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35–634 2008

STATE APPROVING AGENCIES 

HEARING 

BEFORE THE

SUBCOMMITTEE ON ECONOMIC OPPORTUNITY 

OF THE

COMMITTEE ON VETERANS’ AFFAIRS 

U.S. HOUSE OF REPRESENTATIVES 

ONE HUNDRED TENTH CONGRESS 

FIRST SESSION 

APRIL 19, 2007 

Serial No. 110–15 

Printed for the use of the Committee on Veterans’ Affairs 

( 


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COMMITTEE ON VETERANS’ AFFAIRS 

BOB FILNER, California, Chairman 

CORRINE BROWN, Florida 

VIC SNYDER, Arkansas 

MICHAEL H. MICHAUD, Maine 

STEPHANIE HERSETH SANDLIN, South 

Dakota 

HARRY E. MITCHELL, Arizona 

JOHN J. HALL, New York 

PHIL HARE, Illinois 

MICHAEL F. DOYLE, Pennsylvania 

SHELLEY BERKLEY, Nevada 

JOHN T. SALAZAR, Colorado 

CIRO D. RODRIGUEZ, Texas 

JOE DONNELLY, Indiana 

JERRY MCNERNEY, California 

ZACHARY T. SPACE, Ohio 

TIMOTHY J. WALZ, Minnesota 

STEVE BUYER, Indiana, Ranking 

CLIFF STEARNS, Florida 

JERRY MORAN, Kansas 

RICHARD H. BAKER, Louisiana 

HENRY E. BROWN, JR., South Carolina 

JEFF MILLER, Florida 

JOHN BOOZMAN, Arkansas 

GINNY BROWN-WAITE, Florida 

MICHAEL R. TURNER, Ohio 

BRIAN P. BILBRAY, California 

DOUG LAMBORN, Colorado 

GUS M. BILIRAKIS, Florida 

VERN BUCHANAN, Florida 

MALCOM A. SHORTER, Staff Director 

SUBCOMMITTEE ON ECONOMIC OPPORTUNITY 

STEPHANIE HERSETH SANDLIN, South Dakota, Chairwoman 

JOE DONNELLY, Indiana 

JERRY MCNERNEY, California 

JOHN J. HALL, New York 

JOHN BOOZMAN, Arkansas, Ranking 

RICHARD H. BAKER, Louisiana 

JERRY MORAN, Kansas 

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

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

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

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

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

is further refined. 


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C O N T E N T S 

April 19, 2007 

Page 

State Approving Agencies ....................................................................................... 1 

OPENING STATEMENTS 

Chairwoman Stephanie Herseth Sandlin .............................................................. 1 

Prepared statement of Chairwoman Herseth Sandlin .................................. 29 

Hon. John Boozman, Ranking Republican Member ............................................. 2 

Prepared statement of Congressman Boozman ............................................. 29 

WITNESSES 

U.S. Government Accountability Office, George A. Scott, Director, Education, 

Workforce and Income Security Issues .............................................................. 4 

Prepared statement of Mr. Scott ..................................................................... 30 

U.S. Department of Labor, John M. McWilliam, Deputy Assistant Secretary 

for Operations and Management, Veterans’ Employment and Training Service .......................................................................................................................... 20 

Prepared statement of Mr. McWilliam ........................................................... 49 

U.S. Department of Education, Carol A. Griffiths, Chief, Accrediting Agency 

Evaluation Unit, Office of Postsecondary Education ........................................ 21 

Prepared statement of Ms. Griffiths ............................................................... 50 

U.S. Department of Veterans Affairs, Keith M. Wilson, Director, Education 

Service, Veterans Benefits Administration ........................................................ 22 

Prepared statement of Mr. Wilson .................................................................. 52 

National Association of State Approving Agencies, Joan L. Ryan, President .... 6 

Prepared statement of Ms. Ryan ..................................................................... 36 

South Dakota State Approving Agency, George W. Summerside, Veterans 

Education Program Specialist ............................................................................. 8 

Prepared statement of Mr. Summerside ........................................................ 44 

SUBMISSIONS FOR THE RECORD 

American Legion, Ronald F. Chamrin, Assistant Director, Economic Director, 

statement .............................................................................................................. 54 

Council of Regional Accrediting Commissions, Jean Avnet Morse, President, 

Middle States Commission on Higher Education, statement ........................... 58 

MATERIAL SUBMITTED FOR THE RECORD 

U.S. Government Accountability Office, Report to the Ranking Minority Member, Committee on Veterans’ Affairs, U.S. Senate, March 2007, ‘‘VA Student 

Financial Aid—Management Actions Needed to Reduce Overlap in Approving Education and Training Programs and to Assess State Approving Agencies,’’ GAO–07–384 ............................................................................................... 61 

Letter, dated April 27, 2007, and Supplemental Statement for the Record 

from Joan L. Ryan, President, and C. Donald Sweeney, Legislative Director, 

National Association of State Approving Agencies, responding to a request 

for additional information from Congressman John Boozman ......................... 72 


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STATE APPROVING AGENCIES 

THURSDAY, APRIL 19, 2007 

U.S. HOUSE OF REPRESENTATIVES, 

COMMITTEE ON VETERANS’ AFFAIRS, 

SUBCOMMITTEE ON ECONOMIC OPPORTUNITY, 

Washington, DC. 

The Subcommittee met, pursuant to notice, at 2:05 p.m., in 

Room 334, Cannon House Office Building, Hon. Stephanie Herseth 

Sandlin [Chairwoman of the Subcommittee] presiding. 

Present: Representatives Herseth Sandlin, Donnelly, Hall, 

Boozman. 

OPENING STATEMENT OF CHAIRWOMAN HERSETH SANDLIN 

Ms. HERSETH SANDLIN. Good afternoon, ladies and gentlemen. 

The Committee on Veterans’ Affairs, Subcommittee on Economic 

Opportunity hearing on functions performed by State Approving 

Agencies (SAAs) will come to order. 

Before I begin with my opening statement, I would like to call 

attention to the fact that Ms. Jean Morse, President of the Middle 

States Commission on Higher Education, has asked to submit a 

written statement for the record on behalf of the Council of Regional Accrediting Commissions. 

If there is no objection, I ask for unanimous consent that the 

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

[The statement of Ms. Morse appears on p. 58.] 

Today we will be hearing testimony on State Approving Agencies. 

The authority of SAAs was established by Congress in 1947 to ensure that veterans and eligible dependents can use the GI Bill educational entitlement in an approved educational program. 

Under contract with the U.S. Department of Veterans Affairs 

(VA), the key function of SAAs is to ensure that education and 

training programs meet VA’s standards through a range of approval activities such as conducting on-site visits, evaluating course 

quality, assessing school financial stability, and monitoring student 

progress. 

Every State assesses each program as to its own standards and 

laws in addition to the VA rules and regulations with all approved 

programs undergoing continuous supervision. 

The programs that can be approved include colleges, universities, 

vocational and technical schools, flight schools, apprenticeship programs, and on-the-job training programs. In addition, SAAs engage 

in outreach activities to foster the usage of the GI Bill. 


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This year, my home State of South Dakota is expecting to have 

approximately 2,100 eligible individuals enrolled in GI Bill eligible 

programs. These programs are now found at 47 schools and 192 

training establishments in South Dakota. So I have a strong interest in exploring the subject before us today to improve the availability of education benefits for our men and women in uniform. 

I understand that there are concerns about the funding change 

that is about to occur for the State Approving Agencies. From fiscal 

years 2003 to 2006, their funding increased from the statutory level 

of $13 million to $19 million to expand services. However, the funding level for SAAs is scheduled to decrease beginning in fiscal year 

2008. 

According to a recent report, the U.S. Government Accountability 

Office (GAO) concluded that the responsibilities of State Approving 

Agencies have expanded since 1995 and that they add value to the 

approval process for education and training programs. However, 

the report also concluded that there was overlap between the efforts of State Approving Agencies and other Federal agencies. While the VA now spends $19 million to fund SAA duties and 

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

activities, especially those that may also be performed by other 

agencies. So I am very interested in hearing your insights on how 

these concerns can be addressed. 

Ranking Member Boozman, I look forward to working with you 

and our colleagues and Subcommittee staff to help with these important services offered by the State Approving Agencies, and I 

now recognize the Ranking Member, Mr. Boozman, for any opening 

remarks that he may have. 

[The prepared statement of Chairwoman Herseth Sandlin appears on p. 29 and the referenced GAO report, GAO–07–384, entitled, ‘‘VA Student Financial Aid: Management Actions Needed to 

Reduce Overlap in Approving Education and Training Programs 

and to Assess State Approving Agencies,’’ appears on page 61.] 

OPENING STATEMENT OF HON. JOHN BOOZMAN 

Mr. BOOZMAN. Thank you very much. 

The State Approving Agencies have for many years been a mainstay in ensuring that veterans attending the education and training programs under the various GI Bills receive quality instruction. 

That is why I thank you, Madam Chairwoman, for holding the 

hearing today. 

A recent GAO report, that updated a 1995 report, again found 

overlaps in the functions performed by the State Approving Agencies, the regional and professional accrediting agencies acting on 

behalf of the Department of Education, and the Oversight Committees provided by the State Employment Services. 

While the recent report was less critical than its predecessor and 

noted SAAs did, in fact, provide perspective not replicated by other 

organizations, GAO again recommended a thorough inter-agency 

review of how the Federal Government oversees the education industry. 

I believe that this is important, that it is important to begin the 

processes and means to improve the education and training opportunities for veterans and their dependents. 


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Another issue is how much funding should VA provide to the 

States to act as VA’s agent. VA currently pays the collective SAAs 

about 19 million out of the readjustment benefits account. As such, 

those payments are mandatory spending and beginning in fiscal 

year 2008, the law cuts that funding to 13 million. 

So the question before us is what is the value of the services provided by the SAAs? 

It looks like we are going to get a report from the regional accrediting agency as well as having somebody from the U.S. Department of Education (DoE) today, so we look forward to that, especially the functions associated with their programs. 

I am sorry that witnesses from the accrediting bodies we invited 

were unable to attend. Their testimony would have been a valuable 

perspective relative to GAO’s findings. 

I would note the accrediting associations overseeing colleges and 

universities are membership organizations who charge their members significant annual dues as well as large fees for other functions such as approving new courses for instruction. 

For example, the alma mater of one of our staff is a small liberal 

arts school in the Midwest with a full-time enrollment of about 

1,800 students. That school pays at least $4,000 in annual dues to 

its main accrediting association in addition to any fees for special 

visits. 

I am not criticizing the accrediting bodies for charging the fees, 

but I thought it important that the members know this aspect of 

their operations. 

Regarding the U.S. Department of Labor (DoL), I am looking forward to hearing about the level of the interaction with SAAs in improving on-the-job training (OJT) and apprenticeship programs. 

Again, thank you, Madam Chairwoman, as always for your leadership in this area and look forward to hearing the testimony. 

[The prepared statement of Congressman Boozman appears on 

p. 29.] 

Ms. HERSETH SANDLIN. Thank you, Mr. Boozman. 

I would also like to welcome all of today’s witnesses, and I very 

much appreciate your testimony as your views and insights are 

critically important to us in examining this important issue. 

I am particularly interested in understanding and exploring the 

views and perspectives on the role and function of State Approving 

Agencies, funding needed to perform those functions, overlap in the 

approval process, and coordination between Federal and State 

agencies. I look forward to hearing from all of you. 

We have been informed that votes would have been called about 

25 minutes ago, so they could be called at any time. We will go 

ahead and start testimony and take as much as we can from our 

first panel and get to any questions of the Subcommittee. 

I think we will go ahead and start with the first panel. Joining 

us is Mr. George Scott, Director of Education, Workforce and Income Security Issues for the U.S. Government Accountability Office. 

That gives us 15 minutes, so we will at least start perhaps with 

Mr. Scott’s testimony in just one moment. I will introduce the other 

folks on the panel. 


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Ms. Joan Ryan, President of the National Association of State 

Approving Agencies; accompanied by Mr. Donald Sweeney, Legislative Director of the National Association of State Approving Agencies, and my friend, Mr. George Summerside, Veterans Education 

Program Specialist, South Dakota State Approving Agency. Welcome to all of you. 

And, Mr. Scott, we will let that buzzer go and then we will begin 

with your testimony. I would ask each of our witnesses to do their 

best to limit their opening statement to five minutes. Your full 

written statement will be submitted for the record. 

Thank you. 

STATEMENTS OF GEORGE A. SCOTT, DIRECTOR, EDUCATION, 

WORKFORCE AND INCOME SECURITY ISSUES, U.S. GOVERNMENT ACCOUNTABILITY OFFICE; JOAN L. RYAN, PRESIDENT, 

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES; 

ACCOMPANIED BY C. DONALD SWEENEY, LEGISLATIVE DIRECTOR, NATIONAL ASSOCIATION OF STATE APPROVING 

AGENCIES; AND GEORGE W. SUMMERSIDE, VETERANS EDUCATION PROGRAM SPECIALIST, SOUTH DAKOTA STATE APPROVING AGENCY 

STATEMENT OF GEORGE A. SCOTT 

Mr. SCOTT. Thank you. 

Madam Chairwoman, Ranking Member Boozman, and members 

of the Subcommittee, I am pleased to be here today to discuss 

GAO’s recent report on State Approving Agencies, SAAs. 

In fiscal year 2006, the Department of Veterans Affairs paid ap- proximately $19 million to State Approving Agencies. Under contract with the VA, SAAs ensure that education and training programs meet VA standards through a number of approval activities 

such as evaluating course quality and monitoring student progress. 

My testimony today will focus on what changes have occurred in 

SAA duties and functions since 1995, to what extent VA’s approval 

process overlaps with the efforts of other Federal agencies, and 

what additional value do State Approving Agencies bring to VA’s 

education benefit program. 

As you know, veterans and other qualified individuals receive VA 

education benefits that allow them to pursue various types of educational programs such as a degree program, an apprenticeship, or 

on-the-job training. 

In general, these programs must be approved by a State Approving Agency in order for individuals to receive VA education benefits. The Departments of Education and Labor also assess education and training programs. 

The Department of Education certifies postsecondary institutions 

for participation in Federal student financial aid programs through 

various oversight functions to ensure that these schools meet Federal requirements and that they are accredited and licensed. 

Similarly, the Department of Labor is authorized to formulate 

and promote labor standards to safeguard the welfare of apprentices. 

Given each agency’s role, the potential for duplication of approval 

efforts among Federal agencies have been a congressional concern. 


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In our study, we report the legislative changes effective in 2001 

created additional responsibilities for State Approving Agencies including promoting the development of apprenticeship and on-thejob training programs, providing outreach services, and approving 

tests for occupational licensing. 

From fiscal years 2003 to 2006, funding for State Approval Agencies increased from $13 million to about $19 million to expand services and support the additional responsibilities. However, as you 

noted, its funding is scheduled to decrease beginning in fiscal year 

2008. 

Many education and training programs approved by SAAs have 

also been approved by other agencies. For example, about 69 percent of all programs approved by SAAs are also offered by institutions that have been certified by Education. 

VA and SAA officials also reported that many apprenticeship 

programs approved by SAAs have also been approved by Labor. 

The agencies also have similar categories of approval standards, 

but the interpretation and application of these standards may differ. 

For example, VA and Labor each require that facilities have adequate space and instruct their personnel to provide quality training, but the definitions of adequacy differ. 

Despite the potential overlap, VA has taken few steps to coordinate approval activities with Education and Labor. 

Additionally we found that VA does not require State Approving 

Agencies to collect information on the resources they spend on specific approval activities. The lack of such data prevented us from 

determining what portions of funds were spent on approval activities that may overlap with those of other agencies. 

SAAs reportedly add value to VA’s approval process through focusing on student services for veterans, ensuring the integrity of 

VA benefits, providing more frequent on-site monitoring of education and training programs that are provided by other agencies, 

and assessing and approving a small number of programs that are 

not reviewed by other agencies. 

While VA does measure various outputs resulting from SAA activities such as the number of supervisory visits conducted, the 

lack of outcome performance measures makes it difficult to assess 

the significance of such activities. 

In conclusion, VA, Education, and Labor have various standards 

and processes in place to ensure that Federal funds are spent on 

quality education and training programs. While we have identified 

some overlap in approval efforts across these agencies, the full extent of the overlap is unknown. It is important that VA work with 

other Federal agencies to determine how the scope of its approval 

process can be streamlined to reduce overlap. 

Furthermore, developing outcome measures to more fully evaluate SAA performance is important to managing the program and 

improving results. 

To help ensure that Federal dollars are spent efficiently, we recommended that VA take steps to monitor its spending on approval 

activities and identify whether any resources are spent on activities 

that duplicate the efforts of other agencies. 


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We also recommended that VA establish outcome-oriented performance measures to assess the effectiveness of State Approving 

Agencies’ efforts. 

VA agreed with our recommendations and stated that it will take 

action to implement them. They will continue to monitor VA’s 

progress in addressing these issues. 

This concludes my statement, and I would be happy to answer 

any questions that you may have. Thank you. 

[The prepared statement of Mr. Scott appears on p. 30.] 

Ms. HERSETH SANDLIN. Thank you, Mr. Scott, and thank you for 

the report and the questions that will be derived from that report 

throughout the hearing today. 

We have just under 10 minutes before the vote and we generally 

only need a few minutes to get down for this first vote. Ms. Ryan, 

if you think you can confine your opening statement to five minutes, we can go ahead and get yours in now before we go down to 

vote. Okay. Thank you. 

STATEMENT OF JOAN L. RYAN 

Ms. RYAN. Chairman Herseth Sandlin, Ranking Member 

Boozman, members of the Subcommittee on Economic Opportunity, 

we are pleased to appear today before you on behalf of the National 

Association of State Approving Agencies to provide comments on 

the functions of State Approving Agencies, the value added by 

SAAs, the issue of overlap in the work of various approving agencies, and funding needed for SAAs to carry out their responsibilities. 

