think my association would endorse those particular 

metrics as a standard for outcomes for all students, all schools in 

this country. 

We stand ready, Senator, and let me emphasize this as clearly 

and as loudly as I can. We absolutely support being judged by the 

same set of risk-based metrics that every other college and university in America is in terms of outcomes. What we do not want to 

happen is, simply because we are for-profit in our organizational 

structure that we are denying students with multiple risks the opportunity to ever even pursue that career-based education that gets 

them a path to the middle class. 

Senator MCCASKILL. And your average cost is three times higher 

than the not-for-profits? 

Mr. GUNDERSON. What you need to stop and do here is say, Are 

you looking only at tuition charge—— 

Senator MCCASKILL. Well, I was looking at your testimony. 

Mr. GUNDERSON [continuing]. Or are you looking at total public 

dollars, because if you look at—— 

Senator MCCASKILL. I was looking at your testimony. The mean 

cost was $928 versus $3,000-some. 

Mr. GUNDERSON. You are looking at my written testimony in 

terms of the—— 

Senator MCCASKILL. The mean cost for a student, $928 versus 

$3,000-some. 

Mr. GUNDERSON. The cost of producing the education? 

Senator MCCASKILL. Correct. 

Mr. GUNDERSON. Yes. 

Senator MCCASKILL. Three times as high. 
25 

Mr. GUNDERSON. Times what? 

Senator MCCASKILL. Three times as high. 

Mr. GUNDERSON. Well, of course, we are going to be higher in 

terms of tuition because we do not have any public subsidies. 

Senator MCCASKILL. Obviously, except for the fact that you are 

worried about more than 90 percent of your money coming from the 

public. 

Mr. GUNDERSON. Yes, but here is the problem, Senator, as I said 

in my testimony. Because of the cutback, and we have seen in the 

last decade a 25 percent—— 

Senator MCCASKILL. I know. 

Mr. GUNDERSON [continuing]. Per capita reduction in public support for 2-year and 4-year institutions in this country. If you are 

pursuing allied health or the career trade skills, you have two opportunities. One is the community college, and I am a big fan of 

community colleges, or it is our schools. Most community colleges 

in this country have no ability to expand to meet the demand for 

increased education in those areas. If we do not exist, there is no 

opportunity for those students. That is the real tragedy. 

Senator MCCASKILL. Well, I would look forward to working with 

your organization. I have found a reluctance to accept metrics by 

your organization, so maybe I have it wrong, and I look forward to 

working with you—— 

Mr. GUNDERSON. Well, I cannot speak for the staff, but we stand 

ready—— 

Senator MCCASKILL. OK. 

Mr. GUNDERSON [continuing]. To work with you on those—— 

Senator MCCASKILL. And I will look forward to getting that number from you for the overall percentage of the revenue for for-profit 

schools coming from taxpayers. 

Mr. GUNDERSON. OK. 

Senator MCCASKILL. Thank you. 

Chairman CARPER. Dr. Coburn and I have focused for a couple 

of years now in another area of the Federal Government, Federal 

expenditures. I think there is actually a correlation here. One of 

our concerns has been the money we spend in Medicare, especially, 

but also in Medicaid, dollars that are spent improperly for services 

provided by dead doctors, maybe to dead beneficiaries. There is a 

lot of money in fraud, in tens of billions of dollars in fraud every 

year, tens of billions of dollars in improper payments every year in 

Medicare. 

And what we have done for years is, Medicare has actually paid 

the money and then chased the dollars. It is called pay and chase. 

I want to make sure that if an institution is screwing up or behaving in a way that is harmful to our veterans, I want us to punish 

them. I want us to pursue them and punish them if we can. 

By the same token, I want to make sure that up front we are 

not paying that money in the first place to an institution that has 

a reputation, maybe well-deserved, for not doing a good job of 

screening, preparing, educating, helping to place, supporting, the 

veteran that has gone through that school. 

I want to take just a moment and talk about the kind of metric 

that we ought to be looking for. Among the metrics that I think are 

appropriate, and I think you said this as much today, to make sure 
26 

that we are working with the veteran to make sure that he or she 

is prepared for the work that they are expected to do. 

Some students work perfectly well over the Internet. That is fine. 

Some need to be face-to-face with a professor, a teacher on a regular basis. Some do well with a combination of the two. The metric 

that I am most interested in is not just well-screening people, offering a curriculum, making sure that they actually get to a graduation or a certificate. 

I want to make sure they get a job and I want to make sure that 

they get a job that actually relates to their education, in many 

cases, and that they will be gainfully employed. I seem to recall a 

couple of years ago the Department of Education actually worked 

on a regulation. I think it was called the Gainful Employment regulation, and I think it was, their effort was to say, how do we actually create a metric that enables us to look at a school and what 

is happening with their graduates, those that receive their certificates, that actually enables us to measure whether or not did he 

get a job. Was it a decent job? Was it the kind of job they hoped 

and expected, that they were led to believe they could get. 

Ms. Petraeus, I do not know if you have any thoughts about that, 

but if you do, I would welcome your thoughts, Ms. Petraeus. 

Ms. PETRAEUS. Yes. I believe the Department of Education is 

poised to take another look at the gainful employment rule. 

Chairman CARPER. I hope so, because what they came up with 

was pitiful, and, as I recall, there was push back, huge push back 

from some of the institutions that we are talking about here today. 

Not all, but some. 

Ms. PETRAEUS. I think as with what you described with Medicare, when there is a great deal of money at stake, and certainly 

I would say $10.5 billion is a great deal of money, and that is, at 

this point, what is being spent on the G.I. Bill. When there is a 

lot of money at stake, there will be a lot of people who will fight 

tooth and nail to get a piece of that money and to fight any restrictions or limitations on how they access it. So they are looking again 

at gainful employment. 

I want to go back a little bit to what Dr. Coburn mentioned 

about schools that market themselves improperly and do not have 

consequences. I would like to mention that the State Attorneys 

General have done a very good job, in many cases, going after those 

schools. There is one I can think of in Chicago that was advertising 

a Criminal Justice degree saying, You could get a job as an Illinois 

State trooper or a Chicago city policeman, but that particular 

school did not have regional accreditation. It was nationally accredited and those organizations would not even look at their graduates. 

So she did file suit against them for false, deceptive advertising. 

So there are some efforts to go after those practices. I wanted to 

mention that while it was still in my head. 

Chairman CARPER. Commander Coy, you talked a little bit about 

the VA doing compliance reviews, and I think the numbers that 

you mentioned were actually quite impressive. I think you said you 

were looking at about 6,000-some this year over 4,000 last year, 

over 2,000 the year before that. Just talk to us about, what is a 
27 

compliance review? What does it entail? Why is it relevant here 

and should we be encouraged by those numbers? 

Mr. COY. Compliance review covers a broad waterfront of things. 

It certainly looks at all of the administrative pieces of the 

post-9/11 G.I. Bill specifically. What kind of information do they 

have and all their procedures and internal-type procedures. 

It also takes a look at all of the marketing material that the 

school has, compares it against what they are actually doing. And 

then finally, the third piece of the compliance reviews are, we actually survey students that go to that school and get feedback directly from them. So it is sort of those three general areas. 

I will let Mr. Worley elaborate, if he has some additional information. But it is generally those three areas, sir. 

Chairman CARPER. Mr. Worley. 

Mr. WORLEY. Thank you, Mr. Chairman. I would add that during 

a compliance survey, a number of student records are looked at. 

The enrollment term, for example, is looked at. The policies for 

progress are examined. There is direct contact with the school’s certifying official and other officials at the school as needed. They look 

at prior credit granted to a particular student, if that is done properly and in accordance with school policy. 

There is a whole host of things that are looked at with the ultimate goal of making sure that the school is complying with all the 

statutory and regulatory requirements for serving those veterans, 

and that ultimately, the information provided to the VA by which 

VA pays these veterans is accurate and proper and timely. 

You mentioned, if I could add one other thing, Senator, at the beginning of the process, approval of programs is the first step. When 

a school wants to have a program approved, they come in with a 

written request to the State approving agency. The State approving 

agency looks over many of the items I just mentioned, standards 

of progress, standards of conduct, and so forth, to make sure that 

school is meeting the statutory requirements to gain approval for 

G.I. Bill benefits. 

Chairman CARPER. I have heard of the State approval process 

that you referred to, and I will be generous and say that the approval process, from what I understand, is uneven. In some States, 

there is rigor; in other States, there is not much at all. And that 

is something I would like to come back the next round and talk a 

little bit more about. Thank you. Dr. Coburn. 

Senator COBURN. Thank you. Commander Coy—I like that name. 

That is great. It goes well. 

Mr. COY. Thank you, sir. 

Senator COBURN. You are working on the centralized complaint 

process and eventually with the hopes of making that a live interactive site, correct? 

Mr. COY. Yes, sir. 

Senator COBURN. Talk to me a little bit about when you see that 

coming to fruition. You have talked a little bit about it, but tell me 

a little detail about that, if you would. 

Mr. COY. Thank you. We are looking at this complaint system 

and we are working with our partners over at the Department of 

Defense, as well as CFPB. There are a number of loops and steps 

that one has to go through to get a system like this up and run-
28 

ning. There is the system of record notification. There is the Paperwork Reduction Act. In other words, you cannot literally survey 

people without getting approval for that process. 

And then there is the actual IT piece of it. And so, all of those 

things, as we walk down that path. The interesting thing that the 

complaint tool, as we are at the final stages of trying to launch 

this, is accepting that complaint, and it will be on our G.I. Bill 

website, it will be on our E-Benefits website, and it will also be on 

the DOD website as well, and we are going to encourage schools 

to also put the link on their websites as well. 

And then collecting the information that basically we want to 

know what your complaint is, what do you think has happened. 

Then we want to know what you think is a fair resolution to that 

issue. We then need to take that complaint. There needs to be a 

centralized place for them all to be in one place, and we will probably be using a centralized database that is already in existence. 

Then we need to have a feedback mechanism for the school. In 

other words, in the case of a school, we need to either send that 

issue or complaint to the school or we will send it to an SAA, or 

in some cases, we may refer it to the Department of Justice for 

something that is extreme. 

Then we also need another mechanism to get feedback back to 

the student or the person that made the complaint, and then a 

place to register all of those complaints. So our initial look was, 

Gee, this is going to be pretty easy to do, and then we looked at 

it and it is a process. 

Senator COBURN. Did I understand from Ms. Petraeus that the 

CFPB has something like that working now? 

Ms. PETRAEUS. Of course, we do take consumer complaints and 

we do take consumer complaints about private student loans, and 

we also have a student loan ombudsman. So just based on that experience, we do have someone who is working very closely with the 

VA on how to help them tailor their efforts. And then we also have 

a suite of tools at consumerfinance.gov, our website. 

We developed a financial aid shopping sheet and then worked in 

concert with the Department of Education to get one that they 

were comfortable with that could be given to schools to use on a 

voluntary basis, and a number of them have adopted it, as well as 

the G.I. Bill calculator, which the VA is also—we are going to work 

with them so they can—— 

Senator COBURN. You have the G.I. Bill calculator already up? 

Ms. PETRAEUS. Yes, it is. 

Senator COBURN. So you cannot just hand that to them? 

Ms. PETRAEUS. The devil is in the details always. It sounds easy. 

As you said, it sounded easy when they were talking about their 

process. We are certainly working with them to share that information so they do not have to replicate. They do not have to start from 

scratch. 

Senator COBURN. Right. Mr. Coy, a recent report by the American Action Forum found that our Nation’s veterans are being overwhelmed by Federal paperwork. For example, a disabled veteran 

seeking health and educational benefits could encounter up to 49 

different forms, 49 different forms, more than—to fill those out, a 

minimum of 4 hours, $125 it cost. If you just do the income net 
29 

worth and employment statement, it has 40 questions, takes over 

an hour to complete, and you get 104,000 of those a year. 

What can Congress and the agencies do to cut down on the duplication and the requirements for our veterans? If you go through all 

49 forms, there is a terrible amount of redundancy, the same question asked in multiple forms. 

Mr. COY. I would agree that certainly the redundant forms are 

a challenge and we are taking that on head-first. General Hickey, 

the Under Secretary for Benefits, is approaching this in a transformative way, and her transformative plan looks at doing a number of different things. 

Internal to VA, we are establishing a central database for veterans. One would think that would be easy; it is certainly not and 

it is a challenge. In a benefits piece, the disability claim process is 

being automated with the Veterans Benefits Management System 

(VBMS). That is a paperless system that is now online at all 56 of 

our regional offices. 

Within education, we have a computer system that is called the 

Long-Term Solution. In that, we just launched automation of supplemental claims. Supplemental claims are those claims where people actually get paid their housing allowance and school. We are 

now averaging about 50 percent of all supplemental claims going 

through the system without being touched by human hands. 

What that has done is it has driven down our supplemental 

claim processing time from about 20 days to currently 5 days. By 

doing that, the original claims, which is where we look at a veteran’s eligibility for various programs, that has been reduced from 

40 to 50 days down to 17 currently. So we are attacking the automation front from about four or five different angles. 

But I would agree with you that the paper process that we have 

is being mitigated now with some of these automation systems. 

Senator COBURN. All right. Thank you. 

Chairman CARPER. Senator McCaskill. 

Senator MCCASKILL. I neglected last time to thank all of you for 

your public service. I think you have all served the public in various capacities, and I thank you all for that. 

Mrs. Petraeus or maybe Mr. Tarantino, do you get a sense that 

there is enough education—and maybe, Sergeant Pantzke, you 

could talk about this? It is one thing for there to be information 

if a veteran tries to seek it out. Are we making any effort, as people 

are leaving the service, as these benefits accrue to them, are we 

making sure our active becoming veteran population learns about. 

They have a Byzantine number of things they need to figure out, 

both from what is their status going to be, in terms of disabilities, 

which is another whole really difficult process. I am sure you could 

educate us about that, Sergeant Pantzke. I am sure. 

But are we making an effort as, for example, the National Guard 

come back, to actually educate these—our military and their families about some of these pitfalls that they need to be watching for? 

If they are not seeking it out, are they getting it anyway? 

Ms. PETRAEUS. I think there are a lot of folks attempting to see 

that they get that information. We did work with the Department 

of Defense and the VA. They revamped the Transition Assistance 

Program that Secretary Coy was talking about. We wrote the fi-
30 

nancial piece for that. So I think it is a vast improvement over 

what was provided to folks before when they were transitioning 

out. 

We are working on initiatives to talk to folks before they enter 

the military to give them a little bit of education so they are aware, 

if they enter with student loans, some of what they might do with 

that. I know the National Guard, when they come back from deployment, has what they call Yellow Ribbon events, not related to 

the government funded Yellow Ribbon for Education. But they also 

have a variety of folks come to those and provide information. 

Senator MCCASKILL. You know what I found in those, though? 

Everyone is so anxious to get to their families. They are not always 

listening as carefully as they might, maybe, in another setting, but 

I do not know. 

Ms. PETRAEUS. That is true. You are kind of standing between 

them and the gate sometimes. 

Senator MCCASKILL. That is exactly right. 

Ms. PETRAEUS. They do bring them back, often 30 days later to 

say, ‘‘OK, how is it going? Here is some more information.’’ 

Senator MCCASKILL. That is great. 

Ms. PETRAEUS. So I think there are a lot of initiatives. Different 

people are going to process the information better at different 

times, so we need to try to reach them at different moments. 

Senator MCCASKILL. Is there a reason, Commander Coy, that you 

could not just put a link over to the CFPB website up right now? 

I do not know about your organization, Mr. Tarantino, or any of the 

other Veterans Service Organizations (VSOs). Is there some ridiculous rule that says that you cannot put a link right now, if somebody went to the American Legion website or went to your website 

or went to the VA website that could not link over to the G.I. Bill 

calculator and all the things that they have online right now and 

available? 

Mr. COY. No, ma’am, there is not, the short answer. One of the 

first things that Holly mentioned to me is we had one of her staff 

members detailed to us to help us work through this, and the first 

thing she said to me is, You are not allowed to steal him. And so, 

the short answer is yes, we can do that link, but what we want to 

do is make sure, because there are some other things that we want 

to put in there, so we want to take, if you will, the bones of what 

they have and then bring it over to us and put some modifications 

on it. 

Senator MCCASKILL. Well, in the meantime, it seems to me that 

the link would be helpful. Do you all have the link on your website 

and can you put it up? 

Mr. TARANTINO. Well, Senator, actually IAVA created the G.I. 

Bill Calculator back in 2008 and, I think, it is still the most comprehensive one you can find and it is on the newgibill.org as well 

as tons of information that links to various sources. 

But I think we are kind of on step two before we have actually 

fixed step one. This whole thing starts with better consumer education, which was the focus of efforts last year by the President 

with his Executive Order, as well as H.R. 4052. We are still living 

in a world today where I can pull out my iPhone to go get lunch, 
31 

I can go on Yelp, and I can look at all the criteria based on my 

individual needs and figure out where to go have lunch. 

There is nothing. We are not even close to doing that for education, because the first thing you have to ask a veteran is, What 

do you want? 

Senator MCCASKILL. Right. 

Mr. TARANTINO. Do you want an English degree? Do you need to 

get a mechanical degree? Are you just going because you want to 

learn poetry and it is interesting to you? You have to start with 

that and then be able to give them tools to make good consumer 

choices based on those needs, and we are nowhere near that. I 

think we are getting there, but it is going to take some time before 

we have the data and the tools and the transparency to actually 

get there. 

Senator MCCASKILL. Yes, I agree with you. It does seem to be 

hard. Do all the VSOs have a G.I. Bill Calculator on their websites? 

Do you know? 

Mr. TARANTINO. As far as I know, we are the only one. 

Senator MCCASKILL. Yes. I think it would be good to reach out 

to them and see if we could—because, with all due respect, Commander Coy, I have heard a lot in my other life on the Armed Services Committee. There is a tendency of people in the military to 

want to do their own requirements. And we have seen some bad 

things happen when something is supposed to be joint, but every 

branch has their own requirements, and before you know it, you 

have a system that has taken twice as long and costs twice as 

much because everybody keeps tweaking their requirements as opposed to just going all in, in one system. 

We have seen this in IT over and over in the military. I do not 

probably need to tell any of you of the horror stories of IT in the 

military with every branch wanting their own requirements and 

not talking to each other. So the simpler we can make this for everybody to be on the same platform the better it would be. I do not 

begrudge you wanting to put additional things on, but I certainly 

would encourage you to use the work that has been done by either 

Mr. Tarantino’s group or CFPB. 

I thank you all for being here today. I learned a lot and, hopefully, we can work together so that there are not very many veterans that find themselves as frustrated by their educational opportunities as they have been by other parts of their recovery from 

a very, very difficult service to our Nation. Thank you. 

Chairman CARPER. Thank you, Senator McCaskill. I want to 

come back, if I could, Sergeant Pantzke, and just to ask you to, 

first of all, just share with us, if you would, a little bit about your 

life since your experience with the Art Institute. Just share with 

us what has happened in terms of education, employment, and so 

forth. 

Sergeant Pantzke. Of course, I did a lot of interviews hoping to 

effect a change of for-profits, deal with veterans of all eras. So what 

I did, after my very last interview, I went around my area that I 

live in to several photography studios, media, stuff like that, and 

I asked them, what would you rather have, a degree from a brickand-mortar or a degree from an online college? And every time, I 
32 

would say, 95 percent of them said they would rather have a degree from a brick-and-mortar traditional school. 

So, that really kind of cut my hopes down quite a bit. The thing 

is, with the Art Institute program, it was supposed to be a 2-year 

degree program, a bachelor of science in photography. My classes 

were 61⁄2 weeks long, two classes per 6 weeks. 

That was really condensed. I would have four to five assignments 

per class. So my days ran from 8 a.m. to 4 a.m. the next morning. 

I would only get 4 hours sleep and it would start all over again. 

And it was just tearing my family apart. 

So like I said, Ms. Morales had asked me—well, both my wife 

and my individual therapist told me, You need to quit, but I did 

not want to give up. I had that mentality of, do not surrender, keep 

driving forward, and I did not realize the pain that I was causing 

myself and my family. So it came to a head where actually I was 

in an auto accident on Easter Sunday in 2011. I had to withdraw 

from school for medical reasons because my right arm was messed 

up. 

So I had a lot of thinking during that time. I just had to withdraw because there was no—there was no way I could complete the 

degree program. And actually, I really did a lot of self-learning, I 

guess, through other Internet resources such as learnmyshot.com. 

There is a gentleman out in Oregon, I believe it is, and I do not 

remember his name, but he has got an eBook out called Photo Extremists, which I have been using and I have learned so much 

more from those two sources than I did my entire enrollment. 

Chairman CARPER. OK, thank you. Let me go back and let us 

talk, if we could, about sort of quality assurance at the front end 

for these institutions, whether they are for-profit, non-profit, private, but in terms of licensure, by whom, accreditation, by whom, 

the standards used across the different States, among different 

agencies, whether State or Federal. Commander Coy, can you talk 

a little bit about that? 

Mr. COY. Yes, sir, and I will ask Mr. Worley to also address that. 

In terms of the accreditation or approval process for schools at the 

VA, if you are a public school and already accredited, it is generally 

accepted as being deemed approved. 

Chairman CARPER. Accredited by? You said if you are already accredited, accredited by whom? 

Mr. COY. By a recognized accrediting agency. 

Chairman CARPER. Within a State? 

Mr. COY. Most of them are national. 

Chairman CARPER. OK. All right. 

Mr. COY. Rob, do you want to—— 

Mr. WORLEY. Recognized by an accreditation recognized nationally by the Department of Education. So this is under Public Law 

111–377, so public accredited institutions and private non-profit institutions are deemed approved if they are accredited by a recognized—nationally recognized accrediting agency. 

Chairman CARPER. Well, what I am trying to get at is the rigor 

of the accreditation or the rigor of the licensure process. Ms. 

Petraeus, do you have anything that you could share with us on 

that? 
33 

Ms. PETRAEUS. I am certainly not an expert in that area, but I 

would say simply that once it is accredited, then I believe the VA 

is obligated to, by law, to put that school on their list of a place 

where benefits can be spent, which to me really points out the importance of a rigorous accreditation process so you do not have 

schools that are able to accept that G.I. Bill and TA money and 

have very poor outcomes for their students. 

Chairman CARPER. Please, go ahead. 

Mr. COY. The accreditation process is a process that is run by the 

Department of Education, so I would defer any specific questions 

on the accreditation issue to them. 

Chairman CARPER. OK. Mr. Worley? 

Mr. WORLEY. If I could just add one more qualifier, that is for 

standard degree programs at those institutions. Some of those institutions provide—— 

Chairman CARPER. A standard degree program would be what, 

a 2-year degree, an associate’s degree, or a B.S., B.A.? 

Mr. WORLEY. Correct. 

Chairman CARPER. OK. Not a certificate program? 

Mr. WORLEY. There are non-college degree—programs offered at 

those institutions as well. Those have to go through a review and 

approval process by the State approving agencies. 

Chairman CARPER. All right. I think we are running out of time 

here and I think we have a vote underway. Does anybody know 

how much time is left? Five minutes? On the clock? Dr. Coburn, 

do you want to add anything else? 

Senator COBURN. No. I just wanted to thank Sergeant Pantzke 

for his service, and I have a query of you. I have read your testimony this morning early, and one of the things—I think one of the 

ways you solve problems is get all sides of the story, and I wonder 

if you would give the Committee a release so that we can get the 

information the school has on you? 

Sergeant Pantzke. Oh, definitely. 

Senator COBURN. So we can see the full story and see where the 

problems land. 

Sergeant Pantzke. Oh, definitely, though when Educating Sergeant Pantzke was released, the Vice President gave me a call from 

99 Division and asked me—well, actually, I am sorry. That was the 

wrong thing. They had mentioned that they had offered me extensive tutoring services. I did not receive one phone call or one email 

about those tutoring services. 

Senator COBURN. That is why I would like you to give us a release so we can have your information—— 

Sergeant Pantzke. Oh, yes, definitely. 

Senator COBURN [continuing]. So we can look at the whole side 

of it. I thank you very much for that. Thank you, Senator Carper. 

Chairman CARPER. You bet. Let me just close by using a term 

that we used a fair amount in the Navy and that is, all hands on 

deck and a call for general quarters when we were under attack. 

When a country is running a deficit of about $750 billion, we need 

all hands on deck. When we are looking down the road in another 

10 years or so, the deficit is going down, but it eventually is going 

to come right back up. So I say that is an all hands on deck. 
34 

When we have not just a handful of veterans but hundreds, probably thousands who have gone through the kind of experience not 

unlike what Sergeant Pantzke has explained and shared with us, 

it is all hands on deck. I am encouraged today that after several 

years of feeling that not a whole lot of attention or time or effort 

or energy was going into making sure that we are righting this 

wrong, I am encouraged that a good deal is being done. 

And part of it is being done by the VA and part of that effort 

is being led by the Department of Education. Part of it is being led 

by a new agency, the CFPB. Part of it is being led by the efforts 

that Congressman Gunderson talked about, and, frankly, some of 

our veterans organizations, particularly the one that is represented 

here today is part of the all hands on deck. 

Are we where we need to be in cleaning up this problem? No. I 

think as Congressman Gunderson said, as long as one veteran is 

being disadvantaged or taken advantage of, that is one too many. 

And unfortunately, it is not just one that is still being taken advantage of. It is not just one taxpayer, it is all of us. We have plenty 

of work to do. 

The driving force for me on the 90/10 Rule is that I find it abhorrent that the Federal Government is going to be paying 100 percent of any post-secondary schools’ revenues. I just do not get that. 

That makes no sense to me. And are there changes that could be 

made to the 90/10 Rule that we are talking about here? Yes. Can 

we improve on it? Yes, we can. 

I am interested in that being part of the all hands on deck and 

part of the, if you will, all the above kind of approach to solving 

this problem. For those of you who are working on it, for those of 

you who shared your life’s experiences with us to help better inform what we do going forward, I want to thank you. And while 

I think we are making progress, I like to say if it is not perfect, 

let us make it better. It is not perfect yet. I think it is getting better. 

With that, this hearing is almost adjourned, but we are going to 

announce that the hearing record will remain open for 15 days, 

that is until August 7, at 5pm, for the submission of statements 

and questions for the record. With that, we are adjourned. Thanks 

so much. 

[Whereupon, at 12:19 p.m., the Committee was adjourned.] 
(35) 

A P P E N D I X 

Opening Statement of Chairman Thomas R. Carper 

"The 90/10 Rule: Improving Educational Outcomes for our Military and Veterans" 

July 23, 2013 

As preparedfor delivery: 

Today's hearing focuses on the considerable investments taxpayers are making in providing high 

quality education benefits to our service members and veterans. In examining this issue, the 

committee is asking the question: are we getting the results taxpayers, service members and 

veterans deserve? 

The GI Bill helped me afford the cost of getting my MBA at the University of Delaware after I 

transitioned off of active duty in the US Navy near the end ofthe Vietnam War. While I was 

grateful for that financial support, those benefits pale in comparison to the considerable taxpayer 

investment that the new GI Bill makes in education for our service members and veterans. 

For years, through the service academies and through programs like ROTC and the GI Bill, 

we've sought to raise the skill levels ofthose who serve in our armed forces, as well as the skill 

levels ofthose who later return to civilian life. However, in 2008, it became clear to Congress 

that, after years of multiple tours of duty in Iraq and Afghanistan, our modem-day military 

needed a modem-day GI Bill to ease soldiers' transition into civilian work here at home. That's 

why we passed the Post-9lll GI Bill to help to help our modem day veterans afford the cost of 

college and put them on the path to getting a good paying job. The modem-day GI Bill pays for 

the tuition and housing costs of any member of the military who served more than 90 continuous 

days on active duty since September 10, 2001. 

Since it was enacted, $29.4 billion has been spent to send veterans back to school. In addition, 

the Department of Defense offers military service members the opportunity to pursue a high 

quality education through the Tuition Assistance Program. Service members and veterans taking 

advantage of the benefits available to them under the GI Bill are free to pursue the educational 

path of their choice. They can go to a public school like I did when I studied at the University of 

Delaware. They can also attend a private non-profit school or a for-profit school. 

However, recent reports show that many veterans have been SUbjected to highly questionable 

recruitment practices, deceptive marketing, and substandard education instruction in some of the 

schools they attend, particularly for-profit schools. Under current law, in order for a for-profit 

school to receive federal student aid from the Department of Education, the school must ensure 

that no more than 90 percent of its revenue comes from federal funding. The definition of federal 

funding that applies to this limit is not as straight forward as you may expect. It turns out that 

under current law, "federal funding" means only money that comes through the Department of 

Education. 

Other federal funds, such as GI BilI benefits that come from the Department of Veterans Affairs 

and military education benefits offered through the Department of Defense are excluded from the 

90 percent limit that makes up the federal share of a school's revenue. This means that a school 

that maxes out on its 90 percent limit can bring in federally funded military and veteran 
36 

education benefits in order to skirt this limit and in some cases get 100 percent of their funding 

from the federal government. 

As several reports have shown, this loophole has in some cases put a target on the backs of our 

military and veteran students. And then once students enroll they're often not obtaining the 

knowledge and skills they need to get a job that will enable them to earn a livable wage and good 

benefits. Clearly, the incentives at some for-profit schools are misaligned. These institutions are 

rewarded for enrolling more students--especially veterans with a fully-paid for education-but 

have too little incentive to make sure that their graduates are prepared to join the workforce and 

begin productive careers. 

Having said that, this is not an issue solely at for-profit schools. There are also many public and 

private non-profit colleges and universities that experience similar issues with extremely low 

degree completion rates, high default rates and a poor record of serving our veterans. And to be 

fair, there are also a number of for-profit institutions that offer a quality education and have a 

history of success with placing students in well-paying jobs. I believe we have a moral 

imperative to ensure that abusive practices--no matter where they occur--are stopped so those 

who have sacrificed for our country can obtain an education that will equip them with the skills 

they need to find a good job, repay any college loans they've taken out, and go on to live 

productive lives. 

Two years ago, I chaired two hearing on this issue in the Subcommittee on Federal Financial 

Management. Today I'm holding this hearing to learn what is being done by the Department of 

Veterans Affairs and others has done to protect our military and veteran students from the 

predatory practices of some bad actors in the for-profit industry. This hearing will also focus on 

what the association that represents for-profit schools has done to address concerns raised about 

the industry it represents. 

My goal for today's hearing is to learn how we can fix this problem by better incentivizing 

schools to deliver a higher quality education to our military and veteran population that will 

enable them to be successful in work and in life. We have a terrific group of witnesses here 

whom I will introduce momentarily. 1 look forward to a productive hearing and to learning more 

about this issue, but first let me tum to Dr. Coburn for any comments he would like to make. 

### 
37 

Opening Statement of Tom A. Coburn, M.D. 

"The 90/10 Rule: Improving Educational Outcomes for our Military and Veterans" 

July 23, 2013 

The cost of college has increased dramatically - even outstripping health care costs. 

We need to take a hard look at why this is occurring, and ask ourselves what is the appropriate 

role of the federal government in higher education. With the passage of the National Defense 

Education Act in 1958, the federal government began its foray into higher education. 

Not everyone agreed with this bill passage; some feared it would lead to federal intrusion into the 

halls of higher learning. For example, Senators Barry Goldwater and Strom Thurmond opposed, 

writing in dissent: "If adopted, the legislation will mark the inception of aid, supervision and 

ultimately control of higher education in this country by federal authorities." 

Fast forward to 2013, and prophecy is manifest. 

Higher education today is dramatically more expensive despite hundreds of billions offederal 

dollars being poured into the system - loans, Pell Grants, GI Bill benefits, research dollars, tax 

benefits and more. 

More money has brought federal interference. Washington seemingly wants to regulate 

everything - even what constitutes a "credit hour" - something that is fundamentally the job of 

colleges. 

There is a lot to be said about the larger topic of the current state of higher education. However, 

when it comes to the 90-10 Rule, it's arbitrary, and government engineering at its worst. 

Let's ask ourselves a few honest questions. 

If 90-1 0 is sound policy, why not apply this rule to all schools - regardless of control type? After 

all, graduation rates of many nonprofit schools around the country leave much to be desired. 

If 90-1 0 is sound policy, why not also apply it to all forms of federal aid - including university 

research dollars? 

And if this is sound policy, why stop at a 10 percent limitation? Why not lower the threshold? 

How about 50 percent applied to all schools, and all federal dollars? 

The truth is that 90-10 is the government picking winners and losers among colleges that have 

already proven themselves by being accredited, approved by State Approving Agencies and by 

complying with myriad forms of compliance. 

In closing, let me thank our witnesses for participating. I look forward to your insights, and hope 

at the end of the day we identify real problems and real solutions. 
38 

STATEMENT OF 

CURTIS L. COY 

DEPUTY UNDER SECRETARY FOR ECONOMIC OPPORTUNITY 

VETERANS BENEFITS ADMINISTRATION 

DEPARTMENT OF VETERANS AFFAIRS 

BEFORE THE 

SENATE HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS COMMITTEE 

July 23, 2013 

Good morning, Mr. Chairman, Ranking Member Coburn, and other Members of 

the Committee, I am pleased to be here today to discuss the Department of Veterans 

Affairs (VA) efforts to safeguard Veteran students from questionable practices by some 

institutions of higher education. I am accompanied today by Mr. Robert Worley, 

Director of VA's Education Service. 

My testimony today will address VA's efforts to implement the provisions of the 

Executive Order (EO) 13607, "Establishing Principles of Excellence for Educational 

Institutions Serving Service Members, Veterans, Spouses, and Other Family Members" 

and Public Law (P.L.) 112-249, "Improving Transparency of Education Opportunities Act 

of 2012," as they relate to ensuring VA's education benefits provide access to 

high-quality educational opportunities that will enhance beneficiaries' educational 

outcomes. The actions required by EO 13607 and P.L. 112-249 reaffirm our 

commitment to ensuring Servicemembers, Veterans, and their dependents are well-
39 

served by our educational programs. I will also provide general observations on the 

"90/10· rule regarding Federal funds used to finance higher education. 

Background 

The Post-9/11 GI Bill, enacted in 2008, is the most extensive educational 

assistance program authorized since the original GI Bill was signed into law in 1944. 

Just as the original GI Bill allowed Veterans to take their educational opportunities and 

leverage them for breakthroughs in automation, business, medicine, science, 

transportation, and technology, today's Post-9/11 GI Bill provides our Veterans with the 

tools that will help them contribute to an economically strong, vibrant, and resilient 

America. 

VA is committed to ensuring all Servicemembers, Veterans, and their family 

members, who may be eligible for this important benefit, receive a useful education 

without the burden of substantial student loan debt as they readjust to civilian life. 

As of July 9, 2013, VA has issued over $30 billion in Post-9/11 GI Bill benefit 

payments to approximately 992,000 individuals and their educational institutions. 