State Approving Agencies add value to the educational experience for veterans by promoting and safeguarding quality education 

and training programs, by ensuring greater educational and training opportunities, and by assisting the DVA in preventing fraud, 

waste, and abuse in the administration of the GI Bill. 

State Approving Agencies carry out their mission through core 

functions of program approval, ongoing contact, and supervision, 

technical assistance, outreach, and liaison. 

As State Approving Agencies working with a Federal program, 

SAAs are in a unique situation to network with stakeholders in 

education and training to coordinate the improved delivery of veterans’ benefits. 

Frequent interaction with officials at all levels within the State 

provides an understanding of how the system works which in turn 

creates a unique ability to assist veterans in accomplishing their 

training objectives. 

As stated by a former Subcommittee staff director for the House 

Veterans’ Affairs Committee in an upcoming SAA outreach film, 

SAAs are the face of the GI Bill at the State level. 

We provide advocacy for veterans, educational consumer protection for veterans. We respond to veterans’ education problems and 

prevent overpayments to veterans. We provide outreach. During 

the last 10 years, we have tripled our number of outreach activities 

and job training opportunity. The number of active apprenticeship 

and on-the-job training facilities has increased over 100 percent in 

the last 10 years. 


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Questions have been raised regarding possible overlap in the 

work of State Approving Agencies with other agencies. A recent 

GAO report states many education and training programs approved by SAAs have also been approved by Department of Labor. 

We disagree. 

It is our understanding that Department of Education does not 

directly approve programs. It certifies institutions by relying heavily on accreditation which is primarily institutional in nature, not 

programmatic. 

Moreover, accreditation is a voluntary, private-sector, quality enhancement process, not a government control mechanism. 

Additionally, SAAs do work with other approval institutions such 

as State licensing and degree-granting authorities and accrediting 

agency personnel. 

It is important to note the major differences between SAAs and 

accreditation. Why? Number one, in their mission, standards, and 

purpose and, number two, operationally in the depth, breadth, and 

frequency of their reviews. Each has a function, but the functions 

are not identical or duplicative. They are complementary. 

Regarding outcomes measures, we agree that more can be done. 

For example, SAAs are heavily engaged in promoting the concept 

of lifelong learning. We see more veterans who do not need a fullscale 2- or 4-year program of education to help them achieve their 

occupational goals. So our work with educational institutions has 

grown in the direction of evaluating and approving noncredit programs which we would begin to identify more clearly. 

The total allocation for SAA activities is stipulated in Title 38. 

Each SAA’s allocation is determined by a formula essentially based 

on the number of active schools and training establishments being 

supervised. The total allocation was capped at $19 million for 2006 

and 2007. If no action is taken, in 2008 the cap will revert back 

to $13 million, a 32 percent cut. 

If the SAAs are unable to perform their duties to the fullest, veterans would invariably suffer. SAAs need funding stability in order 

to plan for and execute activities that meet the requirements of 

Title 38 between the State and the VA. 

In order to provide an acceptable level of service to veterans, 

Congress, and the DVA and to continue to take on additional roles 

as needed, SAAs must consistently be funded at an adequate level. 

Once restored to the current level of $19 million, the amount 

should be adjusted each year by a government approved COLA applied to other benefit programs. 

In closing, Madam Chairman, an important reason for the existence of the State Approving Agencies is service to veterans. Every 

one of our activities from TAP briefings on bases to job and career 

fairs, from working with schools and registrars and college deans, 

to helping employers meet requirements for approval, each of these 

add values to the educational experience for veterans. It is our purpose and our passion. Because we are in the schools, job training 

sites, and on bases, we are the face of the GI Bill to veterans. 

We would like to thank you and the members of the Subcommittee again for the opportunity to comment on the functions 

of State Approving Agencies, the value added by State Approving 

Agencies, the issue of overlap in the work of approving agencies, 


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and funding needed for SAAs to carry out their responsibility so 

that the GI Bill remains the country’s premier education assistance 

program bar none. 

Mr. Sweeney and I would be happy to take questions later. 

[The prepared statement of Ms. Ryan appears on p. 36.] 

Ms. HERSETH SANDLIN. Yes. Thank you, Ms. Ryan. I appreciate 

that. 

Mr. Summerside, we are going to have to wait. Mr. Boozman and 

I need to get down to the House floor for a couple of votes. We will 

be back hopefully within the half hour and then we will resume 

with your testimony and move to questions. 

Thank you. 

[Recess] 

Ms. HERSETH SANDLIN. Okay. Well, thank you for your patience, 

and we will just move immediately then to Mr. Summerside’s testimony. Please begin. 

STATEMENT OF GEORGE W. SUMMERSIDE 

Mr. SUMMERSIDE. Thank you, Chairwoman Herseth Sandlin and 

members of the Subcommittee on Economic Opportunity. 

I am pleased to appear before you today on behalf of the South 

Dakota State Approving Agency to discuss the functions of the 

State Approving Agencies and the value our agency has in the 

State of South Dakota. 

Sixty years ago, Congress determined that each State should create an agency that approved programs within its boundaries and 

to determine which programs it was appropriate for veterans to enroll and receive their VA educational benefits. 

After a few years, States realized that a national association was 

needed. And in 1948, the National Association of State Approving 

Agencies was formed. 

One of the keys to the success of our association has been the 

use of technology. We created a viable Internet website for the utilization of our members, our service partners, and our customer, 

the American veteran. 

South Dakota has been the web master for this site since its creation in 1998. The primary responsibility and focus of our agency 

continues to be the review, evaluation, and approval of quality programs of education and training. Our agency conducts annual supervisory visits to each active facility to review the resources and 

capabilities which are required for continued approval. This on-site, 

ongoing supervision is vital to ensure these approved institutions 

continue to provide quality educational programs and meet VA 

compliance requirements. 

We have become advocates for quality education and training for 

veterans and other eligible persons. We have developed service 

partnerships with veterans’ groups and other agencies to facilitate 

even greater and more diverse educational opportunities for those 

we serve. 

We provide technical assistance on a wide range of VA educational issues. Our staff is continually developing creative and innovative ways to promote and educate the public on VA educational programs. 


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Last fiscal year, we distributed over 6,000 brochures and other 

outreach materials to those within our service network. 

You have asked what is the value of our agency. This can be best 

answered by those we serve. The following comments offer their 

opinion. 

I was most appreciative for the professionalism from the person 

from the State Approving Agency who worked with my employer 

and me to design a tailored training program. No doubt, without 

availability of this education benefit, I would not have been able to 

accept this training position. Ron Boyd, State Adjutant, South Dakota American Legion. 

On behalf of the veterans and their dependents attending the 

University of South Dakota, I can honestly claim that the support 

of our State Approving Agency is essential to our success. Jennifer 

Jost, Association Registrar. 

The philosophy that bigger is better does have its limits and the 

impact on our smaller States can be negative. There is a need for 

each State to have a fully staffed SAA so the veterans in that State 

do not suffer with additional delays in obtaining their educational 

benefits. These agencies are vital and any reduction in funding 

would negatively impact VA educational programs. Del Johnson, 

retired South Dakota ELR. 

To ever lose or restrict the State Approving Agency due to Federal budget restraints would be a huge disservice to South Dakota 

veterans. Ken Lindblad, Beadle County Veteran Service Officer. 

State Approving Agencies have not only ensured that those eligible for VA educational benefits enroll in quality education and 

training programs, but they have also served as a champion of veterans’ educational benefits. Bill Locken, South Dakota Veterans 

Commissioner. 

In the past few months, George Summerside has been an excellent client advocate. Without his dedication and loyalty, the veterans’ education program would be nothing. Sincerely, Samantha 

Donley. She is a Chapter 35 recipient. 

Our agency has a proven record of dedicated and professional 

service as depicted in the comments I just read. If a funding solution is not found, South Dakota’s contract would be reduced by 32 

percent next fiscal year. This would be a reduction of over $66,000. 

The many things we are doing in outreach and customer service 

would no longer be possible. 

The testimonies today cannot truly measure our value. Our true 

value rests in the heart of each of the dedicated staff whose sole 

purpose is the approval of quality programs of education and training. Our agency’s worth is found in the dedicated devotion to excellence and our Nation’s veterans deserve no less. 

In closing, Madam Chairwoman, I would like to thank you and 

the members of the Subcommittee again for the opportunity to 

comment on the functions of the South Dakota State Approving 

Agency and the value we add to our State. I would be happy to respond to any questions you might have. 

[The prepared statement of Mr. Summerside appears on p. 44.] 

Ms. HERSETH SANDLIN. Well, thank you, Mr. Summerside, and 

all of our witnesses on the first panel for your testimony. 


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I have a number of questions, but I will defer to our Ranking 

Member and then we have also been joined by Mr. Hall who has 

another Subcommittee hearing that is going on simultaneously. 

In an effort to accommodate him, I would like to ask Mr. 

Boozman to begin the questioning so that we can move to Mr. Hall 

for any opening statement or questions he may have and we will 

circle back to me at the end. 

Mr. BOOZMAN. Thank you, Madam Chairwoman. 

I appreciate your testimony, Mr. Summerside. I think that in visiting with your Arkansas equivalents, I think they would concur 

with your testimony or it would be very, very similar. So it is good 

to have you here to kind of give us some, you know, firsthand as 

to effects testimony. 

For the State Approving Agencies, can you provide us some details how the State Approving Agencies differ from other organizations performing similar functions, if that makes sense? 

Ms. RYAN. I would like to give that to Mr. Sweeney, if you do not 

mind. 

Mr. BOOZMAN. Yes. 

Mr. SWEENEY. I think Ms. Ryan really summed it up in her comments when she said the Department of Education’s process relies 

heavy upon accreditation which is primarily institutional. 

The Department of Education certifies institutions that offer programs to those people who are entitled to or eligible for Title 4 

funding. 

There is a huge difference between saying that programs approved by State Approving Agencies are also approved by the Department of Education. As I said to one of the staff members during the break, it is not quite 180 degrees, but it is close to 179. 

There is a huge difference between certifying institutions that offer 

programs than approving each and every program in accordance 

with provisions of Title 38. 

The basis for Title 38, beyond ensuring the academic integrity 

and quality of a learning experience—which could be anywhere 

from a certificate program in automotive technology to a Bachelor 

of Science Degree in Engineering—is also to ensure that the provisions of Title 38 that pertain to payment of benefits are in place 

as well. They are intertwined. 

So when we talk about the differences between the two processes, Mr. Boozman, if I understand the question correctly, it 

seems like much of this really centers around accreditation. Am I 

correct in the intent of the question more so than it is, for example, 

State licensing or degree granting authority? It’s really around accreditation. And the vast majority of accreditation is institutional. 

For example, before leaving the State of Maine where I happened 

to be—we are all volunteers. The National Association of State Approving Agencies has no paid staff. I mean, I am the Director of 

the Maine State Approving Agency. Joan is the Director of Illinois. 

We take on these titles of President and Legislative Director and 

basically what it does, it keeps us in the office to eight o’clock at 

night and on weekends. 

But by and large, one of the things that I took a look at before 

leaving the State of Maine was how many of the University of 

Maine system programs have specialized accreditation. Now, that 


wwoods2 on PRODPC68 with REPORTS
11 

gets us a little bit closer to the process utilized by State Approving 

Agencies. 

Stop me if I am losing you here, but there are the various types 

of accreditation that we refer to in our written testimony, there is 

institutional accreditation, there is programmatic accreditation. 

And the programmatic accreditation is probably the closest that 

you will find to the State Approving Agency process where we take 

a look at the legitimacy of the objective, what is that program objective, is it, for example, someone that wishes to be an automotive 

technician, what does it take to learn those skills, how are those 

skills taught, by whom, and under what circumstances. 

And Title 38, as the Committee is aware, is quite prescriptive in 

that regard with respect to admissions requirements, credit for 

prior learning, satisfactory progress, all those kinds of things that 

pertain to student enrollment. 

Well, anyway, taking a look at the University of Maine system 

of which there are seven campuses, we have roughly about 600 programs. A little over 125 have specialized accreditation, so that 

leaves 500 or close to 500 that are strictly viewed as, quote, approved under an institutional umbrella of accreditation, not programmatic, institutional. 

That institutional accreditation, and I have had the privilege and 

honor of serving on a number of accrediting teams over the years. 

I have about close to 35 years in the field of education. I have been 

an administrator. I have served as an instructor and again on accrediting teams. 

That process, when I say institutional, I could go on for hours on 

this just to give you some idea of what I mean by institutional, but 

suffice it to say for the hearing purposes, it is far more superficial 

than the programmatic accreditation and the process used by State 

Approving Agencies. 

And I thank you for all the time you have given me because I 

think I have already gone too far. 

Mr. BOOZMAN. No. That is fine. 

Let me just ask one more thing if it is okay, Madam Chairwoman? My time is up in a little bit. 

But I guess really the bottom line, and you alluded to it, Mr. 

Summerside, with the cutting in funding, what it would do in your 

State. 

Again, if we go from the current $19 million to $13 million, what 

is the practical effect that that is going to have on the program? 

Ms. RYAN. The effect will be local. Each State may approach it 

a little differently. There are some States who may, in fact, choose 

not to contract with VA, some of the smaller States who have small 

contracts. If that is the case, then VA would have to pick up the 

approval function in that State. 

There are some States who may not do outreach. There just will 

not be the time, the budget. There are States who will lay people 

off, I have no doubt. But, you know, it is an individual, it will be 

a local decision how it is made. 

Mr. SWEENEY. Is it possible to add to that, Mr. Boozman? 

I think a big piece for us is that State Approving Agencies truly 

believe that, as Ms. Ryan stated in her closing remarks, the GI Bill 


wwoods2 on PRODPC68 with REPORTS
12 

should be the premier educational assistance program in this country bar none. 

We have one percent of our population defending the other 99 

percent and for many of us these days, we are not sure how large 

of a portion of that 99 percent really care about the other one percent. 

Veterans, as Mr. Summerside said, deserve no less than the fullest attention that we can give. Removing the amount of funding 

that is currently provided a State Approving Agency is definitely 

going to jeopardize, after 30 plus years in the business, is definitely 

going to jeopardize the success of the GI Bill, no doubt in my mind. 

We are, as stated earlier, the face of the GI Bill at the State 

level. The level of interaction that we have with the players—there 

is no comparison to other processes. That level of interaction gives 

us an opportunity to not only know the folks but know the systems, 

but also to be able to identify what areas need attention and what 

areas do not really need attention. And that is what helps us to be 

as effective as I think we are. 

Mr. BOOZMAN. Thank you, Madam Chair. 

Ms. HERSETH SANDLIN. Yes. Thank you. 

And thank you both to Ms. Ryan and Mr. Sweeney. 

Mr. Hall, do you have questions for the panel? 

Mr. HALL. Briefly. Thank you, Madam Chairwoman. 

I apologize for being late and leaving early, but I am double and 

triple booked today. 

But I thank you, panelists, for your testimony which I have been 

reading. I heard part of Mr. Summerside’s testimony that was 

given earlier. 

I just want to say that the cut from $19 million or the drop this 

action has taken from $19 to $13 million seems like whoever made 

that decision must have made it in a vacuum. 

But there is a lot of talk going on now on the full Veterans’ Affairs Committee and the Subcommittees and when I go home and 

meet with veterans in my district about outreach and communicating what programs are available, what help is available to our 

veterans. 

And so I hope and believe that we will find a way to keep you 

performing your services that you have been so generously performing to date. 

I wanted to ask whether there is a difference, whether you are 

seeing a difference in terms of program targeting or tailoring of 

programs for, yet this may be that it is too early in terms of OEF/ 

OIF, but whether the veterans coming back from these wars are in 

need of different things or different kind of programs or different 

assistance than vets you worked with before to anybody who would 

like to answer or not answer. 

Ms. RYAN. Well, one of our association’s focuses in the last few 

years has been a concept of lifelong learning. As I said in my statement, many of them do not want or need the two- or four-year college education. They want to, for example, learn how to start their 

own business, so now there are entrepreneurship courses that they 

can take and use GI Bill to do that. 


wwoods2 on PRODPC68 with REPORTS
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There are the licensure and certification test reimbursements 

that they can get reimbursed, you know, they can get reimbursed 

for the cost of the course, those kind of things. 

In Illinois, we are seeing a tremendous increase in the on-the-job 

training and apprenticeship. Many of them do not want to go to 

school, do not want to go to college. They want to work. They have 

families. They are older. So that has been a big increase for us. 

And, you know, employers in the State are very, very interested 

in hiring veterans. You know, they recruit for veterans. They love 

having them. And so it is an easy sell in many ways. 

Mr. HALL. Thank you. 

And I am just curious. How much overlaps are you aware of or 

any of you aware of between the work that you do and the work 

that is being done either by the VA or by the VSOs? I mean, do 

you consider the work that you do to be filling a unique niche that 

otherwise would go unfilled? 

Ms. RYAN. Absolutely. And I do not want to overstate it, but we 

really are the face of the GI Bill out there in the schools and in 

the job training establishments. When we approach our approvals, 

we do it from the standpoint of Title 38, what is required for veterans, which is different sometimes than for just students in general. 

Mr. HALL. And, last, maybe, you two, you could just pick a figure 

out of the air, what do you think this 2008 budget should allot for 

SAAs? 

Ms. RYAN. We would be happy with 19 percent or $19 million. 

Mr. HALL. Nineteen-percent increase? 

Ms. RYAN. Yeah. No. No, no, no, no. I am thinking of the COLA. 

Mr. HALL. If we continue the existing funding, you——

Ms. RYAN. Yeah, what the COLA would be. 

Mr. HALL. You could work with that? 

Ms. RYAN. Yeah. That would be adequate for sure. 

Mr. HALL. Thank you very much, Madam Chairman. I yield 

back. 

Ms. HERSETH SANDLIN. Thank you, Mr. Hall. 

Mr. Summerside, did you have anything you wanted to add to 

Ms. Ryan’s answers to Mr. Hall’s question from your perspective? 

Mr. SUMMERSIDE. I can just say in South Dakota, I know if there 

is anything to do with VA educational programs, the office they call 

is ours. That can be from a County Service Officer. That can be 

from a vet rep or a DVOP. That can be from other agencies within 

State government. 