The 90/10 Rule 

Enacted in 1992 and amended most recently in 2008, the 90/10 rule in section 

487(a)(24) of the Higher Education Act of 1965 (HEA) requires institutions of higher 

education to have at least a defined minimum amount of revenues from sources other 

than the student aid programs in title IV of the HEA. Under the 90/10 rule, institutions 

may not receive more than 90 percent of their revenue from funds under title IV of the 

2 
40 

HEA. While VA defers to the Department of Education (ED) on the 90/10 calculation, 

there is an argument for including the Post-9/11 GI Bill in the 90 percent limit on Federal 

funding or related proposals. Under the present structure, some institutions may be 

marketing to Veterans because the Federal education benefits they receive are treated 

the same way as private funds in the 90/10 calculation. VA believes institutions should 

not aggressively recruit Veterans principally because offinancial motives. 

Modifications to the 90/10 rule could provide additional tools to assist VA and ED 

in monitoring and oversight, and could help to prevent aggressive targeting of Veteran 

students for financial reasons. However, including Post 9/11 GI Bill benefits in the 

90/10 calculation could cause some schools to exceed the 90 percent threshold and 

potentially lose their eligibility to participate in the Title IV or Post 9/11 GI Bill programs. 

In order to minimize adverse effects on Veterans, how this change is implemented is 

important and would require ED and VA to provide information about the amount of 

dollars from various Federal education benefit programs that flow to each higher 

education institution. VA would welcome the opportunity to work with ED and the 

Committee as it considers changes in this area. 

Oversight 

VA is aware of concerns raised regarding for-profit institutions and potential 

fraudulent activities. Under existing VA statutes, for-profit institutions are held to the 

same standards and criteria as non-profit institutions for the purpose of approval for use 

of VA education benefits. For example, the law requires all schools to maintain a 

complete record of all advertising, sales, and enrollment materials utilized within the last 

3 
41 

12 months. These materials are reviewed during compliance surveys to ensure that the 

institution has not engaged in erroneous, deceptive, or misleading enrollment practices. 

VA believes Veterans and their eligible dependents should be able to choose to use 

their education benefits at the academic institution - public, private non-profit, or private 

for-profit - that best meets their specific needs and is approved by the State Approving 

Agency (SAA) of jurisdiction. 

If a school is found to be non-compliant with one or more approval requirements, 

the SAA or VA Education Liaison Representative immediately attempts to make 

necessary corrections during site visits to the school. If additional time is needed, the 

SAA may suspend approval for up to 60 days. In this situation, current students 

continue to receive benefits, but the school is not permitted to certify new students. If 

the school does not provide a resolution or response, approval is withdrawn. Since 

fiscal year (FY) 2011, VA has withdrawn the approval of 9 schools for erroneous, 

deceptive, or misleading practices. 

VA will continue to provide oversight through compliance reviews and 

face-to-face interviews with Veterans. Additionally, section 203(d) of P.L. 111-377, 

expanded VA's authority to utilize SAAs for oversight of programs and institutions. VA 

began to use SAAs for compliance reviews under this authority in fiscal year (FY) 2012. 

In FY 2012, compliance surveys of 4,755 facilities with 350,603 students were 

completed; of those, 2,418 were for-profit facilities with 96,334 students. 

4 
42 

Executive Order 13607 

Issued by the President on April 27, 2012, EO 13607 directs VA, the Department 

of Defense (000), and ED, in consultation with the Department of Justice (DOJ) and the 

Consumer Financial Protection Bureau (CFPB), to develop and implement "Principles of 

Excellence" to strengthen oversight, enforcement, and accountability within Veteran and 

military educational benefit programs. 

These principles apply to educational institutions receiving funding from Federal 

military and Veterans educational benefit programs, including benefits provided under 

the Post-9/11 GI Bill. The principles will ensure that educational institutions provide 

meaningful information to Service members, Veterans, spouses, and other family 

members about the cost and quality of educational institutions. The principles will also 

assist prospective students in making choices about their Federal educational benefits; 

prevent abusive and deceptive recruiting practices that target the recipients of Federal 

military and Veterans' educational benefits; and ensure that educational institutions 

provide high-quality academic and student-support services to Servicemembers, 

Veterans, and their families. I am pleased to report that 6,325 campuses have 

voluntarily agreed to comply with the Principles of Excellence as of July 10, 2013. 

These institutions are listed on our GI Bill Web site (http://www.gibill.va.gov).VAis 

also developing a Comparison Tool/GI Bill Benefit Estimator that will enable prospective 

students to compare educational institutions using key measures of affordability and 

value through access to school performance information and consumer protection 

information. VA placed a link to ED's College Navigator on the eBenefits Web site in 

November 2012. ED's College Navigator is designed to help students find information 

5 
43 

about postsecondary institutions in the United States - such as programs offered, 

retention and graduation rates, prices, aid available, degrees awarded, campus safety, 

and accreditation. VA subsequently embedded ED's College Navigator into the GI Bill 

Web site in March 2013. As a long-term plan, VA will integrate data from ED's College 

Navigator with data from VA's Web-Enabled Approval Management System to calculate 

tuition and fees, monthly housing allowance, and books and supplies estimates. The 

tool will include indicators on graduation rates, retention rates, loan default rates, 

average student loan debts, Veteran population, Yellow Ribbon Program and Principles 

of Excellence participation, as well as an estimated cost of attendance. We anticipate 

this tool will be available on the GI Bill Web site and the eBenefits Web site by April 

2014. 

In addition, VA, 000, ED, CFPB, and DOJ are developing student-outcome 

measures that are comparable, to the extent practicable, across Federal educational 

programs and institutions. We have vetted a set of proposed measures with the 

Veterans Service Organizations (VSO), and school organizations, and received positive 

feedback. VA will begin collecting data elements from our stakeholders in August 2013. 

EO 13607 also requires VA and DoD, in consultation with ED, CFPB, and DOJ, 

to create a centralized complaint system for individuals to register complaints about 

particular educational institutions on topics such as student loans, quality of education, 

refund policies, and post-graduation job opportunities. Complaints will be received, 

processed, responded to, and ultimately transmitted to the Federal Trade Commission's 

(FTC) Sentinel database so that the information is available to other Federal agencies, 

law enforcement organizations, and SAAs. VA will review and triage all complaints 

6 
44 

received. Valid complaints will be sent to schools or employers for a response and to 

the FTC's Consumer Sentinel Network. 

Public Law 112·249 

P.L. 112-249, was enacted on January 10, 2013, and much of the new law 

overlaps and complements the work of EO 13607. P .L. 112-249 requires VA to develop 

a comprehensive policy to improve outreach and transparency to Veterans and 

Servicemembers through the provision of information on institutions of higher learning 

(IHL) and to implement online tools to facilitate the policy. The law also requires VA to 

develop a policy and plan for promoting Chapter 36 educational and vocational 

counseling to Veterans and recently separated members of the Armed Forces; develop 

a centralized mechanism for tracking and publishing feedback from students and SAAs 

regarding the quality of instruction, recruiting practices, and post-graduation 

employment placement of IHLs; and develop a policy and plan to disapprove any 

courses offered by an IHL that provides 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 or in 

making decisions regarding the award of student financial assistance. VA was also 

required to perform two market surveys related to academic readiness and 

commercially available off-the-shelf online comparison tools. 

To implement P.L. 112-249, VA is partnering with ED, 000, CFPB, and the 

National Association of State Approving Agencies. As required by this law, VA 

submitted a report to the Congress in April 2013 that included a description of the 

7 
45 

comprehensive policy, our plan to implement the policy, and the results of the market 

surveys conducted to determine the availability of commercially available off-the-shelf 

online tools. The full report is available on our GI Bill Web site. 

As a result of the market surveys, VA plans to pilot use of an online assessment 

tool called CareerScope® that allows a Veteran or Servicemember to assess whether 

he or she is ready to engage in postsecondary education and determine his or her likely 

vocational aptitude. VA conducted another market survey for an online tool that 

provides a Veteran or Servicemember with a list of providers of postsecondary 

education and training opportunities based on specific postsecondary education criteria 

selected by the individual. We discovered that many online tools provide much of the 

required information; however, none of the Web sites provide all the data required in the 

law. As a result, VA plans to build a tool that aggregates information from existing Web 

sites to provide all data, which will be hosted on the GI Bill and eBenefits Web sites. 

To promote Chapter 36 educational and vocational counseling (provided under 

38 United States Code (U.S.C.) § 3697A), VA will increase awareness and inform 

eligible participants about Chapter 36 counseling services, including how to determine 

an appropriate degree program and the education benefit program most appropriate for 

their individual circumstances. VA will facilitate applications for interested eligible 

participants as a part of the redesigned Transition Assistance Program (TAP) process. 

VA is also promoting Chapter 36 counseling services through the VetSuccess on 

Campus programs at more than 32 schools. In addition, we will provide information 

about Chapter 36 counseling services to our stakeholders, including other Federal 

agencies, VSOs, school certifying officials, SAAs, and other private-sector entities that 

8 
46 

provide information and guidance to Veterans and Servicemembers about VA 

educational benefit programs. Title 38, U.S.C., section 3697, currently appropriates 

payments not to exceed $6 million in any FY for contract vocational and educational 

counseling. VA submitted an FY 2014 legislative proposal to increase the amount to $7 

million. By FY 2014, VA expects a substantial increase in requests for these counseling 

services due to vocational assessments required for VA's collaboration with DoD's 

Integrated Disability Evaluation System, VetSuccess on Campus program, and the 

ongoing modernization of TAP in conjunction with the current military drawdown. 

P.L. 112-249 provides a process for acquiring the necessary information and the 

guidelines for communicating with IHLs. It also specifies that VA efforts should not 

duplicate the efforts being taken by other Federal agencies. It further specifies that 

VA's comprehensive policy must be consistent with the requirements and initiatives of 

EO 13607. 

The Cost of Postsecondary Education and the Increase in Non-college Degree 

Programs 

VA's focus, through implementation of the EO and P.L. 112-249, is to do 

everything possible to ensure Servicemembers, Veterans, and family members are 

informed consumers, so they pursue an approved program of education at the 

academic institution - public, private non-profit, or private for-profit - that best meets 

their specific needs and that results in good educational and professional outcomes and 

a smooth transition to civilian life. As part of the Veterans Opportunity to Work to Hire 

Heroes Act of 2011, which made TAP generally mandatory for all separating 

9 
47 

Servicemembers, VA worked with DoD and ED to redesign the curriculum. As part of 

the new Transition Goals, Plans, and Success (Transition GPS) curriculum, 

Servicemembers will receive pre-separation counseling and register for an eBenefits 

account. Transition GPS also has a new optional track, Accessing Higher Education, 

which provides information on education and/or training opportunities including VA 

education benefits. 

Conclusion 

Veterans' hard-earned educational benefits are the vehicle by which many of our 

Nation's heroes pursue their educational goals and successfully transition to civilian life. 

VA is dedicated to ensuring that Veterans are able to make well-informed decisions 

concerning the use of their benefits and receive a quality education. We look forward to 

working with the Committee and our Federal agency partners to provide the very best 

support possible to our Veterans and beneficiaries as they pursue their educational 

goals. Through further continuing interagency cooperation and student outreach, VA 

will ensure that Veterans are informed consumers and that schools meet their 

obligations in training this Nation's next "greatest generation." 

Mr. Chairman, this concludes my statement. I would be pleased to answer any 

questions you and other Members of the Committee may have. 

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48 

Hollister K. Petraeus 

Assistant Director, Office of Servicemember Affairs 

Consumer Financial Protection Bureau 

Testimony before 

U.S. Senate Committee on Homeland Security and Governmental Affairs 

July 23, 2013 

Chairman Carper, Ranking Member Coburn, and distinguished Members ofthe Committee, 

thank you for the opportunity to testify before you today concerning higher education for our 

nation's servicemembers and their families. As you know, the Dodd-Frank Wall Street Reform 

and Consumer Protection Act (Dodd-Frank Act), which was signed into law on July 21, 2010, 

established the Consumer Financial Protection Bureau (CFPB) as an independent bureau within 

the Federal Reserve System and charged it with ensuring that consumers have timely and 

understandable information to make responsible decisions about financial transactions. In 

addition, the law assigns my office, the Office of Servicemember Affairs (OSA), the 

responsibility to "educate and empower service members and their families to make better 

informed decisions regarding consumer financial products and services." I am happy to take part 

in a dialogue like today's hearing, to ensure that military families have all the information they 

need to make sound decisions about where and how they spend their military education dollars. 

The government has provided a number of benefit programs to assist servicemembers and, in 

some cases, their family members, to gain a post-secondary education. The largest and most 

significant are the GI Bill, which may be used mostly after military service in pursuit of a college 

or technical degree, and the Military Tuition Assistance (TA) program, which is designed to be 

used to take courses while on active duty. These are valuable benefits and I think we would all 

like to see them replicate the success story that happened after World War II, when a generation 

of veterans came home, went to college on the GI Bill, and became the engine that drove our 

economy to tremendous success. 

Holding at least a bachelor's degree is a "must" for many jobs in today's economy. And studies 

have shown that a college degree tremendously increases one's lifetime earnings potential. So 

we're seeing a new generation of servicemembers and veterans who are eager to earn advanced 

degrees, hoping to give themselves the best possible chance for success-both in the military and 

beyond. And many for-profit colleges are eager to enroll them as students, due in no small part 

to the "90-10 rule" created by the 1998 amendments to the Higher Education Act (HEA). Put 

simply, the 90-10 rule says that a for-profit college has to obtain at least 10 percent of its revenue 

from a source other than Title IV federal education funds. The rule has been explained as being 

necessary to ensure that a college does not exist solely on federal funds, but offers an education 

valuable enough that people are willing to pay for it through other means. 

Although TA and the GI Bill are certainly federally funded, they are not Title IV student aid 

funds administered by the Department of Education (ED), and that puts them squarely into the 
49 

JO-percent category of the 90-10 rule. This means that for every servicemember using T A or GI 

Bill funds (as well as the spouse or child of a servicemember, in the case of the Post 9-11 GI 

Bill) that a for-profit college recruits, the college can then go out and enroll nine other students 

who are using Title IV funds. And that can be a problem. . 

This has given some for-profit colleges an incentive to see servicemembers as nothing more than 

dollar signs in uniform, and to use some very unscrupulous marketing techniques to draw them 

in. To give some examples that I've heard in my travels around the country: 

An active-duty military spouse at Fort Campbell, Kentucky, told me that she was 

attending a "military-affiliated college" (she wasn't; it was a for-profit school with no 

official military status, but she had been given this impression by the recruiter). After she 

filled out an interest form she was called multiple times per day until she enrolled. But 

when she had trouble logging on to her online class, she couldn't get anyone from the 

college to help her. She failed the class due to lack of access, but was charged the full fee 

anyway. 

National Guard education officers in Ohio and North Carolina told me they are besieged 

by for-profit colleges desiring access to the troops. They noted that if one of their 

National Guard units holds a job fair, over half the tables may be for-profit colleges, and 

that servicemembers may see a school's presence at ajob fair as an implied promise that 

you will get a job if you graduate from that school. 

In Nevada, I spoke with a woman from the V A Regional Office who was overseeing 

vocational rehabilitation for veterans. She told me that she had patients with traumatic 

brain injury (TBI) and post-traumatic stress disorder (PTSD) who had been persuaded to 

sign up for classes at for-profit colleges, and didn't even remember doing so. That didn't 

stop the colleges from pressing them for full payment, even though they were not 

regularly attending classes. She said that some of the schools were also pushing her 

patients to enroll in master's degree programs even though they were not capable of 

doing the work. Their tactics were aggressive enough that she described it as 

"tormenting veterans." 

At loint Base McGuire-Dix-Lakehurst in New lersey, I discovered that a military spouse 

who was employed by a for-profit college had a regular standing appointment at the 

Wounded Warrior barracks to provide educational counseling - the only college rep with 

that access. 

The overall cost to the government of the GI Bill and TA has soared in recent years. According 

to VA records, while the number of individuals using Department of Veterans Affairs (VA) 

education benefits has roughly doubled since 1998 - from less than 500,000 recipients to nearly 

I million- the monetary cost has grown ten-fold, rising from less than one billion to nearly ten 

and a half billion dollars.1 And the cost ofTA has also grown exponentially, on what I have 

heard described as an unsustainable upward trajectory, with for-profit colleges taking an 

increasing share of those TA dollars. In 2011, for-profit colleges collected one of every two T A 

dollars, totaling $280 million of the $563 million disbursed during the year. This is an 8% 

1 This information was provided by The Department of Veteran Affairs. 

2 
50 

increase over 2009, when for-profit schools collected 42% of the $515 million in TA funds 

disbursed? 

If the TA benefit is cut back at a future date and servicemembers are asked to pay a greater share 

of the cost of courses taken under the TA program, it's possible that colleges may encourage 

servicemembers to "top up" the costs by using their GI Bill benefits, or by using other loans to 

fill the gap. And with the 90-10 rule as it now stands, it would be in the financial interest of a 

for-profit college to drive service members not to a Title IV loan, but instead to the school's own 

private student loan arrangement - even though it is likely to be more expensive - in order to 

keep those revenues in the ten percent category for purposes of the 90-10 rule. 

According to a study in 2012 by the Senate Committee on Health, Education, Labor & Pensions 

(HELP), for-profit schools spend a substantial amount of money on marketing: 23% oftheir 

revenue in the case of the schools studied by the HELP Committee. One effective way to market 

to the current generation of students is online, and there have been concerns about leadgeneration websites with URLs or names that use "GI Bill" or "Military" in their titles in order to 

market to servicemembers. Although some presented themselves as offering unbiased, helpful 

advice on GI Bill benefits, they actually served to direct visitors to the limited list of schools that 

were funding the site. We showed one such site, GlBill.com, to the Attorney General of 

Kentucky during a visit to Fort Campbell, and he was joined by 19 other AGs in pursuing a case 

against the site's owner, Quin Street, that led to substantial changes to that company's websites, 

monetary damages, and the agreement to tum over the URL GlBill.com to the VA. 

Subsequently, the VA copyrighted the term "GI Bill" in an effort to prevent future such abuses. 

And when I searched "GI Bill schools" recently on Google, I was pleased to see that the majority 

of the first-page results now lead directly to the VA. 

The OSA, Congress, and the state Attorneys General are certainly not the only ones to take an 

interest in how military education benefits are being used. President Obama has taken 

extraordinary steps to address the issue, as well. In April 2012, I watched him sign Executive 

Order 13607, "Establishing Principles of Excellence for Educational Institutions Serving Service 

Members, Veterans, Spouses, and Other Family Members" and since then, the CFPB has been 

working in concert with the VA, Department of Defense (DoD), ED and the Department of 

Justice (DOJ) to implement its provisions. 

As part of those efforts, the VA, DoD and ED are poised to launch a centralized complaint 

system for students receiving military tuition assistance and GI Bill benefits, so they can register 

complaints about educational institutions that fail to follow the Principles. Now that 

servicemembers, veterans, and family members will have a centralized place to share their 

stories and seek resolution to their issues, J believe we will have a clearer picture of what is 

happening on the ground. And I challenge schools to be ready to start resolving these complaints 

as they come in. 

Another requirement of the President's Executive Order is for ED, in consultation with DoD and 

the V A, to collect from schools information about the amount of funding those schools are 

2 http://www.help.senate.gov/imo/medialfor profit report/PartJ-Partlll-SelectedAppendixes.pdf. 

3 
51 

receiving from the Post-9f11 GI Bill and T A programs. Previous efforts to collect and analyze 

this type of data did not succeed because the VA and DoD's lists of approved programs did not 

sync with ED's lists of schools. But now ED, 000 and the V A are working on a data crosswalk 

that links ED's database of schools (over 7,000 institutes of higher learning) to the VA's lists of 

approved programs (over 30,000). The data crosswalk will allow the VA and ED to share data 

about schools across agencies, improve consumer information available to beneficiaries, and 

allow V A to track outcome measures that compare education benefit programs. 

The crosswalk will also allow policymakers to accurately assess which schools would be in 

danger of violating the 90-10 rule if military and veterans' education benefits were included in 

the calculation. 

OSA is certainly not the only, or even the primary, office at the CFPB interested in these issues. 

CFPB has an Office for Students led by our Student Loan Ombudsman. He has reported to 

Congress on student loan issues, and has raised concerns about both the amount of student loan 

debt being carried by Americans, and problems servicing those student loans. Under his 

leadership, CFPB has developed a suite of products for the Bureau's website, 

consumerfinance.gov, intended to help individuals identify useful information about student loan 

issues. And in partnership with ED, we've developed a financial aid shopping sheet to improve 

the way schools communicate financial aid offers. Colleges and universities could use this 

shopping sheet to help students better understand the type and amount of grants and loans they 

qualify for. The shopping sheet could also be used to help students easily compare aid packages 

offered by different institutions. As of July 11,2013, over 750 schools3 have adopted it for all of 

their students and over 6,220 campuses4 have agreed to offer the shopping sheet to students 

receiving federal military and veterans educational benefits. 

As part ofCFPB's Paying for College suite of tools, we built the federal government's only 

online GI Bill benefits calculator. CFPB's GI Bill calculator informs veterans and their family 

members what their Post-9f11 GI Bill benefits are worth at different educational institutions. As 

part of the President's Executive Order, the VA is also working to build a GI Bill benefits 

calculator and is leveraging CFPB's existing tool to develop their calculator. 

CFPB's Office for Students also partnered with my office to produce a report on the servicing of 

military student loans, an area where we are seeing troubling similarities to the mortgageservicing crisis of recent years. For example, borrowers may have trouble finding out who 

currently owns their loan, which may have been securitized and sold. As our report indicates, 

student loan holders are facing a number of challenges, including an inability to get timely and 

accurate answers to their questions or have corrections made to their account when an error is 

3 http://www2.ed.gov/policylhighered/guid/aid-offer/shopping-sheet-institutions.xls. 

4 http://gihill.va.gov/resources/education resources/Principles of excellence/poe Jist 2012.hlm!. 

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52 

made by the lender. Our reportS also raised concerns that student loan repayment benefits for 

military service can be complex, confusing, and even conflicting with one another.6 

In conclusion, there are some very worthwhile efforts underway to improve the ability of 

military personnel, veterans and their families to learn more about the schools where they may 

choose to spend their hard-earned education benefits. However, it seems prudent for Congress to 

examine whether the 90-10 rule in its current form is a sensible framework, given the significant 

increase in the number of veterans receiving benefits under the Post-91l1 01 Bill. As long as the 

90-10 rule adds a significant extra incentive for for-profit colleges to enroll military students, this 

concern will remain. 

Although there may be some for-profit colleges with solid academic credentials and a history of 

success for their graduates, some for-profit colleges have low graduation rates and a poor gainful 

employment history.7 They also tend to have a higher-than-average student loan default rate, 

which can be an indicator that students are being recruited with little concern for their ability to 

do the coursework, graduate, and repay their loans. Although the Association of Private Sector 

Colleges and Universities recently convened a "blue-ribbon" task force to make 

recommendations for best practices for military and veteran students, one of the recommended 

best practices was simply that schools "consider ... assess(ing) academic readiness prior to 

enrollment," which indicates that there is still plenty of room for improvement. 8 

For veterans, the 01 Bill should provide the opportunity to build a better future. We all want our 

veterans to become successful, productive contributors to our society. Education can be the key 

to that success, and the wonderful education benefits provided to our military and their families 

through TA and the 01 Bill should not be channeled to programs that do not promote and may 

even frustrate - this outcome. 

Thank you for the opportunity to testify before the Committee. 

5 Consumer Financial Protection Bureau: The Next Front? (2012). See 

http://www.consumerfinance.gov/reports/the-next-front-student-Ioan-servicing-and-the-cost-to-our-men-andwomen-in-uniform!. 

6 For example, the Federal Perkins Loan provides for principaJ reduction for certain service in an ~'area of hostility." 

However, to take advantage of Public Service Loan Forgiveness, the servicemember must convert the Perkins Loan 

into a Direct Consolidation Loan. This new Direct Consolidation Loan may not qualify for the Servicemembers 

Civil Relief Act rate cap. Members of the Judge Advocate General corps have shared with the CFPB that this 

process is very challenging. 

7 http://www.help.senate.gov/imo/medialfor profit reportlPartl-PartIIl-SelectedAppendixes.pdf (see 55 n.158, 73, 

120-121). 

8 Association of Private Sector Colleges and Universities, Best Practices/or Military and Veteran Students,Pg. 6, 

Issued Feb. 2013, available at http://www.apscu.orglpolicy-and-issues/federal-issues/rnilitary-veteransed/upload/MVBP-Brochure Feb20 I 3.pdf. 

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WRITTEN TESTIMONY OF STEVE GUNDERSON 

PRESIDENT AND CEO 

THE ASSOCIATION OF PRIVATE SECTOR COLLEGES AND UNIVERSITIES 

Before the 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

July 23, 2013 

Chairman Carper, Ranking Member Coburn, and members of the committee, I would like to thank you for 

the opportunity to appear before this committee and for holding this important hearing on Improving 

Educational Outcomes for our Military and Veterans. 

I am here to represent the member institutions of The Association of Private Sector Colleges and 

Universities, their faculty and the nearly four million students who attend our institutions. Our institutions 

provide a full range of higher education programs to students seeking career-focused education. We 

provide short-term certificate and diploma programs, two- and four-year associate and baccalaureate 

degree programs, as well as a small number of master's and doctorate programs. We educate students for 

careers in over 200 occupational fields including information technology; allied health; automotive repair; 

business administration; commercial art; and culinary and hospitality management. 

APSCU and our member institutions want to ensure that our students are well-prepared to enter the 

workforce and that every institution of higher education lives up to the high standards expected by our 

students. Private sector colleges and universities have a long and important relationship with our nation's 

military and veteran students. We celebrate who they are and what they do. Our actions as educators of 

military and veteran students honors this partnership by providing our military and veteran students with 

the best possible educational experience at our institutions. 

According to the latest data obtained by APSCU from the Department of Defense, 762 private sector 

colleges and universities (PSCUs) have been approved to offer courses to active duty military. The 

Department of Veterans Affairs reports that more than 325,000 veterans and their families have been 

served by our institutions using their post 9/11-G1 benefits. Although veterans make up less than 10 

percent of our students, we are proud to serve those who choose our institutions. More than 1,200 of our 

institutions participate in the Yellow Ribbon Program and a majority of those impose no limits on the 

number of eligible students while providing the maximum institutional contribution. 

Why do veterans and active duty military choose to attend our institutions? Quite simply, the answer lies 

in our customer service. We understand the challenges that arise when our military men and women 

transition back to civilian life and enter into postsecondary education. Often, traditional institutions of 

higher education are not the best fit. Our military and veteran students are not the fresh-out-of-high school, 

first-time, full-time student living on campus and attending college thanks to the generosity offamily. Our 

military and veteran students are like many of our new traditional students - working, with a spouse and 

children and paying for their education with money they have saved. 
54 

Service members and veterans attend our institutions because we design courses to be relevant, 

concentrated, and suited to the personal goals of our students. This education foundation is of a particular 

benefit to military and veterans seeking a promotion, advance in rank or supplementing skills attained 

during their service. This type of purposeful, tailored education ensures that veteran and military students 

nimbly move from the classroom onto their next academic or professional goal. The ability to offer 

courses on-base, online, and on the student's schedule is of tremendous value. Because of our longer 

school days and year-round academic programming, our students can often complete an associate's degree 

in 18 months or a bachelor's degree in just over three years. 

We share your commitment to ensuring that every postsecondary institution provides the highest level of 

service to each and every student, especially active duty military, veterans and their families. We take 

great pride that our institutions are designing and delivering education in ways that meet the needs of 

today's military and veteran students. We strive to ensure that all students receive the education they 

deserve. 

Our Veteran Students 

We offer veteran students who are juggling work, school and family a more efficient approach to 

completing their careers by offering flexible schedules, focused academics and accelerated programs so 

that they may more expeditiously begin their careers. 

Because the Integrated Postsecondary Education Data System (IPEDS) does not count anyone but firsttime, full-time students in their database, no one has an accurate source of data on veterans, or other nontraditional students attending our schools. Earlier this year we surveyed several member institutions and 

looked at 16,500 veteran graduates. We can share with you the following description of the veterans 

enrolled in our schools: 

24% are single parents; 

Over 50% attend part-time; 

• Nearly 80% are 25 years of age or older and almost all of them are living independent of their 

parents; 

Over 33% are female; 

46% have dependents; 

29% are African American; and 

12% percent are Hispanic. 

PSCUs are providing skills that put Americans back to work. Today, in America, there is a very real skills 

gap that is impeding job creation and economic growth. Our institutions are working to bridge this gap by 

combining postsecondary education and career skills in ways that equip veteran students with workplace 

skills. 

Of veteran graduates, 75 percent earned certificates and associates degrees while 25 percent earned 

bachelor's and graduate degrees. 

Forty percent of all the veteran graduates earned credentials in healthcare fields, one of the fastest growing 

industries in the country. These occupations range from medical, dental and veterinary assistants to nurses 

and technologists of various types with weighted average annual median salaries of$33,000 for certificate 

and associate degree holders to $56,000 for bachelor and graduate degree holders. 

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Another 20 percent of veteran graduates earned credentials in skilled trade programs, such as construction, 

maintenance and repair, and engineering technologies. According to the U.S. Bureau of Labor Statistics, 

the United States will need more than I million additional workers to fill these jobs by 2020. The 

weighted average annual median salary for graduates earning their certificates and associate degrees in 

these fields was $44,000. 

Ten percent of veteran graduates earned awards in computer and information programs like computer 

programming, computer graphics, computer systems networking, and information technology. The 

weighted average annual median salary is $57,000 for certificate and associate degree holders and $89,000 

for bachelor and graduate degree holders. The US will need nearly 3 million additional computer and IT 

workers by 2020. 

We want to work with you to provide our service members and veterans, particularly young combat 

veterans, with the tools and resources to make an informed, thoughtful decision about which educational 

opportunity will best prepare them for the workforce. 

Access to Postsecondary Education 

During the recent economic downturn when states and local communities reduced education budgets, 

many of our colleagues at public institutions had to endure budget cuts reSUlting in limited access and 

service for students. But our institutions continued to invest in their schools to offer students industryleading innovation while expanding capacity and meeting the evolving demands of employers. Because 

we are not dependent on brick-and-mortar facilities to expand access, we are able to meet the growing 

demand for postsecondary education through vastly expanding online technology offerings, and perhaps 

our most successful academic delivery - a blend of online and on-site programs. 

Even while investing in education programs, our schools have been successful in reducing the cost of 

attendance for our students. Recently, the U.S. Department of Education released an analysis that 

compares the average costs at institutions between 2010-2011 and 2012-2013. Only our institutions 

experienced a reduction in the average costs by - 2.2 percent; other sectors experienced an increase in 

costs, with public in-state cost increasing 6.7 percent, public out-of-state increasing 4.1 percent and private 

non-profit rising 3.1 percent. For two-year institutions, our schools were able to reduce costs to students 

by 0.2 percent, while public in-state cost increased 6.4 percent, public out-of-state increased 3.9 percent 

and private non-profit rose 1.8 percent. Unlike our public colleagues, we don't have differing rates of 

tuition for in-state versus out-of-state students. 

Just as important as the cost of attendance to students is the spending on instruction by institutions of 

higher education. According to the latest U.S. Department of Education data, instruction expenses as a 

percent oftota! expenses is 32 percent for public institutions, 33 percent for private non-profit and 27 

percent for our institutions. Considering our institutions have fewer tenured and research faculty, our 

spending on instruction is very comparable to our postsecondary peers. 

On the subject of marketing and student recruitment, our institutions seldom recruit students through high 

school guidance counselors because most of our students have been out of school for some time. We 

cannot count on hundreds of years of history or an NCAA sports team to get oumames known. As a result, 

we do advertise and depend substantially on word-of-mouth referrals. As we have discussed today, many 

of our students are new traditional students who cannot be reached through a high school guidance 

counselor. The average school will only enroll lout of a 100 initial inquiries. As a result, we must raise 

awareness of our institutions as viable postsecondary education options. According to financial analyst 

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reports, the per student cost of enrollment does not differ that much among the institutions of higher 

education. According to the National Association for College Admissions Counseling (NACAC) 2011 

report, the mean cost per enrolled student was $2,407.73 ($987.01 public, and $3,042.52 private nonprofit.) This compares to a median of $3,858 for seven ofthe 15 publicly-traded PSCU for FY 20 II. 

We've expanded educational opportunities for many people, as evidenced by the increasing number of 

degrees our institutions have awarded. Yes, much of this is the simple result that our sector of 

postsecondary education is probably the newest with new campuses and forms of academic delivery. But 

in an era when we expect 65 percent of all jobs and 85 percent of all new jobs to require some level of 

postsecondary education this growth in access is important. Between 2008 and 2012, while the country 

was deep in recession, our institutions prepared 3.5 million adults with the education and skills essential 

for real jobs, real incomes and a real chance at America's middle class. 

Our institutions experienced a higher growth in degrees awarded than all others between 201012011 and 

201l/2012. Degrees conferred by our institutions increased 8.6 percent compared to 5.2 percent by public 

and 3.2 percent by private nonprofits. According to Bureau of Labor Statistics data, the degrees and 

certificates awarded by our institutions are in some of the fastest-growing occupations nationwide. For 

example, in 20 I 0120 II we awarded 52 percent of all Dental Assistant Certificates, 50 percent of all 

Veterinary Technologists and Technicians Associate Degrees and 40 percent of all Diagnostic Medical 

Sonographers Associates Degrees. Without our students, employers in these fields would be unable to find 

the well-trained staff they need to deliver services to patients and customers. 

Importance of Postsecondary Education for Military Students 

As an all-volunteer force, during a period of prolonged conflict, effective recruitment, retention and 

morale initiatives are essential to attracting and retaining professional personnel. More importantly, 

service members have taken their ambitions and turned them into reality by taking classes and earning 

degrees, diplomas and certificates. 

Sergeant 1st Class James Wallace who is stationed at Ft. Knox Kentucky, and is attending Sullivan 

University, wrote to me recently about how pursuing his education at Sullivan University has helped him 

apply to become a Warrant Officer. He strongly believes that pursuing an education while in the military 

is a great tool no matter if the soldier is going to make a career out of the military or serve one enlistment. 

Another student, Staff Sergeant Thomas M. Windley wrote that he began attending ECPI University in the 

summer of2004 as a veteran recently discharged from service in the U.S. Navy, "Several months after 

enrolling with ECPI, I enlisted in the U.S. Army. During my attendance at ECPI, I was appointed System 

Administrator for my unit because of my knowledge of computer systems." 

"I was able to complete my degree program and obtain an associate's degree in Network Security within 

18 months. In 2007, I earned another Associate's degree in electrical engineering. It was at this point in 

my military career that my civilian education assisted me in being promoted over my peers. In 2010, 1 

worked on a network installation team and within three months [earned my CompTIA A+, Network+, and 

Security + certifications due largely to my education, experience, and opportunity that ECP[ provided 

me," 

"In 2010, my military assignment took me overseas to Afghanistan. While deployed, I earned my 

bachelor's degree in Computer Information Science with a concentration in Network Security. Earning my 

degree led to another promotion, which was due to the tools and benefits ECPI provided in the areas of 

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57 

leadership, professionalism, and core curriculum content. I have been tasked, since my promotion, with 

training others in my unit both below and above me in rank, to sit for certifications, thus far those I have 

trained have a 100 percent pass record. I would highly recommend this program to fellow service 

members, I believe ECPI to have the best customer service of any online school and I have attended 

several. Furthermore, the curriculum is very precise and concentrated in the areas most needed to perform 

the job at maximum proficiency." 

Whether we are talking about Sergeant First Class James Wallace, Staff Sergeant Thomas M. Windley or 

an Army Major working on her Master's degree for career advancement, these men and women know 

what they want and are committed to getting it. Their service coupled with their commitment to getting an 

education is truly extraordinary. 

APSCU Best Practices For Military And Veteran Students 

In recognition of the growing numbers of military and veteran students enrolling at our institutions, 

APSCU adopted Five Tenets of Veteran Education that included the creation of a Blue Ribbon Taskforce 

for Military and Veteran Education. The Taskforce was comprised ofa broad group ofindividuals who 

share a common commitment towards the education of service members and veterans representing a 

diverse range of institutions, including non-APSCU members, as well as representatives of nationallyrecognized leadership organizations in the area of military and veteran postsecondary education. The 

Taskforce was specifically charged with identifying, collecting, and documenting practices and programs 

that meet the unique needs of military and veteran students, on the road toward their academic and 

professional goals. 

I have attached a copy of these Best Practices to this testimony, so I won't discuss them in detail, but I 

would just highlight the four major topic areas addressed by the Taskforce. (I) Consumer information, 

enrollment and recruitment makes clear that information should be provided in clear and understandable 

language and that no student should be subjected to aggressive or misleading recruiting practices. (2) 

Institutional commitment to provide military and veteran student support identifies initiatives related to 

personnel and faculty designed to help employees understand the special needs of military and veteran 

students. It also identifies institutional policies aimed at assisting military and veteran students such as 

participating in the Yellow Ribbon program, offering a reduced military tuition rate, maximizing the use 

of military training credit recommended by ACE, or exceeding the standards of the Uniformed Services 

Employment and Re-Employment Act for deployed employees. (3) Promising practices for ensuring 

military and veteran student success through student services discusses the need for student centers and 

partnerships, such as establishing a Student Veterans of America chapter or having a military and veterans 

lounge where students can meet and find peer to peer support. (4) Establish institutional research 

guidelines for tracking military and veteran student success encourages the collection and use of data to 

improve programs and evaluate program effectiveness. We are encouraging all our institutions and our 

colleagues at other institutions of higher education to look at these Best Practices and find opportunities to 

implement them where appropriate in order to best serve our military and veteran students. 

A 20 I 0 study by the Rand Corporation and American Council of Education (ACE) entitled "Military 

Veterans' Experiences Using the Post 9111 GI Bill and Pursuing Postsecondary Education reported 

findings which support the view that our institutions are working to support these students. The report 

noted the following: 

Rate of satisfaction with the credit transfer experience was 60 percent among survey respondents 

who had attempted to transfer military credits to our institutions, versus only 27 percent among 

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58 

those from community colleges and 40 percent among respondents from public four-year colleges. 

Only participants from private nonprofit colleges reported higher credit transfer satisfaction rates, 

at 82 percent; 

Respondents from our institutions reported fewer challenges to accessing required courses than all 

other institutions except for four-year public institutions (33percent of respondents at public twoyear colleges, 26 percent at private nonprofits, 22 percent at our institutions and 18 percent at 

public colleges). 

• Survey respondents in private sector colleges and universities reported higher than average 

satisfaction rates with academic advising, at 67 percent, versus about 50 percent satisfaction among 

respondents at other institution types. 

Reasons for choosing our institutions included: career oriented programs with flexible schedules, 

like-minded adult students, flexible credit transfer rules and same institution in multiple locations. 

Serving Military and Veteran Students 

Many PSCUs offer a reduced military tuition rate for active duty, National Guard, and reserve service 

members and their spouses to minimize out-of-pocket student expenses and offer scholarships to wounded 

service members and their spouses as they recover from their injuries and prepare for new career 

opportunities. Some also maintain a military-friendly deployment policy, which allows military students to 

withdraw and return to school at any time if they are deployed and provide specialized military student 

advisors to evaluate past military training and experience and assess eligible academic transfer of credit 

based on ACE recommendations. The generous awarding of credit for military skills and experience and 

fair transfer of credit policies exemplify how PSCUs strive to be responsible stewards of this educational 

benefit, as exiting service members are not forced to take duplicative or extraneous classes. 

This gives rise to the important issue of transfer of credits between institutions of postsecondary education. 

Students, both traditional and new traditional, routinely transfer to new institutions, enroll in classes at 

more than one institution concurrently, and take courses online, in person, and within new competencybased leaming models. We now see the majority of postsecondary students attend more than one 

institution before completing their education. When students transfer, they often face the nerve-wracking 

and uncertain task of having credits accepted by the new institution. All too often, institutions will simply 

not accept credits earned at an institution accredited by a different organization, especially when the 

sending institution is nationally and not regionally accredited. As students transfer, the rejection of credits 

they have earned costs them in terms of time - needing to retake classes and delayed entry into the 

workforce - and money - in the form of additional loans and grants. APSCU encourages this Committee, 

and the Congress, to examine policies that facilitate credit transfer so that completion is not delayed and 

extra debt amassed as a result of repeating coursework, especially when it comes to helping our active 

duty military and veterans continue and complete their postsecondary education. 

Recent Bureau of Labor Statistics (BLS) data suggest that the unemployment situation of our nation's 

veterans is improving, particularly in the 18-24 age category that has historically experienced higher 

unemployment than civilians. The Administration, veteran advocates, and veteran service organizations 

(VSOs) have responded by developing and implementing initiatives to put veterans in jobs. 

The American Legion has partnered with DoD to educate state legislators and governors on the actual 

value of military skills and experience and how they translate into a civilian employment environment. 

6 
59 

Additionally, the American Legion is serving as an advocate for changing current state laws to enable 

credentialing and/or licensing boards to consider military skills and experience when evaluating a 

candidate for a license or certification. The American Legion has also partnered with the Administration 

and the Departments of Defense, Energy, Labor, and Veterans Affairs to evaluate the current job-task 

analysis UTA), identify any gaps in the JT A, and work with the private sector and postsecondary 

education institutions to best address how to fill the gaps through higher education, on-the-job-training, or 

apprenticeships. This initiative relies on the symbiotic relationship between credentialing, higher 

education, public and private entities to proactively work together to reduce veteran unemployment. 

When members of the armed forces separate from their service, they enter a pivotal transition period that 

is often wrought with challenges, and as a result, the potential for failure is high. As we have discussed, 

our institutions are fully committed to helping veterans achieve success in higher education. This 

commitment and focus on educating members of the military, as well as veterans and their families is 

critical because according to the Defense Activity for Non-Traditional Education Support (DANTES) over 

80 percent of members have only a high school diploma. 

Addressing the Skills Gap and Building the Middle Class 

Our nation currently faces twin crises - stubbornly high unemployment and a skills gap where employers 

all across the country cannot find trained and job-ready workers. The key to narrowing the skills gap and 

reducing civilian and veteran unemployment is an "all-hands-on-deck" approach to postsecondary 

education. All sectors of higher education must be part of the solution and accountable for the educational 

experience and outcomes of all students, especially military and veteran-students. 

The facts are simple: Career-oriented schools are educating America's next generation and helping secure 

our nation's economic vitality. We all agree that a higher education degree greatly improves employment 

opportunities and income. At a time of extended, high unemployment and economic hardship, we should 

be supporting anyone seeking access to skills and training that will allow them to better their own future. 

President Obama has challenged all Americans to commit to at least one year or more of higher education 

or career training, under the belief that if we are to succeed economically as a nation, every American will 

need to get more than a high school diploma. To meet President Obama's challenge we will have to ensure 

that people who historically have not pursued higher education or succeeded in completing their 

postsecondary education attend and complete their education. From both a jobs and a global 

competitiveness standpoint, our institutions can help fill the existing education and skills gap and meet 

capacity demands that cannot be satisfied by public and private non-profit colleges alone. Increasing the 

number of educated people is essential. Research shows that raising the college graduate rate just a single 

point will unleash $124 billion per year in economic impact on the 51 largest metropolitan areas in the 

U.S. 

We share President Obama's commitment and passion for education, and look forward to working with 

him and the Congress to ensure that all Americans can attain the skills they need to access meaningful 

opportunities. 

There is an ongoing conversation in higher education and Congress about the post-9111 GI Bill, as well as 

issues like 90/10. I would like to comment specifically on 901l O. But I would like to do so in the context 

of to day's student veterans attending our schools, and the skill demands of these future workers. 

7 
60 

The postsecondary federal loan and grant programs were created to allow Americans who cannot afford to 

pay for college on their own to have access to college with the help of the federal government. 

Unfortunately, the 90/10 Rule encourages institutions to not enroll students most in need of postsecondary 

education simply because they use the federal funds made available by the government. 

The 90/1 0 Rule is not a measure of institutional quality. It is a financial calculation that is a measure of the 

socioeconomic position of the student population served by an institution. An institution that is close to 

the 90 percent threshold is enrolling low-income students in need of postsecondary education. The 

government should be encouraging this behavior, rather than penalizing institutions serving a majority of 

low-income students. This metric undercuts the very reason we have loan and grant programs. 

Further, across the country, public institutions like community colleges have reached capacity and simply 

cannot meet the demand for postsecondary education. Imposing changes that make 90/10 more punitive 

endangers student access and choice. It may also require institutions to deny an individual not based on 

their qualifications, but rather for their method of payment. Such denial would significantly interfere with 

the individual's right to select the institution that best fits their needs. 

As mentioned earlier, our recent survey shows that 75% of the student veterans attending our schools are 

enrolled in certificate or AA degree programs. This is higher than the 68% of all students attending our 

schools pursuing similar degrees. This is critically important because a June 2013 study by The 

Georgetown Center for Education and the Workforce shows that between 2010 and 2020 the American job 

market will grow its demand for workers with these very skills (certificates and AA programs) by 9 

million. Our veterans have chosen the right career paths. But if we take steps to limit their access to the 

schools providing these programs we will deny them the education, the skills and the jobs they deserve. 

Private sector colleges and universities have demonstrated a unique capability to confront the challenges 

of educating America's middle class. We have been at the forefront of the effort to close the skills gap by 

offering career-focused training aiding business owners seeking workers with specific training and 

expertise. We have made it our mission to close this gap and are working every day to achieve that end. 

We take seriously the charge to work with veteran and military student populations and prepare America's 

students to succeed in the workforce. Private sector colleges and universities look forward to helping these 

students achieve their dreams, maintain military readiness and prepare them for life after the military. 

Thank you for your time. I look forward to answering your questions and discussing these important issues 

with you today. 

8 
61 

BEST PRACTICES FOR 

MILITARY AND 

VETERAN STUDENTS 

FEBRUARY 2013 
62 

MISSION STATEMENT 

The Association of Private Sector Co lieges and Universities (APSCU) has 

established this "Blue Ribbon" Taskforce to ensure that every service member, 

veteran. and famiiy member utilizing their earned, postsecondary education 

benefits are provided with the quality education to which they are entitled at every 

institution of higher education. The Taskforce is comprised of a broad group of 

individuals who share a common commitment towards the education of service 

members and veterans representing a diverse range of institutions, including nonAPSCU members, as weli as representatives of nationally-recognized leadership 

organizations in the area of military and veteran postsecondary education. 

The Taskforce has been specifically charged with identifying, discussing, and 

documenting the very best postsecondary education practices and support 

services that meet the specific needs of military and veteran students. The 

primary objective of the Taskforce is to puNish a set of recommended institutional 

standards and associated operational practices that foster persistence, program 

completion, and other factors that will enable the military and veteran student 

population to achieve its academic and professional goals. The final product will 

represent a condensed, practical set of suggested actions and poliCies for all 

institutions of higher education. 

Ribbo 

visit \> 

APseu BLl'E RIBHON 
63 

MEMBERS OF THE APSCU BLUE RIBBON 

TASKFORCE FOR MILITARY AND 

VETERAN EDUCATION 

The Taskforce has been led by JaR Cropsey, Vice President for Strategic Initiatives at 

Grantham University and Chair, Public Affairs, Council of College and Military 

Educators and James Hendrickson, Vice President of Military Relations at Colorado 

Technical University and Executive Director of the CTU Wounded Warrior and 

Spouse Scholarship Program. 

Other Members of the Taskforce indude: 

JeN Arthur - CIO and Vice President of Financial Assistance, ECPI University 

, Mlke"l1; - General Manager, Military Student Initiatives, Education 

Corporation of America 

Scott A. Kilgore -Senior Vice President of Military of Affairs, Kaplan 

University 

IUII811 Kltchner, Ph.D. - Vice President for Regulatory and Governmental 

Relations, American Public University System 

Scott D. Palumbo, LCDI. USNI - formerly National Director of Military 

Affairs, DeVry University 

Jamal Shane, Jr., 8G. USA (let.) - Director of Military and Veterans 

Affairs, Sullivan University 

Kathy Snead - Servicemembers Opportunity Colleges Consortium President 

and Vice President for Military and Veteran Partnerships, American 

Association of State Colleges and Universities 

Dennis Trlnlde, Ph.D. - Provost and Chief Academic Officer, Harrison 

College 

Joseph W. Wescott, Ph.D. - Executive Director, Veterans and Military 

Education Programs, North Carolina State Approving Agency and Vice 

President, National Association of State Approving Agencies 

Garland H. Williams, Ph.D., Col. USA (let.) - Associate Regional Vice 

President. Military Division, University of Phoenix 

Special AdYisors: 

Michael Dakduk - Executive Director, Student Veterans of 

America 

Ryan M. Galluccl- Deputy Director, National Legislative Service, 

Veterans of Foreign Wars of the U.S. 

Sten Gonzalez- Assistant Director, National Economic Division, 

American Legion 

APSCU BLUE RIBBON 
64 

BEST PRACTICES FOR MILITARY 

AND VETERAN STUDENTS 

PREAMBLE 

These Best Practices represent the collective efforts of the work of the Blue 

Ribbon Taskforce. The institutions represented on the Taskforce are incredibly 

diverse in size, ownership structures and academic programming and provide 

career-centered education ranging from skilled trades to post graduate degrees. 

However diverse, these Best Practices were created to encourage all institutions 

of higher education to aspire to high levels of service for this special 

group of students. 

The Best Practices are organized under four subject areas: 

Full transparency and accuracy of information in the recruitment and 

enrollment process. 

Institutional commitment supporting the military and veteran students' 

academic needs. 

Appropriate student services reflectingthe numbers and needs of their 

military and veteran student population. 

Pursuit of outcomes data related to retention, degree completion and other 

metrrcs for an institution's military and veteran students, enabling us to 

learn and improve our services in the future. 

The Tashforce IS mindful that the diverSity of Institutions - in size, number of 

veterans and/or military students. types of academic programming, and otiler 

factors will result in implementation of many, but not necessarily all the Best 

Practices, in ways appropriate to the needs of each institution and its military and 

veteran students. We recognize and celebrate this diversity of service while being 

unified in our commitment to excellence in military and veteran education. 

APSCU BU'E RIBBON 
65 

BEST PRACTICES FOR MILITARY AND VETERAN STUDENTS 

I. Consumer Information, Enrollment and Recruitment .page 4 

II. Institutional Commitment to Provide Military and Veteran 

Student Support...page 7 

[I!. Promising Practices for Ensuring Military and Veteran Student 

Success Through Student Services ... page 9 

IV. Establish Institutional Research Guidelines for Tracking Military 

and Veteran Student Success ... page 11 

CONSU\~I~R INFORMATION. ENROLLMENT 

AND RFlkiUITMENT: 

Prospective military and veteran students should receive appropriate, 

relevant information in order to make a sound, informed decision about 

their postsecondary education. Information should be provided in clear and 

understandable language. Prospective students looking to utilize their U.s. 

Department of Defense (000) or U.S. Department of Veterans Affairs (VA) 

education benefits should not be the subject of aggressive or misleading recruiting 

practices. Institutions should follow all federal and state laws and regulations to 

ensure that the recruitment of military and veteran students is appropriate. 

A. ConsulIler fl1JiJrmalion 

i. Provide accurate and complete information to prospective students on: 

Institutional and programmatic accreditation status for each 

offered program; 

Whether program meets minimum requirements to qualify student for 

state licensure in relevant occupation(s); 

Potential earnlllgs and employment pathways of 

program completers; 

Financial obligations and cost of educational program; 

Institution participation in various military and veteran programs and 

partnerships; and 

Institution transfer of credit policies. 

Ii. Require prospective students to affirm receipt and understanding of the 

required disclosures. 

APSCU BUIE RIBBON 
66 

iii. In an effort to achieve complete transparency. include information in 

catalogs. websites. and other media outlets that adheres to the 

following minimums: 

Clearly articulated and defined mission statement; 

Clearly defined academic and financial information about program 

requirements; and 

Total cost of admission. tuition. instructional materials. and all 

ma ndatory fees. 

iv. Provide in-depth financial counseling. so that prospective students fully 

understand their financial obligations upon enrolling in an educational 

program. 

Explain the extent to which DoD Tuition Assistance and VA education 

benefits will pay for the cost of the education; 

Explain the ramifications of student loan debt. in terms of monthly 

repayment obligations when feasible; 

Explain long term financial obligations related to use of educational 

benefits as compared to borrowing under federal or private loan 

programs; and 

Always encourage responsible borrowing if a student needs or 

chooses to borrow to pay for education costs or other personal 

expenses which may be covered by federal loan funds. 

B. Recruitmenr 

i. Develop and/or maintain enrollment and recruitment policies appropriate 

to higher education institutions and compliant with federal and accrediting 

agency regulations. 

ii. Use only promotional and recruitment materials and practices that do 

not have the capacity to mislead or coerce students into enrolling and 

are consistent with policies of the VA. Federal Trade Commission (FTC). 

Department of Education (ED). and all applicable federal and state 

regulations. 

iii. Create reasonable internal policies for contacting potential students that do 

not exert high pressure to enroll through unsolicited follow-up calls or other 

forms of personal contact. 

For example: 

Marketing and outreach systems. including third-party vendors. must 

have an opt-out feature for individuals who do not wish continued 

recruiting contact; and 

Establish and enforce internal call limits on unsolicited recruiting 

calls, such as a "Three Calls then Stop" policy. 

iv. Employ appropriate sanctions, including termination of employment. on 

recruiters and managers found to have engaged in predatory recruitment 

practices. 

i\PSCU BL{lf: RIBBON 
67 

C. Flll'Oiilllelli 

i. Ensure students are appropriately placed and prepared for the programs 

in which they enroll. Consider employing any of the following practices: 

(a) assess academic readiness prior to enrollment; (b) offer appropriate 

remediation if necessary; (c) offer limited course loads; (d) offer a 

reasonable "Trial Period" for enrollment; (e) offer penalty-free drop/add 

periods upon enrollment. 

ii. Offer military and veteran students a tailored orientation program, which 

would provide an overview of specific information regarding VA certification 

requirements, satisfactory academic progress, and additional tutorial 

assistance. as appropriate. 

APSCLJ BUIE RIBBON 
68 

INSTI 

VETE 

'IONAL COMMITMENT TO PROVIDE MILITARY AND 

STUDENT SUPPORT 

Institutions should actively support and promote programs and services for 

military and veteran students, Institutions should employ an engaged faculty that 

understands the needs of military and veteran students and provides mentoring 

and advising to ensure the success of these students, Institutions should 

consider instituting the following, as applicable: 

A. Personne{/F(lculty 

L Appoint a senior-level administrator to lead the institution's military and 

veteran support programs (or Office of Military and Veteran Affairs), 

ii, Designate an employee, or team of employees (as student enrollment 

numbers dictate), to provide support/services tailored to the needs of the 

military and veteran students, 

iii. Appoint a Military and/or Veteran Student Ombudsman to escalate and 

resolve issues related, but not limited. to DoD or VA educational benefits, 

academic enrollment issues, and institutional policies and procedures. 

iv. 

v, 

vi. 

vii. 

Conduct regular roundtable discussions, focus groups, and/or interviews 

with service-member military and student veteran organizations, either oncampus or virtually, to establish a continual understanding about the needs 

of the military and veteran student population enrolled at the institution and 

how to meet those needs, 

Appoint an interdepartmental military and veteran education taskforce to 

evaluate the institution's policies, practices and procedures relating to the 

military and veteran students. 

Institute faculty development training to ensure that faculty members: 

Receive the necessary tools and information regarding the unique 

qualities of the military and veteran learner; 

Learn effective classroom instructional practices to better meet the 

needs of this non-traditional student population; and 

Understand the various support services available to military and 

veteran students and the associated referral processes for accessing 

those services. 

Institute campus wide training on the specific needs and resources 

available for military and veteran students and their families. 

APseu BLUE RIBBON 
69 

R. Administrative folicies (/nd fmc/iet's 

i. If applicable, become a Yellow Ribbon Program participating institution, 

offsetting the unmet cost of an education for eligible VA education 

beneficiaries and consider the following: 

ii. 

iii. 

iv. 

v. 

vi. 

vii. 

viii. 

Allow "all" or an unlimited number of eligible veteran students 

to enroll; and 

Offer the maximum Institution contribution allowed under 

the program. 

Offer alternative grants to veterans and their spouses who may not be 

eligible for the Post-gill GI Bill benefits to cover any funding gaps not 

covered by other financial aid benefits, such as the Montgomery GI Bill. 

Offer a reduced military tuition rate for active duty, National Guard, and 

reserve service members and their spouses to minimize out-of-pocket 

student expenses beyond what DoD Tuition Assistance (TA) benefits cover. 

Adopt a policy for evaluating and awarding credit for military training and 

experiences, maximizing the use of military training credit recommended by 

the American Council on Education (ACE). 

Comply with eXisting federal requirements related to the postsecondary 

education of military or veteran students, including: 

Enter into the DoD Memorandum of Understanding (MOU) 

for partiCipation in TA; and 

Formally agree to accept the Principles of Excellence outlined In 

Executive Order 13607 - Establishing Principles of Excellence for 

Educational Institutions Serving Service Members, Veterans, Spouses, 

and Other Family Members. 

Become a member of the Service members Opportunity Colleges 

(SOC) Consortium. 

EstabliSh Human Resources policies that exceed the standards set by the 

Uniformed Services Employment and Re-Employment Rights Act (USERRA). 

Institutions of higher education with employees currently serving in the 

military should exceed USERRA guidelines for employees during military 

training activities and deployment status. 

Offer multiple learning formats for military and veteran students to access 

and interact with program curriculum and course materials, which allow 

students the freedom to pick the format that best suits their learning style. 

These formats may include videos, text, a library of archived audio content 

of classroom instruction, problem-solving activities. and practice tests. 

APSCU BIXI': RIBBON 
70 

G PRACTICES FOR ENSURING MILITARY AND 

V· STUDENT SUCCESS THROUGH 

STUDENT SERVICES 

Recent studies and anecdotal information related to military and veteran student 

success reveal a growing trend toward centralized student services at institutions 

with significant populations of military and veteran students. Building on the 

success of existing programs, institutions of higher education should strive to 

provide the following services and programs tailored to the specific needs of their 

military and veteran students: 

A. Centers 

i. When the number of students necessitates its creation, institutions should 

establish an Office of Military and Veterans Affairs with clearly articulated 

goals and expectations, which complement the mission of the institution, 

accompanied by the full support and resources from the institution's 

leadership. The Office of Military and Veterans Affairs would typically 

administer and manage the following: 

Military and veteran-specific Student Advisors in the areas of 

admissions, academics, and benefits; 

Specific academic counselors for the military and veteran student 

population trained to address transfer credit and awards for prior 

academic or military credit (College Level Examination Program 

(CLEP), portfolio, military training); 

Trained VA certification specialists to assist with the timely processing 

of educational benefits documentation to avoid benefit funding 

delays; and 

A tailored orientation program for military and veteran students, 

developed to enable active-duty, Guard, or Reservist students or 

transitioning veterans to optimize the available institution resources 

and support programs. 

ii. Another approach is to establish a Military Student Center (MSC), which 

acts as a hub to guide military and veteran students throughout their 

postsecondary experience, beginning with recruitment and ending with 

job placement. The MSC functions as a clearinghouse of information for 

all military and veteran benefit programs and assists potential and current 

students with navigating the intricacies of the federal programs for which 

they may be eligible. More specifically, the MSC may function as follows: 

Counsel prospective students who self-identify themselves as militaryor veteran-affiliated on the best way to access and maximize the 

benefits for which they are eligible; 

Staff the MSC with specialists who are either a military veteran or 

spouse who received specific training in DoD and VA benefits eligibility 

and processes; and 

APSCU BLUE RIBBON 
71 

Provide transfer of credit assistance, help with military and priorcollege transcript requests upon application and acceptance to a 

program of study, training to Program Directors and Deans regarding 

ACE guidelines for the award of military credit, and recommendations 

for credit acceptance based on review of military transcripts and 

Military Occupational Specialty (MOS). 

n, Parmerships 

i. Support student veterans interested in organizing a campus-based, or 

online. student organization with necessary resources and use the Student 

Veterans of America (SVA) as a resource and guide. Institutional support 

for student veterans to create a student veteran organization or club is 

critical to fostering successful veteran student transition. peer support, 

and camaraderie, and providing needed opportunities for student veterans 

to network and make social connections with other student veterans who 

possess similar interests or experiences. 

ii. Establish a Campus Military and Veterans Lounge or Virtual Student 

Gathering Place, which allow military and veteran students to interact, 

access program-related resources and services, and provide peer-to-peer 

support. 

iii. Establish and maintain student chapters of professional organizations 

and academic honor societies to expose students to potential professional 

networks. Encourage student membership and participation in relevant 

local, regional or national professional societies while completing 

coursework. 

iv. Introduce and partner with established veteran service organizations, such 

as the American Legion or Veterans for Foreign Wars of the U.S. (VFW), 

within the geographical area of the campus to further connect veteran 

students to community resources and peers. 

v. Institutions with a sufficiently large military and veteran population should 

develop a specific career services strategy, including: 

Establishing partnerships with employers who will work with students 

while enrolled and offer quality job opportunities upon graduation; 

Establishing formal alumni networks for military and veteran 

graduates, allowing students who have completed programs of study 

to interact with one another, building geographically based or industrybased professional networks; and 

Engaging with local Employer Support for Guard and Reserves (ESGR), 

professional associations such as Society for Human Resources 

Management (SHRM), or the National Association of Colleges and 

Employers (NACE). 

APSCU BLUE RIBBON 
72 

II INSTITUTIONAL RESEARCH GUIDELINES 

ING MILITARY AND VETERAN 

SUCCESS 

Tracking data related to credit completion, degree completion, and student 

satisfaction is vital to understanding successful student outcomes. Accurate data 

collection is essential to understanding and addressing the needs of military and 

veteran students and their families. To the extent practicable, institutions should: 

A. Collect/Use Dam 

i. Identify and track military and veteran student populations with regard to 

retention, degree completion, persistence, and other valuable metrics. 

ii. Analyze and use data to identify areas in need of improvement and ways to 

better serve military and veteran students. 

iii. Use data to develop measures to evaluate program effectiveness. 

B. Xational Student Clearinghollse 

i. Participate in the National Student Clearinghouse to help to provide 

meaningful data for military and veteran students across higher education 

(transfer, degree completion, and persistence). 

ii. Provide meaningful data to the VA and 000 for use in developing programs 

to better serve military and veteran students. 

APSCU BLUE RIBBON 
73 

APPENDIX 

APPENDIX I: INSTITUnON RESOURCES 

i. Supportive Education for the Returning Veteran (SERV) 

ii. Veteran-Civilian Dialogue 

iii. Veterans in Transition Course 

iv. Military to Civilian Transition Manual 

v. Mobile National Test Center (NTC) for CLEP and DSST exams 

vi. Transfer credit evaluation at no cost - awards transfer credit for ACE 

approved military training 

vii. Webinar series for veterans and employers of veterans 

viii. Institution Skills Translator 

ix. ACE Toolkit for Veteran Friendly Institutions, March 2012 

APPENDIX II, COMMUNITY INtnATIVES AND PARTNERSHIPS 

i. Veteran Stand Down (KCMO) - volunteer annually 

ii. Toys for Tots - collect toys annually 

iii. Partners with Veterans Today Network to hire veteran employees 

iv. Teamed up with CCME Cares to send care packages to deployed troops 

over Valentine's Day 

v. Fundraising for Wounded Warrior Project over Veterans Day 

vi. Annual sponsor of KC Association of the United States Army's Army 

Birthday Ball 

APPENDIX III: MEMBERSHIPS AND AFFiliATIONS 

I. 

ii. 

iii. 

iv. 

v. 

SOC 

CCME 

Yellow Ribbon Program 

DoD MOU 

Principles of Excellence 

APPENDIX IV, PUBLICATIONS 

i. From Boots to Books: Applying Scholssberg's Transition Model to the 

Transition of Today's American Veterans to Higher Education 

ii. From Combat to Campus: VOices of Student-Veterans 

iii. A New Generation of Student Veterans: A Pilot Study 

iv. The Difficult Transition from Military to Civilian Life 

v. Veterans' Post-Secondary Education: Keeping the Promise to 

Those Who Serve 

vi. Servicemembers Opportunity Colleges (SOC) Consortium Publications/ 

Forms/Resources (Principles and Criteria, Standards of Good Practice for 

Servicemembers Opportunity Colleges. Pocket Guide for College Outreach 

to Military Students, Veteran and Military Family Programs and Services, 

and Military Student Bill of Rights) 

vii. Educational Attainment: Tracking the Academic Success of Servicemembers 

and Veterans, July 2012, Education Working Group convened by SOC 

APSCU BLlJE RIBBON 
74 

viii. From Soldier to Student II Assessing Campus Programs for Veterans and 

Service Members, July 2012, prepared by American Council on Education 

(ACE), American Association of State Colleges and Universities (AASCU), 

NASPA: Student Affairs Administrators in Higher Education, and National 

Association of Veteran's Program Administrators (NAPVA) 

ix. Time is the enemy, September 2011, Complete College America 

x. Service Members in School: Military Veterans' Experiences Using the 

Post-9/ll GI Bill and Pursuing Postsecondary Education, November 2010, 

prepared by the RAND Corporation, with support from Lumina Foundation 

for Education for the American Council on Education (ACE) 

xi. National Survey of Student Engagement (NSSE), Major Differences: 

Examining Student Engagement by Field of Study, Annual Results 2010, 

sponsored by The Carnegie Foundation for the Advancement of Teaching. 

xii. Military Service Members and Veterans in Higher Education: What the 

New GI Bill May Mean for Postsecondary Institutions, July 2009, prepared 

by Alexandria Walton Radford, MPR Associates, Inc. with support from the 

ACE Center for Policy Analysis Center for Lifelong Learning and the Lumina 

Foundation for Education 

xiii. From Soldier to Student: Easing the Transition of Service Members on 

Campus, July 2009, prepared by ACE, SOC, AASCU, NASPA: Student Affairs 

Administrators in Higher Education, and NAPVA with support from the 

Lumina Foundation for Education 

/lPseu BLUE RIBBON 
75 

SPECIAL ADVISORS 

American legion 

The American Legion was chartered by Congress in 1919 as a patriotic veteran's 

organization. Focusing on service to veterans, service members and communities, 

the Legion evolved from a group of war-weary veterans of World War I into one 

of the most influential nonprofit groups in the United States. Today, membership 

stands at over 2.4 million in 14,000 posts worldwide. The posts are organized into 

55 departments: one each for the 50 states, along with the District of Columbia, 

Puerto Rico, France, Mexico and the Philippines. The birth of the Servicemen's 

Readjustment Act of 1944, known informally as the GI Bill of Rights, was a law 

that included several key parts: educational opportunity; on-the-job training; 

unemployment benefits; home. farm and business loans; review of discharges; 

health care; disability claims and veteran employment services. Today. the 

American Legion continues to work with all stakeholders in protecting and creating 

meaningful veterans education benefits that truly meet the needs of our 21st 

century veterans. 

Student Veterans of America (SVA) 

The mission of SVA is to provide military veterans with the resources. support, 

and advocacy needed to succeed in higher education and following graduation. 

Today's veterans face numerous obstacles in their path to attaining a college 

degree. These challenges range from a missing sense of camaraderie to 

feeling like an outsider amongst 18 year old traditional students to a lack of 

understanding by university faculty. When coupled with the visible and invisible 

wounds of war, a college degree can be an elusive goal for men and women 

returning from military service. SVA makes that goal a reality. SVA is a coalition of 

student veterans groups on college campuses around the globe. These member 

chapters are the "boots on the ground" that help veterans reintegrate into campus 

life and succeed academically. Each chapter must be an officially recognized 

student group by their university or college and provide a peer-to-peer network 

for veterans who are attending the school. Additionally, chapters often coordinate 

campus activities. provide pre-professional networking, and generally provide a 

touchstone for student veterans in higher education. 

Veterans of Foreign Wars of the U,S, (VfW) 

Since 1899, the VFW has continued to be a leading voice in veterans' advocacy, 

helping to enact nearly every major Quality of Life initiative for the benefit of every 

generation of veteran, military service member and their families. Composed 

of 2 million VFW and Auxiliary members in 7,200 VFW Posts across the country 

and around the world. the VFW creates, protects and enhances these benefits 

and programs by actively engaging with Congress and the White House. From the 

passage of the original World War II GI Bill of Rights in 1944 to the Montgomery 

GI Bill and now Post-9/ll GI Bill. the VFW will continue to advocate for studentveterans to improve their earned educational benefits and the consumer product 

information they deserve to receive. 

APseu RUlE RIBBON 
76 
77 

IRAQ AND AFGHANISTAN 

VETERANS OF AMERICA 

Statement of Tom Tarantino 

Chief Policy Officer, Iraq & Afghanistan Veterans Of America 

before the 

Senate Committee on Homeland Security & Governmental Affairs 

July 23, 2013 

Chairman Carper, Ranking Member Coburn, and Distinguished Members of the Committee: 

On behalf of Iraq and Afghanistan Veterans of America (lAVA), I would like to extend our gratitude for 

being given the opportunity to share with you our views and recommendations regarding this important 

issue that affects the lives of thousands of service members and veterans. 

lAVA is the nation's first and largest nonprofit, nonpartisan organization for veterans of the wars in Iraq 

and Afghanistan and their supporters. Founded in 2004, our mission is critically important but simpleto improve the lives of Iraq and Afghanistan veterans and their families. With a steadily growing base of 

nearly 270,000 members and supporters, we strive to help create a society that honors and supports 

veterans of all generations. 

In partnership with other military and veteran service organizations, lAVA worked tirelessly to see that 

the Post-9/11 GI Bill was passed because we understand how valuable a meaningful education can be 

to service members and veterans. lAVA will continue to fight to protect the GI Bill and work to support 

legislation that establishes a robust consumer education program in order to ensure that there is some 

measure of accountability in this industry. We must act now to ensure that veterans are able to safely 

use their GI Bill to receive the kind of quality training that will help them realize their full potential. 

In 1944, Congress passed the Servicemen's Readjustment Act. Lawmakers of the WWII era viewed 

this policy not as a handout to veterans, but as an investment in the future of the nation. Now, 

generations removed from the initial iteration of what is commonly referred to as the GI Bill, the benefits 

of this initial investment in America's 'Greatest Generation' are still being felt. 