You know, I do work closely with Department of Education in 

South Dakota with some of my high school approvals, but they do 

not look at the things that we look at. They do not look at the 

things and they do not measure the things that the VA does. 

You know, a lot of the things is not just the quality of the program, but it is also based on how they can measure the payment 

for that program as far as the VA and their benefits. And that is 

unique to State Approving Agencies. 

Now, I am not as knowledgeable as my esteemed colleague, Don, 

over here, but I do know in our State as far as on-the-job and apprenticeship training, we are not a highly regulated State. A lot of 

our apprenticeship programs are nonregistered. They are not regVerDate Aug 31 2005 01:27 Apr 02, 2008 Jkt 035634 PO 00000 Frm 00017 Fmt 6633 Sfmt 6633 E:\HR\OC\35634.XXX 35634

wwoods2 on PRODPC68 with REPORTS
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istered apprenticeships that have oversight of the Bureau of Apprenticeship and Training. 

And the other thing, the Bureau of Apprenticeship and Training 

from my point of view has a wider spectrum to look at. We have 

one focus; it is the veteran. That is our only focus and that makes 

us uniquely qualified to serve them in this role. 

Ms. HERSETH SANDLIN. Well, thank you for your response. 

I would like to go back to Mr. Sweeny and Ms. Ryan, if that is 

okay, if I direct the question directly to Mr. Sweeney, because you 

both talked a lot about the differentiation between the State Approving Agency’s process versus the DOE’s accreditation process. 

Would you wish to elaborate on where you see this same type of 

differentiation or not, perhaps taking issue with how the GAO report characterized overlap as it relates to the Department of Labor? 

I think Mr. Summerside touched on it to an extent, but if you 

wanted to elaborate. 

Mr. SWEENEY. Well, what I recall, and I brought this huge notebook and put everything in it, but it might take too long to find 

the page that I need to find so what I recall is this. Certainly with 

registered apprenticeship programs where what is to be taught, for 

example, what knowledge and skills are to be taught, developed by 

the Federal Department of Labor or by the State Apprenticeship 

Councils where they exist. George knows this probably better than 

I, with State Councils, it is very similar to institutional programs. 

For example, a Bachelor of Science Degree in Engineering, you 

compare that to an apprenticeship program that is registered and 

you know that your State Council has already taken a look at what 

is to be taught, what knowledge and skills are to be learned. We 

can oversee that process in much less time in our evaluation than 

what it would take for a nonregistered apprenticeship program or 

what we term other on-the-job training. 

And I think the Department of Labor did mention in their comments or the GAO did with regard to apprenticeship and OJT that 

Department of Labor has no influence whatsoever on OJT programs. They do not have responsibility for them. There is no jurisdiction. So that is strictly an SAA function. 

I mean, for us, many times we are the only ones that take a look 

at that kind of a training program. We are the only ones that say 

it leads to a legitimate objective, here is what it is going to take 

to achieve the objective, here is what the process is going to be, and 

you can be reasonably assured that you will get a job in that occupation once you go through the process. 

Ms. HERSETH SANDLIN. Thank you. 

Mr. Scott, let us give you a chance to respond to some of the testimony and the answers to questions already posed as they relate 

to the accreditation process. And you did mention where you see 

some overlap and obviously some concerns have been raised and 

some respectful disagreement with how that has been characterized. 

When you undertook this review, did you conclude anything with 

regard to an approximate number or percentage of programs that 

are not reviewed by other agencies as just described by Mr. 

Sweeney? 


wwoods2 on PRODPC68 with REPORTS
15 

Mr. SCOTT. Well, thank you, Madam Chairwoman. Just a couple 

points if I could in terms of clarification. 

Just overall, I think looking at our report in terms of percentage 

of veterans and others enrolled in programs, the vast majority are, 

in fact, enrolled in an institution of higher education, colleges and 

universities. So from our perspective, that is one of the key areas 

to look at. 

And as such, the Department of Education is not simply reviewing schools for accreditation purposes. The Department of Education also looks at schools for ongoing compliance with the rules 

and regulations required to participate in Federal student aid programs. 

So I am hearing a lot of talk about accreditation, but that is just 

one part of the story. The Department has ongoing monitoring of 

colleges and universities and other schools who participate in Title 

4 programs, the ‘‘Higher Education Act.’’ So in our view, that is another level of on-site overview at the Department of Education. 

I think more fundamentally one of the things that I think is important about this hearing today is that in light of the number of 

changes in Federal oversight of colleges and universities, since 

State Approving Agencies were first created, clearly there is a 

much different role now in terms of the Department of Education’s 

oversight, in terms of their ongoing monitoring of these schools. 

So I think it is appropriate to now take a step back and look at 

given the role of the Department of Education, what is, in fact, the 

appropriate role for State Approving Agencies in terms of their 

oversight and monitoring of institutions that have been certified by 

the Department of Education. 

Ms. HERSETH SANDLIN. Well, let me stick with you for the remaining time I have and we will do another round of questions 

here. 

Mr. Scott, are State Approving Agencies positioned to provide 

better site monitoring than other agencies as it relates to on-thejob training, apprenticeship programs, and others? 

Mr. SCOTT. Well, I think clearly as we pointed out in our report, 

there are areas where State Approving Agencies do add value. I 

think the reason we recommended that the Department of Veterans Affairs sort of get together with the Departments of Education and Labor is to sort out exactly where are the overlaps. 

I mean, clearly there are some areas where no one is looking on 

accredited schools and programs, for example. That is one potential 

area where SAAs clearly add value because no one is looking at 

those. I mean, clearly some of the apprenticeship programs, that is 

another area where they add value. 

I think our more fundamental message, though, is it is important 

to take a step back, look, and sort of given the current funding 

problems that the SAAs are likely to face, where is the best way 

for them to use their limited resources. 

And I think our recommendations to the Department of Veterans 

Affairs to take a look at the overall potential overlap will help sort 

of sort out where, in fact, it is best to use those limited resources. 

Ms. HERSETH SANDLIN. Thank you. 

Mr. Boozman, do you have some followup? 


wwoods2 on PRODPC68 with REPORTS
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Mr. BOOZMAN. The only comment I would make, Madam Chairwoman, and, again just really what he was discussing, I think it 

does make all the sense in the world for VA and the State Approving Agencies and GAO to get together and really sort out the overlaps. Which is, it just does not seem that is being done. And so that 

certainly would be very helpful to myself and I think all of us, and 

our staffs are kind of sorting out where we go. 

But that is really the only comment I would make and I yield 

my time. 

Ms. HERSETH SANDLIN. We have also been joined by Mr. Donnelly on the Subcommittee. I would recognize Mr. Donnelly for any 

opening statement or questions he might have for the panel. 

Mr. DONNELLY. I would want to support the Chairwoman’s comments, also our Ranking Member’s as well, and yield back. 

Ms. HERSETH SANDLIN. Let me follow up on a couple of things. 

We know that some States have more than one State Approving 

Agency. 

Ms. Ryan, which States have more than one and are there any 

areas of responsibility that are divided up there or is it a matter 

of population only, again in an effort to prevent what can be overlap or duplication of services and how we best maximize the resources that are allocated to each State? 

Ms. RYAN. Okay. I can’t tell you exactly how many States have 

more than one. Several have two. Often there is one agency that 

handles the schools, the other that handles apprenticeship and onthe-job training. More often the on-the-job training aspect is in a 

Department of Labor kind of agency, State Apprenticeship Council, 

something like that. 

There are a couple where the division is with higher ed and nondegree and proprietary and nonproprietary. Basically, however, it 

is a local decision. Again, it is up to the Governor in each State to 

decide and appoint who is going to be the State Approving Agency 

in that State. 

We have seen in the past, since more States have taken on the 

OJT and apprenticeship function, we have seen a few more with 

two contracts. We have had a few who have combined. 

Mr. SCOTT. Madam Chairwoman, based on the information I 

have, there are eight States with two State Approving Agencies. 

Ms. HERSETH SANDLIN. Which are they? 

Mr. SCOTT. California, Connecticut, Indiana, Minnesota, North 

Carolina, Oregon, Washington, and Wisconsin. 

Ms. HERSETH SANDLIN. Thank you. 

For Mr. Summerside and Ms. Ryan, the issue of outreach and 

how your services have increased. Could either of you elaborate on 

how your outreach activities through your State Approving Agency 

have increased since National Guard and Reserve deployments 

that began in 2003? 

Mr. SUMMERSIDE. Madam Chairwoman, in the State of South Dakota, we kind of geared up for the activation of the Guard and Reserve in our State. I think there is over 3,000 that have been activated since 2003. 

Our agency was the lead as far as a welcome home brochure and 

since 2004, we distributed a little over 14,000. It is kind of the 

mainstay when they do the demobs. 


wwoods2 on PRODPC68 with REPORTS
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And that was the other thing Governor Rounds did. He obligated 

our division and other partners within our veteran service network 

to go actually to the sites where these National Guard and Reservists were being—the demob site. They would travel out of State 

wherever it was. 

And a big part of those briefings was the part on educational 

benefits. Many times if I was not there or other staff were not 

there, I would receive calls on the various different things on educational benefits. 

I recently did an outreach effort in Aberdeen. And at the end of 

that, it was an Army Reserve unit, there was various groups there 

and agencies and the longest line was the one to talk to me about 

educational benefits bar none. I was the one that was there far 

longer than anyone else. 

We have a combination of effort as far as outreach. But, you 

know, this is not new and did not start in 2003 in South Dakota. 

It started 50, 60 years ago in South Dakota. On-the-job and apprenticeship training is a byproduct of that aggressive outreach effort that we have always done. 

And in the last 25 years, we have been part of the Department 

of Military and Veterans Affairs. We have a direct connection not 

only with the veterans, the Guard, Reservists, and the dependents 

or survivors, but those county and tribal service officers and those 

veteran groups that make it just a great relationship in our development of any outreach plan that we do have. 

Ms. HERSETH SANDLIN. Let me just ask you another followup 

question then. For you, Ms. Ryan, how many State Approving 

Agencies do you know have actually been present at the demobilization sites for National Guard or Reserve soldiers? 

Ms. RYAN. I cannot tell you exactly. Many, many, many. We talk 

about it often in our National meetings. I can certainly get you that 

information. 

Ms. HERSETH SANDLIN. Mr. Summerside or Ms. Ryan, you have 

already talked about a reduction in funding and how that would affect your outreach and customer service efforts. 

As you made some decisions working with Governor Rounds and 

with the State Adjutant General, were the funds coming from the 

VA for the State Approving Agency? Did you allocate more of the 

funding in the last two years to the cost associated with providing 

specific outreach or has it just been broader and some of the issues 

that we have talked to as it relates to your relationship with the 

processing of education claims and the veterans that are coming to 

you? Are you allocating funding differently in any way over the last 

five to six years? 

Mr. SUMMERSIDE. The only thing that I can say from my perspective, we have always done outreach. Over the last couple of years, 

the VA has actually afforded us a payment for that outreach. And 

primarily in our State, it is the many outreach materials that we 

are able to—you know, sometimes we use a vendor as far as these 

quick reference guides that we provide on a wide range of topics, 

but specifically all the different chapters of education, you know, 

that is one thing that we progressively pursued in our State. 

And then that is the in-house stuff that we do, the welcome 

home, the OJT brochure, the school benefits brochure. We have two 


wwoods2 on PRODPC68 with REPORTS
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different brochures that we have developed in our State. And the 

other things, the technical manuals that we try to use and train 

these service professionals within our State, the County Service Officers, the vet reps, and Veteran Service Organizations. 

So to answer your question, we do have a line item for outreach 

over the last few years and I cannot go back to the exact contract 

year it started, but we have always done it somehow. 

Ms. HERSETH SANDLIN. Mr. Boozman? 

Mr. BOOZMAN. Very quickly. On page 20 of the GAO report, there 

is a graph, a summary of the functions. I guess what I would like 

to know is if you all, the State Approving Agencies, could get with 

GAO and really provide a more detailed breakdown than what we 

have got on the page. I think it would be very helpful to me to 

know what these different things represent and exactly what you 

are doing and, know what Education and Labor is represented. 

Again, if you could show us the contrast in this kind of vehicle, 

it would be very helpful. Thank you. 

Ms. RYAN. We would be glad to do that. 

[A followup letter, dated April 27, 2007, and supplemental information was provided by Ms. Ryan and Mr. Sweeney in response to 

Mr. Boozman’s request.] 

Mr. BOOZMAN. Thank you. 

Ms. HERSETH SANDLIN. One final question for Mr. Summerside 

and Ms. Ryan. Ms. Ryan, you stated in your testimony as it related 

to the GAO recommendation for the VA to establish outcome-oriented performance measures and you acknowledge that more could 

be done in that area. I am interested in your and Mr. 

Summerside’s perspectives on the other recommendation which 

would require SAAs to track and report data on resources spent on 

specific activities. 

Could you comment on how you view that recommendation and 

the administrative ease or difficulty in tracking and monitoring 

these activities? 

Ms. RYAN. We already do track the activities pretty extensively. 

We have quarterly reporting. George has developed a pretty extensive mechanism to do that. We report, you know, all kinds of numbers, outreach activities and approvals, and it is part of our selfevaluation process that happens at the end of the year. 

Ms. HERSETH SANDLIN. And each State Approving Agency does 

that or is this—— Ms. RYAN. Absolutely. 

Ms. HERSETH SANDLIN. Okay. 

Ms. RYAN. Yeah, absolutely. 

Ms. HERSETH SANDLIN. So this would be a matter of sitting down 

with the folks at the VA who agreed with that recommendation, 

showing them what you have——

Ms. RYAN. Yes. Yes. 

Ms. HERSETH SANDLIN [continuing]. And making any changes 

that may be necessary, but perhaps none would be required as they 

see the depth and breadth of what you are tracking? 

Ms. RYAN. Right. And they have access to that information. 

Ms. HERSETH SANDLIN. Okay. 

Ms. RYAN. They do have that. What we do not do is take it to 

the next step where we assign dollar figures to what we do, you 


wwoods2 on PRODPC68 with REPORTS
19 

know, X amount of dollars for outreach, X amount of dollars for approvals. We do not do that at this time. 

Ms. HERSETH SANDLIN. How difficult would it be to do that? 

Ms. RYAN. It would be difficult. 

Ms. HERSETH SANDLIN. Okay. 

Mr. SWEENEY. Could I add to that? 

Ms. HERSETH SANDLIN. Yes, please. 

Mr. SWEENEY. I think in part because it is a profession, we are 

not on a clock eight to five. I mean, I can be shoveling snow or 

riding around on my lawn mower cutting grass on a Saturday 

morning thinking about how I am going to resolve a problem. 

It is literally a profession. I think for most of us it is definitely 

not an eight to five, 40 hour week. So, you know, we could do a 

time clock mentality and try to break this out, but there is going 

to be some limitations on that. And that is part of the difficulty. 

Ms. HERSETH SANDLIN. I understand. 

Mr. Scott, do you have any comments? 

Mr. SCOTT. Yes, Madam Chairwoman. I think as we point out in 

our report along with the recommendations that we would hope 

that the recommendations in terms of how they would be implemented would be in proportion to the amount of program dollars 

we are talking about here. So we, of course, would not expect SAAs 

to come up with a multi-million dollar tracking system to keep 

track of $19 million. 

On the other hand, though, to the extent that these are Federal 

taxpayers’ dollars being spent, we do think it is important to make 

sure we can account for how the money is being spent. We did ask 

for data on sort of, you know, could you tell us how much, you 

know, of the resources are spent toward site visits, how much of 

the resources are spent toward outreach and that sort of thing. And 

they were not able to provide that information, they being the Department of Veteran Affairs. 

So we do think it is important to come up with some mechanism 

to provide a better accounting of how dollars are being spent and 

so that will help in terms of developing more outcome-oriented performance measures. 

Ms. RYAN. As a followup, we have had discussions with Keith 

Wilson at the central office about doing that very thing. 

Ms. HERSETH SANDLIN. I appreciate that because I did not want 

to get into the minutiae of how we go about doing that now. I 

would think that with the data that you have been collecting and 

sitting down as it relates to all three of these recommendations, 

there might be a way to address the issue of accountability that 

Mr. Scott has raised. 

Well, if there is nothing further from the members of the Subcommittee, I thank you each for your testimony and for being here 

today. We will look forward to following up with you as our staff 

and the other members may have additional questions that will be 

submitted as part of the hearing and record for today. Thank you. 

I would now invite our second panel to the witness table and as 

they are coming up allow me to introduce them to those who are 

at the hearing today. 

We have Mr. John McWilliam, Deputy Assistant Secretary for 

Operations and Management, Veterans’ Employment and Training 


wwoods2 on PRODPC68 with REPORTS
20 

Service of the U.S. Department of Labor; accompanied by Mr. Anthony Swoope, Administrator, Office of Apprenticeship, Employment and Training Administration for the U.S. Department of 

Labor; Ms. Carol Griffiths, Chief, Accrediting Agency Evaluation 

Unit, Office of Postsecondary Education of the U.S. Department of 

Education; and Mr. Keith Wilson, Director of the Education Service, Veterans Benefits Administration of the U.S. Department of 

Veterans Affairs respectively. 

All of you are very familiar with the Subcommittee and we appreciate you being here again today. We will go ahead and start 

with you, Mr. McWilliam, with your opening statement. 

STATEMENTS OF JOHN M. MCWILLIAM, DEPUTY ASSISTANT 

SECRETARY FOR OPERATIONS AND MANAGEMENT, VETERANS’ EMPLOYMENT AND TRAINING SERVICE, U.S. DEPARTMENT OF LABOR; ACCOMPANIED BY ANTHONY 

SWOOPE, ADMINISTRATOR, OFFICE OF APPRENTICESHIP, 

EMPLOYMENT AND TRAINING ADMINISTRATION, U.S. DEPARTMENT OF LABOR; CAROL A. GRIFFITHS, CHIEF, ACCREDITING AGENCY EVALUATION UNIT, OFFICE OF POSTSECONDARY EDUCATION, U.S. DEPARTMENT OF EDUCATION; 

AND KEITH M. WILSON, DIRECTOR, EDUCATION SERVICE, 

VETERANS BENEFITS ADMINISTRATION, U.S. DEPARTMENT 

OF VETERANS AFFAIRS 

STATEMENT OF JOHN M. MCWILLIAM 

Mr. MCWILLIAM. Thank you, ma’am. 