The GI Bill is arguably one of the most successful government investment programs in our nation's 

history, doubling the number of degrees awarded by colleges and universities from 1940 to 1950, and 

resulting in a five-fold increase in the percentage of Americans with bachelor's degrees from 1945-95' . 

It is estimated that for every dollar invested in America's veterans through the GI Bill, the government 

took in $7 in tax revenue, which illustrates not only the success of the policy specifically for the men 

and women who served their country with distinction and honor in its hour of need, but the successful 

impact this thoughtful policy had on the nation in general. 

1 "100 Documents that Shaped America". Servicemen's Readjustment Act {1944}. U.S, News and World Report. 

http://www.usnews.com!usnews/documentsjdocpages/document_page76.htm 

Page 1 of 3 
78 

Statement of Tom Tarantino 

Chief Policy Officer, lAVA 

Tuesday, July 23, 2013 

Page 2 of 3 

In 2008, Congress passed a new GI Bill that took into account the realities of our modern higher 

education system in order to better serve Post-9/11 service members and veterans. Over 800,000 post9/11 veterans have utilized the educational benefits they earned during their terms of service to the 

nation under the Post-9/11 GI Bill program. 

When applied effectively, these funds can mean the difference between a veteran who struggles with 

the transition from military to civilian life and a veteran who is able to extend the leadership abilities 

attained in the military to the classroom and beyond. It is essential that the benefits our nation's service 

members and veterans have earned are protected, not only for the benefit of these heroes, but for the 

benefit of the country as well. 

The proposed reforms seek to make educational institutions accountable to free market principles by 

counting Post-9/11 GI Bill funds as government sourced funds under the 90-10 rule. The predecessor 

to the 90/10 rule was the 85/15 rule, which mandated that educational institutions maintain an 85%-

15% veteran-to-civilian student ratio. With the dramatic decrease in the student veteran population that 

occurred over the past 65 years, the development of a new formula became necessary. Rather than 

focusing solely on a head-count of service members and veterans enrolled at educational institutions, 

the 90/10 rule says that no more 90% of revenue for a school can come from governrnent funds, and at 

least 10% must come from private sources, giving the government another avenue through which to 

ensure that educational institutions are providing service members and veterans with a quality product. 

The intent of Congress with regard to each of these rules was not only to decrease instances of fraud 

and predatory targeting of veterans by educational institutions, but also to ensure that these institutions 

provided a quality product to students by making them accountable to free market forces. 

Unfortunately, due to a loophole in the law, military and veterans benefits are counted as part of the 

10% of revenue that is supposed to come from private sources. This puts a target on every veteran's 

back. Every veteran that a for-profit school recruits is worth nine more students using federal financial 

aid. 

The problem is that the Post-9/11 GI Bill did not exist when the 90/10 rule was put in place, and 

Congress has yet to update this rule to include Post-9/11 GI Bill funds in its language. This means that 

Post-9/11 GI Bill funds are not counted as government sourced funds for the purpose of the 90/10 rule. 

However, the tuition payrnents associated with the Post-9/11 GI Bill are paid directly to educational 

institutions by the Department of Veterans Affairs (VA), and these payments are indeed taxpayer 

funded. As such, these funds should absolutely be considered governrnent funds, because they 

unquestionably are. 

The goal of the proposed reforms is not to penalize educational institutions, but to ensure that 

America's veterans are receiving a quality education that will help them transition successfully from 

military to civilian life. Unfortunately, as a result of the actions of some bad actors in the systern, this 

transition is being made more difficult for too many of our nation's veterans. 

One lAVA mernber, Maggie Crawford, expressed frustration with for-profit schools on lAVA's Defend 

the New GI Bill webpage. After serving a tour of duty in Afghanistan, Maggie, a member of the Army 

National Guard, enrolled in ITT Tech to study nursing. It wasn't until the second quarter of her program 

that they told her she didn't have 100 percent GI Bill coverage and couldn't request a Yellow Ribbon 

scholarship. During the course of her classes, her professors discouraged her from asking questions, 

insisting that all the answers she needed would be in her books. According to Maggie, ITT was also 

dishonest about its nursing accreditation, at first telling her they were accredited and later telling her 

that its accreditation was pending. Maggie quit ITT and is still working to pay off the debt she incurred 
79 

Statement of Tom Tarantino 

Chief Policy Officer, lAVA 

Tuesday, July 23, 2013 

Page 3 of 3 

with them. She is currently enrolled at another for-profit school and is pleased with her experience so 

far. 

Another lAVA member, Howard Toller, expressed similar frustrations. Howard joined the Army in 2004 

and deployed to Iraq twice. He enrolled in ITT in 2010 for a degree in computer networking services, 

and later admitted that he was duped by their advertising. A couple of months after his enrollment, he 

learned that ITT wasn't properly accredited by a national organization, thereby rendering his degree 

worthless. In his words, the classes are subpar, the teaching is subpar, and the instructors are subpar. 

The experiences of these veterans demonstrate the need for more effective policies to protect military 

and veteran education benefits from the practices of predators in the higher education system. Many 

for-profit institutions are valued participants in education. They provide veterans with a service that is 

not widely available in traditional non-profit universities, including online and vocational programs that 

offer highly technical degrees. Unfortunately, it is difficult to separate the good actors from the bad 

actors in for-profit education without closing the 90/10 loophole. This loophole undermines the spirit and 

the intent of the GI Bill and should be closed. 

As lAVA's CEO and founder, Paul Rieckhoff, commented a year ago, "Education is the single best tool 

that veterans have to level the playing field in this tough job market. lAVA is committed to ensuring that 

each and everyone of them can maximize their benefits ... [and] lAVA refuses to allow predatory forprofit colleges to gouge the New GI Bill and pad their pockets at the expense of our nation's veterans." 

At the same time, the American public deserves to have its tax dollars spent effectively and efficiently, 

especially with regard to the investment our nation makes in the future success of our service members 

and veterans through military and veteran education benefits. 

Although less than 20% of veterans are attending for-profit schools, these schools are taking over a 

third of all GI Bill funds. Drop-out rates at for-profit schools are above 60% on average, and even 

though they account for just 13% of all college students, they produce half of all loan defaults. In this 

period of deficit cutting and waste reduction, the failures of for-profit schools with regard to providing 

quality job training and education programs to service members and veterans clearly represents an 

unacceptable threat to the future of the GI Bill. 

Like the Servicemen's Readjustment Act before it, the Post-9/11 GI Bill was passed with the intent of 

providing America's veterans with the opportunity to reach their full potential. An opportunity they 

earned by answering their country's call to service. It is not a handout; it is an investment in service 

members, veterans, and the nation. In order to ensure the Post-9/11 GI Bill is as impactful on the lives 

and livelihoods of this New Greatest Generation of Americans as it was on previous generations we 

must protect its intent and its integrity. 

We again appreciate the opportunity to offer our views on this important topic, and we look forward to 

continuing to work with each of you, your staff, and this Committee to improve the lives of veterans and 

their families. 

Thank you for your time and attention. 
80 

Prepared Statement of Sergeant Christopher J. Pantzke, USA, Retired 

"The 90/10 Rule: Improving Educational Outcomes for our Military and Veterans" 

July 23, 2013 

Greetings to the committee, panel, members of the media, 

Let me start by telling you a little bit about myself. My name is Christopher James Pantzke, 

SGT, US Army, RET. I am a 100% disable Iraq Combat Veteran. I hail from Minnesota but live in 

Prince George, VA., where myself, wife and son currently live. I will try to keep my story short as 

possible due to my time frame with the committee. I will start when I re-enlisted with the US Army. 

My family and I were living in Fergus Falls assisting my mother and step-father with everyday 

life as they were aging. In October of 2002 I decide to enlist with the MN Army National Guard. During 

my time in the MN Nation Guard I was promoted from Private First Class to Specialist due fact that I 

had strived for excellence in the tasks that assignments that were put to me. During this time my stepfather passed and my mother went into an assisted living home. My wife and I know that my mother 

would be well taken care of. So, I decided that I needed to provide a better life for my wife and son. I 

went and spoke with my chain of command and told them I wanted to re-enlist into the US Army. I was 

granted permission on one condition that I would keep my rank of Specialist (E-4). When I enlisted into 

the US Army I given three choices of duty stations, I chose Ft. Lee. I was notified that I would have to 

wait six months due to fact that my receiving unit was deployed at the time. In April of 2004 I signed in 

at Ft. Lee. 

When we arrived at Ft. Lee, VA, I was assigned to the J09'h Quartermasters Company, 240'h 

Quartermaster Battalion, 49'h Group. From 2004 to 2005 my squad leader, SGT Ivan Andrade saw 

leadership potential in me and started mentoring, training, and testing me to become a sergeant, a leader 

of soldiers. In late September of 2005 I was promoted to sergeant and five day later the J09th QM CO 

was deployed to Iraq. 

The 109'h QM CO was stationed at AI Asad Airbase were we became a transportation company, 

moving supplies, from I to class X supplies to various parts of Iraq. I was as assigned to several convoys 

during my deployment all but one went without a hitch. In late October early November of 2005 we set 

out on a convoy to Rawah Firebase to drop off a J lens (Video Camera). The following day we left on 

our way back to AI Asad Airbase about 3 p.m. in the afternoon my convoy was hit by VBIED (Vehicle 

Borne Improvised Explosive Device). The vehicle that I was traveling in was about 125 meters from the 

center of the blast. We stopped as we watched the explosive plume engulf one of our security vehicles, it 

completely disappeared. We both felt the concussion from the blast. My driver and I had sinking feeling 

that road had completely been destroyed, trapping the rest the convoy that was behind us, setting up for 

an ambush. I told my drive to go, go, go, push through, push through. As drove through the "kill zone" 

we saw bits and parts of the vehicle plus possible burnt body parts. I submitted a request for a Combat 
81 

Action Badge buts denied due to that the commanding Colonel had change the distance from the blast 

radius from 150 meters to 100 meters. 

In December of2005 I was assigned to COP North, a small outpost five miles south of the 

Syrian border to support the 414th CAV division. I was assigned to help resupply the outpost with food, 

water, and water. I became my XO's administrative assistant. I was place in charge of keeping track of 

the food, water, fuel supplies and supplies that were needed to operate the outpost. I had even created an 

excel tracking program to help in keeping track of our supplies, which I believe is still in use today. 

Shortly before our redeployment many of us received the Army Accommodation Medal for our 

participation in completing our mission objective. We also transported over 1.2 million gallons of fuel 

during our deployment. 

In June of2006 the 109th QM CO redeployed back to states. When we got back we were released 

for a thirty day leave. In which my family and I went back to Minnesota to visit my mother. After 

getting back from Minnesota we started our daily routine of preparedness. In the months to follow I 

started to get moody, depressed, and angry. My immediate leadership became concerned and was sent to 

the behavioral health center and Ft. Lee's Kenner Army Health Clinic. Where I was evaluated by Dr. 

Robert Brown and was recommended to be place in hospital for further evaluation. I was placed on 

medication to help with my mental health issues. When I was released three days later back to my 

company, it was recommended that I be place on thirty days of covalence leave as I started my mental 

health treatment. 

I tried to complete my tasks and assigned duties as a sergeant, once again I found myself 

becoming angry, depressed, and suicidal. My treatment intensified as my doctors became concerned 

about well being. In 2008 I was place in the WTU at Ft. Lee so I could concentrate on healing and 

decide whether I wanted to continue on with my military career, or not. In November 2008 I was once 

again hospitalized for two weeks with anger, depression and suicidal tendencies. After being released 

from the hospital and sent back the WTU, I had decided that I was no longer a viable leader, I was 

damaged. So, after that decision Rene' (my wife) and I sat down discuss what I was going to do with my 

enormous free time that would be coming. I have always been interested in photography so, I search the 

web for online photography classes and schools. One school came up over and over, The Art Institute of 

Pittsburgh, which had an online photography degree program, a Bachelors Degree of Science in 

Photography. 

The following day I called The Art Institute of Pittsburgh and spoke with a recruiter and told her 

that I was interested in the photography program that is offered. I told her first and foremost that I was 

Iraq Combat Veteran I Wounded Warrior, and that I had memory issues and PTSD. She responded that I 

would not be a problem that we will take care of you if you needed anything. [was satisfied with her 

response. She told me we need to get started on the admittance paper right away so I can be enrolled by 

start of school. She E-Mailed me the paperwork that [ needed to be filled out plus other paperwork 

needed to complete the admittance process. She asked about if I any loans outstanding I told her that 

was not sure, and that I was very doubtful that I would be able to attend school. She told me to let her 
82 

handle that and not worry. As we were speaking I received and printed out the admittance paperwork, 

which I informed her that I received it. She told to fill out the paper work as quick as possible so she 

could submit the paperwork higher. We hung up and immediately started fill out the paperwork and got 

together the rest of the requested paperwork. That afternoon I E-Mailed my paperwork to my admittance 

officer. I also called her to let her that I returned my admittance paperwork. The next day less than fortyeight hours I received a call from the admittance officer telling that I "got in, you are good to go." I was 

very surprised that I was accepted into The Art Institute of Pittsburgh Online Division. 

On March 19, 2009 I was medically retired and placed on TDRL status. Shortly after my release 

from the US Army we moved out of government housing to our current residence. I believe it to be July 

of2009 I started my classes through the Art Institute of Pittsburg. I started my core classes such as 

Math, English, Art History, etc., the first quarter was a little shaky, I was starting to struggle a little bit. 

Shortly after I started my classes I receive (about 2 months) my VA back pay and some funds from AiO 

and I purchased my photographic equipment. I was very excited when I got my equipment. I then 

notified my Academic Advisor that I gotten my photographic equipment and was ready for some of my 

photography courses. 

In 2010 Summer Quarter I became so depressed due to fact that I was struggling in all my classes 

that I failed to login into my classes for a week. In which I failed the two classes that I was in. AiO had 

believed that I withdraw me from school, which I had not. They also did not contact me to see what was 

going on. I understand that it is not the school's responsibility for my participation in my classes, but 

they should been concerned about me and what is going on. Just to give you an idea of my struggle with 

my classes. I had two classes every 9 1/2 weeks, and I would have anywhere from 8 to 10 assignments / 

projects due each week between the two classes. I would get up around 8 a.m. and I would not get to bed 

until 4 a.m. the next day. Another issue that I was having was with many of photographic assignment I 

was told I need to photograph people ..... well, that would be fine but to fact that I have PTSD, crowds 

and I do not get along. I get very nervous and fell enclosed. I told my instructors and academic advisor 

(which I five during my time at AiO) about that I was unable to go out in crowd of people and start 

taking photographs. I finally contacted my academic advisor and told her that I was really struggling 

with my classes. I had asked her if there were remedial course that I could take (for math), or if there 

was any kind tutoring, such as "face to face. I told that there were no tutoring services available for me. I 

asked why, because I had told my enrollment officer that I was disabled veteran. My academic advisor 

did know that I was disabled, I was furious. She told that I had to apply for disability accommodations. 

The person I need to contact was Ms. Sarah White Assistant Disability Director. 

I was still considered to be withdrawn from school when I contacted Ms. White. When speaking 

with Ms. White I explained to her what was going on and that I was struggling my classes. She said that 

I needed to apply for disability services and also needed to submit "evidence" of my disabilities. After 

about week I was readmitted to school with accommodations. My accommodation was that I was given 

one extra day to complete my assignments. 1 was unable to get simplified instructions, which frustrated 

many of my instructors. So, I had to break down assignment into simple bulleted format, in which my 

wife assisted me in doing. There was one photography assignment that I messed royal that my instructor 
83 

asked me what I was doing. My wife had e-mail my instructor back asking her for clarification for the 

assignment. My wife explained to the instructor that I had a hard time following complex instructions. 

My instructor was kind enough to simplify the instructions through my wife. Only one instructor offered 

tutoring at designated time during the week which I attended religiously, this was one my math classes. 

During my struggle with the Art Institute of Pittsburgh, I was contact by a journalist Dan Golden 

from Bloomberg, who had heard about my demise with AiO (Art Institute of Pittsburgh, Online) and 

wanted to interview about my experience with AiO. I said I that I would be pleased grant him an 

interview. Hoping this would affect change in the way AiO was treating me. When Mr. Golden arrived 

at my home in August of2010 and we did some talking before the interview, making me feel at ease 

with him. He asked if! know that The Art Institutes were a "For-Profit" school and they charge more 

tuition than average on ground campus college. I was taken back, as I listened to Mr. Golden telling me 

about how these schools bait veterans to enroll into their schools. He also mentioned that there was an 

instant where a recruiter from one of these for-profit college had gotten into a wounded Marines 

barracks and enrolled Marines with TBI. I was angry, felling that and realizing that I had been swindled. 

After the interview I continued on with my studies as best as I could, because I did not want to 

give up I wanted to attain my degree no matter what. Even though I knew that AiO was taking 

advantage of my benefits (Post / 911 GI Bill), I continue on with my courses and doing my best to deal 

with AiO and my assignments. In December 2010 or January 201 I PBS Frontline contacted me after 

they had seen Mr. Golden's article on my struggle with AiO they also wanted to interview my about my 

experience with the Art Institute. I was more than pleased, since the interview with Mr. Golden had no 

effect on how AiO was handling veterans. The PBS Frontline's piece called "Educating Sergeant 

Pantzke" air on June 27, 2011. A day or two after the Frontline piece aired I received a phone call from 

the Vice President of the Online Division of The Art Institute of Pittsburgh asked to make a statement to 

PBS that AiO was taking care of me and that I was doing fine. I had thought about making the 

statement, but wife with her infantine wisdom practical kick me in the hind end to put my brains back 

into my head as did my individual therapist (not literally). Within the PBS Frontline piece AiO had 

stated that AiO had offered me "extensive tutoring services," that was news to me because I did not 

receive on phone call or e-mail from AiO saying they were offering me tutoring services. 

Though before Educating Sergeant Pantzke aired I was involved in a serious car accident on 

Easter Sunday 201 I which left me injuries where I was unable to continue with school. My right hand 

was broken, fractured wrist and a rib fracture. I notified AiO right away that I was unable to continue 

with school due to my injuries. I applied for medical leave from school, which was granted. I was told to 

let the school know when I would be returning to class. I was required to have surgery to pin one of my 

bones in my right hand together. I was in a cast hot pink cast from March to early July 2011. Once the 

cast came off my wife and I sat down once again to discuss if! should go baek to school and was it 

worth the struggle. I also spoke with my individual therapist about returning to school, I was still on the 

wall about it at that time. I still had that military mindset not give up and do not surrender. I was in a 

battle. 
84 

In July or early August I was contacted by ABC wanting to interview about my experience with 

AiO. I figured the more attention I could get on how AiO treats veterans especially that are disabled 

maybe AiO would change how they do business. I did the interview with ABC Nightly News with 

Dianne Sawyer. ABC was going to air it that night after they done interviewing, which did not happen. I 

received a phone call from who I believe to be the segment producer asking me to sign a release of 

information so they could speak with Ai about me. I signed the released and e-mailed it back. The next 

day I received call form the segment producer asking me more questions about AiO. One thing that 

infuriated me was Ai had accused me in using funds to take exuberant trips spending money from 

school. I did take ONE trip to Virginia Beach, three day two night stay, but I spent my own money. I 

also went to V A Beach to do a photographic assignment. The ABC piece never aired. 

Then in October of 20 11 NBC's Rock Center contacted me wanting to interview me about my 

experience with AiO. I agreed to do the interview hoping that NBC would air their piece. There two 

other interviewees where also there being interviewed by Natalie Morales. It was myself Mike 

DeGiacomo and Rikk Wolf. I knew of Mike as he also appeared in Frontline's Education Sergeant 

Pantzke. He had contacted me shortly after the airing of Educating Sergeant Pantzke. The piece did air 

on NBC's Rock Center but my segment was not. When I was speaking with Mrs. Morales we discussed 

why I had not withdrawn for AiO due to fact that I was struggling and the amount of tuition that they 

charge my Post 191 1 GI Bill. She was the deciding factor, along with my wife, son and my therapist. So 

the day after I got back from New York I wrote a withdraw letter with the main points being that the 

education that were giving would not yield a gratifying and successful career in photography and the 

lack of disability services. 

Throughout my attendance at AiO my PTSD was raging. My items through my house grew 

wings and started flying about, yelling and screaming, I had put a hole in my wall with my elbow as I 

was going through a PTSD fit. My PTSD is monster or demon that I keep under tight control. When it 

shows its ugly head it is not pretty, everyone and everything is a target. 

These days I continue to learn about photography on my own, it sad that I have learned more 

about photography on my own than I ever did when I was a student at AiO. I believe AiO had failed to 

provide proper disability services which when I was first admitted to AiO that I needed to apply for 

disability services and set me up for failure. I also have taken up the gauntlet to help others to make 

informed decision when they are considering applying to a for-profit college. I try to warn them of the 

pitfalls before it is too late and end up in the situation that I was in. 

When I watch T.V. and I see the commercials for University of Phoenix, The Art Institutes, ITT 

Tech, De Vry etc. I see that they use older alumni or those are in higher professional positions where 

they already have degrees from other schools, or they were students before the school became 

possession of a corporation, and public traded on the stock market. it sickness me due fact that they lure 

unsuspecting potential students from all walks of life. 
85 

Now that I am no longer a student at AiO, not having worries about how I am going to this 

assignment in on time, or am I going to fail this class again. I work on my own creative photography. I 

use photographic websites like Learn My Shot (http://www.learnmyshot.com/index.php?mode=browse) 

I believe that anyone can take a picture but a photograph is created and with proper schooling a 

photography student can become a great photographer like Frank Capa and Annie Leibovitz. 

Here is a slide show if some Annie Leibovitz, as you can see why she is an inspiration for 

me. http://www.youtube.com/watch?v=m04pjdVseEs&feature=player embedded 

I close with this education should never be for sale and certainly education should not be trade 

on the stock market. It not right for anyone to benefit from a student that is attending college except the 

student who is striving for their future. 

Thank you for your Time 

Christopher J. Pantzke 

SGT, US Army, RET 
86 

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jTuition·Military 

jlnstltutioMI SOcrat65 G(ant 2009·10 

I Stipend . SUSSTAF 2009·10 

IVA Ch.epte( JJ Sene-fits (Post 9/11) Payment 2009-10 

IVA Chapler 33 Senefits (PosI9/11) Payment 2009.1 0 

I VOID VA Chapter 33 Senefils (Po.19J11) 

IVA Chapter 33 Senefits (PosI9111) Payment 2009-10 

I SlIpend. SUBSTAF 2009-10 

I SlIpend· SUBSTAF 2009·10 

I Stipend· UNSBSTAF 2009·10 

I Stipend· UNSSSTAF 20og.10 

I Stipend· VA33 2009-10 

I Sllpend· VA33 2009·10 

I BooksiSupplies 

I Tuition· Military 

I On~ne- Lab Fee 

I DnOne lab Fee 

I Online Lab Fee 

I Online Lab Fee 

I BooksiSupplies 

! Federal Direct Subsidized Loan 2009-10 

I Federal Direct UnsubsldlZed Loan 2009·10 

I Federal Pell GranI2009·10 

IVA Chapter 33 Benefits (Post 9/11) Payment 2009·10 

I Stipend· DLSUB 2009·10 

I Slipend· DLUNSUS 2009·10 

I Stipend· VA33 2009·10 

I VA Chapter 33 Benefils (Post 9111) Paymen12009-10 

! VA Chapter 33 Benefits (Pest 9111) Payment 2009-10 

I StIpend • VA33 2009·10 

I BOOks/Supplies 

I Feders! Oirect Un:subskHzed Loan 2009-10 

I Tuition· Military 

I Online Lab Fee 

I Online Lab Fee 

I Online Lab Fee 

I Online Lab Fee 

! Digital Resource Fee 

I Digital Resource Fea 

I Digital Resource Fee 

I Federal Direct Subsidized Loan 2009~10 

16ookS/SUPPlies 

I Federal Pel! Grant 2010-11 

I Stipend· DLUNSUB 2009·10 

I Stipend . DLUNSU6 2009·10 

I Stipend. DLSUB 200S·10 

I Stipend· VA33 2009·10 

I Refund· PELL 2010·11 

J Books/Supplies 

I Digital Resource Fee 

I Online Lab Fee Adjustment 

! TuitIon Adjustment - MiIltar), 

I Tuition Adjustment - Military 

IOnfiM Lab FeR Adjustment 

I Refund· VA33 2009·10 

I Refund· DLSUB 2009-10 

I Refund· PELL 2010·11 

I Refund· DLUNSU8 2009·10 

I Federal Pell Gra,12010-11 

I iuitiM - Military 

I 

0111512010 I 0112212010 

0112812010 I 0210112010 

0210lnOl0 I 

0310112010 1 

0310112010 

0310212010 I 

03/0212010 I 

0310212010 I 0310212010 1 

0310212010 

0310212010 1 

0410212010 

0410512010 I 

04/0512010 I 0410512010 I 0410512010 I 

0410512010 I 

0410612010 I 

0410712010 1 

0410712010 1 04108/2010 I 0411512010 I 04/2212010 I 

04122;2010 I 0412212010 

0610212010 I 0610212010 

0511012010 I 

0512512010 I 

0710712010 I 0711212010 I 

0711212010 I 0711212010 

0711212010 

0711212010 

0711212010 I 

0711212010 1 

0711212010 1 

07/1312010 

0711312010 1 

0711312010 I 0712012010 

0712012010 

0712012010 1 

0712012010 I 08/2312010 I 0812512010 1 

0812512010 

0812512010 I 0812512010 I 0612512010 

0812512010 I 

0812512010 I 

0812512010 I 0812512010 1 

0612512010 

09/3012010 I 

10/0412010 I 

I 

1 

(51,274.00)1 578.81 1 

(5333.00) (5254 19) 

5254.191 I $0001 ($6,15800) (68.158.00)1 

I ($6.224.00) ($12,382.00)1 

$6.224.00 I ($8.156.00) 

I ($6.224.0011<$12.38200) I 51,160.171 1($11,221.63)1 

$1,061.16 1($10,16067" 

$1,989.00 I I (S8,171.67) I 

$1,990.00 I ($6.18167) 

53,463.811 ($2,717.86) 

$2,717.851 50.00/ 

I ($240.00) (S240.00) 

$4,550.00 $4,310.00 

$100.001 $4,410.001 

5100001 I 54,510.001 

$100.001 I $4,610.001 

$100.001 54.710.001 

$240.00 I $4,950.00 I I ($1,162.00) $3,788.00 

I ($664.00il $3,124001 

($1,764.00)1 51,340.001 

I ($2,868.00>/ (SI'548'00)1 

$1,162.00 I I (5386.00) 5146.00 (5240.00) 

$240.00 $0.00 

I (52,650.00)1 ($2,650.00)/ 

I ($6,462.00) I ($9,112.00) 

$2,850.00 I I ($6,462.00) I 

I ($32.19)1 (58,494 19)1 

($664.00)1 ($7,158.19)1 

$4.200.001 I ($2.95819)1 

$100.001 I ($2,858.19) I 5100.001 I ($2,758.19) 

$100.001 I ($2.658.19)1 

$100.00 I ($2.55819) 

$70.00 ($2,488.19) 

$10.001 I ($2.416.19)1 

$70.00 I ($2,34819) I 

S240.00 

($1,162.00)1 ($3,510.19)I 

I ($3,270,19)1 

1$1.850.00)1 ($5,120.19) 

$664.00 (S',456.19) 

$32.19 I ($4,424.00) 

$1,162.00 I ($~,262.00)1 

$~.262.00 I I SO 00 I 

592500 I I 5925.00 I . I ($240.001.1 $68500 I 

I (S7000) $615.001 

I 

(5200.00) $415.00 I 

($2.100.00)1 (SI,685.0011 

(S1,050.00) I (52,735.00) I 

($100.00) ($2,835.00" 

5607.511 1 1$2.027.49) I 51,16200 I I ($985.49) I 

5201.491 I ($664.00) I 

$664.00 SO.OOI 

I ($1,850.00)11$1,85000)1 

$4,550.00 52.700001 I I 

Page 20f4 

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I Digital Resource Fee I I Online Lab Fee 

I Onli"" Lab Fee I 

I Online lab Fee 1 

I Oig11al Resource Fe. I I Digital Resource Fee 

I Digital Resource Fee 

! Online Lab Fee I 

I BookslSupplies I 

I Books/Supplies I 

IVA Chapter 33 Banefits (Post 9111) Payment 2010·11 II 

! Digital Resource Fee 

I Stipend· VA33 2010·11 II 

I Tuition· MUllalY 

I Federal Direct Subsidized Loan 2010·11 I I Federet Direct Subsidized Loan2010·11 I 

I Digita! Resource Fee II 

I 51ipend - VA33 2010·11 

! Digital Resource Fee I I Stipend - DLSUe 2010·11 II 

! Digital Resource Fee 

I Refund· OLsue 2010·11 

I VA Chapter 33 Payment 20t 1·12 I 

I VA Chapter 33 Payment 2011·12 I I Refund - VA33XEFA 20"-t2 I I Refund· VA33XEFA 201 t-12 I I Tuition· MIHla'Y 

I Online Lab Fee 

i Online Lab Fee 

I Online Lab Fee 

I Online Lab Fee ! 

1 Digita! Resource Fee I 

I Digital Resource Fe. II 

I Digital Resource Fee 

IVA Chapter 33 Payment 2009-10 I 

I Online Lab Fee I I Digital Resource Fee 

I TUition· Military ! 

I Onlin. Lab Fe. I 

! Digital ReSOlJrce Fee I I Online Lab Fe. I 

I Digital Resource Fee 1 

j Tuition - Military I 

I Online Lab Fe. ! I Digital Resource Fee 

IVA Ch 33 Banefils [post 9111) XEFA Payment 2011.12 

!VA Chapter 33 Benefits (100%) P~yment 2011~12 I !FederaJPellGrant2010.11 I 

I Refund· VA33 2010-11 II 

I Stipend - VA33XEFA 2011·12 

I Refund· VA33XEFA 2011-12 I 

I AR Forgiveness I' IVA Ch 33 eenefils [Post 9111J XEFA Payment 2010-11 

IAR Forgi""n.ss I 

jTotal ChargesiCredits I 

10/0412010 I 1010412010 

10104/2010 

10104/2010 I 10104/2010 

1010412010 I 10/04/2010 1 10/0412010 I 10/04/2010 I 1010812010 I 10/1212010 I 1011812010 I 1012012010 I 

1012712010 I 10127/2010 

1012712010 I 1012912010 I 1110212010 I 1112312010 I 1113012010 1 

1212912010 

0111312011 I 

02107/2011 I 

02/07/2011 I 0211012011 I 02110/2011 I 02/1712011 I 02/1712011 I 0211712011 I 0211712011 I 0211712011 I 0211712011 I 02117/2011 I 

02/17/2011 I 0310912011 I 0311512011 I 0311512011 

03/1512011 I 0311512011 I 0311512011 I 

0311612011 I 0311612011 I 0311612011 I Q3f16/2011 

03116/2011 

0312412011 I 041111201 t I 05/0412011 I 

0510512011 I 

0512412011 I 

101T112011 I 

10/1112011 I 1211912011 I 0110512012 

I 

$000 

550.001 I 52,750,001 5100,00 $2,850,00 

$100.00 I $2,95MO I 5100001 $3,05000 1 $75.00 $3,125.00 I 

550.00 $3,175,00 I 

$50,00 I 53,225,00 

5100.00 I I $3,325,00 I 

I ($60.00) I $3,265,00 1 

$60.001 , 53,325,001 

I (55,,50.00)1 ($1.825,QO)I 

(550,00) (51,875.00) 

$1,875,001 I 50.001 I (S35O,00) ($350.00) 

I (51,162.0011 ($1,512,QO)1 

I (51,161.00)1 ($2,673,00)1 

I (575.00)1 (52,748.00)1 

52,748.001 50,001 

I (550,00) I (S50,OO>l 

$50,00 I I $0,00 I I ($50,00)($50.00) I 

S50.00 I I SO,OO I 

I (52,700,00)1 (52,700,00) I 

I ($2,350,00) I (65,050,00) I 

$2,700,00 I I (52,350.00) I 

$2,350,00 50,00 I 

$4,550,00 I $4,550,00 I 

$100,00 I I $4,650.00 1 

$100001 I $4,750,001 

$100.001 $4,850,00 

5100001 1 54,950.001 

$50,00 I I 55.000.00 

$50,00 I I 55,050,00 I 

$50,00 I I $5,100.00 

I (526928) I $4.830,72 1 

I ($100,00)1 54,730,72 1 

I (55000)1 $4,680,72 1 

1 ($2,100,00)1 52,580.721 

I (Slo0,00)1 52,450,72 1 

I (550,00) I $2,430,72 1 

$100.001 ' 52,530721 

$50,00 I I 52,580.721 52,450.00 $5,03072 

$100.00 I I $5, 13072 1 

$75,00 I I 55,205,72 1 

($2,700.00)1 $2.505721 

I IS2,775,00)I (S269,25)I 

I ($925.00) I ($1,194.28) I 

Sl77.00 1 J IS1,017.2S)1 

$1,017.28 I $0.00 

$2,350,00 I I $2,:)50,00 I 

($2,350,00) $0,00 1 

1 ($2,350.00)1 ($2,350,00)1 

52,350,001, I SO,OO 

591,927,1] ($91,927,13~ $0,00] 

$000 

If you prefer to mail your payment, please print this page and mal! your payment to: 

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i\t The Art Institute of Pittsburgh~ 

Date: 0711712013 

Amount Du.e: $0.00 I 

Student Account Balance: SO,Qol 

RIIDACTED 

Please note thai total account balance mal'! not reflect financial aid and/or other financial resources tnat have not yet posted, 

Charg Paymen Balanc 

$50,00 ' (S50,00) 

Application Fee 0611212009 I $50,00 SO 001 Enrollment Fee 0611212009 $100,00 $100,00 

Online Lab Fee 07113120091 5100,00 $200,001 

TUition 0711312009 55.681,00 $5.881.001 Online Lab Fee 07113120091 $100,00 $5.961,00 

Online Lab Fee 0711312009 $100,00 $6,081.001 

Online Lab Fee 0711312009 $100,00 I 56,181,001 

BooksiSupplies 0711312008 $240,00 $6.421,0°1 

Federal Unsubsiaized Stafford Loan 2009· 0712312009 I $1,990,00 $4,431,00 

Interest Charge 0813112009 I $5,56 1 $4,436,581 

Supply Kit 0912912009 I $589,98 1 $4,826,54 

Military Tuifion Reduction 2009~ 10 09130120091 

I 

$1,13e.oO $M90,54I 

Military TuitIon Reduction 2009·10 0913012009 $1,136,00 $2,$54,54 1 

Federal Pell Grant 2009--10 1010112009 $1,784.00 $710.541 Fedoral Pel! Grant 2009·10 10101120091 $1,783,00 ($1,012.46) 