Chairwoman Herseth Sandlin, Ranking Member Boozman, Mr. 

Donnelly, I am pleased to appear today before you on functions performed by the State Approving Agencies. Accompanying me today 

is Mr. Tony Swoope, Administrator of the Office of Apprenticeship 

in the Department of Labor. 

DoL has a separate responsibility from that of the State Approving Agencies. Under the ‘‘National Apprenticeship Act 1937,’’ Labor 

is the Federal agency authorized to register apprenticeship programs for Federal purposes. Federal purposes include any Federal 

contract, grant, agreement, or arrangement and all Federal financial assistance. 

Department of Labor’s role is to safeguard the welfare of apprentices, ensure equality of access to apprenticeship programs, and 

provide integrated employment and training information to sponsors and the local employment and training community. 

Title 38 states that an eligible veteran may be paid a training 

allowance while pursuing a full-time program of apprenticeship 

when that program is approved by a State Approving Agency as 

meeting the standards published by the Secretary of Labor. 

Those standards require that the program be registered by either 

Department of Labor or a DoL recognized State apprenticeship 

agency. These State apprenticeship agencies are separate from the 

State Approving Agencies being discussed at today’s hearing. 

Labor has not determined what, if any, overlap exists between 

reviews conducted by Labor and the State Approving Agencies. We 

believe there may be overlap in the review of program sponsors’

performance. 


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Labor supports working with the Departments of Veterans Affairs and Education to review both the similarities and differences 

between the assessment components. We met with the VA in 

March on this subject. We look forward to continuing collaboration 

with our partners. 

DoL does not have any responsibility for, as mentioned earlier, 

nor do we participate in OJT programs for veterans. 

Madam Chairwoman, that concludes my testimony. Mr. Swoope 

and I will be pleased to answer your questions. 

[The prepared statement of Mr. McWilliam appears on p. 49.] 

Ms. HERSETH SANDLIN. Thank you very much, Mr. McWilliam. 

Ms. Griffiths. 

STATEMENT OF CAROL A. GRIFFITHS 

Ms. GRIFFITHS. Good afternoon, Madam Chairwoman, Ranking 

Member Boozman, and Mr. Donnelly. 

I appreciate the opportunity to be here today to share with you 

information regarding the Secretary’s recognition process. 

In context, the ‘‘Higher Education Act 1965’’ requires that the 

Secretary publish a list of accrediting agencies and State Approval 

Agencies that she recognizes as reliable authorities as to the quality of education provided by the institutions and programs that 

they accredit. Currently she recognizes 62 accrediting agencies and 

five State Approval Agencies. 

Understand that State Approval Agencies in the context of our 

process are units within the State Departments of Education whose 

function is the approval and oversight of public postsecondary vocational education. These programs are usually offered via the K 

through 12 school districts to adult students. 

The Secretary’s recognition enables over 8,100 institutions they 

accredit to establish eligibility to participate in the Title 4 student 

financial aid programs administered by the Department of Education as well as programs offered by other Federal departments. Recognition provides access to approximately $90 billion annually by institutions of higher education, students, and their families. 

The recognition process includes a self-review by the accrediting 

or State Approval Agency, a review conducted by the Department 

staff, review by an external body representative of the higher education community. This 15-member body is known as the Secretary’s National Advisory Committee on Institutional Quality and 

Integrity, the NACIQI. 

Ultimately after those reviews, the Secretary makes a decision of 

recognition. The review conducted is a compliance model review 

against the Secretary’s criteria for recognition. Accreditors must 

not only describe their policies, procedures, standards, and practice, 

they must show evidence or documentation of how they apply 

them. 

Department analysts review and evaluate that information and 

also conduct on-site evaluations and observations of accrediting 

agency activities in regard to the accreditation process as well as 

conduct file reviews at the agencies. 

Staff review includes an assessment of an agency’s organizational 

structure, its administrative and financial capacity, its adherence 


wwoods2 on PRODPC68 with REPORTS
22 

to principles of due process, what mechanisms it has in place to 

prevent conflicts of interest, its responsiveness to complaints, and 

its use of public input in the review of its standards and policies 

and practices, as well as, at the core of the accreditation process, 

a review of the agency’s quality standards by which they evaluate 

institutions and programs for accreditation and their consistent application of these and ongoing monitoring for compliance with 

them. 

Specifically as outlined in the ‘‘Higher Education Act’’ and in the 

Secretary’s criteria, these standards include administrative and fiscal capacity of an institution or program, an evaluation of curriculum, of faculty, of student support services, facilities and other 

resources and standards in the area of student achievement. 

From that Department staff draw conclusions of compliance and 

make a recommendation regarding recognition. All of the information provided by agency and by the Department staff go forward to 

the Secretary’s National Advisory Committee who meet twice a 

year to review agencies seeking both initial recognition or renewal 

of their recognition. 

After hearing from Department staff, from the agency, and other 

third-party commenters who show an interest, the Committee deliberates and provides the Secretary with a recommendation as to 

whether they recommend that she defer, deny, or renew recognition 

of that agency. 

Each accrediting agency is reviewed once every five years and 

State Approval Agencies are reviewed once every four years. 

In summary, currently the Secretary recognizes 62 accrediting 

agencies and five State Approval Agencies as reliable authorities of 

the quality of education and training provided by the institutions 

and programs they accredit. 

The recognition process is comprehensive, it is ongoing. It includes input from both internal and external sources. The recognition provides a critical oversight function for many Federal programs and, as I said before, enables access to $90 billion annually. 

I hope this information has been helpful to you and your members, and I am ready to answer any questions you may have regarding the recognition process. Thank you. 

[The prepared statement of Ms. Griffiths appears on p. 50.] 

Ms. HERSETH SANDLIN. Ms. Griffiths, thank you very much. 

Mr. Wilson, you are recognized. 

STATEMENT OF KEITH M. WILSON 

Mr. WILSON. Good afternoon, Madam Chairwoman, Ranking 

Member Boozman, and members of the Subcommittee. Thank you 

for the opportunity to discuss VA’s education programs and the role 

of the State Approving Agencies in those programs. 

My testimony will highlight the vital role of SAAs in ensuring 

that veterans receive the maximum benefit for their educational 

programs. 

VA and the SAAs work together to ensure the successful readjustment of veterans to civilian life through educational opportunities. VA administers educational assistance to eligible veterans and 

dependents while the SAAs ensure the quality of the educational 


wwoods2 on PRODPC68 with REPORTS
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and vocational programs pursued and monitor the institutions providing education and training to veterans. 

Since 2001, they also conduct outreach programs and provide 

outreach services to eligible servicemembers and veterans. Title 38 

establishes the parameters for this relationship. 

A recent GAO report contained three major recommendations. 

VA generally agrees with all three recommendations. We are taking actions to address these recommendations in cooperation with 

the National Association of State Approving Agencies as well as 

our colleagues at the Department of Labor and Department of Education. 

Public Law 100–323 requires an annual joint peer review group 

to meet for the purposes of evaluating performance of the individual State Approving Agencies. The JPRG is composed of four 

SAA representatives as well as four VA representatives. There are 

three designated ratings, satisfactory, minimally satisfactory, and 

unsatisfactory. 

For 2006, two SAAs received an unsatisfactory rating, three received a minimally satisfactory rating, and 54 agencies received a 

satisfactory rating. In fiscal year 2007, VA will provide approximately $19 million in 

funding to the SAAs. For fiscal year 2008, the amount of funding 

for SAAs will decrease to approximately $13 million per section 301 

of Public Law 107–330. 

The outreach activities added to the SAA’s role in 2001 may be 

impacted by the reduction in SAA funding. However, VA has taken 

steps to mitigate this impact. 

Information concerning VA education benefits is mailed three 

times to servicemembers while they are on active duty and again 

at separation. 

The Transition Assistance Program operated jointly by DoL, VA, 

and DoD, as well as benefit briefings for demobilizing National 

Guard and Reserve members provides information on education 

benefits available to these members. 

VA has also participated in the training of newly created State 

benefits advisors. 

Despite these efforts, a reduction in SAA funding may negatively 

impact our efforts to promote the use of VA education benefits, particularly the promotion of OJT and apprenticeship programs with 

employers. The extent to which these efforts could be impacted is 

difficult to predict. 

Madam Chairwoman, this concludes my statement. I would be 

pleased to answer any questions you or other members of the Subcommittee may have. 

[The prepared statement of Mr. Wilson appears on p. 52.] 

Ms. HERSETH SANDLIN. Thank you all for your testimony. 

I will start with a brief question. Mr. Wilson, you just said that 

there were two SAAs in 2006 that received an unsatisfactory rating; is that correct? 

Mr. WILSON. That is correct. 

Ms. HERSETH SANDLIN. Did either of them lose funding due to 

that unsatisfactory rating? 

Mr. WILSON. No. The way we approach this is from a progressive 

standpoint. We set up training and mentoring relationships with 


wwoods2 on PRODPC68 with REPORTS
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them. Ultimately if they do not perform to an acceptable level, we 

have the option of reducing funding or not opting to offer them a 

contract entirely, which we have done in the past. 

Ms. HERSETH SANDLIN. Okay. Do you know if the Administration 

intends to take a position as it relates to the need for increased resources beyond $13 million for the State Approving Agencies? 

Mr. WILSON. The Administration will not take a position. 

Ms. HERSETH SANDLIN. And, Ms. Griffiths, have you found it 

beneficial to maintain the distinction between national and regional institutional accreditors and is there overlap between the 

two? 

Ms. GRIFFITHS. Thank you for the question. 

In terms of the Secretary’s recognition process, all accreditors 

that seek recognition must comply with the same criteria, you 

know, in the context of the scope of their accrediting activities. 

Ms. HERSETH SANDLIN. So it has been beneficial to maintain the 

distinction between national or regional accreditors? 

Ms. GRIFFITHS. I think that, yes, that we have to evaluate and 

make the distinction based on the type of accrediting activity with 

the type of educational and training program being provided. 

Ms. HERSETH SANDLIN. Does the activity of the national 

accreditor and the regional accreditor differs in the process, in the 

review process? I am a little unclear as to—maybe you could just 

explain what a national institutional accreditor does that a regional one does not or there are distinctions in their—I know you 

just said that they use the same criteria. 

Ms. GRIFFITHS. Yes. Their processes are the same. They are free 

to develop their own standards, but the components of the accreditation process are the same between national institutional 

accreditors and regional and even programmatics. 

But an agency that evaluates a specialized single program perhaps applies those standards differently. They all have to have 

standards in the same areas, but they apply them in the context 

of the type of accrediting activity they do. 

Ms. HERSETH SANDLIN. Okay. 

Ms. GRIFFITHS. I hope that helps. 

Ms. HERSETH SANDLIN. I may have some other questions. We 

just have another series of votes, so let me move quickly to our 

Ranking Member for any questions. 

Mr. BOOZMAN. Thank you very much. 

First of all, I want to thank all of you. I know that you worked 

very hard and, we are trying to move things forward and do the 

very best that we can for our veterans. 

But I am a little bit concerned. Mr. Wilson, on your testimony 

at the end you alluded to the fact that we really did not know how 

this was going to affect the ability of our men and women to know 

what was going on and things. 

And I guess one of the threads that I have seen, and I think we 

work really hard at this now, but one of the threads I have seen 

in being with our troops, from the testimony that we have taken 

in different deals was right now, was then many of our people in 

uniform do not understand the flexibility that they have in the GI 

Bill and what they can be used for. 


wwoods2 on PRODPC68 with REPORTS
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It sounds like you are not supporting an increase from the $13 

million; is that correct? 

Mr. WILSON. We are not taking a position on the increased funding. 

Mr. BOOZMAN. But on the other hand, that is going to be potentially even more of a problem, even though we are working on it 

hard now, that is a big problem. 

Mr. WILSON. It is a concern for us as well. One of the unknowns 

as we move forward into a potential reduction is whether we have 

the flexibility in VA obviously to manage this contract. On the 

other hand, the States also have the flexibility of deciding whether 

or not they want to enter into a contract with us. 

And it may be simply that there could be some States that it is 

no longer to their benefit, that we are not able to reimburse them 

to the level that they need. And that is the unknown that we have 

difficulty quantifying. 

Mr. BOOZMAN. Well, our Committee really is to interface in that 

regard with you. And so, if we lose any of that—in fact, I would 

like for us to push that we do a better job of making that known 

because it is so important. The benefit is there and, again, a lot of 

them do not understand. 

When you look at the numbers of taking up the slack through 

the rest of the agency and when you look at the average salary, 

then according to Mike Smith, and you are talking about 76, in the 

70s FTEs doing that. So when you do that, we already have a problem with processing educational claims, I just do not see how you 

can do it. And so, again I guess I feel very strongly that we are 

going to hold you accountable to do that. 

You mentioned the fact that some of the agencies, had problems. 

And, again, we very much need to rectify that. And I think it is 

good that we have the process in place so we can recognize when 

somebody is not doing their job. 

On the other hand, as we, the VA Committee, you the VA, run 

into problems all the time and we solve those problems. You do not 

throw away everything. 

So, again, I would just say that I would hope VA really thinks 

this through. I want to help you. I want to get you the funding that 

you need. I want to fight for it. 

But if you do not feel like, and it sounded like in your testimony 

you were waffling a little bit, you cannot do it, then, like I said, 

we are going to come after you because you are going to mess up 

in these other areas and we are going to have a bigger mess. But 

I would say that in some of those areas, we are not doing a very 

good job now. 

So I would appreciate if VA would really think this through and 

then I think you need to come out one way or the other. If you cannot do your job with $13 million, then you need to tell us what it 

is going to take. And it sounds to me like we are really having a 

little bit of trouble with the $19 million. 

I yield back to the Chairwoman. 

Ms. HERSETH SANDLIN. Thank you, Mr. Boozman. 

I associate myself with his comments and we are trying to just 

determine what level of activity is best to be maintained which is 


wwoods2 on PRODPC68 with REPORTS
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why some of our earlier questions from the prior panel tried to 

probe this area, this issue of overlap or duplication. 

I understand because it is a statutory cap, the Administration 

may not want to take a position at this point, but would you at 

least share with us from your perspective as the Director if the 

Secretary feels? As I think we heard from the first panel, that Operation Iraqi Freedom and Operation Enduring Freedom have had 

an impact, an expansive impact on the mission of the State Approving Agencies. 

Mr. WILSON. It absolutely has, particularly from the perspective 

of outreach as we have been talking about. 

What we do not have a good handle on, and an area that I look 

forward to working with my colleagues in DoL and DoE on, is 

where is potential overlap and are there things that we can do 

more efficiently that will allow us yet further to mitigate the impact of any potential reduction in funding. 

I think the folks at GAO did a very good job with their report. 

However, one thing that troubles me is I believe that there may be 

a belief that our responsibility, the programs that we administer in 

VA are equivalent to Federal student aid, even to the point of GAO 

using aid as a term when they talked about veterans’ programs. 

Speaking as a veteran now, I do not equate it with aid. That is 

a benefit that is earned. And I believe we have a higher level of 

responsibility than really exists with Federal student aid. And we 

have to find a way of meeting that. 

Ms. HERSETH SANDLIN. I appreciate that comment, Mr. Wilson. 

I think it is a very good point for us to keep in mind as we do 

maybe go another level or two further, as the Ranking Member has 

suggested, as I think it is a good recommendation talking with staff 

about this issue of overlap and how these measures in the matrix 

are used. We need some more specificity so that distinctions such 

as you just articulated are adequately accounted for. 

That does lead me to a question, Mr. McWilliam, did you mention that DoL has yet to determine if overlap exists between reviews by the registered apprenticeship system and the State Approving Agencies? 

Mr. MCWILLIAM. That is correct, ma’am, and I will ask Mr. 

Swoope, if I may, to elaborate on that. 

Ms. HERSETH SANDLIN. I appreciate that. Is the review being undertaken currently? 

Mr. SWOOPE. Yes, Madam Chairwoman. We are having conversations with the Department of Veterans Affairs and we hope to continue with that conversation to see how we can better partner our 

activities to benefit the veterans that are coming out and receiving 

the services that are required and we would like for them to participate in that. In our case, the National Apprenticeship System. 

Ms. HERSETH SANDLIN. Have the State Approving Agencies, or 

any of their representatives, been at the table in these discussions 

as they relate to not just coordination between DoL and the VA but 

as we heard from the first panel, the importance of what they have 

been sitting down with you about, Mr. Wilson? Have they been—— Mr. SWOOPE. Two things. At the national level, we just had a 

conversation with the VA. At the State level where our staff is 

working in that area in Federal States where they had the responVerDate Aug 31 2005 01:27 Apr 02, 2008 Jkt 035634 PO 00000 Frm 00030 Fmt 6633 Sfmt 6633 E:\HR\OC\35634.XXX 35634

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sibility for registering program, we encourage our staff to partner 

and work with the veteran organizations or approving agency so 

that veterans can receive VA benefits. 

So we try to include that on an ongoing basis by our Federal staff 

and the State agency staff at the local level to ensure that they 

know where we are, what we are, what we are doing, and how do 

we have this partnership where the veteran can receive VA benefits that they are entitled to, going through an apprenticeship program. 

Ms. HERSETH SANDLIN. I appreciate that. 

One final question and then I am going to see if the Ranking 

Member has any further followup. 

Ms. Griffiths, you said that the Department of Education recognizes five State Approving Agencies. Describe these five for me. 

When you say State Approving Agencies, are you talking about a 

different type of entity than what we are talking about when we 

say State Approving Agencies that work with VA funding and how 

would you characterize or describe Department of Education’s relationship with the State Approving Agencies that testified today? 