Tuition· Military 1010512009 55.681,001 54.868.54 

OnUne Lab Fee 1010512009 $100.00 $4,768.841 

On~ne Lab Fee 1010512009 S100'001 54,868.54 1 

Online Lab Fee 10105120091 5100.00 $4,968.54 1 

Online Lab Fee 1010512009 S100.00 

51,161.1sl 

55,068,541 

Books!Supplies 10}05l2009 5240,00 55,308.541 

Feaerat Subsiaized Stafford Loan 2009~ 10 10}06/2009 $4,147,38 1 

Federal SUbsidized Stafford Loan 2009·10 1010612009 I Sl,161.16 1 $2,965,221 

Federal UnstJbsidizea Stafford Loan 2009~ 1010712009 I Sl.990.00 $996.221 

In~lijutiQn81 Socrates Grant 2009-10 10115120091 5333.00 1 $663,221 

Books/Supplies 1011912009 ($23.34) I 5639.661 

Supply Kit 10/2312009 I ($369.96) 

$1,179.651 

$249.90 

VA Chapter 33 Benefits (Post 9111) Payment 2009~10 ',116120091 I ($929.95) 

Stipend· SU8ST AF 2009·10 12102/;2009 1 ($929.95) I SOOOI 

Supply Kit '2131120091 $369.98 1 $389.96 1 

Federal Pel! Gr~nt 2009·10 01104120'0 $1,783.00 I ($1,393.02) I 

Military TtJition ReduClion2009·10 0110612010 I I $586.001 ($1,961.02) 

Online lab Fee 0111112010 I 5100.001 I ($1,861.02) I 

Online Lab Fee 0111112010 $100.00 ($1,76102li 

Tuition· W!ttary 0111112010 I $5,824.00 $4,062,98 1 

Online Lab Fee 0111112010 $100.00 $4.162,98 1 

Onnne Lab Fee 0111112010 $100.00 $4,252.98 1 

Booksl$uppnes 0111112010 $240.00 54,502.981 

Federal Unsubsidiled Stafford Loan 2009- 0111412010 I $1.990.001 $2,512.981 

Federal Subsidized Stafford Loan 2009-10 01/1412010 ! $1,160.17, $1,352,81 1 

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Tuition ~ Military 

Institutional Socrates Grant 2009-10 

Stipend· SUBSTAF 2009·10 

VA Chapter 33 Benefits (Po,t 9J11) Payment 2009-10 

VA Chapter 33 Benefits (Post 9/11) Payment 2009·10 

VOID VA Chapter 33 Benefits (Post 9111) 

VA Chapter 33 Benefits (Post 9/11) Payment 2009-10 

Stipend - SUBSTAF 2009-10 

Stipend· SUBSTAF 2009-10 

Stipend. UNSBSTAF 2009·10 

Stipend· UNSBSTAF 2009·10 

Stipend· VA33 2009.10 

Stipend - VA33 2009--10 

800kslSupplies 

Tuition-Military 

Online Lab Fee 

Online Lab Fee 

Online Lab Fee 

Online Lab Fee 

BooksfSupplies 

Federal Direct Subsldlled Loan 2009·10 

Federal Direct Uns,ubsidized Loan 2009~ 10 

Federal PeH Grant 2009-10 

VA Chapter 33 Beneflts (Post 9111) Payment 2009-10 

Stipend· DLSUB 2009·10 

Stipend· DLUNSUB 2009-10 

Stipend· VA33 2009-10 

VA Chapter 33 8enefrt.s {Post 9/11) Payment 2009-10 

VA Chapter 33 Benefits (Post 9111) Payment 2009-10 

Stipend· VA33 2009-10 

Books/Supplies 

Feeeral Direct Unsubs!dized Loan 2009-10 

Tuition· Military 

Online Lab Fee 

Dnnne Lab Fee 

Online Lab Fee 

Online Lab Fee 

Digltsl Resource Fee 

Digital Resource Fee 

Digital Resoutce Fee 

Federal DIrect SubsidiZed Loan 2009·10 

Sooks/Supplies 

Federal Pall Grant 2010·11 

Stlp.~. DLUNSUB 2009-10 

Stipend· DLUNSUB 2009-10 

Stipend - OLSUB 2009-10 

Stipend· VA33 2009-10 

Refund· PELl2010-11 

Books/Supplies 

Diglta! Resource Fee 

OnUne Lab Fee Adjustment 

TuUlon Adju3tment - MUita'Y 

Tuition Adjustment - Military 

Online L-ab Fee Adjuslment 

Refund - VA33 2009-10 

Refund· DLSU8 2009-10 

Refund - PELl2010-11 

Refund· DLUNSUB 2009-10 

Federal Pell Grant 2010·11 

Tuition· Military 

Oigital Resource Fee 

01/1512010 1 0112212010 I 

0112812010 I 

0210112010 

02/()112010 

0310112010 

0310112010 

03/0212010 

03/0212010 

03/0212010 

0310212010 

0310212010 

0310212010 

0410212010 I 0410512010 

04105/2010 I 04/05/2010 

0410512010 

0410512010 

0410612010 1 

0410712010 I 04107/2010 I 0410812010 

0411512010 

0412212010 

0412212010 

0412212010 

08l02I2010 

0610212010 1 

0611012010 I 0612512010 I 0710712010 I 0711212010 I 

07/1212010 

07/1212010 1 

0711212010 

0711212010 

0711212010 

0711212010 

07/1212010 

07/13/2010 I 0711312010 1 

01/1:3~010 I 0712012010 

0712012010 

0712012010 

07120/2010 I 08/2312010 I 0812512010 

08/2512010 I 0812512010 I 0S,2512010 

0812512010 I 0812512010 

0812512010 

0812512010 I 0812512010 I 

08/2512010 1 

0913012010 I 1 1lI041201 0 

10104/2010 

(51,274.00)/ I $

7881 1 5333.00 ($254.19) 

($254.19) $0.00 

I $6,158.001 (So,158.00)I 

$6,224.00 ($12.382.00) 

I ($6.224.00) ($6.158.00) I 

$6.224.00 (512,382.00) I 

I (51.160.17) (511.221.83)1 

I ($1,061.16) ($10,160.67)1 

($1,989.00) ($6,171.67) 

(51,990.00) (S6,161.67)1 

I ($3,463.61)1 ($2,717.86)1 

I (52,717.86>1 $0'001 ($240.00) I ($240.00) 

54,550.00/ I $4,310.00 $100.00 $4,410.00 

$100,00 I $4.510.00 I 5100.00 I $4,610.00 

$100.00 I $4,710.00 

$240.00/ $4.950.00 

51.162.00 $3,788.00 

5664.00 $3,124.00 

51,764.00 $I,34().OO 

I $2,886.00 ($1,546,00) 

1 (51,162.00) ($388.00) 

I ($146.00) (5240.00) I 

(5240.00) SO.OO 

I $2,650.00 1 ($2,650.00) 

I $6.462.00 I ($9,112.00) I I ($2,650.00) I ($6,462.00) 

(532.19)1 I ($6.494.19) 

I $664.00 ($7.15819)1 

$4,200.00 I 1 ($2,958.19) I 

$100.00 I ($2,858.19)1 

5100.001 ($2,758.19) 

$100.00 ($2,658,t9)I 

5100.00/ ($2,558.19>! 

$70.00 ($2,466.19) 1 

$70.00 ($2.41B.19) 

570.001 ($2,348.19)1 

51,162,00 ($3,510.19)1 

5240.00 ($3'270.t9)1 

($240.00) 

(S70.00) 

($200.00) 

($2,100.00) I 

(51.050.00) 1 

(5100.0011 

I 

$4,550.001 

$50.00 ! 

51.850.00 I ($5,120.19) 

(S664,OO) ($4,456,19) 

($32,19) ($4,424.00) 

($1,162.00) ($3,262.00) 1 

($3,262.00) $0.00 I 

($925.00) 5925.00 I 

($807.51) 

I 5685.001 

$615.001 

I $415,001 

($1,685.00>! 

(52.735.00) I 

(52.835.00) I 

($2,027.49) I 

($1,162.00) 

($201.49) 

($664.00) 

51.850.001 

($665.49)! 

(5664.00)1 

50.00 

($1,850.00>1 

52.700.001 

$2,750.00! ! 

Page 2 of4 

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OnliM Lab Fee 

OnUne lab Fee 

Online Lab Fee 

DIgital Resource Fee 

Digital Resource FGC 

O!gil1ii Resource Fee 

Online Lab Fee 

Bool<slSuppl;eo 

Books/Supplies 

VA Chapter 33 Benefit> (Post 9/11) Payment 2010-11 

DIgital Resource Fee 

Stipend· VAll 2010-11 

Tuition - Milrtary 

Federal Oirect Subsidlled Loan 2010-11 

Federal Dtrect Subsidized Loan 2010-'1 

Digita! Resource Fee 

Stipend· VA33 2010·11 

Dlgltal Resource Fee 

Stipend· DLSUe 2010-11 

Digital Resource Fee 

Refund· DLSUS 2010-11 

VA Chapter 33 Payment 2011.12 

VA Chapter 33 Payment 2011·12 

Refund· VA33XEF A 2011-12 

Refund· VA33XEFA 2011·12 

Tuition· Military 

Online Lab Fee 

Online Lab Fee 

Online Lab Fee 

Online Lab Fee 

Digital Resource Fee 

Dighsl Resource Fee 

Digital Resource Fee 

VA Chapter 33 Payment 2009·10 

Online Lab Fee 

Digital Resource Fee 

Tuition - MJlitary 

Online Lab Fee 

Digital Res.ource Fee 

Online Lab Fee 

DlQital Resource Fee 

Tuition .. Military 

Online lab Fee 

Digital Resource Fee 

VA Ch 33 Bene1ks [Po.t ~1111 XEFA Payment 2011-12 

VA Chapter 33 Benefil:s {100%) Paymer1l2011·12 

Federal PeH Grant 2010-11 

Refund - VA33 2010,11 

Stipend - VA33XEFA 2011-12 

Refund· VA33XeFA 2011·12 

AR Forgiveneu 

VA Ch 33 B.nefils [Po.t 9/111 XeFA Paymont2010-11 

AR Forgi\leness 

MilKary TuKion Redudion 2010-11 

MilKar)' Tuition Reduction 2010-11 

Military TUlt10n Reduction 2010-11 

Mfiltary TUition Reduction 201()"11 

Stipend· VA33XEFA 2011-12 

Stipend· VAll 200~10 

Stipend· VAS3 200~10 

Stipend· VA33 200S·10 

1010412010 I 

10I04I2010 ~=~~I 10I04I2010 

1010412010 I 

10I04I2010 I 10I04I2010 

1010812010 

1011212010 I 1011812010 I 1012012010 

1012712010 I 1012712010 I 1012712010 I 1012912010 I 11/0212010 I 11/2312010 

11/3012010 

1212912010 I 0111312011 I 0210712()11 I 0210712011 I 0211012011 I 0211012011 1 02117/2011 

0211712011 

0211712011 , 

0211712011 

02/1712011 I 0211712011 

0211712011 I 0211712011 

03109/2011 

0311512011 

0311512011 

0311512011 

0311512011 

0311512011 

0311612011 

0312412011 

~~jgmll 04t1112011 

0510412011 

05/0512011 

0512412011 I 10/1112011 

1011112011 I 1211912011 

01105/20121 

0212712012 

0212712012 I 02127/2012 I 02127120121 

0310912012 

03109120121 

0310912012 

03/0912012 I 

$100.00 

$100.00 

$100.00 

$75.00 

$50.00 

$50.00 

$100.00 

($6Q.00) 

$60.001 

(550.00)1 

($350.00)1 

($7MO)1 

($50.00)1 

(550.00)1 

I 

$4,550.001 

$100.00 

$100.001 

$100.00 

$100.00 

550.00 

$50.00 

$50.00 

($100.00) 

($50.00) 

($2.100.00) 

($100.00) 

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5100.001 

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$100.00 I $75.001 

1 

I 

($2.350.00)\ 

$2.350.001 

I 

I 

$5,150.001 

($1.875.00)1 

$1.,62.001 

$1.161.00 

($2,748.00)1 

($50.00) 

($50.00)1 

52,700.001 

$2,350.00 

($2.700.00) 

($2,350.00) 

5269.28 I 

$'1.650.001 

52,950.00 I 

$3,050.001 

53,125,00 

53,175.00 

$3,225.001 

$3,325.00 

S3,265.OO 

53,325.00 I 

($1,825.00) I 

($1,875.00) 

$0.00 I 

($350.00) I 

($1.512.00) I 

($2.673.00) I 

($2.748.00; I 50.001 

(550.00)1 

50.001 

($50.00) I 50.001 

($2,700.00) I 

($5.050.00) I 

($2,350.00) I 

:::~.EII 54,750.00 

54,850.00 

54,950.001 

$5.000.00 

$5,050.001 

$5,100.001 

$4.830.72 

$4,730.72 

$4,680.721 

$2,580.72 

$2.480.721 

$2,430.72 

I $2.530.72 

I

I $2.580.721 

$1l.030.72 

$5.130.72 1 

I $5,205.721 

$2.700.00 $2,505.721 

$2.775.00 I ($2119.28) I 5925.00 I ($1. HM.28) 

(5177.00) ($1,017.28) 

($1,017.28) $0001 

($2,350.00) $2.350.00 I 

I $0.001 

$2,350.001 ($2,350.00)1 

I $0.00 

S$10.00 (5910.00) 

$210.00 ($1.120.00)1 

5490.00 5$40,00 ($2,45!I.00) ($1,960 .... 00. ) I 

($220.12) ($2,229.28) 

($1I10.0D) ($1.319.28) I 

($82.16) ($1,237,12)1 

($87.12)1 (51,150.00)! 

Page 3 of4 

hnps:limycampus.nionline.edulportallserver.ptlgateway/PT ARGS_ 0_139614_3647_20 '_6... 7/17/2013 
92 

Print Account 

Stipend - DLSU8 2010-11 

Stipend - DLSU8 2010-11 

Stipend - VA33 2009-10 

Military TuiUan Scholarship 2009-1 0 

Military TUition Scholarship 2009-10 

MUitaryTuition Schols",hip 2009~10 

Stipend - UNS8STAF 2009-10 

otai Charges/Credits 

If you prefer to mail your payment, please print this page and mail your payment to: 

Art Institute of Pittsburgh· Online Division 

1400 Penn Avenue 

Pittsburgh. PA 15222-4332 

Attn: Student AccQuntlng 

Page 4 of4 

Student AGGOunt Balance: 

$0.00 

To speak to someone about your account, please contact your financial Aid Officer. You can find your Finandal Aid Officer's contact 

information on Ihe Campus Common Home Page under the MyContadsiFinancial Services Section, 

https://mycampus.aionline.eduiportallserver.ptlgateway/PT ARGS_ 0_1396 J 4_3647_201_6... 7117/20 l3 
93 

Unot1!claJ l ranscnpt Page j 012 

i\t The Art Institute of PittsburghUnofficial Transcript 

Student Name: Christopher Pantzke Date: 0711712013 

Student 10: 0906054080 

2011 Winter/Spring Full Quarter 

Course Title Credits Status Grade 

ENG1020 composition and Language 1I 4,00 Dropped W 

PHl34 Dig!tal Image Illustration 3.00 Dropped W 

MTH1Ql0 College Math I 4,00 Complete 

PH133 Introduction to Photojournalism 3.00 Complete A2010 Fall Quarter Full 

Course Title Credits Status Grade 

fND132 Fundamentals of the Internet 3,00 Complete A 

PH123 Principles of Digital Photography 3,00 Complete 

MTH100 Elementary Algebra 3.00 Complete C+ 

PH124 DigItal Image Management 3,00 Complete 

2010 Summer Quarter Full 

Course Title Credits Status Grade 

FND132 Fundamentals of the Internet 3.00 Complete 

PH124 Digital Image Mcmagement 3.00 Complete 

2010 Spring Quarter Full 

Course Title Credits Status Grade 

ARTi02Q Art History: Prehistory to the Early Modern Era 4.00 Complete 

FND110 Drawing 3,00 Complete 

CPU101_S Computer Literacy 3.00 Complete 

MTH099 Basic Mathematics 3.00 Complete 

2010 Winter Quarter Full 

r;ourse Title Cr"dits Status Grade 

ENGlOlO ComposltlOn and Language 4.00 Complete 

FND115 Color Theory for Web and Multimedia 3.00 complete 

CPU10CS Computer Literacy 3.00 Complete 

https:llmycampus.aionline.eduiporlal/server.ptlgatewayIPTARGS_O _139614_793 _201_0_... 7/1712013 
94 

MTH099 Bas!c Mathematics 

2009 Fall Quarter Full 

Course 

ENGIOI0 

FND115 

CPU101_S 

MTH099 

Title 

Composition and language 

Color Theory for Web and Multimedia 

Computer literacy 

BlIsicMathematics 

2009 Summer Quarter Full 

Course 

ARTI020 

CPUI01_S 

ENG095 

55100 

Title 

Art History: Prehistory to the Early Modern Era 

Computer literacy 

Transitional English 

Strategies for Online Learning 

Cumulative GPA: 2.79 

~ -0 .... - "" .... 

3.00 Complete cCredits Status Grade 

4.00 Complete 

3,00 Complete 

3,00 Complete 

3.00 Complete 

Credits Status Grade 

4,QO Dropped W 

3.00 Dropped W 

3.00 Complete 

3.00 Complete 

https:llmycampus.aionline.eduiportallserver.ptlgatewayIPTARGS_ 0_139614_793_201_0_... 711712013 
IPEDS Graduation Rates for First-Time, Full-Time Undergraduates, 2011 

LT LT 

GRS 4YR 4YR LT4YR 4YR 4YR 4YR 

INSTNM RESPONSE STATE SECTOR 100% 150% 200% 100% 150% 200% 

Beebe HosEital School of Nursing Not DE Private 

Dawn Career Institute Inc Respondent DE Private 2-}l:ear 86 86 86 

Delaware Technical and Community CollegeOwens Reseondent DE 2-;{ear 12 19 25 Delaware Technical and Respondent DE 2-year 15 19 Delaware Technical and Community CollegeStanton-Wilmington Respondent DE Public- 2-}l:ear 13 Delaware State University Reseondent OE Public- 4-;{ear or above 15 34 36 University of Delaware Respondent OE Public- 4-year or above 59 75 77 

Private not-for-profit- 4-year or 

Goldey-Beacom College Reseondent OE above 30 49 49 

Schilling-Douglas School of Hair Design DE 26 67 71 

Widener University-Delaware Cameus 45 64 64 

Delaware College of Art and Design Respondent DE Private not-for-erofit- 44 45 56 Harris School of BUSiness-Wilmington Campus ResEondent OE Private for-erofit- less-than 2-:tear 49 57 57 Harris School of Business-Dover Cameus Reseondent OE Private for-profit- less-than 2-year 52 60 60 Delaware Learning Institute of Cosmetology Respondent OE Private for-erofit- less-than 2-;{ear 52 80 100 

Strayer University-Delaware Not aeplicable OE Private for-profit· 4-year or above 

Academ}l: of Massage and Respondent OE Private fOf-profit- less-than 2-lear 

Paul Mitchell The School-Delaware ResEondent OE Private less-than 2-year 78 78 University of PhoeniX-Delaware Not aee!icable DE Private for-erofit- 4-year or above 

American Broadcasting School-Oklahoma City OK 40 50 50 

Southern Nazarene University 32 49 53 

Broken Arrow Beaut!{ Arrow Reseondent OK Private 2-year 75 75 

pontotoc Technology Center OK Public- less-than 2-:lear 98 99 100 

Cameron University Respondent OK Public- 4-year or above 20 23 
IPEDS Graduation Rates for Undergraduates, 2011 '"$11tW9n: 2 Yeitror 1.:_ 1n.S!ftl!tI01l,,,,"yearor Above 

LT LT 

GRS 4YR 4YR LT4YR 4YR 4YR 4YR 

INSTNM RESPONSE STATE SECTOR 100% 150% 200% 100% 150% 200% 

Carl Albert State College Respondent OK 2-year 15 26 29 

Central State Academy Reseondent OK Private for-erofrt- !ess-than 2-lear 86 100 100 

of Central Oklahoma Respondent OK Public- 4-lear or above 12 36 41 

Claremore College Respondent OK Private for-profit- Jess-than 2-lear 0 92 92 

Connors State College Reseondent OK Public- 2-lear 11 20 23 ________

East Central University ResQondent OK Public- 4-year or above 11 32 36 Eastern Oklahoma State College Respondent OK Public- 2-year 14 22 23 Redlands Community College ResQondent OK Public- 2-year 15 23 25 

Enid Beauty College Respondent OK Private for-profit- less-than 2-lear 17 69 69 Eves College of Hairstllin£! Respondent OK Private for-profit- Jess-than 2-year 38 56 56 

Private 4-year or 

Hillsdale Free Will Baptist College Respondent OK above ___ 9 __

CosmetoJogl Center Respondent OK Private less-than 2-'l..ear 31 69 69 

Langston University ResQondent OK Public- 4-year or above 13 27 38 Murray State College Respondent OK Public- 2-year 12 22 25 

Spartan College of Aeronautics and Technology Respondent OK Private for-profit- 4-lear or above 95 100 100 

Northeastern State Universitl Respondent OK Public- 4-lear or above 11 30 34 

Beaut'!.. Technical College Inc Respondent OK Private for-profit- less-than 2:rear 75 75 

Northern Oklahoma College Respondent OK Public- 2-year 14 23 25 Northeastern Oklahoma Colle£!e Respondent OK Public- 2-lear 16 24 27 Northwestern Oklahoma State Universit'l.. OK Public- 4-y:ear or above 15 31 34 

Oklahoma State University Center for Health 

Sciences Not applicable OK Public- 4-year Of above 

Private not-for-profit- 4-year or 

Oklahoma Christian Respondent OK above 28 51 51 

University of Oklahoma Health Sciences Center Not OK Public- or above 

Oklahoma Panhandle State Universitl'. Respondent OK Public- 4-l'.ear or above 23 38 39 

Oklahoma State University-Main Came:us Respondent OK Public- or above 31 60 63 

Oklahoma State University-Oklahoma Citl Respondent OK Public- 4-lear or above 

Private not-for-profit- 4-year or 

above 41 55 56 

Oklahoma City University Respondent OK above 40 56 57 
IPEDS Graduation Rates for Undergraduates, 2011 II1SIituIlon: 2 Yea, 0' 1,,_ .lnstitl!tlOll: ","Year or A\>ove 

LT LT 

GRS 4YR 4YR LT4YR 4YR 4YR 4YR 

INSTNM RESPONSE STATE SECTOR 100% 150% 200% 100% 150% 200% 

of Oklahoma Norman Cameus OK Public- or above 30 63 66 

Oklahoma School of Reseondent OK Private for-erofit- less-than 2-year 84 84 84 Oklahoma State University Institute of TechnologyOral Roberts Universitl' 39 52 53 

Tulsa Technol09Y Center-Peoria Cameus Respondent OK Public- 2-year 100 100 

Platt College-Central OKC OK Private for-erofit- 2-year 57 57 57 

14 18 

Saint Gregorys 23 28 28 Standard College of Oklahoma LLC Reseondent OK Private for-erofit- less-than 2-l'ear 14 59 59 

Universitl' of Science and Arts of Oklahoma Reseondent OK Public- 4-year or above 19 30 33 

Seminole State College Respondent OK 14 23 25 

Southern School of Beauty Inc Reseondent OK Private for-erofit- less-than 2-year 91 91 94 Southeastern Oklahoma State University OK Public- 4-year or above 11 30 33 

Private not-for-profit- 4-year or 

Southwestern Christian University Reseondent OK above 15 27 42 Southwestern Oklahoma State University Respondent OK Public- or above 12 31 34 

Tulsa Community College Reseondent OK Public- 2-year 12 18 Tulsa Welding School-Tulsa Campus Respondent OK Private for-erofit- 2-year 25 66 67 

Private not-for-profit- 4-year or 

University of Tulsa Reseondent OK above 44 62 63 

Virgils Beauty College Reseondent OK Private for-erofit- less-than 2-year 68 72 

Indian Caeital Center-Tahleguah Respondent OK Public- 2-:t.ear 73 73 

yvestern Oklahoma State College Reseondent OK Public- 2-year 11 18 20 

Woodward Beauty College Reseondent OK Private for-profit- less-than 2-year 44 74 74 

High Plains Center Reseondent OK PUblic-less-than 2-tear 59 62 64 

Private not-for-profit- 4-year or 

Mid-America Christian Respondent OK above 17 20 

Platt College-Tulsa Respondent OK Private for-profit- or above Ponca College Respondent OK Private for-I,?:rofit- less-than 2-l'ear 81 85 Francis Tuttle Technology Center Respondent OK Public- 2-year 26 32 43 
IPEDS Graduation Rates for FirstwTime, 2011 InsHtulion: 2 Year or I.es$ Institution: 4-Year or Above 

LT LT 

GRS 4YR 4YR LT4YR 4YR 4YR 4YR 

INSTNM RESPONSE STATE SECTOR 100% 150% 200% 100% 150% 200% 

Career POInt College _____ Reseondent OK Private 72 72 72 -Central Technology Center Respondent OK 2wyear 78 78 78 --------

Moore Norman Technology Center Respondent OK 2-year 96 96 96 

Red .River Technology Ce!1ter Respondent OK Publicw 39 53 59 

Tulsa TechnoJo9l': Center-Lemley Respondent" OK Publlc- 2-year 100 100 100 

Campus Reseondent OK 2-year 100 100 100 

Tulsa Technolo9l': Arrow Respondent OK 2-year 91 91 97 

Metro Technology Centers Reseondent OK 70 73 76 

Great PlaIns Technology Center Res20ndent OK 2-year 77 77 78 

Pioneer Techn.ology Center Respondent OK 78 85 95 

Caddo Kiowa Technology Center Respondent OK Public- __ 62 62 86 

Southern Technology Center Reseondent OK Public- 31 40 40 

Aut!}' Technology Center " Reseonde_nt ___ __ ?ub!ic- 55 55 55 

Canadian Valley Technology Center Respondent OK Public:- less-than 2-year 36 49 49 

American Institute Respondent OK __ Private 

Meridian Technology Center Resp.ondent 42 54 56 

Northwest Center-Alva Respondent OK Public- !ess-than 2-year 100 100 100 

Southwest Technology Center Reseondent OK Public- 24 81 94 

CC's Cosmetology College Respondent OK less-than Chisholm Trail Reseondent OK 2-year 43 43 52 

Gordon Technology Center Respondent OK Public- 99 99 99 

Kiamichi Technology Center-Atoka Respondent OK Public- less-than 100 100 100 

Kiamichi Technology Center-Durant Respondent OK 89 97 97 -----------

Kiamichi Technology Center-Hugo Respondent OK Public- Jess-than 2-year 95 97 

Kiamichi Technology Center-McAlester Respondent OK less-than 2-year 22 54 57 

Kiamichi Technology Center-Idabel ResEondent OK Public- less-than 2-year 78 78 78 Kiamichi TeChnology Center-Poteau Respondent OK Public- 2-:tear 88 88 95 Kiamichi Technology Center-Seiro Reseondent OK Public- less-than 2-:tear 88 88 88 Kiamichi Technology Center-Talihina Respondent OK Public- 2-year 48 48 57 

Kiamichi Technology Center-Stig!er Reseondent OK Public- 2-year 83 83 92 

-

Northwest Technology Center-Fairview Respondent OK Public- less-than 2-year 100 100 100 
IPEDS Graduation Rates for Undergraduates, 2011 Institution: 2 Year or Less Institutlon: 4·Year or Above 

INSTNM 

GRS 

RESPONSE STATE SECTOR 

_____ ___ O_K ____ 

IT 

4YR 

100% 

IT 

4YR l T 4YR 4YR 

150% 200% 100% 

59 59 

4YR 

150% 

4YR 

200% 

__ 

.. 

__ __ __ _____ ___ _____ _________________

__ ____ 

""" 

___ "_"_""_" _____ ____ Private _______ ._g __ __ __ " ____ ____ _

or 

__________ """_ " __ . __ " __ ____ ____________ " ____ _____ ______ _____ " _____________ _

Tr] ___ __ . __ OK PUblic-less-than ________ ___ ______ 

_-'.n.dian _____ __ 91 91 91 __ " __ _'!Vestern Technology Center Respondent ____ ___ __ 90 

__ ______ OK 2-year _. __ ___ " __ __ ____ " .. __ 

_ 

. 

______ __ OK 2:year ____ " ____ __ " ___ _____ __ "". _______ ___ " __ m _

Oklahoma ___ ____ ____ . ___ __ ____ _____ __ " _______

Wes Watkins _______ ____ ______ __ 4_6 ___ ___ " ____ __ 

TechnicaJ Institute of Cosmetology Arts and 

Sciences __ ______ OK Private 59 71 ___ .EL ___ .___ """"" _________ _

Respondent" OK ___ . ____ __ ___ 64 ______ ." _______ __ Respondent ___ __ ____ __ ____ _ 

____ 

OK __ __ §J ___ " ___ __ ___ __ 

__ "_. __ ._. ____ . ___ OK _____ ___ ___ _ 

Platt _____ " ____ _____ ____ ___ for-profit* __ __ " __ ______ 

____ ___ __ ___ ___ . Public- less-than 66 66 79 

_ Northeast ____ _____ less-than 2-year 60 69 69 __ ___ "_"". ___ " __ ____ " __

__ of Phoenix-Oklahoma City Campus Respondent ___ __ " ______ ____ 4 ____ __ E ___

of Phoenix-Tulsa Campus Respondent _________ . ____ " __ 18 " ____ 

___ _____ ____ __ fQr-Plofit* ___ ___ __ """. ____ __ __ __

___ 

. 

__ m. ________ • __ __ __ ___ ___ _____ " __________ " ________

______ 

. 

___ 

" 

____ OK Private __ __ 63 __ ________ ____ " __ _" _

__ __________ __ Private 41 85 85 

.. . __ __ 

______________ ____________ o______ _____ _

Institute ______ __ . ____________ .. ___ __ . ___ ___ . ________ __ 
IPEDS Graduation Rates for First-Time, Full-Time Undergraduates, 2011 

INSTNM 

GRS 

RESPONSE STATE SECTOR 

Platt College-North OKC OK Private for-profit- 4-year or above 

Central State Massage Academy Respondent OK Private for-profit- less-than 2-year 

Platt Colleg-",Moore Respondent OK Private for-profit- 2-year 

DeVry University-Oklahoma Not applicable OK Private for-profit- 4-year or above 

Brookline College-Oklahoma City Respondent OK Private for-profit- less-than 2-year 

Broken Arrow Beauty College-Tulsa Respondent OK Private for-profit-Iess-than 2-year 

ITT Technical Institute-Oklahoma City Not applicable OK Private for-profit- 4-year or above 

ITT Technical Institute-Tulsa Not applicable OK Private for-profit- 4-year or above 

American Institute of Medical Technology Respondent OK Private for-profit- 2-year 

Clary Sage College Respondent OK Private for-profit- 2-year 

Edge School of Cosmetology Respondent OK Private for-profit- less-than 2-year 

Brown Mackie Colleg-",TulsaNot applicable OK Private for-profit- 4-year or above 

AcademyoLHair Design Not applicable OK Private for-profit-Iess-than 2-year 

Northeast TechnologyCentera€"Claremore Not applicable OK Public-less-than 2-year 

ATI Career Training Center-Oklahoma City Respondent OK Private for-profit-Iess-than 2-year 

liistlbttlOf!! ZYear or LiIss 

IT IT 

4YR 4YR lT4YR 4YR 4YR 4YR 

1000/0 1500/0 2000/0 1000/0 1500/0 2000/0 

75 88 88 

§i 79 79 

17 17 25 

10 70 70 

65 88 96 

14 71 71 

20 60 75 

31 34 38 

ATI Career Training Center-Oklahoma City Not applicable OK Private for-profit- less-than 2-year . _______________________

DeVry University's Keller Graduate School of 

Management-Oklahoma Not applicable OK Private for-profit- 4-year or above 

National American University::!ulsa Not applicable OK Private for-profit- 4,year or above 

Oklahoma Technical College Respondent OK Private for-profit- 2-year 

American Respondent OK Private for-profit- less-than 2-year 
101 

The 90/10 Rule: Improving Educational Outcomes for our Military and Veterans 

Committee on Homeland Security and GovernmentalAffairs 

July 23, 2013 10:30AM 

On behalf of the more than 70,000 active duty military and veteran students attending American 

Military University (AMU), I respectfully ask that the following information and perspectives be 

entered into the record associated with this hearing. At the outset, please know that the university 

recognizes the importance of the issues surrounding how educational institutions serve 

America's military personnel, veterans, and their families. In fact, those considerations were the 

sole rationale for the creation of the AMU in 1991, and they remain the guideposts that direct our 

efforts to serve those populations. Within the past few years, legitimate concerns have been 

raised regarding predatory recruiting practices, and some institutions from both for-profit and 

not-for-profit sectors are culpable in this regard, but these issues are not as simple as some would 

propose. Consequently, it is essential that Congress acknowledge the fundamental difference 

between "predatory" and "effective" marketing practices. Recent legislative attempts in this 

regard do not do justice to those institutions that have a long-standing history of serving these 

populations well, with integrity, and at a cost that represents a genuine value to both students and 

taxpayers. 

Specifically, bills have been introduced that call for a radical change in the Higher Education Act 

of 1965 related to the so-called "90/10 formula," which stipulates that market-funded institutions 

must derive a minimum of 1 0 percent of their revenue from sources other than federal financial 

aid. In this regard, the Act specifically excluded from the definition offederal fmancial aid 

military tuition assistance and veterans educational benefits. 

Unfortunately, some in Congress are unwilling to acknowledge that educational funds allocated 

by the Department of Defense (Tuition Assistance) and the Veterans Administration (GI Bill) 

represent compensation that has been earned. In fact, one can say with some assurance that in the 

case of DoD funds, the various branches typically consider TA to be a strategic tool by which to 

support the acquisition of specific skills and knowledge that are deemed important to their 

specific mission. As such, the benefits of those funds accrue as much to the armed forces as to 

the individuals to whom they are assigned. In any case, both TA and V A funds historically and 

appropriately have not been viewed as financial aid, but rather earned compensation. Moreover, 

many of the current legislative initiatives fail to take into account the collateral impact that 

changing the 90/1 0 formula would have on both military students and high-performing 

institutions. The latter may have to institute enrollment quotas that exclude military students, or 

raise the tuition those students pay in order to avoid being out of compliance with a revised 

90/10 formula. Neither of these developments serves military and veteran students' interests, for 

the following reasons: 

1. They will increase the cost of attendance and/or limit the options for those students; 

2. They diminish the educational benefits earned through military service; 

3. They have the effect of questioning the ability of military students and veterans to make 

informed choices; 

4. They undermine the ability of colleges and universities that have historically served these 

students well to continue to fulfill that mission. 
102 

AMU is more than willing to lend its support to initiatives that will be more appropriate and less 

harmful to those whose interests we are collectively striving to maintain. Those interests include 

the legitimate concerns raised by members of Congress and taxpayers, but our efforts should not 

have the effect oflimiting the educational options for military students and veterans, or 

undermining the ability of institutions like AMU to provide those opportunities. Rather than 

adjusting the 9011 0 formula, I would propose that the following suggestions: 

1. Exclude Differentiated Tuition Models - Perhaps the most effective single benchmark 

that Congress could establish to prevent predatory recruiting practices is to exclude from 

adjustments in 90/10 (or future adjustments in that formula) any institution that does not 

have a differentiated tuition modeL Many institutions discount tuition to military 

personnel and veterans, some for sound reasons and others solely to avoid breaching the 

9011 0 threshold, but often a differentiated tuition model reflects predatory recruiting 

practices. 