Ms. GRIFFITHS. In terms of the recognition process, we do not 

have a relationship with State Approving Agencies from the Department of Veterans Affairs. What we have, our State Approval 

Agencies, they are units within State Departments of Education 

that have an oversight function for public post-secondary vocational 

education in their states. 

And these approval agencies, some of them, should they choose 

to, seek the Secretary’s recognition by submitting to this evaluation 

and review. If they are recognized State Approval Agencies, again 

units in State Departments of Education that have that function, 

then those public postsecondary vocational education programs 

that they approve are eligible to participate in Title 4 student financial aid programs. 

Ms. HERSETH SANDLIN. Okay. But separate from this formal recognition of an agency, if they do not go through that process because that might require substantial changes at the State level 

with some of the folks that we heard from earlier. How do you envision the Department of Education being a part of this collaboration with the VA and the Department of Labor and the State Approving Agencies that work with the VA? 

Ms. GRIFFITHS. I am not sure I can answer that question. I do 

not know that I today have sufficient information to talk about 

what that would look like. But I do know that we would be most 

open and willing and eager to sit down and talk with and find out 

more information and see what we can do in the best interest of 

the use of tax dollars. Yes. 

Ms. HERSETH SANDLIN. I appreciate that. I do think it is important as, Mr. Swoope, as you worked to undertake this review and 

analysis, that DoE’s perspective be shared. It will help us answer 

some questions raised in the GAO report so we can have a better 

understanding from the State Approving Agencies’ perspective 

where they do not really consider it an overlap of services but actually a more targeted service to the veteran himself or herself. 

Any final comments from any our panelists on that point with regard to collaboration? 


wwoods2 on PRODPC68 with REPORTS
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Mr. WILSON. If I could add just a brief comment to Mr. Swoope’s 

statement. 

Ms. HERSETH SANDLIN. Sure. 

Mr. WILSON. Getting back to your original question, we will be 

engaging the SAAs in these discussions. We are not at that point 

yet. We will be engaging them as I would hope that we would be 

engaging the staff of this Committee. We certainly will be looking 

at procedural and regulatory issues, but I think it is important to 

look at the statutory requirements that we are all responsible for 

meeting as well. 

Ms. HERSETH SANDLIN. Another point well-taken. Thank you, 

Mr. Wilson. 

Mr. Boozman. 

Mr. BOOZMAN. No. With the Committee’s approval, we might 

have a question or two that we will submit. Thank you. 

Ms. HERSETH SANDLIN. Certainly. Thank you again. I appreciate 

the insight and perspective you have offered. As is common with 

the Subcommittee, first under Mr. Boozman’s leadership as Chairman and now in the 110th Congress, we appreciate the working relationship we have with all of your offices, the work of our staff 

who worked with you in the past and not only as staff of this Subcommittee but other VSOs that they have worked with. We look 

forward to the followup that I think will be necessary for us to take 

full advantage of the good work as you described it, Mr. Wilson, in 

the GAO report and the perspective of the State Approving Agencies that was offered today. 

Thank you very much. 

We have got three minutes from the vote, so this hearing better 

stand adjourned. 

[Whereupon, at 3:53 p.m., the Subcommittee was adjourned.] 


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A P P E N D I X 

Opening Statement of the Honorable Stephanie Herseth Sandlin, 

Chairwoman, Subcommittee on Economic Opportunity 

Good afternoon, ladies and gentlemen. The Veterans’ Affairs Economic Opportunity Subcommittee hearing on functions performed by State Approving Agencies 

(SAA) will come to order. 

Before I begin with my opening statement, I would like to call to attention to the 

fact that Ms. Jean Morse, President of the Middle States Commission on Higher 

Education has asked to submit a written statement for the record on behalf of the 

Council of Regional Accrediting Commissions. If there is no objection I ask for unanimous consent that this statement be entered for the record. 

Today we will be hearing testimony on State Approving Agencies. The authority 

of SAAs was established by Congress in 1947 to ensure that veterans and eligible 

dependents can use the G.I. Bill educational entitlement in an approved educational 

program. Under contract with the Department of Veterans’ Affairs (VA), the key function of SAAs is to ensure that education and training programs meet VA standards 

through a range of approval activities, such as: conducting on-site visits, evaluating 

course quality, assessing school financial stability, and monitoring student progress. 

Every state assesses each program as to its own standards and laws in addition 

to the VA rules and regulations, with all approved programs undergoing continuous 

supervision. The programs that can be approved include colleges, universities, vocational and technical schools, flight schools, apprenticeship programs, and other onthe-job training programs. In addition, SAAs engage in outreach activities to foster 

the usage of the G.I. Bill. 

This year, my home state of South Dakota is expecting to have approximately 

2,100 eligible people enrolled in G.I. Bill eligible programs. These programs are now 

found in 47 schools and 192 training establishments in my state. I have a strong 

interest in exploring the subject before us today to improve the availability of educational benefits for our men and women in uniform. 

I understand there are concerns about the funding change that is about to occur for SAAs. From fiscal years 2003 to 2006, their funding increased from $13 million 

to $19 million to expand services. However, the funding level for SAAs is scheduled 

to decrease beginning in fiscal year 2008. 

According to a recent report, the Government Accountability Office concluded that 

there was overlap between the efforts of SAAs and the other federal agencies. While 

VA spends $19 million to fund SAA duties and functions, it does not track the 

amount it spends on specific SAA activities, especially those that may also be performed by other agencies. I am very interested in hearing your insights on how 

these concerns are being addressed. 

f 

Opening Statement of the Honorable John Boozman, 

Ranking Republican Member, Subcommittee on Economic Opportunity 

Good afternoon, everyone. 

The State Approving Agencies have, for many years, been a mainstay in ensuring 

that veterans attending education and training programs under the various GI Bills 

receive quality instruction. That is why I thank you, Madam Chairwoman, for holding this hearing. 

A recent GAO report that updated a 1995 report again found overlaps in the functions performed by the State Approving Agencies, the regional and professional accrediting agencies acting on behalf of the Department of Education, and the oversight services provided by the state employment services. While the recent report 

was less critical than its predecessor and noted that SAAs did, in fact, provide perspectives not replicated by the other organizations, GAO again recommended a thorough interagency review of how the federal government oversees the education industry. I believe that it is important to begin that process as a means to improve 

the education and training opportunities for veterans and dependents. 


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1GAO, VA Student Financial Aid: Management Actions Needed to Reduce Overlap in Approving Education and Training Programs and to Assess State Approving Agencies, GAO–07–384 

(Washington, D.C.: Mar. 8, 2007). 2GAO, VA Student Financial Aid: Opportunity to Reduce Overlap in Approving Education and 

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

Another issue we face is how much funding should VA provide to the states to 

act as VA’s agent. VA currently pays the collective SAAs about $19 million out of 

the Readjustment Benefits Account (RBA). As such, those payments are mandatory 

spending and beginning in FY 08, the law cuts that funding to $13 million. So, the 

question before us is what is the value of the services provided by the SAAs? 

I note that we will also hear from a regional accrediting agency as well as a representative from the Department of Education. I look forward to their testimony, especially the functions and costs associated with their programs. 

I am sorry that witnesses from the accrediting bodies we invited were unable to attend. Their testimony would have been a valuable perspective relative to the GAO’s 

findings. I would note that accrediting associations overseeing colleges and universities are membership organizations who charge their members significant annual dues 

as well as large fees for other functions such as approving new courses of instruction. For example, the alma mater of one of our staff is a small liberal arts school 

in the Midwest with a full time enrollment of about 1,800 students. That school 

pays at least $4,000 in annual dues to its main accrediting association in addition 

to any fees for special visits. I am not criticizing the accrediting bodies for charging 

fees, but I thought it important that the Members know this aspect of their operations. 

Regarding the Department of Labor, I am looking forward to hearing about the 

level of their interaction with the SAAs in approving OJT and apprenticeship programs. 

Madame Chairwoman, thanks again for your leadership on this issue and I yield 

back. f 

Statement of George A. Scott, Director, Education, Workforce and Income 

Security Issues, U.S. Government Accountability Office 

Madame Chairwoman and Members of the Subcommittee: 

I am pleased to be here today to present information from our March 2007 report 

on state approving agencies (SAA).1 In fiscal year 2006, the Department of Veterans 

Affairs (VA) paid approximately $2.1 billion in education assistance benefits to more 

than 470,000 beneficiaries and about $19 million to state approving agencies to assess whether schools and training programs offer education of sufficient quality for 

veterans to receive VA education assistance benefits when attending them. Qualified 

individuals—veterans, service persons, reservists, and certain spouses and dependents—receive benefits through a number of education assistance programs for the 

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

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

by an SAA in order for qualified individuals to receive VA education assistance benefits. Under contracts with VA, SAAs ensure that education and training programs 

meet VA standards through a variety of approval activities, such as evaluating 

course quality, assessing school financial stability, and monitoring student progress. 

The Departments of Education (Education) and Labor (Labor) also assess education and training programs for various purposes, primarily for awarding student 

aid and providing apprenticeship assistance. These assessments are based, in part, 

on evaluations against standards set by laws and regulations, such as those applicable to accrediting agencies. In 2006, under Title IV of the Higher Education Act, 

Education provided nearly $77 billion in student aid in the form of both grants and 

loans. Education assesses and certifies postsecondary institutions for participation 

in Title IV programs through various oversight functions to ensure that these 

schools meet federal administrative and financial requirements and that they are 

accredited and licensed. Similarly, under the National Apprenticeship Act 1937, 

Labor is authorized to formulate and promote the furtherance of labor standards to 

safeguard the welfare of apprentices. To ensure programs comply with federal 

standards, Labor directly registers and oversees apprenticeship programs in less 

than half of the states and has given state apprenticeship agencies or councils in 

the remaining states such authority over their own programs. 

Given each agency’s role, the potential of duplicative efforts among federal agencies has been a congressional concern. In 1995, GAO reported on this matter and 

concluded that there was a substantial amount of overlap between the efforts of 

SAAs and the other federal agencies.2 My testimony today is based on information 

from our recent report and will focus on (1) changes that have occurred in state apVerDate Aug 31 2005 01:27 Apr 02, 2008 Jkt 035634 PO 00000 Frm 00034 Fmt 6604 Sfmt 6621 E:\HR\OC\35634.XXX 35634

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

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

proving agencies’ duties and functions since 1995, (2) the extent to which the SAA 

approval process overlaps with efforts by the Departments of Education and Labor, 

and (3) the additional value that SAA approval activities bring to VA education benefit programs. 

In summary, we found that: 

• Since 1995, legislative changes effective in 2001 created additional responsibilities for SAAs, including promoting the development of apprenticeship and onthe-job training programs, providing outreach services, and approving tests for 

occupational licensing.3 From fiscal years 2003 to 2006, SAA funding increased from $13 million to $19 million to expand services and support the additional 

responsibilities. However, funding is scheduled to decrease beginning in fiscal 

year 2008. • Many education and training programs approved by SAAs have also been approved by Education or Labor, and VA and SAAs have taken few steps to coordinate approval activities with these agencies. In addition, information is not 

available to determine the amount of resources spent on SAA duties and functions, including those that may overlap with other agencies and programs. • SAAs reportedly add value to the approval process for education and training 

programs through (1) a focus on student services for veterans and on the integrity of VA benefits, (2) more frequent on-site monitoring of education and training programs than provided by Education or Labor, and (3) assessments and approval of a small number of programs that are not reviewed by other agencies. 

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

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

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

recommended that the Secretary of the Department of Veterans Affairs take steps 

to monitor SAA spending and identify whether any resources are spent on activities 

that duplicate the efforts of other agencies. We also recommended that the Secretary 

establish outcome-oriented performance measures to assess the effectiveness of SAA 

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

take a number of steps to address them. 

To conduct our work, we reviewed applicable laws, regulations, and program materials; and interviewed officials from each of the entities involved in the various 

approval processes, including federal agencies, state approving agencies, schools and 

training programs. We also reviewed and analyzed data on approval decisions from 

VA, Education, and Labor. Our work was performed in accordance with generally 

accepted government auditing standards. 

Background 

VA, Education, and Labor assess education and training programs for various 

purposes. VA’s approval process is meant to ensure that education and training programs meet VA standards for receipt of veteran education assistance benefits, while 

Education’s and Labor’s processes are primarily for awarding student aid and providing apprenticeship assistance. 

VA administers a number of programs designed to assist individuals in gaining 

access to postsecondary education or training for a specific occupation (see table 1). 

VA generally provides its assistance in the form of payments to veterans, service 

persons, reservists, and certain spouses and dependents. 

Table 1: VA Beneficiaries of and Funding for Education and Training Assistance 

Programs in Fiscal Year 2006 

Programs * Beneficiaries Expenditures 

Montgomery GI Bill (Chapter 30) 313,766 $1,909,014,605 

Reserve Educational Assistance Program (Chapter 1607) 23,747 $151,397,610 

Educational Assistance for the Selected Reserve 

(Chapter 1606) 65,145 $48,716,031 

Dependents and Survivors Educational Assistance Program (Chapter 35) 74,532 $38,787,332 

Veterans Educational Assistance Program (Chapter 32) 575 $59,113 

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

Source: VA. 

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


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Benefits can be used to pursue a degree program, vocational program, apprenticeship, and on-the-job training (see fig. 1). Before an individual entitled to VA education assistance can obtain money for an education or training program, the program must be approved by an SAA, or by VA in those cases in which an SAA has 

not been contracted to perform the work. 

Figure 1: Veteran Enrollment by Program Type in Fiscal Year 2006 

VA’s administrative structure for the education and training assistance programs 

includes its national office, which oversees the four regional processing offices 

(RPO), and the national contract with SAAs. RPOs administer the education assistance programs and process benefits for veterans. SAAs review education and training programs to determine which programs should be approved and ensure schools 

and training providers are complying with VA standards. SAAs have six core duties: 

(1) approval of programs, (2) visits to facilities, (3) technical assistance to individuals at facilities, (4) outreach, (5) liaison with other service providers, and (6) contract management. Sixty SAAs exist in the 50 states, the District of Columbia, and 

Puerto Rico. Eight states have two SAAs. SAAs are usually part of a state’s department of education (31 SAAs). In some states, SAAs are organizationally located in 

other departments such as labor (9 SAAs) or veterans’ services (19 SAAs). 

The U.S. Department of Education’s approval process is to ensure that schools 

meet federal Education standards to participate in federal student financial aid programs. In order for students attending a school to receive Title IV financial aid, a 

school must be (1) licensed or otherwise legally authorized to provide postsecondary 

education in the state in which it is located, (2) accredited by an entity recognized 

for that purpose by the Secretary of Education, and (3) certified to participate in 

federal student aid programs by Education. As such, the state licensing agencies, 

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

approval activities. 


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• State licensing agencies grant legal authority to postsecondary institutions to 

operate in the state in which they are located. Each of the states has its own 

agency structure, and each state can choose its own set of standards. • Accrediting agencies develop evaluation criteria and conduct peer evaluations to 

assess whether or not those criteria are met by postsecondary institutions. Institutions or programs that meet an agency’s criteria are then ‘‘accredited’’ by 

that agency. As of November 2005, there were 60 recognized private accrediting 

agencies of regional or national scope. • The U.S. Department of Education’s Office of Postsecondary Education evaluates and recognizes accrediting agencies based on federal requirements to ensure these agencies are reliable authorities as to the quality of education or 

training provided by the institutions of higher education and the higher education programs they accredit. • The U.S. Department of Education’s Office of Federal Student Aid determines 

the administrative and financial capacity of schools to participate in student financial aid programs, conducts ongoing monitoring of participant schools, and 

ensures participant schools are accredited and licensed by the states. 

The purpose of the Department of Labor’s approval process is to establish and 

promote labor standards to safeguard the welfare of apprentices. Labor establishes 

standards and registers programs that meet the standards. Labor directly registers 

and oversees programs in 23 states but has granted 27 states, the District of Columbia, and 3 territories authority to register and oversee their own programs, conducted by state apprenticeship councils (SACs). Labor reviews the activities of the 

SACs. SACs ensure that apprenticeship programs for their respective states comply 

with federal labor standards, equal opportunity protections, and any additional state 

standards. 

Figure 2 shows the agencies responsible for the approval processes for the various 

types of education and training programs. 

Figure 2: Agencies Responsible for the Approval Process for Education 

and Training Programs 

Source: GAO Analysis. 

Legislative Changes Effective in 2001 Created Additional Responsibilities 

for SAAs 

In 2001, SAAs received additional responsibilities as a result of legislative 

changes. This included responsibility for actively promoting the development of apprenticeship and on-the-job training programs and conducting more outreach activities to eligible persons and veterans to increase awareness of VA education assistance. SAAs were also charged with approving tests used for licensing and certification, such as tests to become a licensed electrician. For those tests that have been 

approved, veterans can use VA benefits to pay for testing fees. From fiscal years 

2003 to 2006, SAA funding increased from $13 million to $19 million to expand services and support the additional responsibilities. Funding is scheduled to begin to decrease in fiscal year 2008. 


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Many Education and Training Programs Approved by SAAs Have Also Been 

Approved by Education or Labor, and VA Has Taken Few Steps to Coordinate Approval Activities with These Agencies 

Many education and training programs approved by SAAs have also been approved by Education and Labor. Sixty-nine percent of all programs approved by 

SAAs are offered by institutions that have also been certified by Education. Seventyeight percent of SAA-approved programs in institutions of higher learning (e.g., colleges and universities) have been certified by Education. Also, 64 percent of SAAapproved non-college degree programs are in institutions that have been certified 

by Education. Although less than 2 percent of all programs approved by SAAs are 

apprenticeship programs, VA and SAA officials reported that many of these programs have also been approved by Labor. 

Similar categories of approval standards exist across agencies, but the specific 

standards within each category vary and the full extent of overlap is unknown. For 

example, while VA and Education’s approval standards both have requirements for 

student achievement, the New England Association of Schools and Colleges, an accrediting agency, requires that students demonstrate competence in various areas 

such as writing and logical thinking, while VA does not have this requirement. Also 

among the student achievement standards, VA requires schools to give appropriate 

credit for prior learning, while Education does not have such a requirement. Table 

2 shows the similar categories of standards that exist across agencies. 