2. Require Fair and Reasonable Academic Transfer Policies - Stipulate that credit 

transfer policies provide clear and convincing evidence that they minimize unnecessary 

duplication of coursework, thus limiting the total cost to students and taxpayers, and 

reducing the time-to-degree/program completion. Such a policy will inhibit institutions 

from attempting to maximize tuition income through policies that limit the transfer of 

credit in the absence of sound academic justification. 

3. Encourage and Support Retention and Persistence - Promote institutional 

accommodation of the special circumstances and expectations of military students and 

veterans, taking into account that those individuals typically are working adults who are 

attempting to balance multiple responsibilities. As such, they deserve an appropriate 

institutional investment in academic counseling, course management policies, and other 

academic support services. They will also benefit from policies that encourage limited 

coursework, especially for first-time students, thus maximizing the potential for academic 

success and persistence. 

4. Correlate Academic Programs with Practical Career Options - Institutions that 

actively recruit military students and veterans should be expected to provide evidence 

that they develop, design, and offer programs of study, and associated methods of 

delivery that align with military-related careers and professional vocations outside the 

military. Some indication of congruence between programs of study and military-related 

experience would help to substantiate an institutional commitment to this population. 

S. Provide Institutional Transparency - Qualifying institutions should establish 

quantifiable indicators of academic integrity and participate in nationally-benchmarked 

surveys and studies. Furthermore, colleges and universities should openly publish 

institutional metrics that effectively inform prospective students, the Departments of 

Defense and Veterans Affairs, and the education service officers and commanding 

officers who routinely interact with military personneL In this regard I would offer the 

following link by way of an example: http://www.collegechoicesforadults.orgi 

These are all measures that could be legislatively stipulated and effectively implemented in an 

effort to inhibit abuse ofTA and VA funds by institutions of higher education. Taken together, 

they would likely serve Congressional objectives related to "eliminating the bad actors," while 
103 

also preserving the ability of high performing institutions to continue to meet the educational 

needs of military students and veterans. Perhaps most importantly, these recommendations 

would have the distinct advantage of ensuring that the educational opportunities of those 

populations are not compromised or climinished in any way, nor their expenses increased. 

As noted above, AMU welcomes that prospect of contributing to this important conversation, 

and we will appreciate the opportunity to provide additional information, data, and perspectives 

at your convenience. 

Cordially, 

Russell S. Kitchner, Ph.D, Vice President 

Office of Regulatory and Governmental Relations 

American Public University System 

American Military University I American Public University 

III W. Congress Street, Charles Town, WV 25414 

T: 304.724.3747 C: 703.268.8689 I rkitchner@apus.edu I www.apus.edu 
104 

EDMC· 

Education Management Corporation 

July 6,2011 

Chairman Kline, 

At Education Management Corporation (EDMC), we take great pride in actively supporting our country's 

servicemembers, veterans, and military spouses. We feel it's our duty and obligation to provide the absolute 

best education and service to our military students. We take this mission very seriously, because we sincerely 

appreciate all they are doing for our country. 

That is why after viewing the 6/28/11 PBS Frontline segment entitled "Educating Sergeant Pantzke," we are 

disappointed with the manner in Which EDMC - and specifically The Art Institute of Pittsburgh - Online Division 

(AiP) - was portrayed. Despite numerous attempts to supply the show's correspondent, Martin Smith, and 

associate producer, Chris Livesay, with balanced information, the program was little more than a one-sided view 

of just one of the thousands of military students who attend our schools. 

We have several military students and graduates who expressed their willingness and availability to share their 

stories of success in our schools with PBS Frontline producers. On more than one occasion, we communicated 

these opportunities to ~roducers and, in fact, they spoke with one of them but his story did not make it into the 

segmen!. Their heavy reliance on the testimony of one individual to assert the claims that an entire population of 

students has somehow been exploited - even after being given access to several military students who earned 

degrees from The Art Institutes and now enjoy successful careers as a result of their education - is irresponsible 

joumalism at its bes!. 

What may be most troubling is that Frontline ran a news story that no longer bears the slightest resemblance to 

Sg!. Pantzke's current status. In April of this year, Sg!. Pantzke re-enrolled at AiP. Due to personal 

circumstances unrelated to his education, he withdrew but has expressed to academic counselors that he is 

planning to re-enter in October. 

Throughout the course of Frontfine's pursuit of this "story," EDMC provided producers with several supporting 

examples of our commitment to assisting and helping Sg!. Pantzke. I'd like to share some of them with you: 

AiP sincerely tried to work with Sg!. Pantzke to ameliorate his concerns. Despite our best efforts and as 

many as 37 documented attempts to render support, Sg!. Pantzke had poor attendance, a general 

reticence to pursue academic support services available in the online program, and an insufficient 

incremental completion rate of coursework, resulting in dismissal the first time he enrolled at AiP. 

While we always encourage our students to graduate with the least possible debt necessary to 

complete their education, records confirm that Sg!. Pantzke secured significant aid beyond what was 

needed for his direct educational costs. Records indicate that he had also defaulted on student loans 

(satisfied through consolidation loans in order to access additional student loans) J1dQr to joining the 

military and prior to enrolling at AiP. 

With regard to providing accommodations based on a specific medical condition, AiP, despite numerous 

requests for such information, was never provided documentation of an official medical diagnosis of the 

condition from a qualified medical professional in order to confirm that which may be limiting or 

impacting Sg!. Pantzke's ability to succeed until recently. 

With regard to academic support and tutoring services, AlP has no documentation to reflect that Sg!. 

Pantzke attempted to utilize available tutoring services, which included Self-Directed Tutorials, Online 

Tutoring Learning Centers, On-Demand Tutoring (where students can select a subject and be assigned 

a "live" tutor to join within minutes), Scheduled Tutoring for an hour-long session with a "live" tutor (using 

an interactive Whiteboard), and an Essay Center (which enables students to submit a paper for review). 

All students are expected to take personal responsibility for ensuring support strategies available to 

them are scheduled and utilized on a regular basis. 

AiP afforded careful consideration to Sg!. Pantzke with regard to tuition and fees, as well. In fact, we 
105 

agreed to lock in his tuition rate for as long as it took him to complete his degree -- at a tuition reduction 

of 21%, compared to a 10% tuition reduction afforded to all veterans, active military, spouses and their 

families. 

And, although EDMC and/or AiP cannot forgive loans Sgt. Pantzke received from the federal 

government, he was notified that the opportunity existed to appeal his dismissal and some of his 

financial obligations for courses charged, but not completed. 

Others were balanced and disceming of the facts as a whole with respect to Sgt. Pantzke's experiences at AiP. 

For example, the day after the piece ran, First Analysis Securities Corp. observed as follows: 

"We presume the story about Sergeant Pantzke failing out of the Art Institute Online and being 

frustrated at his classes (to the point of punching a hole in his wall) was intended by the producers to 

convey the idea that the school was aggressive in recruiting military students and provided insufficient 

support. However, we note 1) the fact that the school did fail him suggests it was maintaining 

academic rigor (as opposed to keeping him enrolled regardless of performance, to keep 

collecting his financial aid), and 2) the fact that he re-enrolled at the Art Institute Online even 

after experiencing Significant frustration and being interviewed for a negative story in Business 

Week suggests he was likely satisfied with his experience. (As a side note, our personal memory of 

college would suggest experiencing some frustration while taking classes is not necessarily a sign of 

insufficient support services, but an almost-inevitable part of engaging in a rigorous academic process): 

We take issue with any allegation that may imply an inherent disregard for our students, especially since EDMC 

institutions are uniquely suited to serve the needs of members of our nation's military. The broad array of 

programs that we offer provide active duty personnel and veterans the quality, flexibility and convenience they 

seek through courses both on campus and online. The online university environment, offered by both traditional 

and proprietary schools, provides students the flexibility of not having to be physically located at a campus, if 

they choose. This has proven to be a better and more convenient option for those with family, career, or other 

obligations, since they do not have to relocate or make lifestyle changes to pursue an education. 

These features have made our schools the preference for many current and former members of the U.S. Armed 

Forces. Students like Chad Dulac, a Lieutenant and Public Affairs Officer in the United States Navy; Catherine 

Carbullido, a Non-Commissioned Officer in Charge of an eight-person team of Air Force broadcasters; Juan 

Bautista, a military veteran who is now an animation engineer for Northrop Grumman Corporation; and Peter 

VanAmburgh, a Lieutenant Colonel with the Georgia Army National Guard who completed his doctoral 

dissertation while stationed in the deserts of Iraq, just to name a few. I've attached their full stories below. 

For more than 40 years, we have been dedicated to delivering education that provides students with the skills 

they need to become successful in their chosen professions. We remain committed, as always, to ensuring that 

students from every walk of life, including those who have served in uniform, get the quality education they 

deserve. 

Should you have any questions, or require any further information, do not hesitate to contact me. 

Sincerely, 

Anthony J. Guida Jr. 

Senior Vice President, Extemal Affairs 

Education Management Corporation 
106 

EDMC: Committed to Military Higher Education 

For more than 40 years, EDMC has been dedicated to delivering quality education that builds 

careers for more than 150,000 students across every "Nalk of life. EDMC institutions are 

uniquely suited to serve the needs of members of our nation's military. The broad array of 

programs we offer proVide active duty service members, reservists, veterans, mnitary spouses 

and familles the quality, flexibility, and convenience they seek through courses both on campus 

and ord!ne. 

What makes EDMC schools appealing to military students? 

When compared to traditional 18-21 year old college students, military stUdents tend to be 

older, IfIIith more real-life responsibilities and experiences. These students often Fee! more 

comfortable at institutions that offer more flexible adminis.trEttive and academic poticies, career~ 

focused curricula, crsditfor pasttrainlng and accomplishments, and support services that strive 

to meet their unique academic and personal needs. And, many of our schools are located near 

military bases, making it convenient to attend onMcampus classes. 

Many EDMC military students pursue their degrees through on!ine programs. Depending upon 

a student's unique circumstances, online higher education can provide the flexibility of not 

having to be physJcally located on campus - a more convenient opUon for those with family, 

career, or other obligations, since they do not have to relocate or make a lifestyle change to 

pursue an education. Some programs even enable active military personnel to stay enroiled 

online while serving overseas. While others may offer the opportunity to allow special start and 

stop accommodations that refled the reality of soldiers and sailors finding themselves deployed 

in the midsl of a course. 

EDMC has a rwmber of program and scholarship opportunities available to milf:lary personnel 

and their families. We encourage prospective students to explore the benefits that may by 

available including the Montgomery GJ. 811l, Vocational Rehabilitation, Veterans Educatronal 

Assistance Program 01EAP), the Post-9--11 G.I. Bill, Dependents Educational Assistance, the 

Reserve G.!. sm and Reservists Activated after Sept. 11, 2001 (REAP). 

As with our natIon's financial aid syslem generally, In which students receive financial aid and 

apply It to a participating institution of their choice, military stUdents have the final authority over 

how their benefits may be administered and at Vllhich institutions. 

Which EDMC schools serve military students? 

Milita Student Po ulation 

314 

3851 

460 

274 

1,482 

What are the most popular programs of study for EDMC military students? 

Program % of Military Students in Program 

ASSOCiate in Culinary Arts 3.2% 

Bachelor's in Graohic Des/em 6.1% 

Bachelor's in Media Arts & Animation 5.7% 

Bachelor's in Photography 5.5% 

Bachelor's in Culinary Manaaement 5.5% 

I Th. 1 South University"" I 
107 

"A Man on Many Missions" 

Chad A. Dulac 

Bachelor of Science - Game Art & Design, 2010 

The Art Institute of Pittsburgh - Online Division 

Chad A Dulac of San Diego has been stationed alJ over the country, serving as Lieutenant and Public Affairs Officer in the 

United States Navy. While exercising his passion to serve his country, Dulac desired to explore his creative arts passions as 

welL And by enrolling in The Art Institute of Pittsburgh - Online Division, he was able to find a perfect fit in balancing military 

service and starting a new career path, 

Dulac graduated with a Bachelor of Science degree in Game Art & Design from The Art Institute of Pittsburgh - Online 

Division in 2010, and according to Dulac, the programs offered at the school gave him the flexibility needed to for him to 

succeed. 'The degree I wanted to achieve in fife wasn't always present in the places where I was stationed, By attending 

The Art institute of Pittsburgh - Online Division, it gave me the flexibility to pursue the degree in games! wanted despite 

moving all around the United States during my time in the Navy." 

In describing his academic experience, Dulac appreciated the "real-time" classes that are germane to his field of study, as 

well as the use of current technology and game art techniques. "It was a robust, diverse program that was every bit as 

enriching as an 'in class' based schooL The instructors used current games as an example for what methods they were 

teaching and! could see, with every class, that I was learning something practical instead of an ambiguous subject that 

wouldn't be worth its merit." 

With five years remaining until his Navy retirement. Dulac has already blazed an exciting creative arts career path. He is a 

Concept Artist working on the Legends of Ethere!!, a fantasy RPG game project. Dulac also provides part-time illustration 

work to Paizo Publishing, rendering non-player characters for Paizo's online "Dungeons and Dragons" Fanzine and serves 

as the creator/writer/illustrator for a six-issue fantasy comic book series called "The Gifted," which is in its final stages of 

production. 

'The career! am currently pursuing is as an illustrator, providing character and !evel design concept art. in both black and 

white, and color. These professional opportunities are a foot in the proverbial door that can easily lead to a long~standjng 

career in games, and great portfolio work,'" 

Dulac credits The Art tnstitute of Pittsburgh - Online Division for providing an inspiring platform to further his education. "With 

the flexibility to work from your home, duty station or overseas aSSignment, The Art Institute of Pittsburgh - Online Division's 

curricula and program delivery model were incredible benefits to me as an active duty service member. This is a 

phenomenal platform to pursue anyone of multiple degree paths in the creative arts, while stll! allowing you to honorably 

serve: 
108 

"An Architect of a New Career" 

Catherine Carbullido 

Diploma - Digital Design, 2007 

The Art Institute of Pittsburgh - Online Division 

Catherine Carbu!lido keeps her comrades on Ramsteln Air Force Base in Germany up to speed on what's happening on 

base and around the wor!d. The Non~Commissioned Officer in Charge leads an eight~person team of Air Force broadcasters, 

while directing and producing news stories and commercials. Previollsly. CarbuHldo was an Air Force graphic illustrator for 

two years before the job was contracted out to civilians. 

As if she weren't busy enough, Carbu!!ldo practically has built a second career in expanding her knowledge. Since 

graduating high school, she's attended Guam Community College, University of Detroit, Oka!oosa Walton Community 

College in Florida and Old Dominion University in Virginia. She earned two associate's degrees with the Community CoUege 

of the Air Force. 

Carbullido decided to attend The Art Institute of Pittsburgh Online Division because it provided the flexibility she needed to 

pursue a four-year degree as an active military member. "Attending The Art Institute of Pittsburgh Online Division made 

balancing gOing to college better because my class schedule was as flexible as my Air Force work schedule." said 

Carbuillido. 

What Carbullido learned In her classes extended beyond the realm of Digital Design. She learned analytical and 

communications skills that have proved beneficial in her current position. "It has also helped my professional career by 

improving my critiquing skills," added Carbullildo. 

"I found that my troops respond better to critiques when they can learn something from it and I've encouraged them to 

critique each other SO that they can learn how to give constructive criticism. J've not only taken what I learned in class, but 

also the method of learning into my broadcast section to create a better work center." 

Carbullido received her Digital Design diploma in 2007 and is now pursuing her bachelor's degree in Graphic Design from 

The Art 1nstitute of PIttsburgh - Online Division. "Attending The Art Institute of Pittsburgh - Online Division has afforded me 

the opportunity to finally get my bachelor's degree and prepare me for working in the civilian sector:' 

Carbullido started her educational journey aspiring to be an architect. but then ·'jell in love" with the graphic arts field when 

the Air Force opened that door jar her. Little did she think she·d be able to build her career brick by brick while travelling the 

world and serving her country. 

''I'm glad that I've discovered an institution like The Art Institute of Pittsburgh Online Division to help me achieve my goals. 

I've been able to attend classes while stationed in Virginia, Portugal. Germany and even completed 19 credits while 

deployed to Afghanistan." 
109 

"Animation Engineer on Top-Secret Government Projects" 

Juan Bautista 

Bachelor of Science - Media Arts & Animation, 2006 

The Art Institute of California Los Angeles 

Not many people have the phrase "top secret" in their job descriptions. But for Juan Bautista, it's a part of every day at the 

office, As an animator/animation engineer for Northrop Grumman Corporation, Juan works on high-level, top-secret projects 

for the United States government And with his company's recent merger with Aerospace, he's begun picking up projects for 

NASA as well. 

Juan's main responsibilities include modeling, lighting, texturing, compositing, directing cinematic shots, and technical 

advising for military hardware such as weapons and tactics. He works with three other animators, jumping from different 

projects as needed, depending on priority. "We are our own production managers and see each project through to the end," 

he asserts, adding that he's a generalist in 3ds Max, Maya, Vue, Shake, After Effects, and Right Hemisphere, 

A military veteran, guitarist, and painter, Juan combines discipline and innovation in his work. He credits his education at The 

Art Institute of California-Los Angeles with helping him to fine-tune his creativity and pursue his love of animation, And he's 

continuing to challenge himself, by taking advantage of Northrop's generous continuing education program-pursuing a 

master's degree in Film at the University of Southern California's Film SchooL 
110 

"Student and Soldier: Earning a Doctorate in the Deserts of Iraq" 

Lt. Colonel Peter VanAmburgh 

Doctorate of Education (Ed.D.), 2003 

Argosy University,Sarasota 

While other doctoral students are working in 

the library or on their computers at home, Lt. 

Col. Peter VanAmburgh, a Bronze Star 

Medal recipient, was completing the final statistical analyses for his doctoral dissertation in a destroyed building at the 

Baghdad airport in Iraq. 

Earning an advanced degree and maintaining a full time job can be a daunting task for anyone. But for Peter C. 

VanAmburgh, the decision to complete a doctoral dissertation in education from Argosy University/Sarasota, while being 

stationed in the deserts of Iraq, was perhaps the biggest feat of all in fulfilling one student's desire for a higher education. 

Argosy University offers the Doctorate of Education (Ed.D.) program in an accelerated format, providing students the option 

to complete coursework online, in the classroom, or a hybrid of both methods. 

VanAmburgh is a Lieutenant Colonel (LTC) with the Georgia Army National Guard whose National Guard Unit was mobilized 

to the war in Iraq in February 2004. For LTC VanAmburgh, this fiexibility became a critical factor in allowing him to continue 

his studies. At the time of his combat deployment, he was in the dissertation phase of his doctoral studies. When his unit 

was called up, LTC VanAmburgh explains, "I loaded all my data and dissertation items on my unclassified laptop to finish the 

project and not fall too far behind when I was not engaged." 

He credits Argosy University's flexible doctoral committee with helping him finish his degree in a rather unorthodox fashion. 

Says Dr. Celia Edmundson, department head of the Organizational Leadership program in the School of Psychology and 

Behavioral Sciences at Argosy University/Sarasota, ~as educators, our priority is helping our students achieve their academic 

goals. In this case, we were more than happy to accommodate Peter's desire to complete his degree under what had to be 

challenging, if not frightening circumstances. Peter has shown, as a student and as a leader, that life is to be lived with 

dedication, integrity and courage." 

According to LTC VanAmburgh, he chose his course of study, Organizational Leadership(OL), because "I have been able to 

apply the lessons to the challenges of Army transformation, for example, building the objective force for CIIHuman 

Intelligence forces of the future, teaching ROTC students, commanding battalion~level organizations, and organizing and 

directing combat operations." 

VanAmburgh moved frequently between Kuwait, Iraq, Afghanistan and Uzbekistan. As for the challenges of concentrating 

on writing a dissertation on a laptop while traveling regularly in military vehicles to and from different locations, LTC 

VanAmburgh jokes that his fellow soldiers allen looked at him with "shock and awe." "Most were very surprised I brought my 

educational pursuits to the Gulf operation." 
111 

ITT Technical Institute ITT 

August 5, 2013 

The HOllOlBble Thomas R. Carper 

Cbairman 

I rT fduc~t'nLa! ':'eIV1Cf~S 

1300u ~onh Mer alar> $~:r,'(); 

U.s. Senate Committee on Homeland Security & Governmental AffaiIS 

430 Dirksen Senate Office Building 

Wasltingtun, DC 20510 

The Honorable Tom Coburn 

Ranking Member 

U.S. Senate Committee on Homeland Security & Governmental AffaiIS 

430 Dirksen Senate Office Building 

Washington, DC 20510 

Re: U.S. Senate Committee on Homeland Security & Governmental Affairs 

Hearing on July 23, 2013 at 10:30 a.m. 

1317/ 706 ~\200 

The 90/10 Rule: Improving Educational Outcome. for our MilitaIy and v.teran. 

R .. ponae by ITf Educational Senieeo, Inc. 

Dear Chairman Carper and Ranking Member Coburn: 

On behalf oflTT Educational Services, Inc. (ITTIESI) and the ITT Technical Institutes (ITT 

Tech), we want to thank the Committee for the opportuoity to respond to the written Statement 

(Statement) by Tom Tarantino, Chief Policy Officer, Iraq & Afghanistan Veterans of American 

(lAVA) dated 1uly 23, 2013, which, we believe, contains allegation. that an: inaccurate. 

While we would have p",ferred to address, with detailed specificity, each and every inaccurate 

allegation made by Mr. Tarantino about the alleged experiences of two former mTech students, 

Howard Toller and Margaret "Maggie' CJ1lwford, we an: constrained from doing so by the Family 

Educational Rights and Privacy Act of 1914, as amended (FERPA), which prohibits us from disclosing 

to you any non-directoty information from those students' education ~rds without their prior written 

consent. Unfortunately, both Mr. Toller and Ms. Crawford have reCused our requests to provide the 

required FERPA consent. Should Mr. Toller and/or Ms. C!1lwford change their minds and provide the 

requisite FERP A consent in the future, we respectfully request the opportunity to correct the Record, 

even ifit is after the date the Record formally close. OD August 7, 2013. 

Due to Mr. Toller's and Ms. Crawford's refusal to provide. FERPA consent, ITT Tech fmd, 

itself in the untenable situation of having to respond to the Statement of Mr. Tarantino who provided 

hearsay testimony, allegedly on behalf of two individuals who were not present at the Hearing and, 

who were not subject to any examination by the Committee. 
112 

ITT Educational Services, Inc. 

The Honorable Thomas R Carper 

The Honorable Tom Coburn 

Augusts., 2013 

Written Statement by TOlD Tarantin(t, ChielPolicy Officer, lAVA 

On July 23, 2013 at 10:30 a.m., the U.S. Senate Committee on Homeland Security & 

Governmental Affairs (Committee) beld a Hearing on "The 90110 Rul.: Improving Educational 

Outcome, for our Military and Veterans" (Hearing). 

As part of the formal record, Mr. Tarantino provided the Committee with a written Statement 

wbich, in relevant part, provides as follows: 

One lAVA member, Maggie C!l!.w1im!. expressed frustration with for-profit ,chool, on 

lAVA', Defend the New GI Bill webpage. After serving a tour of duty in Afghanistan. 

Maggie, a member of the Anny National Guard, enrolled in ITT Tech to study nursing. It 

wasn't lUltil the second quarter of her program thllt they told her ,he didn't have 100 percent 

GI Bill coverage and couldn't request a Yellow Ribbon SCholarship. During the course of her 

classes, her professors discouraged her from asking questions, insisting that all the answers she 

needed would be in her boob. According to Maggie, ITT was also dishonest about its nursing 

accreditation, at first telling her they were accmtited and later telling her that its accreditation 

was pending. Maggie quit ITT and is still working to payoff the debt she incuned with them. 

She is cwrentty enroUed at another for-profit school and is pleased wjth her experience so far. 

Another TA V A member. Howard ToUer. expressed similar frustrations. Howard joined the 

Army in 2004 and deployed to Iraq twice. He enrolled in ITT in 2010 for a degree in computer 

networking services, and later admitted that he was duped by their advertising. A coup1e of 

months after his enrollmen~ he learned that ITT wasn~ properly accredited by a national 

organization, thereby rendering his degree worthless. In his words) the classes are subpar, the 

teaching is subpar, and the instructors are subpar (emphasis added). 

See pages 2 and 3 of Mr. Tarantino's Statement. 

ITr TKh Denies Each and Every Inaccorate Allegation in Mr. Tanmtino's Statement That 

Wore Purportedly Made by Mr. Toller and Ms. Crawford 

11T Tech denies each and every inaccurate allegation contained in Mr. Tarantino's Statement 

including the complaints. allegedly made by Mr. Toller and Ms. Crawford. Furthermore, neither Mr. 

Toller nor:Ms. Crawford testified at the Hearing nor were questioned regarding the veracity of the 

allegations contained in Mr. Tarantino's Statement. 

rrr EducatioDal Services, Inc. - Background 

ITTIESI is a lceding proprietary provider of postsecondruy degree programs in the United 

States. As of the date of the Hearing. lTTJESI was offering master, bachelor and associate degree 

programs to approximately 59,000 students at its ITT Technical Institutes and Daniel Webster College. 

lITIESI bas 149 college locations in 39 states. All ofITTIESl's college locations are authorized by 

the applicable education authorities of the states in which they operate and are accredited by an 

accrediting commission recognized by the U.S. Department of Education (liED"). 

Page 12 
113 

l1T Educational Services,. Inc. 

The Honorable Thomas R Carper 

The Hono.rahle Tom Coburn 

August 5, 2013 

ITT Tech - Ethics and Compliance Programs gnd Training for All Employ~ and Rec:ruinnent 

Repreaentativ£S 

All fIT Tech employees "'" required to be fully knowledgeable of and conver.;ant with lIT 

Tech's Policies and Procedures, Codes~ Handbooks, etc.~ (policy or Policies), which govern their 

conduct and are readily available to employees on the TIT Tech Employee Portal Key Policies 

include: 

• The Code of Business Conduct and Ethics for Employees; 

• The Employee Handbook; 

• General Po1ities which apply to alI Employees; 

• Recruitment Policies; and 

• Legal8Ild Ethical Principles to be Followed by Recruitment Personnel. 

When hired. employees me required to successfully complete, and recertify bi-annually, a 

course entitled "The Code of Business Conduct and Ethics for Employees." Additionally, recruitment 

perSonnel who meet with prospective studen:ts are also required to take, and successfully pass, a series 

of courses related to "Recruitment Policies"" m:iQr to meeting with a prospective student. 

Enrollment Proass - Required Documentation aDd DisdoSURS 

To ensure that prospective students receive accurate infonna.t:ion about ITT Tech, and to guard 

against misrepresentations, lIT Tech utilizes a standard electronic recruitment presentation (Standard 

Presentation), that cannot be altered or amended by recruitment personneL Each recruiter is required 

to use !he Standard Presentation and must be «certified" that sIhe is fully conversant with its content 

prior to meeting with a prospective student. While rhe Standard Presentation covers a broad range of 

infonnation about m Tech, a portion of the presentation that would have been given to Ms. Crawford 

and Mr. Toller, provides rhe following information about m Tecfl's accreditation. 

"Accredited by the Accrediting Council for :Independent G9lleges and Schools') 

(empbasis added). 

Once a prospective student has met with a recruitment representative and a member of the 

Finance Department, and bas decided that slbe would like to enroll at lIT Tech, the prospective 

student is required to review and sign a series of documents, agreements and disclosures, including, 

among orhers, an: 

Page 13 

• Enrollment Agreement (EA); and 

• Cost Summary and Payment Addendum to Enrollment Ag"",ment (CSPA or EAlCSPA). 

In relevant part, the EA provides as follows: 

"3.. Catalog: Student agrees to all tenns of the School catalog, as revised and amended from 

time to time by the School ("Cata1og"). The Catalog contains, among other things, 

information about the School, the Program and the Program courses. Prior to Student signing 

this Agreement, the School bas given Student a copy of the current Catalog. (See the 
114 

m Educll1i<maJ Services., Inc. 

The HooorBble Thomas R. Carper 

The Honorable Tom Coburn 

August 1,2013 

Acknowledgment Section below.) All !<nnS of the Catalog are incofporated in this Agreement 

and made a part of this Agreement as if they were originally and fully set forth in this 

Agreement, and the Catalog constitutes an addendum to this Agreement. If any tenns of the 

Catalog conflict with any terms of this Agreement, the tenns of this Agreement will control in 

detennining the agreement between Student and the Schoo!." 

ITT Tech'. Catalog i. also posted on the ITT Tech web.ite and is readily available to 

prospective students, current students and the public at large. With respect to m Tech'. 

Accreditation, the Catalog contains the following information: 

"Accreditation 

Accredited by the Accrediting Ccuncil for Independent College., and Schools to award 

associate of applied science degrees and bachelor of science degrees. 

Accrediting Council for Independent Colleges and Schools 

750 First Slreet, NE Suite 980 

Washington, OC 20002-4241 

Telephone: (202) 33 &-6780 

Evidence of the institution's accreditation is on display at the school or may be obtained from 

the Director." 

Also, governing the enroJhnent process is mlESI Recruitment Procedure 1.4, Documentation 

and Disclosure SUrnrn.aI)' Completion Procedure, which. in relevant part, provides as foHows: 

Pagel 4 

"It is policy of the Company to provide both prospective and reentry students (prospective 

students) with important infornlBtion about ITT Technical lnstitute, including, without 

limitation, all disclosures required by applicable laws and regulations, and sound business 

practices, including details on cost of attendance and refund procedures. Further, Company 

policy requires that the prospective student. and a witness. must sign the Documentation and 

Disclosure Summary which serves as eviden"c that the prospective student received and 

IF~~ documet!-ts and disclosures critical to providing sufficient information !hY:iJl..&Jh.~ 

enrollmen~ process"" (emphasis added). 
115 

lIT Educationa1 Services,. Inc. 

The Honorable Thomas R.. Ca:rpc:r 

The Honorable Tom Cooum 

August 5, 2013 

The "Documentation and Disclosure Summary" (Disclosure Summary), which all prospective 

students receive and are required to sign and acknowledge, is as foHows: 

"DOCUMENTATION AND DISCWSURE SUMMARY 

I, _____ ' acknowledge and agree that I have received and reviewed 

the following documents and disclosures as part of my enrollment in a program of study at 

m Technical Institute and that all of the fullowing docomenlS and disclosures were fully 

completed. 

EnrolJment AgreemeDt 

[J Including Cost Summary and Payment Addendum 

School Catalog 

The following topics are outlined in the School Catalog: 

C Program of Study CUrriculum 

o Homework 

o Attendance Requirements 

o Unlikely Transferability of Credits to Other Institutions 

Student Conduct 

o Student Complaint/Grievance Procedure 

11 Resolution of Disputes 

n Financial Aid Assistance 

Ll Career Services Assistance 

n Accredited by the Accrediting Council for fudependent Colle&..~iID4 Schools 

IACICS) (emphasis added). 

Student Handbook 

Graduate Employment Information (or State Specific. 88 3Pplieable) Disdosure 

Student Right~to-Koow Act Disdoslll't:S 

Applicant Signature: ___________ Date: 

~::~~~e: ~i~::;--------

Note: Original is maintained in the Prospective student's File, and a copy must be provided to 

the Prospective student." 
116 

rrr l-":ducational Sel'\lices. Inc. 

The Honorable TholIlti It Carper 

The Honorable Tom Coburn 

August 5, 2013 

Of particular interest i. the G",duale Employmenl Infonnalion Disclosure (GEl Disclosure), 

which is referenced above in the Disclosure Summary and provides prospective students with 

infonnation regarding reoenl graduares from the prospective student'. prognun of study. While the 

GEl Disclosure is discussed more fully below as it relates to Mr. Toller's claim that he was "duped." 

the GEl Disclosure provides the prospective student with information, among other things, about the 

(i) the number of grnduates and employed grnduates and (il) !be high, average and low salary of those 

employed grnduaies. Prospectivo studeots an: required to oonfum, by signature, that they have read 

and understand the GEl Disclosure. 

Howard ToOer - Student at the lIT Teehnicallnstilotes in Seattle, WA and Cary, NC 

Complaint "Duped by Their Advertising" and "Not Properly Accredited by a National Or!!ll!!ization" 

According to Mr. Taraotioo's smtemen~ Mr. Toll .. alleges that "[h Je enrolled in m in 2010 

for a degree in computer networking servic~ and 1ater admitted that he was duped by their 

advertisin •.... " (emphasis added). If Mr. Toller was doped when be enrolled in 2010, the Committee 

must ask, why then did he re-enroll two more times.. once in March 2011 and then again in December 

2011. 

The public "",oro reflect> that HoWBrd Toller enrolled in the Associate Degree prognun in 

Infonnation Tecbnology-Compnter Networl< Systems (ITCNS) at the m Tech in Seattle, W A, and 

attended for three academio quarters beginning in June 2010 before dropping out in March 20 II. As 

noted above, prospective students enrolling at that time would have: 

• been required to sit through the Standard Presentation; 

• signed an EA and a CSPA; 

• signed the Disclosure Summary (which references accreditation); and 

• received the GEl Disclosure. 

When Mr. Toller fust enrolled in the ITCNS prcgnun of study at the m Technical Institute in 

Seattle W ~ prospective students received a GEl Disclosure which, in relevant part, provided that. of 

the 29 total grnduaies of the prognun in 2008, 79%, or 23, of those graduate were employed in 

positions utilizing their education at an average salary of $40,646. 

While Mr. Tatantino advised the Committee that Mr. Toller, "was duped by their rm-Tech'!] 

advortising [in 2010] "Mr. Toller subsequently re-enrol1ed a second time in the ITCNS prcgnun of 

study at the m Technical InstiUlte in Cary, NC in March 2011 (emphasis added). As a prospective 

student who enrolled at that time, Mr. Toller would have again: 

• been required to sit through the Standard Presentation; 

• signed a new EA and CSPA; 

• signed a new Disclosure Summary (which references accreditation); and 

• received a new GEl Disclosure. 

Mr. Toller attended the m Technicallnstitute in Cary, NC for one academic quarter 

beginning in March 2011 before dropping from his prognun of study in June 2011. 

Pagel 6 
117 

ITT Educa1ionaJ Services, Inc. 

The Honorable Thomas R. CIUper 

The Honorable Tom Cobum 

August 5.2013 

Thereafter, despite Mr. Tarantino's claim that Mr. Toller, "was duped by their !ITT-Tech'.l 

adyertising fin 20 lO]," Mr. Tollor then enrolled a third lime in the !TCNS program of s!u!\y at the ITT 

Tecbnicallnstitute in Cary. NC in December 2011 (emphasis added). This time, Mr. Toller remained 

enrolled for approximately four academic quarters before again dropping from his program of study in 

December 2012. As a prospective student who enrolled at that lime, Mr. Toller would bave, fur the 

third time: 

• been required to sit through the Standardized Presentation; 

• sign a new EA and CSPA; 

• signed a new Disclosure Summary (which references accreditation); and 

• received a new GEl Disclosure. 

In December 2011, prospective students enrolling in thelTCNS program of study at the ITT 

Technical Institute in Cary. NC campus would have received a GEl Disclosure which, in relevant part, 

provided tba~ of the 28 total graduates of the program in 2010, 82%, or 23, of those greduates were 

employed in positions utilizing their ednc.ation at an average sa.lary of$31,295. 

Finally, while Mr. Tarantino stated that Mr. Toller clams that his "degree" from IT Tech is 

worthless, the fact is, as explained ahove, Mr. T{)lIer never graduated from an ITT Tec:hnicalInstitute 

and, therefore, has no ITT Tecb degree. In addition. the placement rates and average salary of 

graduates from Mr. ToUer's program at each time of his enrollment suggest a different level of 

program quality. 

Howard Toller - Conclusion 

Mr. Tarantino claims that Mr. Toller says that be was "duped" by ITT Tech and thaI "a couple 

montha after be enrolled be learned that ITT Tech wasn'l properly aeeredited by a national 

organization, thereby rendering his degree worthless."" The truth is, however, that m Tech was (and 

is) aceredited by ACICS, an accrediting agency recognized by the U.S. Department ofEducstion and 

prospective students. such as Mr. Toller, who enrolled at ITT Tech were fully apprised of the nature of 

ITT Tech's accreditation and, among other things, the success of previous greduates of that program of 

study. In addition. the program for which Mr. Toller was enrolled does nol require programmatic 

accreditation and be n><lnrolled two more times after aUegedly learning that ITT Tech was Dol 

properly accredited. 

ITT Tech would need a FERPA consent from Mr. Toller before it can demonstrate via grades, 

attendance records, student surveys, and other education records to the Committee that the claims Mr. 

Tarantino attributes to Mr. Toller are inaccurate, including the claims with respect to whether his 

"classes are subpar, the teaching is subpar. and the instructors are subpar." 

Page 11 
118 

ITIEducatiOWll Serviccs,Inc. 

The Honorable ThOlllllS R.. Carper 

The HonorabJe Tom Coburn 

AugustS, 2013 

Margaret "Maggie" Crawford - Student at Strongsville, OH 

Complaint - Accreditation 

Mr. Tarantino states that "[a ]ccording to Maggie. lIT was also dishonest about its nursing 

accreditation." Margaret "Maggie" Crawford enrolled in the Associate Degree program in Nursing at 

the fIT Technical Institute in Strongsville, OH in September 2011 before dropping from her program 

of study in December 2011. 

As noted above, prospective students enrolling at that time would have: 

• been required to sit through the Standard Presentation; 

• signed an EA and CSPA; 

• signed the Disclosure Summary (which references accreditation); and 

• received the GEl Disclosure. 

As a result, prospective students. such as Ms. Crawford. enrolling at that time would have 

been funy informed nffIT Tech's accreditation bY the ACICS. Also, since the fIT Tech's 

accreditation by the ACICS is disclosed in the school catalog and posted on the fIT Tech Web site, 

prospective students can access that infonnation at any time prior to enrollment. 

It is true that at the time ofMs. Crawford's enrollment,. our Nursing Program was not 

accredited by the National League for Nursing Accrediting Commission (NLNAC). and we stiU do not 

have this accreditation. Nnrsing Program. are not eligible to apply for NLNAC accreditation until the 

tim class of students has geeduated. As the first grnduating class from the N1ll1ling Program at 

Strongsville did not complete their program until June 0[2013, NLNAC accreditation would not even 

have been possible at the time of Ms. Crawford's enrollment. 

As to not deliberately or otherwise mislead prospective students with respect to the Nursing 

Program's accreditation, a discussion ofNLNAC accreditation does not appear in the approved 

Enrollment Presentation. E.A or signed Disclosure Summary that prospective students recei .... e. The 

Catalog doe' provide, however, that "[ u jpon grnduation from the Nursing program geeduates are 

eligible to make application to the National Council of Stab:: Boards of Nursing (~CSBN") National 

Council Licensure Examination for Registered Nurses ("NCLEX-RN')." 

Complaint - Financial Net 

Mr. Tarantino states that <I[i]t wasn't until the second quarter of her program that they [lIT 

Tech] told her she didn't have 100 percent GlBiI! coverage and couldn't request a Yellow Ribbon 

scholarship." 

ITT Tech supports and participates. in a broad range of programs for service members and their 

families, including the following: 

• the Post 9111 G.!. Bill Education Program; 

• the Department ofDefunse" Military Spouse Career Advancement Accounts MyCAA; 

PagelS 
119 

rnEducal.ionIllServices,.lnc. 

The Honorable TOOma.'l R. Carper 

The HODOmbk Tom Coburn 

August S, 2013 

• the Yellow Ribbon G.1 Education Enhancement Program; 

• the Montgomery OJ. Bill Education Program; 

• the Reserve Education Assistance Program (REAP); and 

• otherfin.mcial aid programs for those who qualify, including grant, loan and scholarship 

programs 

In relevant part, the m Tech website also provides as follows: 

"YELLOW RIBBON GI EDUCATION ENHANCEMENT PROGRAM 

The Yellow Ribbon GI Education Enhancement Progrsm (Yellow Ribbon Program) i. a 

provision of the Post-9/1! Gr Bill Veterans Edw;ationaJ Assistance Act of200S. Under this 

program. m Tecbnicallnstitures have entered into an agreement with the United States 

Depar1menl of Veterans Affairs (VA) to fund the toition expenses of eligible students which 

exceed the highest public in-state undergraduate toition rate. ITT Technicallnstimtes and the 

VA each contribute 50010 of those excess expenses. 

Under the Yellow Ribbon Progrun, ITT Technical InstiIU!es: 

• Provide contributions to eligible students who apply for the YeJIow Ribbon Program on a 

first-come first~served basis, regardless of the rate at which the student is pursuing training 

in any given academic year; 

• Provide contributions during the current academic year and aU subsequent academic years 

in which the lIT Technicallnstitutes participate in the Yellow Ribbon Program and the 

student maintains satismctory academic progress, conduct, and attendance; 

The Post-9/11 Gr Bill Veterana Educational Assistance Act of200S (post-9/11) pays up to the 

highest public in-state undergraduate tuition charged to eligible students. If an eligible student's 

tuition and fees exceed the highest public in-state undergraduate tuition, additional funds are 

available under the Yellow Ribbon GI Education Enhancement Program (Yellow Ribbon 

Program) for the tuition costs without an additional charge to the student's VA entitlement. 

Only students entitled to the maximum benefit rate (based on service requirements) may 

receive Yellow Ribbon Program funding. Therefore, a student may be eligible ifhe or she: 

Served an aggregate period of active duty after September 10. 200 1. of at least 36 months; 

WB1i honorably discharged from active duty for a service connected disability and served 

30 continuous days after September 10.2001; or 

• Is a depeudent eligible for Transfer of Entitlement under the Post-9I!! GIBill based on a 

veteran's service under the eligibility criteria listed above. 

More infonnation about the Yellow Ribbon Program and the Post··9f11 Veterans Educational 

Assistance Act of200S can be found on the VA's website at www.gibilLva..gov." 

When. veteran e""'Us atm Tech, the EAlCSPA is completed by the prospective student and 

the school. and the school provides. among other things, an estimate of potential financial aid for 

which the service member or his/her family member may qualify. The CSPA provides as follows: 

Pagel 9 
120 

mEducationai Scrvices, IDe. 

The Honorable Thomas R. Carper 

The Honorable Tom Coburn 

August S, 20tJ 

"Estimated Funds tile Sc:bool EXpects' to ~ewe From or on Behalf ofStudeoc 

$.00' Ql $Ql 

VA Chapter 33 Benefit Tota1Amount Q2 $Q2 

r-vA-Yel1owRib~ -_._----- -~- $03 

$.00 Ql $QI 

Program Benefit Total Amount Q2 $Q2 

I (VAYRPB) Q3 $03 

School Matching VA $.00 QI SQI 

Yellow Ribbon Program Tota1Amount Q2 $Q2 

Benefit (VA YRPBl- Q3 $Q3 

$.00 Ql $QI 

Federnl Pell Grant Total Amount Q2 $Q2 

Q3 $Q3 

Federal Subsidized [Etc. Etc. Etc.] 

StaIford LOAN 

: ($0 Less Fees): 

Federnl Unsubsidized 

StaIford LOAN 

, ($0 Less Fees): 

Federal PLUS LOAN 

(SO Less Fees): 

Bank LOAN: OTHER 

Academic 

Competitiveness Grant: 

SMART Grant: 

Family Supplemental 

Educational 

! Opportunity Grant: 

Other: New Temporary 

Credit 

Other: New Temporary 

Credit Exemption 

TOTAL 

"'Note, an actual EAlCSPA would be completed with quarter by quarter estimates, not zeroes. 

While ITT Tech provides the student with an "estimate." it is the student's responsibility to 

apply for and make certain eJections which are approved by the U.S. Department ofVetenms Affairs 

(VA). The VA then issues the student a Certificate of Eligibility (CDE) which formally advises the 

student of the benefits for which slhe would qualify. If the student delays the COE process, for any 

reason, including the failure to complete andlor submit all applicable fonns. etc~ the VA's 

determination of benefits may be delayed for weeks. even months. 

Page 110 
121 

fIT HduCIflional Services, Inc. 

'Tht: Honorable Thomas R. Carper 

The Honorable Tom Coburn 

AUPFS1S.2013 

Again, it is the student who has an affmnative duty to select henefits and complete the 

appropriate forms. And, it is the V A, Dot individual institutions, !hat detennines a stodent's percentage 

of veteran benefits and eligibility for the Yellow Ribbon Scholarship. 

While ITT Tech has additional infonnation about the handling of Ms. Crawfurd's financial aid 

that is roevant to the complaint that Mr. T8I1Illtino alleges was made by Ms. Crawford, TIT Tech is 

precluded from sharing this information with the Committee without first receiving a FERP A consent 

that Ms. Crawford has ",fused to provide. 

Regarding other types of fmancial aid, however, it should be noted th.t the Higher Education 

Act of 1965, as amended. requires each school 10 have a written policy for the return of Title N aid 

received by students who withdraw. tenninate enrollment or stop attending class before completing 60 

percent of the enrollment period Ali such, TIT Tech requires exit counseling in wbicb all students are 

informed of the financial ramifications of withdrawing from class or tenninating enrollment prior to 

completion of the academic quarter. 

Complaint - Classroom Concerns 

Mr, Taraotino states that Ms. Crawfurd further alleges that, "her professors discouraged bet 

from asking questions, insisting that all the answers she needed would be in the bock.» The TIT Tech 

instructors who taught the course sections in which Ms, Crawford was "'Sisiered deny that they 

refused to answer any student's questions, and TIT Tech has never received any student complaints 

with respect to those instructor:s in that n:Jgani. Those same instructors also said that they encourage 

students to look for answers in the course materials before they would give the student the answers. 

This is a common and respected pedagogy followed by lIT Tech instructors because it encourages 

students to study their cou:rse materials and helps them learn. 

Unfortunately, without a FERPA consent from Ms. Crawford allowing nT Tech to share 

infonnation from her education reconl with the Committee, ITT Tech cannot fully demons.trate that the 

claims Mr. Tarantino attributes to Ms. Crawford are inaccurate, inc1uding those wherein he alleges that 

she was improperly discouraged from asking questions. 

Margaret "Maggie" Crawford - Conclusion 

Mr. Tarantino's claims that, with respect to Ms.. Crawford, m Tech misrepresented its 

accreditation, fuiled to properly advise her concerning ber VA benefits, and then discoumged ber from 

asking questions in class are inaccurate. The truth is (i) that ITT Tech was (and is) accredited by 

AcrCS, an accrediting agency...oognized by th. U.S. Department of Education (ii) that prospective 

students, sucb as Mr. Crawford, who enrolled at ITT Tech, w"'" fully apprised of the 08_ of ITT 

Tech's accreditation and, among other things, (iii) !hat it does not improperly advise students 

regarding their VA benefits but rather relies on the student to obtain a COE, and that its fmancial aid 

staff only estimates benefits, (iv) that it advises students of the financial ramifications of withdrawing 

before completing an academic quarter, and (v) that it its instructors do not improperly discourage 

students from asking questions. 

Page III 
122 

rrr EdU(,:l1tiOlUll Services, Inc. 

The Honorable Thomas R. Carper 

'Inc Honornhle Tom Coburn 

August S. lOB 

Again, without. FERPA con,ent from Ms. Crawford,lIT Tech is unable to respond, with 

specificity, to each and every allegation made by Mr. Tarantino aUegedly on behalf of Ms. Crawford. 

Conclusion 

In closing, m Educational Services~ Inc. and the ITT Technical Institutes would like to thank 

the Committee for this opportunity to respond to Mr. Tarantino's Slalement and requests that, should. 

FERPA consent be signed by either Mr. Toller and/or Ms. Crawford, it would be pennitted to amend 

its response and the Record. 

per 

• Chief Compliance Officer 

Educational Services, Inc. 

13000 N. Meridian Street 

Cannel,lN 46032 

cc: Members of the U.S. Senate Committee on Homeland Security & Governmental Affairs 

Page 112 
123 

..At The Art Institute of Pittsburgh ~ Online Division 

ADA ACCOMODATION: CONFIRMATION OF ACCOMODATION 

Student Name: Christopher Pantzke (0906054080) 

Accommodations for this student have been approved by the Accommodations Committee. 

Any questions or concerns regarding these accommodations should be directed to Disability 

Services at aiods@aiLedu. 

Thefollowing accommodations have been approvedfor this student: 

• Allow student 1-112 time (an additional 50% time) in completing assignments. 

The above accommodations are being provided for the following terms and for the indicated 

academic year. 

• Accommodations approved for the remainder of student's current degree program. 

DigitaHysig"edby$arahP,White 

Sarah D Wh,"te "",rn=S".hD.Whl'.,o='DMC,=_O,'Joo • StudentAff>ljr5,emili!""~whlte@edmc,edu.-o:oUS 

Oate:2()tO.l0.2908;03;SO-04'OO· 

School Official Signature 

Campus Use Only: 

October 29.2010 

Date 

Date Confirmation of Accommodations Form completed: 10128/10 

Date Confirmation of Accommodation Form provided to student: 10/29/10 

All accommodations, unless otherwise noted, are for the duration of the student's current program. A change of 

program, change of student status, or change in requested accommodations will be reviews by Disability Services 

Accommodations Committee. 
124 

PASSBACK QUESTIONS FOR THE RECORD 

U.S. Senate Committee on Homeland Security and Governmental Affairs 

The 90/10 Rule: Improving Education Outcomes for our Military Veterans 

July 23,2013 

Post-Hearing Questions for the Record Submitted to Curtis L. Coy from 

Senator Tom A. Coburn, M.D. 

1. Too often veterans enroll at colleges and universities and despite having GI 

Bill benefits that cover tuition costs, choose to also take out student loans under 

the Department of Education's Title IV program. While it may be necessary in 

limited circumstances, this also can lead to over-borrowing that burdens the 

financial futures of these individuals and their families. What in your opinion can 

be done to help prevent unnecessary borrowing? 

VA Response: While some borrowing is unavoidable, the Department of Veterans 

Affairs (VA) believes Executive Order 13607, Establishing Principles of Exce"ence for 

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

Family Members, will help reduce unnecessary borrowing. Prior to enrollment, 

educational institutions will be required to provide prospective students, who are eligible 

to receive Federal military and Veterans educational benefits, with a personalized and 

standardized form, as developed in a manner set forth by the Secretary of Education, in 

collaboration with the Secretaries of Defense and Veterans Affairs, to help those 

prospective students understand the total cost of the educational program and the debt 

burdens associated with any educational loans for that program. The prospective 

students will get a break-out of the tuition and fees; the amount of that cost that will be 

covered by Federal educational benefits; the type and amount of financial aid for which 

they may qualify; the estimated student loan debt upon graduation. The information 

also covers program outcomes; and may include other information to facilitate 

comparison of financial aid packages offered by different educational institutions. In 

addition, students can now take advantage of new tools that can help them better 

understand their loan debt and stay on track in repayment. The Department of 

Education has launched two key features on its StudentLoans.gov website: a Complete 

Counseling Web page and a new Repayment Estimator that lets borrowers compare 

what their monthly payment amounts would likely be across all seven repayment plan 

options. Among other things, this online resource provides students with the basics of 

financial management and information about their federal student loan debt (and total 

student loan debt if they enter information about their private student loans), estimates 

what their student loan debt is likely to be when they leave school, and provides 

financial planning tips. 

2. Under current law, financial aid officers at colleges and universities cannot 

restrict the amount of money a student borrows, even if they know these students 

are over-borrowing. While they do have the authority under law to exercise what 

is known as "professional judgment" so that students can access federal dollars, 

they are powerless to keep students from needlessly racking up debt. Do you 
125 

support giving financial aid officers greater "professional judgment" to rein in 

unnecessary borrowing in limited circumstances? 

VA Response: VA defers to the Department of Education with regard to allowing 

financial aid officers greater "professional judgment". 
126 

Post-Hearing Questions for the Record 

Submitted to Hollister K. Petraeus 

From Senator Thomas R. Carper 

"The 90/10 Rule: Improving Educational Outcomes for Our Military and Veterans" 

July 23, 2013 

1) Your testimony discussed the data crosswalk that the Departments of Veterans Affairs, 

Defense, and Education are developing to link the Education Departments database of 

schools (over 7,000 institutes of higher learning) to the VA's lists of approved programs 

(over 30,000). Is it accurate to say that the federal government lacks basic data on where GI 

benefits are spent, the extent to which those benefits cover tuition and fees, and how much 

and what type of student loan debt veterans incur? When will this crosswalk be available? 

Response 

Pursuant to Executive Order (EO) 13607, "Establishing Principles of Excellence for Educational 

Institutions Serving Service Members, Veterans, Spouses, and Other Family Members" and the 

Comprehensive Veterans Education Information Policy law (Public Law 112-269), the 

Department of Veterans' Affairs (VA), Department of Defense (DoD), and Department of 

Education (ED) have been working on a data crosswalk to link ED's database of schools to the 

VA's list of approved programs. 

While each of those departments possesses rich data on the benefits they administer, the lack of a 

crosswalk makes it difficult to compare data across federal agencies. For example, the VA 

knows how much money they spent in tuition and fees per beneficiary at a particular educational 

institution, but the V A does not know the average retention rate for students attending the same 

institution. 

Once completed, the crosswalk will allow VA, DoD, and ED to share data about educational 

institutions across agencies, improve consumer information available to beneficiaries, and allow 

VA to track outcome measures that compare education benefit programs. 

This crosswalk will be available sometime this fall. 

2) Your testimony discussed the new complaint system for service members and veterans that is 

scheduled to go live later this summer. Can you describe the shortcomings in the various 

departmental complaint systems--Education, Veterans Administration, and DOD-that 

necessitated the creation of this new system? How will the new system address those 

shortcomings? 

Response 
127 

While the Consumer Financial Protection Bureau (CFPB) handles consumer financial product 

and service complaints and includes those complaints in the Federal Trade Commission's (FTC) 

Consumer Sentinel database, there is currently no similar mechanism for different agencies or 

branches of the military to share complaints about educational institutions. 

For example, if a servicemember or veteran submits a complaint about an educational institution, 

there is no formal process to account for the complaint or share it between agencies. Complaints 

about educational institutions have been dealt with on an ad hoc basis between agencies, making 

issues and trends difficult to identify and resolve. 

As part of implementation efforts of EO 13607, VA partnered with DoD, ED, CFPB, the 

Department of Justice, and the FTC to develop a centralized complaint system for educational 

institution complaints. Beneficiaries of military and veteran education benefits will soon have 

the opportunity to submit feedback about educational institutions that fail to follow EO 13607's 

Principles of Excellence. 

VA's implementation plan for EO 13607 will allow beneficiaries to submit feedback or 

complaints via the OJ Bill Hotline (1--888--442-4551), or via an online web form located on 

gibill.va.gov and eBenefits.va.gov. This feedback will be shared internally with State Approving 

Agencies (SAAs) and VA personnel. 

To create a centralized repository for these educational institution complaints, VA, DoD, and ED 

will begin forwarding complaints each agency receives to the FTC's Consumer Sentinel 

database. V A, DoD, and ED have been working with the FTC to streamline this submission 

process by standardizing the complaint intake form and the files provided to the FTC. 

Once these educational institution complaints reside in the Sentinel database, any law 

enforcement agency (federal, state, and local) that has access to Sentinel will also have access to 

those complaints. VA is working with the FTC to gain access to the Consumer Sentinel database 

for V A personnel. 
128 

September 17, 2013 

Via Emai! (laura kilbride0Jhsgac.senate.gov) 

The Honorable Tom Carper 

Chainnan 

U.S. Senate Committee on Homeland Security and 

Governmental Affairs 

340 Dirksen Senate Office Building 

Washington, DC 20510 

Dear Senator Carper: 

In response to your letter of August 21 , 2013, attached please find answers to the questions posed 

following the hearing titled "The 90/10 Rule: Improving Educational Outcomes for our Military and 

Veterans." r greatly appreciated the opportunity to testify before your Committee and discuss the 

commitment of private sector colleges and universities to our nation's veteran and military students. 

[fyou have any additional questions. please do not hesitate to contact me. 

Sincerely, 

Steve Gunderson 

President and CEO 

Attachments (2) 
129 

Post-Hearing Questions for the Record 

Submitted to The Honorable Steven C. Gunderson 

From Senator Thomas R. Carper 

"The 90/10 Rule: Improving Educational Outcomes for Our Military and Veterans" 

,July 23. 20U 

1) The Blue Ribbon Task force, which you described in your testimony. recommcnded that schools 

consid(;'r assessing academic readiness prior to enrollment. Why isn't such an assessment a prerequisite for admission? 

The APSCU Blue Ribbon Task Force was established to develop best practice recommendations for 

our member institutions and for all of postsecondary education to the extent institutions found the 

recommendations applicable to their individual programs. The actual recommendation related to 

enrollment is for institutions to "ensure students arc appropriately placed and prepared for the 

programs in which they enrol1." Assessing academic readiness prior to enrollment is one means 

identified for accomplishing the recommendation. However. for many or our institutions that have 

open admissions policies similar to our community college colleagues, other means for assisting 

students included in the Best Practices are: offer appropriate remediation if necessary; offer limited 

course loads: offer a reasonable trial period ror enrollment: offer penalty-free drop/add periods upon 

cnrollment. The extent to which an institution engages in pre-enrollment testing will depend on each 

individual institution's established practice. 

2) Your testimony highlights the -2.2 percent decrease in the cost to students at for-profit schools 

compared to an increase of 6.7 percent for in-state tuition at public schools. This is welcome 

news, but isn't the cost ofa degree at a for-profit school. e.g. an associate business degree, 4 to 5 

times more expensive than at a public institution? What accounts for this significant disparity? 

The tuition statistics cited arc taktm directly rrom the U.S Department of Education report: 

Postsecondary Institutions and Cost of Attendance in 2012-2013; Degrees and other Awards 

Conferred. 201 1- 12; and 12-Month Enrollment. 2011-2012. July 2013. The statistics apply to four 

year institutions where most students arc enrolled. As stated in the report. "[a]fter adjusting ror 

inflation, public institutions reported a 7 percent increase (to about $7500) for in-state students and a 

4 percent increase (to approximately $1 7,0(0) for out-of·state students and nonprofit institutions 

reported a 3 percent increase (to about $24.300). For profit institutions reported average tuition and 

required fees of approximately $15.400 for 2012~ 13, which represents a decrease of2 percent when 

compared w-ith the inflation-adjusted figure from 2010-11:' In Fiscal Year 2012, a total of$81.1 

billion in educational appropriations for higher education was spent by state and local 

governments, accounting for a combined 57% of total revenue supporting general operating 

expenses of public higher education institutions, according to the State Higher Education 

Finance FY 2012 Report of the State Higher Education Executive Officers (SHEEO). 

Any accurate comparison of the cost to attend a private sector college versus a public college should 

factor in the significant public subsidy provided by state taxpayers. As noted above, the price at 

private sector colleges is very similar to out~()f.·statc students at public institutions (those not 

benefiting from state taxpayer subsidies). 
130 

3) Your testimony indicated that 75 percent ofvcteran graduates at for~profit schools carned 

certificates and associate degrees \\'hile 25 percent earned bachelor and graduate degre.::s, Can 

you tell us \~.:ha1 the withdrawal rate was for veterans at t{)r-profit schools? 

The Depanment of Education does not report withdra ... val rates. so I don't have the information to 

answer your question, However. the most recent data. which Vvas released in Decemher 2012. show 

the four year graduation rate at private sector institutions is 42%. an increase of nearly 14% since the 

previous year .... vhilc the other sectors show little or no change, The 14% increase is eyidence of the 

cffons being made by our institutions to help more of the new traditional student who has multiple 

risk factors (Pel! eligible. single parent. older and "yorking full or part time) succeed in postsecondary 

education. it is ..... orth noting that our institutions do not apply selective admissions nor do they 

predominantly enrol! middle and upper class students, Moreover. this same report sho\vs that our 

graduation rate at two year institutions is 62.7%. which leads all institutions. 

4) How many for-profit schools would he at risk for losing access to federal taxpayers' dollars if the 

90/10 rule were modified to include veteran and military service memhcr educational benefits on 

the 90 percent side ofthc equation? 

APSCU docs not have institutional levd information with respect to vetcran and military benefits so 

we cannot provide a definitive answ'cr to your question, I can provide you with some independent 

insight into this issue by sharing a report that Mark Kantrowitz. a nationally-recognized expert on 

student financial aid, recently published. in his paper Mr. Kantrowitz \\-Tote: 

"Counting military student aid in addition to Title IV federal student aid ... \·ould increase the 

percentage of revenue from federal studcnt aid by ahout 2 percentage points on average. 

While this is not much ora change overall. individual col!ege~ that are more reliant on 

military student aid might be more significantly impacted by such a change in the scope of the 

90/10 rule. This includes colleges that have 1:1 high military student enrollment because they 

are bettcr at addrcssing thc needs of service members and vetcrans, The 90/10 rule might then 

preclude some veterans from enrolling in these colleges:' 

[···1 

[t is noteworthy that "[t]hc percentage of Tit!e IV revenue is highest at public colleges in part 

because they charge 10·wer tuition and fces. Generally. colleges that charge less than $8.000 in 

tuition and fees have a much higher 90/10 percentage than colleges that chargc $8.000 or 

morc, The lenver tuition and fees means that the federal student aid covers more of the cost. 

making it 1110re difficult for the college to comply with the 90/10 rule. Most public colleges 

,,",ould not be able to comply \-vith the 9011 0 rule if it applied to them. especially if statc 

appropriations and grants were included in the percentage of revenue from governmcnt aid, 

More than 90% of the real cost of education at public colleges and universities comes from 

federal aid. state aid and state appropriations." 

As Mr. Kantrowitz aSSerts "the 90/10 rule is ineffective at measuring educational quality, Instead, it 

depends heavily on the demographics of each college's student population. measuring ability to pay 

more than a 1-villingness to pay:' Sec Mr. Kantrowitz's fuJI report titled: Consequences qlthe 90/fO 

Rule, which is attached. 
131 

~Edvisors® Go Higher. 

Highlights of Consequences o/the 90/10 Rule 

The 90/10 rule requires private for-profit colleges to get at least 10% of revenue from sources 

other than federal student aid, based on a "skin in the game" rationale. 

Findings 

• This paper demonstrates that colleges that enroll significant numbers oflow-income 

(family AGl < $50,000) students are at greater risk of violating the 90/10 rule. 

• Other demographic characteristics that hurt compliance with the 90/1 0 rule include Pell 

Grant recipients, low EFC (especially zero EFC), underrepresented minority students, 

female students, independent students, GED recipients, low high school GPA, low 

admissions test scores, first-generation college students, part-time enrollment, and high 

unsubsidized Stafford loan amounts. 

• Colleges that charge under $8,000 in tuition are at greater risk of violating the 90/10 rule. 

• Counting military student aid in addition to Title IV federal student aid would increase 

the 901 I 0 percentage at private for-profit colleges by 2 percentage points on average. 

• Counting education tax benefits in addition to Title IV federal student aid would increase 

the 90/10 percentage at private for-profit colleges by 5 percentage points on average. 

• 42% oftuition revenue at private non-profit colleges, 70% at private for-profit colleges 

and 82% at public colleges (98% at community colleges and 77% at public 4-year 

colleges) comes from Title IV federal student aid. 

• The majority of public colleges, including 80% of community colleges, would fail the 

90/10 rule if it applied to them. This is due, in part, to the lower tuition at these colleges. 

• The need to comply with the 90/10 rule may cause some colleges to discriminate against 

high-risk students, perhaps by adopting more selective admissions policies. 

Recommendations 

The 90/10 rule measures ability to pay more so than willingness to pay. It is an ineffective proxy 

for direct measurement of educational qUality. This paper proposes several possible solutions. 

• Repeal the 90/10 rule, replacing it with direct measurement of educational quality (e.g., 

licensing rates on state licensing exams, pass rates on independent competency tests). 

• Exclude student loans from the scope of the 90/10 rule if the college has a high loan 

repayment rate. A loan that is repaid represents skin in the game. Alternately, count only 

the college's annual dollar default volume as part of revenue from federal student aid. 

• Exclude low-income students (e.g., Pell Grant recipients, zero-EFC students) from the 

90/10 rule calculation. 

• Count students only if their EFC exceeds the unsubsidized Stafford loan limits. 

• Waive the 90/10 rule for colleges that charge below-average tuition and fees and which 

have below-average tuition inflation rates as compared with public colleges or CPI-U. 

• Use a weighted measure where the 9011 0 percentage associated with an individual 

student is weighted by the student's EFC. This would count the contributions from highincome students more heavily than the contributions from low-income students. 
132 

Student Aid Policy Analysis 

Consequences of the 90/10 Rule 

Mark Kantrowitz 

Senior Vice President and Publis/rer of &/visors.colII 

August 19,2013 

OVERVIEW 

The 90/10 rule requires for-profit colleges to get at least 10% of their revenues from sources other than 

federal student aid. Proponents argue that the "skin in the game" rationale behind the rule ensures that the 

programs are of sufficient qUality that students are willing to invest some of their own money in their 

education. But low-income students may be incapable of contributing any funds to the cost of their 

education, even if they are willing to do so, because they lack financial resources. Accordingly, colleges 

that enroll significant numbers oflow-income students may be at greater risk of violating the 90/10 rule. 

This paper analyzes the characteristics of students and institutions that help or hurt a college's compliance 

with the 90/10 rule. For example, Federal Pell Grant recipients, low-income students, students with a low 

Expected Family Contribution (EFC) (especially zero EFC). students with greater utilization of federal 

unsubsidized Stafford loans, underrepresented minority students (especially Black and Hispanic students), 

female students, independent students, OED recipients, first-generation college students, part-time 

enrollment, and students with lower high school OPAs and test scores may hurt compliance with the 

90/10 rule. 

Collegesl may have a tendency to discriminate against these characteristics as the percentage of revenue 

from federal student aid approaches the 90% threshold. This type of discrimination may not be readily 

apparent, since these characteristics tend to be over-represented at the institutions that are subject to the 

90/10 rule. For example, colleges with about 62% or more of their enrollment receiving the Federal Pell 

Grant are at higher risk of non-compliance with the 90/10 rule. With only about a quarter of the students 

at public and private non-profit colleges receiving a Federal PelJ Orant,' for-profit colleges could reduce 

their share of Federal Pell Grant recipients and still enroll a greater proportion of Federal Pell Grant 

recipients than the traditional colleges. Similarly, adopting a more selective admissions policy might 

improve compliance with the 90/10 rule. 

Counting military student aid in addition to Title IV federal student aid would increase the percentage of 

revenue from federal student aid by about 2 percentage points on average. While this is not much of a 

change overall, individual colleges that are more reliant on military student aid might be more 

significantly impacted by such a change in the scope ofthe 9011 0 rule. This includes colleges that have a 

high military student enrollment because they are better at addressing the needs of servicemembers and 

veterans. The 90/10 rule might then preclude some veterans from enrolling in these colleges. 

Counting education tax benefits, such as the American Opportunity Tax Credit, Lifetime Learning Tax 

Credit and Tuition & Fees Deduction, as part of federal student aid would have a greater impact than 

counting military student aiel, increasing the percentage of revenues from federal student aid by about 7 

1 The term 'colleges' as used In this paper is Intended to include both colleges and universities. 

223.0% and 26.3%. respectively. 

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133 

percentage points overall. The increase would be 5 percentage points at private for-profit colleges, 4 

percentage points at private non-profit colleges and 10 percentage points at public colleges. 

Some opponents of the 90/10 rule have argued that the rule should be applied to all colleges, not just forprofit colleges, since the government should seek to improve the quality of all colleges. Overall, almost 

two-thirds of institutional revenue across all types of colleges comes from federal student aid. The figures 

are 42% for private non-profit colleges, 70% for private for-profit colleges and. 82% for public colleges 

(98% at community colleges and 77% at public 4-year colleges). 

The percentage of Title IV revenue is highest at public colleges in part because they charge lower tuition 

and fees. Generally. colleges that charge less than $8,000 in tuition and fees have a much higher 90/10 

percentage than colleges that charge $8,000 or more. The lower tuition and fees means that the federal 

student aid covers more of the cost, making it more difficult for the college to comply with the 90/10 rule. 

Most public colleges would not be able to comply with the 90110 rule ifit applied to them, especially if 

state appropriations and grants were included in the percentage of revenue from government aid. More 

than 90% of the real cost of education at public colleges and universities comes from federal aid, state aid 

and state appropriations. 

RECOMMENDATIONS 

As is, the 9011 0 rule is ineffective at measuring educational quality. Instead, it depends heavily on the 

demographics of each college's student population, measuring ability to pay more than willingness to pay. 

There are several possible approaches to addressing the shortcomings of the 90/10 rule, ranging from 

repeal, to exchiding high-risk students from the scope of the metric to normalizing the metric according to 

student demographics or the EFC distribution. One could use these solutions alone or in combination. 

Repeal the 90/10 rule. The 90/10 rule is one of several financial proxies for perceived 

institutional quality. including cohort default rates and gainful employment. But aside from 

limiting federal investment in postsecondary education, the 90/10 rule acts in conflict with key 

public policy goals, such as reducing college costs and increasing enrollment by underrepresented 

minority students, low-income students and other high-risk populations. Substituting direct 

measurement of institutional quality, such as licensing rates on state licensing exams and pass 

rates on independent competency tests, might be more effective. 

Exclude student loans Cram the 90/10 rule If the college bas a low cobort deCault rate.3 After 

all, if a loan is repaid. it represents skin in the game. Loans also aren't really financial aid, since 

they are usually repaid with interest. Alternately, one could count only the college's annual d01lar 

default volume as part ofthe revenue from federal student aid, so colleges with a higher default 

rate would be penalized in the 90/ I 0 rule. 