Apprenticeship

Table 2. Approval Standards of Education and Training Programs Used by VA, 

Education, and Labor 

Categories of approval standards 

SAA 1,2 Education3 Labor 

IHL/NCD 

accredited 

IHL/NCD 

nonaccredited Apprenticeship 

On the 

job 

training 

Education’s 

certification 

Federal 

Standards 

for accrediting 

agencies 

Connecticut 

state licensing 

agency 

Student 

achievement X X X X X X X 

Curricula, program objectives, 

and faculty X X X X X X X X 

Facilities, 

equipment, 

and supplies X X X X X X X 

Institutional 

objectives, 

capacity, and 

administration X X X X X X 

Student support 

services X X 

Recruiting and 

admission 

practices X X X X X X 

Record of student 

complaints X X 

Process related 

requirements 

(e.g. application 

requirements) X X X X X X X 

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

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

agencies. SAAs have different sets of standards for each program type (e.g. IHL and NCD). Education’s approval 

process involves different sets of standards used by different entities, such as accrediting agencies. Labor has 

one set of standards that is applicable to apprenticeship programs. 1 By statute, courses must meet certain criteria. These relate to: (1) recordkeeping of student progress; (2) recordkeeping of students’ previous education; (3) quality, content and length of courses; (4) qualifications of administrators and instructors; and (5) equipment, space, and instructional materials. We categorized the first two criteria as student achievement, criteria (3) and (4) as Curricula, Program Objectives and Faculty, and criterion (5) 

as Institutional objectives, capacity, and administration. 2SAA approval requirements for non-accredited courses encompass a number of additional criteria, such as 

having a tuition refund policy and enrollment limitations. 3 Connecticut’s standards may not be representative of standards across the country. 

While agencies have the same approval standards in some instances, the interpretation and application of these standards may differ. For example, VA, accrediting 

agencies, and Labor each require that facilities have adequate space, equipment, 

and instructor personnel to provide quality training, but the definitions of adequacy 

differ in the level of specificity. Similarly, VA and accrediting agencies both require 


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that schools have policies related to student achievement, such as minimum satisfactory grades, but the requirements differ in level of specificity. 

Despite the overlap in approved programs and standards, VA and SAAs have 

made limited efforts to coordinate approval activities with Education and Labor. VA 

reported that while it has coordinated with Education and Labor on issues related 

to student financial aid and apprentices’ skill requirements, it believes increased coordination is needed for approval activities in order to determine the extent of duplicative efforts. Most of the SAA officials we spoke with reported that they have coordinated with SACs to register apprenticeship programs in their states. Labor reported that it coordinated with VA’s national office in several instances, including 

providing a list of registered apprenticeship programs. Education reported that it 

does not have formalized coordination with VA but has had some contacts to inform 

VA of its concerns regarding specific institutions. 

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

duties and functions, including those that may overlap with those of other agencies. 

VA does not require SAAs to collect information on the amount of resources they 

spend on specific approval activities. The SAA officials we spoke with said that their 

most time-consuming activity is conducting inspection and supervisory visits of 

schools and training facilities. However, the lack of data on resource allocation prevented us from determining what portions of funds spent by SAAs were for approval 

activities that may overlap with those of other agencies. 

SAAs Reportedly Add Value to the Approval Process for Education and 

Training Programs, but the Lack of Outcome-Oriented Performance 

Measures Makes It Difficult to Assess the Significance of Their Efforts 

SAA and other officials reported that SAA activities add value because they provide enhanced services to veterans and ensure program integrity. According to these 

officials, SAAs’ added value includes a focus on student services for veterans and 

on VA benefits, more frequent on-site monitoring of education and training programs than Education and Labor, and assessments and approval of a small number 

of programs that are not reviewed by other agencies, such as programs offered by 

unaccredited schools, on-the-job training programs, and apprenticeship programs 

not approved by Labor. 

SAA approval activities reportedly ensure that (1) veterans are taking courses 

consistent with occupational goals and program requirements, (2) schools and training programs have evaluated prior learning and work experience and grant credit 

as appropriate, and (3) school or program officials know how to complete paperwork 

and comply with policies required by VA educational assistance through technical 

assistance. According to officials we interviewed, SAAs generally conduct more frequent on-site monitoring of education and training programs than Education or 

Labor, possibly preventing fraud, waste, and abuse. Some officials reported that 

SAAs’ frequent visits were beneficial because they ensure that schools properly certify veterans for benefits and that benefits are distributed accurately and quickly. 

States, schools, and apprenticeship officials we spoke with reported that without 

SAAs, the quality of education for veterans would not change. However, veterans’ receipt of benefits could be delayed and the time required to complete their education and training programs could increase. 

Despite areas of apparent added value, it is difficult to fully assess the significance of SAA efforts. VA does measure some outputs, such as the number of supervisory visits SAAs conduct, but it does not have outcome-oriented measures, such 

as the amount of benefit adjustments resulting from SAAs’ review of school certification transactions, to evaluate the overall effectiveness and progress of SAAs. (See 

table 3.) 

Table 3: Examples of VA Output Measures and Potential Outcome Measures 

Examples of Existing VA Output 

Measures 

Examples of Potential Outcome 

Measures 

Percentage of visits to facilities for supervisory Amount of benefit adjustments resulting 

and inspection purposes completed within from SAAs’ review of school certification 

VA specified timeframes transactions 

Number of times technical assistance provided Error rate of certification transactions 

to interested parties such as individuals and identified by SAAs 

schools 

Number of approved facilities with approved Completion rates of beneficiaries 

programs 

Source: GAO analysis. 


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Prior Recommendations and Agency Response 

We made several recommendations to the Department of Veterans Affairs to help 

ensure that federal dollars are spent efficiently and effectively. We recommended 

that the Secretary of the Department of Veterans Affairs take steps to monitor its 

spending and identify whether any resources are spent on activities that duplicate 

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

the total resources of the program. Specifically: 

• VA should require SAAs to track and report data on resources spent on approval activities such as site visits, catalog review, and outreach in a cost-efficient manner, and • VA should collaborate with other agencies to identify any duplicative efforts and 

use the agency’s administrative and regulatory authority to streamline the approval process. 

In addition, we recommended that the Secretary of the Department of Veterans 

Affairs establish outcome-oriented performance measures to assess the effectiveness 

of SAA efforts. 

VA agreed with the findings and recommendations and stated that it will (1) establish a working group with the SAAs to create a reporting system to track and 

report data for approval activities with a goal of implementation in fiscal year 2008, 

(2) initiate contact with appropriate officials at the Departments of Education and 

Labor to identify any duplicative efforts, and (3) establish a working group with the 

SAAs to develop outcome-oriented performance measures with a goal of implementation in fiscal year 2008. While VA stated that it will initiate contact with officials 

at Education and Labor to identify duplicative efforts, it also noted that amending 

its administrative and regulatory authority to streamline the approval process may 

be difficult due to specific approval requirements of the law. We acknowledge these 

challenges and continue to believe that collaboration with other federal agencies 

could help VA reduce duplicative efforts. We also noted that VA may wish to examine and propose legislative changes needed to further streamline its approval process. 

Madame Chairwoman, this completes my prepared statement. I would be happy 

to respond to any questions that you or other members of the subcommittee may 

have. 

GAO Contacts 

For further information regarding this testimony, please contact me at (202) 512– 7215. Individuals making key contributions to this testimony include Heather 

McCallum Hahn, Andrea Sykes, Kris Nguyen, Jacqueline Harpp, Cheri Harrington, 

Lara Laufer, and Susannah Compton. 

f 

Prepared Statement of Joan L. Ryan, President and C. Donald Sweeney, 

Legislative Director, National Association of State Approving Agencies 

INTRODUCTION 

Chairwoman Herseth Sandlin, Ranking Member Boozman and members of the 

Subcommittee on Economic Opportunity, we are pleased to appear before you today 

on behalf of the National Association of State Approving Agencies to provide comments on the functions of State Approving Agencies (SAAs), the value added by 

SAAs, the issue of overlap in the work of various ‘‘approving agencies’’ and funding 

needed by SAAs to carry out their responsibilities. 

BACKGROUND 

State Approving Agencies recently celebrated sixty years of partnership with the 

U.S. Department of Veterans Affairs (DVA) in the administration of the veterans’ educational assistance programs, more commonly known as the GI Bill. Through the 

program approval and supervision process, they ensure that money spent on veterans education is money well spent, and assist in reducing the opportunities for 

fraud, waste and abuse. 

In many ways the fundamental mission of State Approving Agencies (SAA) is the 

same today as it was when they were founded sixty years ago. State Approving 

Agencies: 

• promote and safeguard quality education and training programs for veterans; 

• ensure greater educational and training opportunities to meet the changing 

needs of veterans; and 

• assist the DVA in preventing fraud, waste and abuse in the administration of 

the GI Bill. 


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As State entities acting on behalf of the Federal government, they have been an 

outstanding example of the workability of the Federal-State partnership, allowing 

Federal interests to be pursued at the local level while preserving the identity, interests and sovereignty of State’s rights in education. 

Under Title 38, United States Code, each Governor designates a state bureau 

or department as the State Approving Agency for the state. Today there are 59 

State Approving Agencies (some states have two) with about 200 professional and 

support personnel, supervising over 10,000 active facilities with approximately 

200,000 programs. Located in various state offices, including state departments of 

education, higher education boards, departments of labor, departments of veterans 

affairs and stand alone agencies—SAA professionals bring a wealth of formal education, training and experience to the appraisal of programs for veterans benefits. 

REMARKS 

A. Functions 

State Approving Agencies carry out their mission through their core functions of 

program approval, on-going contact and supervision, technical assistance, outreach, 

and liaison. As described below, each of these core functions continues to evolve as 

State Approving Agencies meet the challenge of a dynamic educational and training 

environment. 

1. Program Approval—The appraisal process whereby SAAs determine whether 

new programs meet the requirements of law and are eligible for veterans’ benefits. 

Under federal law, there are a host of approval criteria designed to (a) facilitate 

the accurate and timely payment of benefits; (b) minimize erroneous payments and 

opportunities for fraud, waste, and abuse; and (c) ensure that tax dollars spent on 

veterans education and training are dollars well spent. Programs are required to 

meet acceptable standards regarding student progress; credit for prior learning; establishment of branch campuses; treatment of residencies; independent study and 

practicums; educational contracting; student recordkeeping; program content; instructor expertise; sufficiency of facilities and equipment; and methods of instruction. 

SAAs also focus on policy issues and practices which frequently lead to problems 

with non-compliance. SAAs are particularly concerned with branch campuses, educational contracting, distance education, high tech courses of short duration, adult 

education, and accelerated classes. Often, it is the systems and policies in place that 

receive SAA attention. This is in addition to a detailed examination of the curricular 

structure and faculty credentials. Much of this can be done during a visit to the 

school in conversation with various school officials and a review of student records. 

• Total Program Approvals Actions (both approvals and disapprovals) rose 97% 

from FY 97 to FY 05 and Apprenticeship and On-The-Job Training program approvals rose 54% from 2,444 in FY 97 to 3,760 in FY 05. • SAAs work with deficient programs to assist them to meet approval standards 

and therefore only about five percent of all program reviews result in disapproval. 

2. On-going Contact and Supervision—General and continuing oversight of our 

institutions to verify continued compliance with federal requirements; to prevent 

fraud, waste and abuse; to offer training; and—at the request of the VA—to investigate and provide assistance with compliance/program issues. 

Even at established schools and longstanding training programs, problems can 

crop up which will adversely affect the quality of the veteran’s program or the 

amount of benefits paid. Pivotal to the protections the GI Bill affords its recipients 

is the on-going, on-site monitoring and supervision of institutions wishing to have 

their programs approved. In this regard there is no comparable association or agency which provides this level of proactivity. And this is why SAAs maintain their discretion to visit even highly regarded institutions. 

In the course of an oversight and training visit to the school or training establishment, the SAA determines whether each of the programs continues to meet the approval requirements of Federal and State law. Just as importantly the SAA assist 

the school/facility in maintaining continued compliance. 

An Oversight and Training Visit usually includes: 

• A review of institutional policies and practices affected by the regulations. SAAs 

make note of changes to programs, facilities, ownership, off-campus offerings, 

internship policies, contracts with other training providers, transfer credit and 

the like. If a policy is not in accordance with the requirements of the regulations, SAAs often are able to negotiate a special policy for veterans or assist 

with the development of a general, school-wide policy that is in compliance. 


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• An investigation of the systems in place to carry out these policies. The SAA 

looks at such questions as: Is the school certifying official in a position to know 

about changes in a veteran’s status? Are veterans being certified only for those 

courses that lead toward their educational, vocational or professional objective? 

Has the veteran’s prior learning been evaluated and the veteran been notified 

of transfer or other credit which actually applies toward their degree? How 

quickly is the VA notified of a veteran’s change in status? (For example, withdrawal from school or a change in programs). 

• An examination of school and student records to verify that institutional policies are being enforced and that the required system of records is in place. SAAs 

also review veteran’s records to ensure that veterans are being certified correctly and that the VA is not making payments based on erroneous information. 

This activity may save the veteran from having to return funds because of an 

overpayment when a problem is discovered on a compliance survey (audit) up 

to three years later. They also uncover evidence of inappropriate activity such 

as false and misleading advertisement. 

• Visits also assist in the development of a good on-going relationship with school 

and training establishment officials. SAAs answer their questions, provide 

training, help them to problem-solve compliance issues, and encourage a greater 

sensitivity and awareness of veterans’ benefits and needs. By nature of their 

job, SAAs have a broad overview of the education and training systems within 

the state. SAAs serve as consultants providing examples of best practices from 

other schools which interested schools can adopt. 

SAAs also conduct Inspection Visits to new schools and programs to ensure that 

they can comply with approval requirements and are familiar with certification and 

reporting procedures. 

• On-going Oversight and Training Visits to all schools and programs increased 

30% from 9,210 in FY 97 to 11,994 in FY 05. 

• Inspection Visits to new schools and programs increased 25% from 2,362 in FY 

97 to 2,955 in FY 05. 

3. Technical Assistance—Assistance given to schools, training establishments and 

individuals regarding approval of programs and certification of veterans. Schools 

and veterans rely on SAAs for timely, on-the-spot information—answering a seemingly endless stream of questions. 

SAAs render assistance to new schools seeking approval of their courses, employers looking to have their apprenticeship or other on-the-job training programs approved, veterans and their families, members of the reserve components, etc. SAAs 

answer questions about how to apply for approval or how to certify a veteran with 

a special problem. They answer questions about program length requirements, how 

to write a training agreement including appropriate wage scale and related instruction, questions about the requirements for practical training, contract courses and 

institutional recordkeeping. 

Further, the SAA serves as a facilitator between the school, the veteran and the 

VA. SAAs are arbitrators of complaints and the advocate for maximization of a veteran’s benefits. They are often the de facto trainers of new school certifying officials 

and they keep the schools apprised of new developments, often holding regional 

workshops for school certifying officials. 

• Total overall training/assistance actions increased 43% from 19,635 in FY 97 to 

28,107 in FY 05. 

• Training/assistance given to Apprenticeship/On-the-Job Training facilities rose 

from 7,359 in FY 97 to 8,959 in FY 05 and training/assistance actions for Institutions of Higher Education and Non College Degree schools rose from 12,001 

in FY 97 to 18,588 in FY 05. 

4. Outreach Activities—Efforts undertaken to reach out to various groups and 

promote the increased usage of veterans’ educational benefits. At the request of the 

DVA, State Approving Agencies are heavily engaged in outreach efforts to promote 

the usage of veterans’ educational benefits. 

Some SAAs have developed radio spots, television videos and print advertising to 

encourage veterans to take advantage of the GI Bill and especially apprenticeship 

and on-the-job training programs. Other SAAs do ‘‘welcome home’’ mailings to newly 

separated veterans congratulating them on their service and informing them of their 

benefits and the educational/training opportunities available to them in their State. 

Many SAAs make presentations at military retirement seminars and the transition 

assistance programs (TAPS) for those leaving the service. SAAs participate in local 

military and veterans events; job fairs, welcome home activities, supermarkets of 


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benefits and other venues where they can encourage the use of benefits. They work 

with their state’s departments of labor to assist veterans to find appropriate employment and training. In some states, the National Guard looks to the SAA approval 

in identifying programs eligible for national guard members to receive tuition support. Additionally, States have developed Web sites allowing veterans to learn about 

their State and Federal benefits and to search for what programs and schools are 

approved and available in their state. 

5. Liaison Activities—Coordination with government, veteran and educational entities to facilitate the approval of programs and increase educational opportunities 

for veterans. As State agencies working with a Federal program, SAAs are uniquely 

situated to network with stakeholders in education and training to coordinate the 

improved delivery of veterans’ benefits. 

State Approving Agencies work with others to exchange information, facilitate the 

increased approval of programs and raise awareness of the veteran, their educational needs and benefits. SAAs have forged links with State Agencies such as Departments of Veterans Affairs, Departments of Education, Higher Education Governing Boards, Departments of Labor and other licensing boards. They meet with 

representatives of accreditation associations, the National Guard and the Reserves, 

apprenticeship councils, union boards, and military service organizations. Some SAA 

staff members also participate on accreditation visits. At a national level, contacts 

are made with the Departments of Defense, Education, Labor, and Agriculture, as 

well as the Federal Aviation Administration, and Federal Trade Commission. 

State Approving Agency activities often complement what is being done at the 

state level and since not all states have program review offices, those SAAs become 

the de facto review entity for the State. SAAs often have ready access to information 

of value to program appraisal such as: a school’s audited financial statements; 

school evaluation reports; results of in-depth assessments in particular areas; program review by governing or coordinating boards; and, institutional statistics and 

research findings. 

B. Added Value 

In addition to the contributions stated in part A. Functions, State Approving 

Agencies help to ensure the success of the GI Bills by responding to new trends in 

education and training and by working with the DVA to take-on new challenges. 

As stated by a former Subcommittee Staff Director of the House Veterans Affairs 

Committee in an upcoming SAA outreach film—‘‘SAAs are the face of the GI Bill 

at the state level.’’

Frequent interaction with officials at all levels within the state provides understanding of how the system works which in tern creates a unique ability to assist 

Veterans in accomplishing their education and training objectives. 

• Special attention has been and continues to be given to the request by Congress 

and the DVA to promote the development and approval of apprenticeship and 

on-the-job training programs. Extensive efforts have been made by SAAs to 

make employers and unions aware of this benefit and to assist them in having 

these programs promoted and approved. As a result, the number of active apprenticeship/on-the-job training (or OJT) facilities has increased over 100% in 

10 years from 2,086 (in 1997) to 4,891 (in 2006). New initiatives include the approval of preparatory courses, licensure and certification examinations, and entrepreneurship programs. 

• SAAs have expanded their outreach efforts to promote increased usage of GI 

Bill benefits as described in the Outreach Activities section of part A of this 

testimony. In FY 97 SAAs conducted 12,724 outreach activities and in FY 05, 

49,885. They continue to actively search for new ways to increase usage of the 

GI Bill and counsel veterans on available benefits and educational programs 

within their state. 

• SAAs are directly involved with the new and emerging trends in education and 

training—ensuring their quality and availability for veterans. More and more 

distance education programs are now being approved. SAAs are reviewing and 

approving new short-term certification programs as illustrated by the growth in 

non-accredited NCD facilities and programs—from 605 in FY 97 to 835 in FY 

03, an increase of 38% percent. Also SAAs continue to evaluate accelerated degree programs, external degree offerings, new branch campuses and traditional 

colleges contracting with private occupational schools to provide training for college credit. 

• SAAs also are directing more attention to promoting and insuring the evaluation and acceptance of credit for military training and experience. 


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• And for the benefit of veterans, other GI Bill eligible persons, and the DVA, 

SAA personnel participate in on-going professional development activities to ensure the availability of a wide range of quality learning experiences. The National Association of State Approving Agencies (NASAA) is in the process of 

completely updating its National Training Curriculum required under law. 

Training Institutes are held for new staff approximately every eighteen months. 

One was just held last week in Chicago where over 50 SAA and VA personnel 

participated. All national meetings have a professional development component 

designed to provide specialized, advanced training in leading edge developments 

in our field such as, distance education, state licensing, outreach techniques, 

DOD recruitment concerns, and approval of short term on-going professional development courses such as Microsoft and Novell. 

• State Approving Agencies have been at the forefront of the enactment of many 

of the improvements to the various GI Bills. They have first hand insights into 

the education and training needs of veterans and are able to bring recommendations to members of Congress and the responsible Committees. SAA personnel 

have had the honor and privilege of working with current and former members 

of Congress, including former Chairman Montgomery, to enact the Montgomery 

GI Bill (MGIB) and to expand program opportunities available under the law. 

Examples include the addition of apprenticeship and other on-the-job training 

(OJT) to Chapters 30 and 1606; non college degree and graduate programs to 

Chapter 1606; accelerated payments for high technology programs; increased 

benefit levels for apprenticeship and OJT participants; and revisions to the laws 

governing the approval of programs such as the period of operation rule, OJT 

wage requirements and pro rata refund policy. 

• As founding member of the Partnership for Veterans Education, SAAs represented by their national association, is currently recommending the enactment of a Total Force MGIB that would simplify the administration of the law 

and bring equity to those who serve in defense of the freedoms that we all so 

thoroughly enjoy—equal program opportunity and benefits for equal service rendered. As you know Madame Chairwoman, this Subcommittee held an excellent 

hearing on the topic just a few weeks ago. 

In short SAAs are the face of the GI Bill at the state level. 

We provide: 

• Veteran advocacy 

• Outreach to Veterans 

• Job training opportunity 

• Consumer protection for Veterans entering education and training programs 

• Assistance to Veteran who encounter problems at schools and training facilities 

• Assistance with the prevention of waste, fraud and abuse 

C. Overlap in the Work of Approving Agencies 

Sixty years ago the Congress chose a path that has served the veteran and the 

taxpayer exceptionally well. Instituting a state level, program approval process to 

ensure the quality and integrity of the various learning experiences in which veterans engage and to assist the federal government in preventing waste, fraud and 

abuse has proven to be an excellent decision. 

To the casual observer, it would appear that the work done by SAAs and that of 

the federal Departments of Education and Labor is similar, if not identical. A closer 

look reveals some stark distinctions, especially among ‘‘approval’’ activities for institutions and their programs. 

Earlier pages of this testimony provided insights into the processes used by SAAs. 

To summarize, the SAA program approval process is: 

• Program oriented—Certificate in Automotive Technology, Associate of Science 

in Nursing, Bachelor of Science in Biology, et al. In lay terms, an evaluation 

of the appropriateness of the program objective, what is being taught to achieve 

the objective, by whom, with what resources and under what circumstances. 

The latter category includes, for example, an evaluation of policies and practices 

pertaining to program admission, credit for prior learning, and satisfactory 

progress. 

• Built upon evaluations by other state and private sector entities when appropriate; e.g., state licensing, degree granting authority, and accreditation (institutional and/or specialized/programmatic) 

• Ongoing contact and monitoring on an annual or bi-annual basis 


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Now let’s take a look at the process used by the Department of Education and, 

in particular, accreditation since this element of the DOE process seems to be the 

major focal point of the discussion about overlap. 

The Departments of Education’s direct involvement in the administration of Title 

IV, Student Financial Aid programs is limited to (1) the authorization and reauthorization of an institution to participate in Title IV through an application process 

that is heavily dependent upon third parties and (2) compliance visits which are 

monetarily oriented, sporadic and generally conducted at an institution where there 

have been reported or perceived problems. Of the two third parties connected to the 

initial (and continuing) authorization, accreditation is perceived to be the one that 

actually attempts to ensure overall quality and integrity at the institutional level. 

The other activity, state licensing, has long been proven to be limited in scope (generally applicable to proprietary business, trade and technical schools only) and generally ineffective because of lack of State funding to conduct full scale initial and 

followup evaluations. The United States has no Federal Ministry of Education or 

other centralized authority exercising single national control over postsecondary 

educational institutions in this country. The States assume varying degrees of control over education, but, in general, institutions of higher education are permitted 

to operate with considerable independence and autonomy. As a consequence, American educational institutions can vary widely in the character and quality of their 

programs. 

In order to ensure a basic level of quality, the practice of accreditation arose in 

the United States as a means of conducting non-governmental, peer evaluation of 

educational institutions and programs. Private educational associations of regional 

or national scope have adopted criteria reflecting the qualities of a sound educational program and have developed procedures for evaluating institutions or programs to determine whether or not they are operating at basic levels of quality. 

(U.S. Department of Education) 

Types of Accreditation 

Institutional accreditation normally applies to an entire institution, indicating 

that each of an institution’s parts is contributing to the achievement of the institution’s objectives, although not necessarily all at the same level of quality. The various commissions of the regional accrediting associations, for example, perform institutional accreditation, as do many national accrediting agencies. 

Specialized or programmatic accreditation normally applies to programs, departments, or schools that are parts of an institution. The accredited unit may be as 

large as a college or school within a university or as small as a curriculum within 

a discipline. Most of the specialized or programmatic accrediting agencies review 

units within an institution of higher education that is accredited by one of the regional accrediting commissions. However, certain accrediting agencies also accredit 

professional schools and other specialized or vocational institutions of higher education that are free-standing in their operations. Thus, a ‘‘specialized’’ or ‘‘programmatic’’ accrediting agency may also function in the capacity of an ‘‘institutional’’ accrediting agency. In addition, a number of specialized accrediting agencies 

accredit educational programs within non-educational settings, such as hospitals. 

(U.S. Department of Education) 

Types of Accrediting Organizations 

Regional accrediting organizations operate in six different regions of the country 

and review entire organizations, 98 percent or more of which are both degree-granting and nonprofit. Regional organizations may also accredit non-degree, for-profit institutions, but this is a rare occurrence. 

National accrediting organizations operate throughout the country and review entire institutions. Of the nationally accredited institutions, 34.8 percent are degreegranting and 65.1 percent are non-degree-granting. 20.4 percent are nonprofit and 

79.5 percent are for-profit. Many are single purpose institutions (i.e. information 

technology or business) and some are faith based. 

Specialized accrediting organizations operate throughout the country and review 

programs and some single-purpose institutions. There are more than 17,600 of these 

accredited programs and single-purpose operations. (Council on Higher Education 

Accreditation) 

Recognized Accrediting Organizations 

There are no laws regarding the development or operation of an accrediting organization. Therefore, some are considered more legitimate than others. Similar to ‘‘diploma mills’’ there are some organizations considered ‘‘accreditation mills’’ that will 

accredit institutions for a fee without the utilization of what is generally considered 

acceptable standards. 


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There are two organizations that are currently considered to ‘‘recognize’’ legitimate accrediting agencies, the U.S Department of Education (USDE) and the Council for Higher Education Accreditation (CHEA). For USDE recognition, accreditation 

from the organization is used by an institution or program to establish eligibility 

to participate in federal student aid or other federal programs. The Council for 

Higher Education Accreditation is a private nongovernmental coordinating agency 

for accreditation. As defined by CHEA, it is ‘‘A national advocate and institutional 

voice for self-regulation of academic quality through accreditation. . . .’’ Individual 

accrediting organizations may be ‘‘recognized’’ by CHEA, the U.S. Department of 

Education, or both. 

Quality 

The term ‘‘quality’’ is used by multiple organizations however, it is rarely defined. 

For the purposes of this document, ‘‘quality’’ will refer to meeting or exceeding a 

minimum set of standards. A functional reality of this definition is that the establishment of the designation ‘‘quality’’ is dependent on the minimum standards of the 

organization performing a review. While an institution may be considered of quality 

by one organization, it may not meet the designation of quality by a different organization using a different set of standards. 

Section Purpose 

The purpose of this section of the testimony is not to portray either State Approving Agencies or accrediting organizations as having more or less value than the 

other. Each serves a purpose in relationship to the educational community. However, the value of each differs in terms of mission, standards, and purpose. State 

Approving Agencies and accreditation organizations each have a function, but the 

functions are not duplicative. State Approving Agency approval and accreditation 

are complimentary, not identical, processes. 

To assist in gaining a better understanding of what accreditation is and is not, 

the following excerpts from a book entitled Understanding Accreditation by Kenneth 

E. Young, et.al. are reprinted. Dr. Young was the founding President of the Council 

on Postsecondary Accreditation, the former umbrella organization for accrediting associations. 

‘‘Accreditation is a process by which an institution of postsecondary education 

evaluates it educational activities and seeks an independent judgment to confirm that it substantially achieves its objectives and is generally equal in quality to comparable institutions or specialized units. Essential elements in the 

accreditation process are (1) a clear statement by the institution of its education 

intentions, (2) the conduct of a directed self-study focused on the achievement 

of these intentions, (3) an on-site evaluation by a selected group of peers, and 

(4) a decision by an independent accrediting commission (comprised of fellow 

educators) that, in light of its standards, the institution or specialized unit is 

worthy of accreditation. The accreditation process is designed primarily to encourage and assist the institution to evaluate itself objectively and then for the 

accrediting body to validate what the institution has said about itself.’’

‘‘Institutional accreditation (1) deals with the total institution, (2) is almost 

always the basis for institutional membership, and (3) focuses primarily on institution-wide objectives, processing, and outcomes.’’

The major characteristics of accreditation are the following: 

1. It is predominantly a voluntary, private-sector activity and therefore cannot mandate compliance or control behavior except by persuasion and peer 

influence. 

2. It is the premier example of self-regulation (as opposed to government regulation) in postsecondary education. 

3. It focuses primarily on judging educational quality—an elusive concept—

and, given the great diversity of postsecondary educational institutions in 

the United States, criteria tend to be general and variable. 

4. It functions essentially as an evaluative process, and institutional selfstudy is at the heart of the process, and 

5. It provides outside consultation, closely tied to the institution’s own research and planning. 

To understand what accreditation is not is also important. Accreditation is 

not governmental, although both federal and state agencies use it—to determine 

eligibility for certain government programs and in relation to professional licensing. It is not mandatory, although there are strong social and political pressures and even some legal prods to encourage participation. It is not a rating 

system, although institutions and programs generally do get compared. It is not 


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a mechanism for formally policing institutional behavior; accrediting bodies do 

not have to assess compliance, even if they wanted to. Rather, it depends on 

informal monitoring, generally through the accrediting body following up on a 

complaint about an institution (usually from an unhappy faculty member or student, another institution or state agency). It does not deal directly with credits, 

despite its name, although it is often used to help distinguish (sometimes erroneously) between worthy and unworthy prior educational experiences. And it is 

not a stamp of approval on individual students or courses; it does not operate 

at that level of analysis, although it is often perceived that way. 

The public is often led to believe that accreditation forces compliance on institutions. Although colleges and universities are certainly expected to comply 

with the policies, procedures, and requirements established by the accrediting 

body to maintain membership, the value and effectiveness of the entire process 

nevertheless lies in the institution’s own commitment to excellence and continuous self-study and evaluation. The public has little understanding of the voluntary nature of accreditation and the fact that compliance guarantees are not 

systematically built in. ‘‘Indeed, any guarantees reside in the individual institution’s seriousness of purpose and its sincerity.’’

In summary, other speakers at this hearing today already have or will address 

the DOE process for Title IV eligibility and the role of accreditation in that process 

so our testimony will not go into greater detail. However, we believe that it is 

important to restate that the major differences between SAAs and accreditation lie 

(1) in their mission, standards, and purpose and (2) operationally in the depth, 

breadth and frequency of their reviews. They each have a function, but the functions 

are not identical or duplicative—they are complimentary. The SAA process is a governmental quality control mechanism while accreditation is a private sector quality 

enhancement process. 

Apprenticeship and Other On-The-Job Training 

The distinctions between the work of SAAs and the federal Department of Labor 

on the approval of apprenticeship and other on-the-job training (OJT) programs also 

can be described as complimentary. The additional work by SAAs with Registered 

Apprenticeship Programs is almost exclusively connected to the specific requirements of Title 38, U.S. Code pertaining to the payment of VA benefits. 

Unregistered apprenticeship and OJT programs are another matter. For the vast 

majority it is only the SAA that works with the program sponsor to review what 

is to be taught/learned, by whom, with what expertise, with what resources and 

under what circumstances. This is in addition to insuring that the requirements of 

Title 38 are also being met. 

D. Funding 

The total annual allocation for SAA activities is stipulated in Title 38. The annual 

share of the allocation awarded to each SAA is determined by a formula essentially 

based upon the number of active schools and training establishments being supervised. The total annual allocation was capped at 12 million dollars from 1989 to 

1994. In 1995, the cap was increased to 13 million dollars until 2001, when it is 

being raised to 14 million dollars. From 2004 thru 2005, the cap was raised to 18 

million dollars and for 2006 thru 2007 it was raised to 19 million dollars. If no action is taken, in 2008 the cap will revert back to 13 million dollars—a 32 

percent cut! 

• The SAAs are periodically in a state of uncertainty. Without either the ability 

to carryover funds from one year to the next or to rely on an annual cost of 

living adjustment, prudent planning is not possible. 

• SAAs/States need funding stability in order to plan for and execute activities 

that meet the requirements of law and the contract between the State and the 

VA. Many SAAs are comprised of one full time professional staff person—some 

have only a part time person. Program approval and monitoring activities, especially those associated with apprenticeship and other on-the-job training programs, require expertise and timely action. Unstable funding does little to support this. 

• In order to provide an acceptable level of service to veterans, the Congress, and 

the DVA and to continue to take on additional roles as needed, SAAs must be 

consistently funded at an adequate level. Once restored to the current level of 

$19 million, the amount should be adjusted each year by the government-approved COLA applied to other benefit programs. 

In summary, SAAs make major contributions to the success of the various GI Bills 

in many ways. These contributions far exceed the proportionate amount of funds reVerDate Aug 31 2005 01:27 Apr 02, 2008 Jkt 035634 PO 00000 Frm 00047 Fmt 6604 Sfmt 6621 E:\HR\OC\35634.XXX 35634

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ceived by the Agencies when compared to the amount of benefits provided to veterans and other GI Bill eligible persons. The contributions include, but are not limited to, the following: 

• determinations regarding the quality and integrity of just about any kind of 

learning experience imaginable (institutional, job training, flight, correspondence, etc.); • work with employers to develop and enroll veterans in job training programs; • assessments of tests for professional and occupational licensing and certification; • training of VA Certifying Officials at educational institutions and job training 

establishments; • briefings during transition assistance programs and retirement seminars, mailings to recently discharged veterans and Selected Reserve personnel, and other 

outreach activities to increase the utilization of the GI Bills; • providing advice and guidance directly to veterans and other GI Bill eligible 

persons and indirectly through educators, trainers and others who counsel veterans; • serving as the gatekeepers for the ‘‘GI Bill’’ and advocates for veterans at the 

state and local levels; • assisting the federal government to eliminate waste, fraud and abuse; and, • state based SAAs provide local insights to the Congress and the VA on revisions 

to law that would better help to meet the education and training needs of veterans. 

CLOSING 

In closing, Madame Chairwoman, we would like to thank you and members of the 

Subcommittee again for the opportunity to comment on the functions of State Approving Agencies (SAAs), the value added by SAAs, the issue of overlap in the work 

of various ‘‘approving agencies’’ and funding needed by SAAs to carry out their responsibilities so that the GI Bill remains the country’s premier educational assistance program bar none. Mr. Sweeney and I would be happy to respond to any questions that you might have. 

f 

Statement of George W. Summerside, Veterans Education Program 

Specialist, South Dakota State Approving Agency 

INTRODUCTION 

Chairwoman Herseth Sandlin, Ranking Member Boozman and members of the 

Subcommittee on Economic Opportunity, I am pleased to appear before you today 

on behalf of the South Dakota State Approving Agency to discuss the functions of 

State Approving Agencies and the value these agencies have for those eligible for 

VA educational benefits in South Dakota. 