• Exclude low-Income students, sucb as Pell Grant recipients or zero-EFC students, Crom the 

90/10 rule calculation. By excluding low-income students, the 90/10 rule would measure the 

extent to which students who are capable of contributing financially to their education actually do 

so. This would eliminate much of the influence of demographics on a student's ability to have 

skin in the game. Most low-income students are generally incapable of contributing to the cost of 

their education. When a student has a very low EFC, the government is effectively saying that 

'It might be better to base this requirement on the college having a high loan repayment rate, since the cohort 

default rate is prone to manipulation by colleges. 

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134 

th~y cannot and should nor payout of pocket for any percentage of their college costs. Most 

Federal Pell Grant recipients are incapable of contributing 10% or more in funds from sources 

other than federal student aid. 

• Count only revenue from students whose EFC exceeds 10% of net tuition revenue or the 

unsubsidized Stafford loan limits. If the EFC is below the annual unsubsidized Stafford loan 

eligibility limits, the student is very unlikely to contribute to the 10% because the student can pay 

for their share of college costs entirely with federal student loans. 

Waive the 90/10 rule for colleges that have below-average tuition rates,4 below-average 

tuition Inflation rates and/or below-average dollar tuition increases as compared with 

public colleges, CPI-U or some other IndeL This would provide the colleges with an incentive 

to offer an affordable college education. 

• Use a weighted measure, where the 90/10 percentage is weighted by the student's EFC. This 

would count contributions to the 90/10 percentage from high-income students more heavily than 

contributions from low-income students. For example, one could calculate a simple weighting of 

the students' contributions to the 90/10 percentage by EFC as follows where fIX) = x: 

f.f=dCEFCi) * Contribution to WPercentage; 

f.f=t!CEFC/) 

A more sophisticated weighting would setf(x) = x for x > 5,000 andf(X) = 0 otherwise. This 

would count the contribution toward the 90/10 percentage of only those students who had an EFC 

greater than 5,000. 

METHODOLOGY 

The analysis in this report is based on data from the 2007-08 National Postsecondary Student Aid Study 

(NPSAS:08) and the 20 I 0-11 Integrated Postsecondary Education Data System (IPEDS). The NPSAS is a 

large survey conducted every four years by the National Center for Education Statistics (NCES) at the 

U.S. Department of Education. The 2007-08 NPSAS surveyed 114,000 undergraduate students about how 

they paid for college. The analysis ofNPSAS data was performed using the data analysis systemS and the 

PowerS tats system.6 

HISTORY OF THE 90/10 RULE 

The 90/10 rule requires private for-profit colleges' to get no more than 90 percent of their revenues from 

Title IV federal student aid. The rule is intended to ensure that students have "skin in the game" - that the 

college is of sufficient quality that the students and their families (or another source) are willing to pay 

part of the cost from their own funds. It is argued that the 90110 rule's restriction on the percentage of 

revenue from federal student aid yields an indirect metric of program quality. For example, The Institute 

for College Access and Success (TICAS) wrote "Someone other than the federal government will have to 

4 Below-average costs would include tuition and all required fees to prevent colleges from manipulating their 

compliance by increasing non-tuition charges. 

5 http://nces.ed.gov/dasol 

• http://nces.ed.goyldatalablpowerstats/ 7 The 90/10 rule applies only to private for-profit colleges. Public and private non-profit colleges are not required 

to comply with the 90/10 rule. 
135 

be willing to pay for its programs. This will happen only if the school is offering a quality education 

worth pay ing for." 8 

The 90/10 rule currently appears in section 487(a)(24) and (d) of the Higher Education Act of 1965 [20 

USC 1094(a)(24) and (d)]. The statutory language states: 

In the case of a proprietary institution of higher education (as defined in section lO02(b) of this 

title). such institution will derive not less than ten percent of such institution's revenues from 

sources other than funds provided under this subchapter and part C of subchapter I of chapter 34 

of title 42. as calculated in accordance with subsection (d)(l). or will be subject to the sanctions 

described in subsection (d)(2). 

The 90/10 rule was originally introduced as the 85/15 rule by the Higher Education Amendments of 1992 

(p.L. 102-325,7/23/(992). effective October I, 1992. 

A similar 85/15 student ratio rule for Veterans Affairs (VA) funding was introduced at about the same 

time. The student ratio rule. which was enacted by the Veterans' Benefits Act of 1992 (P.L. 102-568, 

10/29/1992) and which appears in 38 USC 3680A{d)(I), requires that no more than 85 percent ofa 

program's students be receiving funding from the Department of Veterans Affairs. A similar requirement 

appeared previously in 38 USC 1 673(d), which was enacted as part of the Veterans' Readjustment 

Assistance Act of 1952, also known as the Korean Conflict GI Bill (p.L. 82-550,7/16/1952). 

The 85/15 rule for federal student aid was subsequently changed to become the 90/10 rule by the Higher 

Education Amendments of 1998 (P.L. 105-244, IOnt(998), effective October I, 1998. This legislation 

also moved the language for the 90/10 rule from section 481 (b) of the Higher Education Act of 1965 [20 

USC 1088(b)] to section 102(b)(I)(F) [20 USC 1002(b){I)(F)]. The Higher Education Opportunity Act of 

2008 (P.L. 110-315,8114/2008) subsequently moved the language to section 487(a)(24) of the Higher 

Education Act of 1965 [20 USC 1094(a)(24)] and replaced the regulations for calculating the percentage 

of revenues with a statutory encoding in a new section 487( d). 

There are several pending legislative proposals for fixing flaws in the 90/10 rule: 

Loopholes in the types of aid that are counted as part of federal student aid 

o Some proponents ofthe 9011 0 rule want military student aid, such 01 Bill and Tuition 

Assistance funds, to be counted as part of federal student aid alongside Title IV federal 

student aid. Military student aid is not currently counted as part ofthe percentage Title IV 

revenue. Some for-profit colleges recruit members of the military to help them comply 

with the 90/10 rule. 

o Some proponents of the 90/10 rule want education tax benefits, such as the American 

Opportunity Tax Credit, Lifetime Learning Tax Credit and the Tuition & Fees Deduction, 

counted as part offederal student aid.9 

B Q&A on the For-Profit College "90-10 Rule", TICAS, October 30, 2011. 

• This proposal Is least likely to be enacted because of practical considerations. Education tax benefits are received 

long after the start of the academic year. Education tax benefits are also received directly by the family, not the 

colleges, so data on student utilization of education tax benefits is not available to the colleges. It might also be 

difficult to calculate the financial benefit. especially if a taxpayer claims benefits for two or more students. 

-4-
136 

Tighter thresholds on the percentage of revenues from federal student aid 

o Some proponents ofthe 9011 0 rule would like to see a return to the 85% threshold that 

was in effect when the 85115 rule was first adopted in 1992. 

o Some proponents of the 90/10 rule have proposed a ban on using federal student aid 

funds for marketing, recruiting and lobbying activities. This would be the equivalent of 

an 80120 rule, since many of the largest for-profit colleges currently spend about 20% of 

revenues on student recruiting, marketing and lobbying efforts. 

Opponents of the 90/10 rule argue that the 90110 rule forces colleges that are close to the threshold to 

increase tuition to compensate for increases in federal student aid. The Government Accountability Office 

(GAO) issue a reportlO that showed no "relationship between a school's tuition rate and its likelihood of 

having a very high 90/10 rate." Colleges with lower tuition rates did not have higher 90/10 percentages. 

However, the GAO study compared absolute tuition levels with absolute percentage Title IV figures, but 

did not study the correlations between changes in tuition levels and changes in the availability offederal 

student aid. 

The analysis in this paper refutes the GAO study by demonstrating an inverse relationship between tuition 

levels and the percentage Title IV federal student aid. The GAO study did find that colleges with a higher 

percentage of low-income students (e.g., Federal Pell Grant recipients) were more likely to have a higher 

90110 rate, consistent with the findings of the present paper. 

IMPACT OF THE 90110 RULE 

There is very little prior analysis of the impact of student characteristics on compliance with the 90/10 

rule. Most previous analyses evaluate the impact of the rule on postsecondary educational institutions, not 

students. 

It is possible to calculate the contribution of student and institutional characteristics to compliance with 

the 90/10 rule. Characteristics for which the percentage of revenue from federal student aid ("90/10 

percentage") is below 90% will contribute to a postsecondary educational institution's compliance with 

the 90/10 rule, while characteristics for which the 90110 percentage is 90% or greater will make it more 

difficult for the institution to comply with the 90/10 rule. 

The 90/10 percentage for a characteristic can be approximated by calculating the ratio of the meanll total 

Title IV federal student aid to the difference between mean tuition and fees and mean institutional 

grants. 12 This is roughly the percentage of net tuition revenue that is attributable to Title IV federal 

student aid 

For example, given mean tuition and fees paid of $5,801 across all types of colleges, mean institutional 

grants 0[$989, and mean total federal Title IV aid 0[$3,071, the percentage of revenues from Title IV 

10 Govemment Accountability Office (GAO), For.Profit Schools: Lorge Schools and Schools that SpeCialize in 

Healthcare Are More Likely to Rely Heavily on Federal Student Aid, GAO-114, October 4,2010. 

http://www.gao.govltgi-blnlgetrpI1GAO·11-4 

11 The mean divides the total by all students (with zerosl. not just the average across the students who received 

the particular form of financlal aid. 

12 Institutional grants are not counted because a college could reduce its 90/10 percentage by raising tuition and 

refunding part of tuition to all or some students in the form of Institutional grants. 

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137 

student aid is $3,071/ ($5,801 - $989) = 64%. Including the mean veterans benefits and DOD of$127 as 

part of federal student aid would increase the percentage to 66%. 

So overall, almost two thirds of institutional revenue across all types of colleges comeS from federal 

student aid. The figures disaggregated by institution type are 42% for private non-profit colleges, 70% for 

private for-profit colleges and 82% for public colleges." The percentage of Title IV revenue is highest at 

public colleges in part because of their lower tuition rates. 

Tables 1-16 show the impact of other demographic variables on the 90/10 percentage. These figures are 

for undergraduate students at all institutions, not just for-profit colleges and universities. Tables 17·28 

disaggregate the data by institutional control. 

Table 1 shows that Federal Pell Grant recipients do not contribute to a college's compliance with the 

90110 rule. The percentage of Title IV revenue exceeds 100% because the aid received by low-income 

students also pays for other components of the college's cost of attendance, such as room and board, 

books and supplies, transportation, and personal/miscellaneoUS expenses, not only tuition and fees. 

Even among Federal Pell Grant recipients, there are differences according to the Expected Family 

Contribution (EFC). Students with lower EFCs receive more Title IV aid and so are less likely to 

contribute to the college's compliance with the 9011 a rule. A college could improve compliance while 

still enrolling the same number of Federal Pel! Grant recipients by shifting the mix of recipients to those 

with higher EFCs. 

"These figures consider only federal student aid, not state grants or direct state appropriations to public colleges. 

Few public colleges would be able to comply with the 90/10 rule if it applied to them and counted 01/ government 

funding, not justjederol aid. 

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138 

Table J shows a similar effect when the 9011 0 percentage is disaggregated by the student's family 

Adjusted Gross Income (AGI). There is a strong correlation between family AGI and the contribution to a 

college's compliance with the 90/10 rule. Students from higher-income families contribute more to a 

college's compliance with the 90/10 rule. 

Family income influences the choice of college, with students from low-income families tending to 

choose lower-cost colleges, as illustrated in the next chart. 

$25,000 

fl $20,000 

c: 

.. 

~ $15,000 ., 

~ 

- $10,000 0 

t: 

0 

u $5,000 

$0 a 

8 

::: 

<flo 

v 

Average Cost of Attendance vs. AGI 

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B B B B B '" B "" '" '" '" '" '" "" '" a a a a a a a a 

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i:( "" i:( "" ~ 8 a 

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S S S S 0 

"" "" "" "" '" a 0 Ll1 0 Ll1 Ll1 ." .... a N N .... .... N N V> V> V> V> '" 

Despite this trend, the net price (cost of attendance after subtracting grants) represents a greater 

percentage of family income among lower-income students. The next chart shows the net price as a 

percentage of family AGJ flattening out after family income reaches about $70,000. 

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139 

Net Tuition and Net Price as Percent of Income 

-Net Tuition as Percent of Income --Net Price as Percent of Income 

100.0% 

90.0% 

GO 80.0% 

E 70.0% B 60.0% .: 

'0 50.0% 

'E 40.0% j 30.0% 

20.0% 

10.0% 

.~ , 

tl 

" ,"-

, " \.. ~ 

......... 0.0% 0 "" "" "" "" "" "" "" "" "" "" '" "" "" "" "" "" "" "" ~ 8 l<l 0 0 0 ~ 0'0 ~ 8 0 0 0 ~ 0 ~ 8 :q 0 ..., .'h In .... 00 ... N ..., :Q In 0 

0 <I> <I> <I> <I> <I> <I> <I> ... ... ... ... ... ... N N N E ... .9 .9 .9 .9 .9 0 0 0 <I> <I> <I> <I> <I> <I> <I> <I> <I> <I> 

<I> ... ... ... (; .9 .9 .9 0 .9 0 .9 .9 .9 .9 v ~ "" "" ~ "" "" "" "" .... .... "" 0 0 0 ~ 0 0 "" "" '" '" "" "" "" "" "" "" 0 ... N '" .. In " 00 0 8 0 0 0 0 0 In 8 :q In <I> <I> <I> <I> <I> <I> <I> <I> m ... N ..., ;!; In .... N <I> ... ... ... ... ... ... N N <I> <I> <I> <I> <I> '" <I> <I> <I> <I> 

FamilyAGI 

Clearly, the concept of "skin in the game" is not valid when students are so poor that they cannot 

contribute any financial resources to their education. This forces them to enroll at lower-cost colleges 

where the federal student aid including loans covers most of the cost and at colleges with more generous 

institutional financial aid policies. Accordingly, colleges that enroll many low-income students are less 

likely to comply with the 90/10 rule. 

The next chart shows the relationship between family AGI and the percentage of revenue from Title IV 

federal student aid. It demonstrates that the contribution to compliance with the 90/10 rule improves with 

increasing family income, providing colleges with an incentive to discriminate against low· income 

students. 

The blue line reflects the percentage of revenues from Title IV federal student aid while the red line adds 

in the impact of military student aid. The disparity is greatest among low-income students, where it is as 

much as 5%. While on average the inclusion of military student aid does not affect the percentage of 

revenues significantly, some colleges may vary significantly from the average. Community colleges, for 

example, have a 9 percentage pOint increase in the percentage of revenues from federal student aid when 

military student aid is included. 

.8. 
140 

Percentage Revenue from Federal Student Aid by Family AGI 

-TItle IV -Title IV with VA/DOD 

"a 120% ,----------------------------

i1~+~---~~~-----------------------------------­ i 80% +-----'''IIII~III;::----------------

i 

j; ~ ::!==========:::~~~~~~~~::::::=======------------- 20% +-I_--------~-~~~~ 

~ 

! 

'0 

#. 

FamllyAGl 

The 90/10 rule's "skin in the game" metric is only meaningful to the extent to which the students are 

capable of contributing financially to their education. As the Percentage Revenue from Federal Student 

Aid by Family AGI chart demonstrates, low-income students are largely incapable of contributing to the 

cost of their education. For most colleges, the percentage of revenue from federal student aid measures 

the extent to which the college serves low-income students, not the students' willingness to pay for their 

education. 

This practice may provide an incentive for colleges to discriminate against low-income students and 

Federal Pell Grant recipients because it may help their institutions comply with the 90/10 rule. 

The 90/10 rule would be a more meaningful metric if the results were normalized according to the 

student's ability to contribute to the cost of his/her education. It would then measure the student's 

willingness to pay all or part of the cost of hislher education. There are several possible approaches that 

base the 90/10 calculation on the student's EFC or the student's status as a Federal Pell Grant recipient or 

non-recipient: 

Exclude Zero EFC students from the calculation because they have no ability to pay. 

Exclude Federal Pell Grant recipients from the calculation. The percentage of revenue from 

federal student aid would then be based only on students who do not receive a Federal Pell Grant. 

Count only students whose EFC exceeds 10% of net tuition revenue or the unsubsidized Stafford 

loan limit. 

Weight the percentage of revenue from federal student aid for each student by the student's EFC. 

Table 4 demonstrates that underrepresented minority students contribute a higher percentage of revenue 

from federal student aid (78%) than Caucasian students (56%), perhaps a reflection ofthe greater 

tendency for underrepresented minority students to come from low-income families. Black or African 

American students have the highest percentage of revenue from federal student aid (96%), followed by 

-9-
141 

Hispanic or Latino students (82%), This provides an incentive for colleges to discriminate against 

minority students since it may help them comply with the 90/10 rule, 

Female students have a higher 9011 0 percentage than male students, potentially leading to discrimination 

against women, 

Table 6 shows the impact of dependency status on the 9011 0 percentage, 

-10 -
142 

Independent students" have a higher 90110 percentage. Independent students are also much more 

common at private for-profit colleges, in contrast with public and private non-profit colleges." 

Table 7 illustrates the impact of academic performance on compliance with the 90/10 rule. Students who 

have a higher high school OPA or higher admissions test scores tend to have lower 9011 0 percentages. 

This may cause colleges to adopt more selective admissions policies to help them comply with the 90/10 

rule. 

A similar phenomenon is seen with high school degree type. Students with a OED tend to hurt a college's 

compliance with the 90/10 rule, so some colleges might decide to stop admitting students with only a 

OED. 

14 Independent student status is defined in the Higher Education Act of 1965 at 20 USC 1087vv(d). It includes 

students who are 24 years old as of December 31 of the award year, married students, students with dependents 

other than a spouse, graduate and professional school students, veterans, service members serving on active duty 

for other than training purposes, and orphans, among other criteria. Any student who is not independent is 

considered dependent. 

15 It is unclear why independent student enrollment is disproportionately high at for-profit colleges and 

disproportionately low at public and private non-profit colleges. Independent students are more likely to work fulltime while enrolled, especially those who enroll at for-profit colleges. Based on data from the 2007-08 NPSAS, 

51.0% of independent students work full-time while in college, compared with 15.5% of dependent students. 

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143 

Curiously, students from larger families contribute more toward a college's compliance with the 90110 

rule, but there is little difference among students who do and do not have siblings in college. Since the 

9011 0 percentages are similar for families of 3 or more, this effect may be due to the impact of 

independent students and students from single-parent households. 

Students who are the first in their family to attend college have a much higher 9011 0 percentage than 

students who are not first-generation college students. First-generation college students are defined as 

having both parents with a highest education level below a Bachelor's degree. 

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144 

Students who enroll part-time have a higher 901l 0 percentage than students who enroll full-time. So 

despite these students having higher income and reduced eligibility for need-based aid, they do not help 

the college comply with the 901l 0 rule. This may be due to the students being independent students who 

need to support themselves and their families in addition to paying for college expenses. 

Similar results are demonstrated by the Persistence and Attainment Risk Index, which counts the number 

of risk factors that are known to affect retention and completion. These risk factors include delayed 

enrollment, lack of a high school diploma, part-time enrollment, financial independence, having 

dependents other than a spouse, single parent status and working full-time while enrolled (35 or more 

hours a week). As Table 12 illustrates, students with more risk factors are less likely to help a college 

comply with the 90/]0 rule. At-risk students need more financial support to succeed, which provides 

colleges with a disincentive to enroll such students. 

Table 13 shows that veterans have a higher 90/10 percentage than students who have not served in the 

military. The 90/10 percentage for students on active duty or in the Reserves is lower, perhaps because of 

the use ofGI Bill and ROTC money to help pay for schooL 

-13 -
145 

Institutional Characteristics 

Institutional characteristics also correlate with compliance with the 901 I 0 rule. Table 14, for example, 

demonstrates that colleges that charge less than $8,000 in tuition and fees have a higher 90110 percentage 

than colleges that charge $8,000 or more. The lower cost means the federal student aid covers more of the 

cost, making it more difficult for the college to comply with the 901 I 0 rule. 

The type of college has an impact on the 90/10 percentage. The 90110 percentage is 82% at public 

colleges and universities (98% at community colleges and 77% at public 4-year colleges), 42% at private 

non-profit colleges and universities and 70% at private for-profit colleges. The 90/10 percentage is higher 

at public colleges than at private for-profit colleges because the costs are lower. Lower tuition and fees 

yields a higher 9011 0 percentage because the denominator is smaller while the numerator (the per-student 

utilization of federal student aid funds) is similar. 

-14-
146 

Many public colleges would not be able to comply with the 901l 0 rule if it applied to them, especially if 

state appropriations and grants were included in the percentage of revenue from government aid. More 

than 90% of the real cost of education at public colleges and universities comes from federal aid, state aid 

and state appropriations. 

Using JPEDS data, it is possible to estimate the number of colleges that would comply with the 90110 rule 

if the 90/10 rule applied to all colleges. The data in Table 16 is based on a comparison ortlle sum oftotaJ 

Federal Pel! Grant and federal education loan funding received by the college with the total gross tuition 

revenue. It may understate the actual 90/10 percentage due to discounting and due to the exclusion of 

FSEOG grants and Federal Work-Study funding from Ihe analysis. 

-15 -
147 

-16 -
148 

90/10 PERCENTAGES 8Y INSTITUTION TYPE 

Tables 17-28 disaggregate the 90/10 percentages by institution type. 

Differences according to control of college are partly due to differences in college costs and partly due to 

differences in enrollment patterns. Public colleges tend to be less expensive, yielding higher 90/10 

percentages. 

Table 18 shows differences by control and race. Notice how the private non-profit colleges have much 

lower 90/10 percentages than for-profit colleges for white and Asian students than for Black or African 

American and Hispanic or Latino students. This may be due to differences in socio-economic status 

within each minority student group at each type of college. 

-17 -
149 

Female students have a greater contribution to the 9011 0 percentage than male students, especially at 

public colleges. 

Note how the differences between dependent and independent students in Table 20 are much greater at 

the public and private non-profit colleges than at the private for-profit colleges. Independent student 

enrollment at for-profit colleges tends to be disproportionately higher than at other types of institutions, 

perhaps because these colleges better address the needs of students who work full-time. 

Independent with Dependents 131% 66% 75% 

-18 
150 

-19-
151 

There is more variation according to family size at public and private non-profit colleges than at private 

for-profit colleges, especially for family size! and 2. This may be due to the greater prevalence of 

independent students at private for-profit colleges. 

98% 52% 71% 

77% 43% 71% 

/I 74% 37% 66% 

5 73% 

6+ 74% 41% 72% 

No 71% 38% 65% 

Yes 66% 36% 61% 

Parent's highest education level has more of an impact on the 90110 percentage at public and private nonprofit colleges than at private for-profit colleges, perhaps because parents have less influence on the 

educational choices of independent students. 

Regardless of the type of college, part-time students have a higher 9011 0 percentage than full-time 

students. 

·20 -
152 

Higher-risk students are more likely to have a higher 90/10 percentage, especially at public colleges. The 

90/10 percentages for students at private for-profit colleges is more uniform, regardless of risk index. 

Three 

Four 

Five 

Veteran 

124% 

146% 

168% 

74% 

115% 

102% 

-21 -

53% 66% 
153 

Tuition and fees are a key driver of the 90/10 percentages. At aillypes of colleges, the 90110 percentages 

decrease with increasing college costs. This may serve as a disincentive for colleges that are subject to the 

90/10 rule to cut their costs below $8,000 a year. 

As the next graph demonstrates, the 901l ° percentages converge when tuition and fees exceed $8,000 per 

year. Private for-profit colleges are more likely to be affected by high 90/10 percentages at lower costs, 

possibly because of greater enrollment of independent students who borrow to pay for living expenses. 

2000% 

1800% 

1600% 

1400% 

1200% 

1000% 

800% 

600% 

400% 

90/10 Percentages by Tuition & Fees 

--Public --Non-Profit --For-Profit 

200% 0% 1~=::~~~~~~~~~~~;;~~~~~~~~=~ 

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154 

IMPACT OF AID ON 90/10 PERCENTAGES 

It may seem obvious, but students who use more federal student aid hurt a college's compliance with the 

901l 0 rule by increasitlg the percentage of revenues from federal student aid, Table I above shows the 

relationship between Pell Grant recipient status and the 901l 0 percentage. Table 2 shows that increases in 

financial need, as evidenced by lower EFe scores, lead to increases in the 9011 0 percentage. The m:xt 

table, Table 29, shows that greater utilization oflhe federal unsubsidized Stafford loan leads to a higher 

90/10 percentage, and that federal unsubsidized Stafford loan amounts of $2,500 or more tend to hurt a 

college's compliance with the 901l 0 rule, Use ofthe federal unsubsidized Stafford loan is subject to the 

student's discretion, Approximately 15% of undergraduate students borrow $2,500 or more in federal 

ullsubsidized Stafford loans, representing two thirds of students with federal unsubsidized Stafford loans. 

Table 30 demonstrates that students receiving $7,500 or more in total federal Title IV student aid tend to 

hurt a college's compliance with the 901I 0 rule. Generally, the greater the amount of total federal Title IV 

student aid, the greater the 901I 0 percentage. 

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155 

MAXIMUM PREVALENCE 

This data can be used to calculate the maximum potential prevalence of a characteristic with a high 90/10 

percentage before an institution risks failing to comply with the 90/10 rule. To the extent that a 

characteristic correlates with a college's compliance with the 90/10 rule, the 9011 0 percentage will 

increase monotonically with increasing prevalence of the characteristic in the student population. The 

maximum prevalence of a characteristic is the highest percentage of the student population that can 

demonstrate the characteristic while still permitting the college to comply with the 90/10 rule. 

Let C be a set of mutual exclusive characteristics including H and L. Let H be the 9011 0 percentage of the 

characteristic with the highest 9011 0 percentage and let L be the 9011 0 percentage of the characteristic 

with the lowest 90/10 percentage. Let P be the maximum prevalence of H. Then H x P + L x (1 - P) :::; 

90% sets the criteria for compliance with the 90/10 rule, with equality occurring at the limit. Note that H 

must be greater than 90%, otherwise any combination of H and L will be compliant with the 9011 0 rule. 

Transforming this equation yields P = (90% - L) 1 (H - L). 

For example, given H = 121% and L = 39% for Federal Pell Grant recipients, we have P= 51%/82% = 62%. Of course, individual colleges will differ in the maximum prevalence of Federal Pell Grant 

recipients due to differences in the high and low 90/10 percentages, but on averBfe a college can have no 

more than 62% Federal Pell Grant recipients and still comply with the 9011 0 rule. 

The maximum prevalence for other characteristics includes: 

• Federal Pell Grant Recipient 62% 

• Very Low Income « $25,000) 88% 

• ZeroEFC 85% 

• Black or African American 85% (vs. White) 

• Tuition < $500 49% 

Risk Index (7) 68% 

Colleges seeking to comply with the rule might do so by changing the mix of students enrolled at the 

college to one that is more likely to help the college reduce its 90/10 percentage. This, in turn, may lead to 

discrimination according to particular student characteristics, such as income, race, Federal Pell Grant 

recipient status, gender, dependency status, academic performance, receipt of a GED, first-generation 

college students, students who enroll on a part-time basis, military service and risk index. 

·24· 
156 

APPENDIX: 90/10 RULE FORMULA 

The formula for calculating the revenue percentages is specified in 20 USC 1094(dXI): 

d. Implementation of non-title IV revenue requirement 

1. Calculation 

In making calculations under subsection (a)(24), a proprietary institution of higher 

education shallA. use the cash basis of accounting, except in the case of loans described in 

subparagraph (O)(i) that are made by the proprietary institution of higher 

education; 

B. consider as revenue only those funds generated by the institution from -

i. tuition, fees, and other institutional charges for students enrolled in 

programs eligible for assistance under this subchapter and part C of 

subchapter I of chapter 34 oftitle 42; 

i1. activities conducted by the institution that are necessary for the education 

and training of the institution's students, if such activities are1. conducted on campus or at a facility under the control of the 

institution; 

II. performed under the supervision of a member of the institution's 

faculty; and 

III. required to be perfonned by all students in a specific educational 

program at the institution; and 

iii. funds paid by a student, or on behalf of a student by a party other than 

the institution, for an education or training program that is not eligible 

for funds under this subchapter and part C of subchapter I of chapter 34 

of title 42, if the program -

I. is approved or licensed by the appropriate State agency; 

II. is accredited by an accrediting agency recognized by the 

Secretary; or 

Ill. provides an industry-recognized credential or certification; 

C. presume that any funds for a program under this subchapter and part C of 

subchapter I of chapter 34 of title 42 that are disbursed or delivered to or on 

behalf of a student will be used to pay the student's tuition, fees, or other 

institutional charges, regardless of whether the institution credits those funds to 

the student's account or pays those funds directly to the student, except to the 

extent that the student's tuition, fees, or other institutional charges are satisfied by 

- 25-
157 

i. grant funds provided by non-Federal public agencies or private sources 

independent of the institution; 

ii. funds provided under a contractual arrangement with a Federal, State, or 

local government agency for the purpose of providing job training to 

low-income individuals who are in need oflhat training; 

lli. funds used by a student from savings plans for educational expenses 

established by or on behalf of the student and which qualifY for special 

tax treatment under title 26; or 

iv. institutional scholarships described in subparagraph (D)(iii); 

D. include institutional aid as revenue to the school only as follows: 

i. in the case of loans made by a proprietary institution of higher education 

on or after July 1,2008 and prior to July 1,2012. the net present value of 

such loans made by the institution during the applicable institutional 

fiscal year accounted for on an accrual basis and estimated in accordance 

with generally accepted accounting principles and related standards and 

guidance, ifthe loans -

I. are bona fide as evidenced by enforceable promissory notes; 

11. are issued at intervals related to the institution's enrollment 

periods; and 

III. are subject to regular loan repayments and collections; 

ii. in the case of loans made by a proprietary institution of higher education 

on or after July 1, 2012, only the amount of loan repayments received 

during the applicable institutional fiscal year, excluding repayments on 

loans made and accounted for as specified in clause (i); and 

iii. in the case of scholarships provided by a proprietary institution of higher 

education, only those scholarships provided by the institution in the furm 

of monetary aid or tuition discounts based upon the academic 

achievements or financial need of students, disbursed during each fiscal 

year from an established restricted account, and only tQ the extent that 

funds in that account represent designated funds from an outside source 

or from income earned on those funds; 

E. in the case of each student who receives a loan on or after July 1.2008, and prior 

to July 1,20 ll. that is authorized under section 1078-8 oftrus title or that is a 

Federal Direct Unsubsidiud Stafford Loan. treat as revenue received by the 

institution from sources other than funds received under this subchapter and part 

C of subchapter I of chapter 34 oftitle 42, the amount by which the disbursement 

of such loan received by the institution exceeds the limit on such loan in effect on 

the day before May 7, 2008; and 

F. exclude from revenues-

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158 

L the IIl1OIIOt ofilmds the instltutlon n:eelved tmdfIr parte ofsubcbapter I 

of ~ M oftille 42, unless the instltution used thoSe flUIdS to pay a 

student's instltutionid. charges: 

Ii. the amouilt of fuiIds the lilstlt\ltion n:eeived WIder ~ 4 ofpan A; 

iii. theamo~ offundsprQ"Yide,d by the.lnslltution.as matdHng lUndsfor a 

PNgraUI WIder this subebapter and part C ot subchapter I of chaPter 34 

of title 42: 

1,,_ the amountoffundsprovlded. by the institution for a program WIder this 

subchapter amtpart C·ofsubehllpter I of chapter 34 ottltle 42 that are 

requll1d to be refunded or l'etumed;and 

Y. the amount cbarged for boOks. supplles, and equipment, unless the 

institution Includes thet amouilt as tw"tlon, fees. or otber Institutional 

charges. 
159 

September16, 2013 

The Honorable Thomas R. Carper, Chairman, 

Senate Committee on Homeland Security & Governmental Affairs 

340 Dirksen Senate Office Building 

Washington, DC 20510 

Dear Chairman Carper: 

Iraq & Afghanistan Veterans of America is pleased to provide the following answers to the questions 

for the record you sent to us following the July 23rd hearing entitled "The 90/10 Rule: Improving 

Educational Outcomes for Our Military and Veterans" before your Committee: 

Question 1: Both the American Legion and the Veterans of Foreign Wars have told the 

committee that they have received almost no complaints about the aggressive and deceptive 

marketing practices of for-profit schools. Your testimony refers to veteran frustration with forprofit schools that was registered on your "Defend The New GI Bill" webpoge. How frequently 

do you receive complaints similar to the ones highlighted in your testimony? Why do you think 

other veterans' organizations might not be receiving as many complaints? 

Response: In 2008, lAVA played a leading role in building a united front among veterans' 

organizations and a bipartisan consensus in Congress in order to pass the Post-9/ll GI Bill. 

Since lAVA is the first and largest organization for Iraq and Afghanistan veterans, a much larger 

proportion of our membership is eligible for Post-9/ll GI Bill education benefits. As a result of 

these unique membership demographic, as well as the prominence and high visibility of our 

NewGIBill.org website, we receive a more diverse variety of education-related 

inquiries. However, we would suggest that simply counting the number of complaints received 

by lAVA or other veterans' organizations is not the best measure of the level of frustration 

amongst veterans when dealing with for-profit schools. 

While lAVA is not the only organization to provide real world examples of veterans and activeduty military personnel being exploited by for-profit universities, there are other entities to 

which troops and veterans are more likely to report these issues. The Consumer Financial 

Protection Bureau (CFPB) is one such alternative repository for complaints, particularly CFPB's 

new Office of Servicemember Affairs. Also, the Better Business Bureau would perhaps be a 

more natural place for a servicemember or veteran to turn to in order to consequentially 

express his or her frustration and report negative experiences with for-profit schools. 

Page 1 of 2 
160 

Æ 

.... 

..................... _- lAVA Responses to QFRs 

Senate HSGA Gmte. 

Sept. 20, 2013 

Page 2 of2 

Question 2: Your testimony notes that some but not all for-profit schools provide a quality 

education. Do you have any advice on ways to help veterans differentiate the good from the bad 

actors in the for-profit sector? 

Response: Our NewGIBiII.org website lists a variety of useful resources to help veterans 

differentiate between the good and bad actors in the for-profit education sector, including the 

Better Business Bureau's "Educational Consumer Tips," the VA's "Factors to Consider When 

Looking for a School," the White House's college scorecard, College Navigator, etc. These 

resources encourage veterans to check the accreditations that the school holds with the U.S. 

Department of Education's database, but also reminds veterans to be vigilant in understanding 

whether their coursework will transfer to a new school. VA explicitly mentions that if a veteran 

were to transfer from an online institution to a public in-state school, there is a possibility that 

not all credit will be accepted, so veterans should find an institution where previously earned 

credit is best utilized towards degree requirements that will help veterans make the most of 

their benefits. 

If you have any additional questions, please don't hesitate to reach out to me or to our Legislative 

Director, Alexander Nicholson at 202-544-7692 or alex@iava.org. 

Thank you again for giving lAVA the opportunity to offer our analysis and the views of our members as 

the Committee continues to consider and debate this very important issue for the military and veteran 

community. 

Respectfully, 

Thomas A. Tarantino 

Chief Policy Officer 

Iraq & Afghanistan Veterans of America