BACKGROUND 

Sixty years ago Congress, determined that each State should create an agency to 

approve the programs within its borders and to determine in which programs it was 

appropriate for Veterans to enroll, in order for them to utilize their VA educational 

benefits. The first State Approving Agencies (SAA) were formed for Veterans after 

World War II. Each State has one and a few states have two or three. One agency 

would approve all school programs, another agency would approve all on-the-job 

training programs, and then possibly a third agency would approve the flight 

schools. Our state approves all programs for those wishing to utilize their VA educational benefits. 

After a few years States realized that a national Association was needed and in 

1948 the National Association of State Approving Agencies (NASAA) was formed. 

The National Association assisted states in coordinating their efforts to do a better 

job for our nation’s Veterans. Also it was a tool to resolve mutual problems that 

were affecting our members. 

One of the keys to the success of this association has been the use of technology. 

Our association created a viable Internet Web site for the utilization of our association, our service partners and our customer ‘‘The American Veteran.’’ Capabilities 

include: directories for State Approving Agencies and State Veterans Affairs Offices, 

legislative updates, State and Federal regulatory information, and veteran-related 

career, educational, and benefit information. Our site is being re-designed and 

should be completed by the end of this month. The redesign will bring many new 

enhancements which will further improve communication between our members and 

the Veterans we serve. South Dakota has been the webmaster for this site since it’s 

creation in 1998. 


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Our website also has a section exclusively for our members. This members’ section 

includes: directories for our membership and other service partners, presidential updates/briefings, committee updates, association projects, calendar of upcoming 

events, samples of work processes for training programs (over 1,000), national training curriculum, outreach materials and online quarterly reporting system. Members 

can also send e-mail to other members and post information through the NASAA 

bulletin board. 

ROLE OF STATE APPROVING AGENCIES 

In many ways the fundamental role of state approving agencies is the same today, 

as it was when they were founded. As state entities acting on behalf of the Federal 

Government, the SAA’s have been an outstanding example of the workability of the 

State-Federal partnership, allowing Federal interests to be pursued at the local level 

while preserving the identity, interests and sovereignty of States’ Rights in education. 

PROGRAM APPROVAL 

The primary responsibility and focus of the SAA’s continues to be the review, 

evaluation and approval of quality programs of education and training under State 

and Federal criteria. SAA’s continue to conduct on-site inspection visits to approved 

institutions and schools seeking approval. The programs that can be approved are 

found in institutions of higher learning (colleges and universities), non-degree institutions (vocational and technical schools), apprenticeship programs, other on-the-job 

training programs, and flight training schools. Each State reviews the appropriateness of each program as to its own standards and laws in addition to VA rules and 

regulations along with any other applicable laws and/or regulations. Then it is either approved or disapproved; continuous supervision is required of approved programs. The following statement is provided to illustrate a school’s viewpoint of the 

approval process for a non-degree institution: 

As Director of the Career Learning Center of the Black Hills (CLC), I was 

approached by Mr. Ken Moon, South Dakota Veteran’s Outreach Representative who asked me if I had considered applying to the South Dakota State 

Approving Agency for approval of our short-term skill training programs as 

non-degree level courses. Mr. Moon conveyed to me that he believed the CLC 

training programs may fit the needs of some of the veterans who are in need 

of skill training, but who are not willing and/or able to commit to a formal 

postsecondary educational program. Mr. Moon gave me the name and telephone number of the Education Program Specialist from the South Dakota 

State Approving Agency, Mr. George Summerside, to contact about making 

application. 

From the first conversation I had with Mr. Summerside, I felt confident 

and assured that any assistance I needed in completing the application 

would be provided. It was also very evident to me that George had the utmost respect for the process and the requirements for the application and 

would make certain that all required components of the application would 

be included in the utmost organized and detailed manner. 

My experience in working with the South Dakota State Approving Agency, 

in preparation of the application for Non-Degree Level Courses was one of 

high-level professionalism with exemplary technical assistance provided. Mr. 

Summerside is acutely aware of the requirements for this application and 

was extremely interested in assisting with inclusion of all the requirements 

for the application. George looked over numerous drafts of the application 

and attachments before we submitted the final and completed application for 

consideration. Since this time, The South Dakota State Approving Agency 

has provided additional advice and assistance in completing paperwork for 

VA students of our courses. 

There is no question that without the assistance, direction, advice and 

support of Mr. Summerside, the application process would have been much 

more difficult and time consuming. 

Gloria Pluimer, Director

Career Learning Center of the Black Hills

The next statement illustrates a veteran’s viewpoint of the approval process for 

an On-The-Job training program: 

I retired from the U.S. Navy in 1993 following 27 years of active service. 

I had not used any of my GI Bill Education benefits at the time of my retirement. I returned to South Dakota with the intent of going back to school and 

completing my college education. 


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I applied for the On-The-Job Training Program in 1994 through the SD 

Division of Veterans Affairs—State Approving Agency—and was enrolled. I 

was most appreciative of the professionalism of the person from the State 

Approving Agency who worked with my employer and me to design a tailored training program. No doubt without the availability of this education 

benefit, I would not have been able to accept this training position. 

Not everyone or every discipline is suited to the traditional classroom style 

of training and education. The On-The-Job Training Program offers an excellent alternative educational benefit opportunity for those individuals and 

disciplines. Without this program, it is most probable that my GI Bill Educational Benefits would have gone unused. Ron Boyd, State Adjutant

SD American Legion

PROGRAM SUPERVISION 

Our agency conducts annual supervisory visits to each active facility to review the 

resources and capabilities which are required for continued program approval. The 

ongoing, on-site monitoring and supervision are vital to ensure these approved institutions continue to provide quality educational programs and meet VA compliance 

requirements. The following statement illustrates the importance of these visits and 

supervisory support provided. 

‘‘When I took over supervision of USD Veterans’ Services in 2005, our 

practices needed to be revamped to meet our obligations to the VA and our 

students. I met with George Summerside, SD State Approving Agency, in 

June 2005 at a regional training session for which he was one of the main 

speakers and coordinators. George immediately offered his full support and 

assistance to the University, and he followed through. 

Throughout 2005 and 2006, George was readily available to clarify laws 

and policies surrounding education benefits. He frequently gave suggestions 

(sometimes directives) about how The University could meet its obligations, 

which have improved our services to the students a hundred fold. He provided us a network of other higher education administrators and people employed by the VA who provided invaluable advice. 

During the same time period, George visited our campus on three occasions. Two were supervisory visits to help us gauge our progress, and one 

was to sit on a panel discussion for a Veterans Day event hosted by the USD 

Veterans Club (a student group). George’s participation in the Veterans’ Day 

event was widely appreciated by our students and the community, because 

it demonstrated a positive link to the individuals in Vermillion and the SD 

Division of Veterans Affairs. 

In addition, George was able to provide me much of the information and 

support I needed to take to my superiors to request the assignment of a fulltime employee to USD Veterans’ Services. A full-time position was filled in 

September 2006. 

On behalf of the veterans and their dependents attending The University 

of South Dakota, I can honestly claim that the support of our state approving agency is essential to our success. Thank you for the opportunity to submit this statement.’’ Jenifer Jost, Associate Registrar

The University of South Dakota

The next statement provides the prospective from Brink Constructors, Inc., an approved training establishment: 

First let me say what a pleasure it has been working with the SD State 

Approving Agency and associated staff. The staff is very knowledgeable and 

always able to assist us with our questions. 

The veterans who join our apprenticeship program are greatly benefited by 

the financial assistance provided to them through the GI Bill and Apprenticeship Program. Judith M. Michael Robin Cressy-Eddy Apprenticeship Human Resource Administrator Coordinator 

LIAISON 

Yet, while the fundamental role of the SAA has remained the same, the SAA’s have grown with the changes in our society over the past sixty years. They have 

become advocates for quality education and training for Veterans and other eligible 

persons. They have become educational partners with the institutions themselves, 

facilitating even greater and more diverse educational opportunities for Veterans. 

They have become strong advocates for the usage of the GI Bill and have developed 


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a working partnership with the Federal government, which other Federal agencies 

have tried to emulate. 

As State and National priorities change, as the function of government undergoes 

perpetual re-examination, and as the needs of our Veterans evolve with changes in 

American society, state approving agencies stand ready to meet the challenges before them. In spite of the need for new approaches and technologies, differing styles 

of oversight and enhanced criteria for performance, the fundamental reasons for 

which the SAA’s were originally created remain as valid today as they were sixty 

years ago. Mr. Del Johnson, Retired SD Education Liaison Representative (ELR) offers his opinion on State Approving Agencies. Del retired with over 28 years of experience with VA educational services. 

In my opinion there is a real value in having a State Approving Agency 

in each state. Approval of VA educational programs requires extensive 

knowledge of many complicated laws and regulations. It is absolutely necessary that the local schools and training establishments have someone with 

whom they can have personal contact. My experience was that there will always be differences in interpretation and the SAA serves a very important 

role between the Veterans Administration and the institutions which offer 

these programs. Now that the Department of Veterans Affairs has become 

more regionalized we have states that do not have an ELR (Education Liaison Representative) located in the Regional Office in their state, South Dakota is one of those states. This makes the institutions and veterans more 

isolated from the VA. 

The philosophy that ‘‘bigger is better’’ does have its limits and the impact 

on our smaller states can be negative. There is a need for each state to have 

a fully staffed SAA so the veterans in that state do not suffer with additional 

delays in obtaining their educational benefits. These agencies are vital and 

any reduction in funding would negatively impact VA educational programs. 

Del Johnson

Retired SD ELR

Our office has developed strong partnerships with many within our veterans’ service network and the following comments illustrate these relationships. 

The State Approving Agency is a valuable resource for South Dakota’s 

County and Tribal Veteran Service Officers whose job it is to properly serve 

these veterans. 

With the new influx of veterans from the War on Terrorism, it is more important than ever that they are provided with all the benefits they are entitled to, including education. 

The State Approving Agency has been there for me on countless occasions 

to provide quick and highly professional assistance at any time a question 

arises while initiating an education claim or by personally contacting the St. 

Louis Regional Processing Center on our behalf when a problem arises during the life of the claim or benefit. 

To ever lose or restrict the State Approving Agency, in particular George 

Summerside or Dr. Tom Murphy, due to federal budget restraints would be 

a HUGE disservice to South Dakota’s veterans. Ken Lindblad

Beadle County Veterans Service Officer

The next statement was submitted by one of our SD Veterans Commissioners. 

The SD Veterans Commission relies on select individuals to advise the 

Commission on veteran related issues and programs. Without the SD State 

Approving Agency’s valuable input our Commission would not be able to 

make informed decisions on VA educational issues. State Approving Agencies have not only ensured that those eligible for VA educational benefits enroll in quality education and training programs, but they have also served 

as a champion of veterans educational benefits. Bill Locken, Commissioner

SD Veterans Commission

The following statement provides a viewpoint from Muth Electric Inc., an approved training establishment. 

We appreciate the value that the SD State Approving Agency provides to 

the employees of Muth Electric. Any time there is a benefit that we can offer 

to our employees, especially those in transition from military to civilian life, 


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we are more than willing to do so. Working with the SD State Approving 

Agency has allowed our employees an opportunity to utilize their military 

benefits while learning an exciting and challenging trade. Amy Tlam

HR Manager

Our agency acts as the state liaison in assisting veterans groups, schools, training 

establishments, and other service partners with a better understanding of the many 

VA educational opportunities. By working together we can facilitate even greater 

and more diverse educational opportunities for those who are eligible for these well 

deserved and earned benefits. 

TECHNICAL ASSISTANCE 

This assistance is provided to schools, training establishments, County and Tribal 

Veterans Service Officers, and individuals on a wide range of VA educational issues 

and concerns. The information is provided during phone conversations, in emails, 

during visits and in correspondence. These inquiries are increasing and they require 

a considerable amount of staff time to be addressed. 

The needs of the VA student are and always will be of primary concern to this 

office. The following statement depicts one student’s opinion of our office. 

In the past few months George Summerside has been an excellent client 

advocate. Without his dedication and loyalty the Veterans Education Program would be nothing. Personally I could not have done the nursing program at Western Dakota Technical Institute without him, for he made sure 

my VA benefits were released to me in enough time to pay my bills, and I 

did not have to go back to work. 

Sincerely, Samantha Donley

OUTREACH 

Our agency is continually developing creative and innovative ways to promote and 

educate the public on VA educational programs. During FY 2006 our staff developed 

and distributed over 6,000 brochures/posters to Veterans, guardsmen/reservists, dependents/survivors and other partners within our veterans’ service network. Our 

agency participates in veterans’ forums, demob briefings, workshops, and other 

events whenever our presence can inform or educate the public on the excellent 

learning opportunities for those eligible for VA educational benefits. 

SUMMARY 

The core functions that I have discussed today all center around the program approval. The primary responsibility and focus of the SAA’s continue to be the review, 

evaluation and approval of quality programs of education and training. Our agencies have sixty years of experience with this process. 

Our National Association has developed the National Training Curriculum to 

serve as a reference and training tool for both new staff and existing agency professionals. This excellent reference guide ensures that staff is trained adequately to 

perform the comprehensive functions of a State Approving Agency professional. In 

addition to the National Training Curriculum our association has created the National Training Institute. This Institute provides classroom training for new staff, 

and both SAA and VA personnel participate. They are held approximately every 

eighteen months. 

If this funding solution is not resolved, there will be a reduction of 32% from the 

current funding level. South Dakota’s contract will be reduced by over $66, 000 dollars in FY 2008. This will have a negative impact not only on our state but across 

this nation. The many things that we are doing in outreach and customer service 

would no longer be possible. 

Today you have heard from different agencies and groups; statistical and narrative information has been provided for your review. The testimonies today are not 

a true measure of our value; our true value rests in the heart of each of the dedicated staff whose sole purpose is the approval of quality programs of education for 

those eligible for VA educational benefits. Our agencies worth is measured by this 

dedicated devotion to excellence, and our nation’s Veterans deserve no less. 

Closing 

In closing, Madam Chairwoman, I would like to thank you and members of the 

Subcommittee again for the opportunity to comment on the functions of the South 

Dakota State Approving Agency and the value they add in the State of South Dakota. I would be happy to respond to any questions that you might have. 

f 


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Statement of John M. McWilliam, 

Deputy Assistant Secretary for Operations and Management, 

Veterans’ Employment and Training Service, U.S. Department of Labor 

Chairwoman Herseth Sandlin, Ranking Member Boozman, and distinguished 

members of the Subcommittee: 

I am pleased to appear before you today on the subject of the role of the State 

Approving Agencies (SAAs) in assisting the Department of Labor (DOL) and other 

issues related to apprenticeships and on-the-job-training (OJT) programs. 

DOL has a separate responsibility from that of the SAAs. Under the National Apprenticeship Act 1937, DOL is the only federal agency authorized to register apprenticeship programs for federal purposes. ‘‘Federal purposes’’ includes any federal contract, grant, agreement or arrangement dealing with apprenticeship; and any federal financial or other assistance, benefit, privilege, contribution, allowance, exemption, preference or right. DOL’s role is to safeguard the welfare of apprentices, ensure equality of access to apprenticeship programs, and provide integrated employment and training information to sponsors and the local employment and training 

community. 

Title 38, section 3687(a)(1) indicates that an eligible veteran may be paid a training allowance while pursuing a full time ‘‘program of apprenticeship approved by 

a State approving agency as meeting the standards of apprenticeship published by the Secretary of Labor. . . .’’ (Emphasis added). 

Therefore, for an apprenticeship program to be approved for veterans’ benefits, it 

first must meet the standards of apprenticeship published by the Secretary of Labor. 

These standards require that the program be registered by either DOL or a DOLrecognized State Apprenticeship Agency. These State Apprenticeship Agencies are 

separate from the State Approving Agencies being discussed at today’s hearing. 

State Apprenticeship Agencies and DOL use basically the same assessment and 

approval criteria. State Apprenticeship Agencies’ regulations conform to federal regulations for the registration of apprenticeship programs. There are, however, variations in the operational procedures between State Apprenticeship Agencies and the 

Office of Apprenticeship (OA) in DOL’s Employment and Training Administration. 

Registration of an apprenticeship program by DOL or a DOL-recognized State Apprenticeship Agency must comply with the requirements set in 29 Code of Federal 

Regulations (CFR) parts 29 and 30, the Department’s regulations for registered apprenticeship. Apprenticeship program sponsors prepare and submit Standards of 

Apprenticeship for review and approval by DOL or a DOL-recognized State Apprenticeship Agency. Standards must state the term of the apprenticeship (not less than 

2,000 hours); the work processes in which the apprentice will receive supervised 

work experience and training on the job; provision for related technical instruction 

(a minimum of 144 hours per year of apprenticeship is recommended); the progressively increasing schedule of wages to be paid to the apprentice consistent with the 

skill acquired; and other requirements pertaining to program administration. When 

DOL or a DOL-recognized State Apprenticeship Agency has determined that the 

standards comply with 29 CFR parts 29 and 30, DOL or the DOL-recognized State 

Apprenticeship Agency issues the program a Certificate of Registration, which recognizes the program as a registered apprenticeship program for federal purposes. 

DOL or DOL-recognized State Apprenticeship Agency staff provides technical assistance to current and potential program sponsors for the preparation or modification 

of apprenticeship standards and to promote compliance with the apprenticeship regulations. 

DOL has not yet determined what, if any, overlap currently exists between reviews by the Registered Apprenticeship System (State Apprenticeship Agencies and 

DOL’s Office of Apprenticeship in the Employment and Training Administration) 

and State Approving Agencies. We believe there may be overlap in the review of 

program sponsors’ performance. As provided by the regulations for registered apprenticeship (29 CFR parts 29 and 30), DOL and DOL-recognized State Apprenticeship Agency staff conduct periodic reviews and evaluations of registered apprenticeship programs, including Quality Assurance Assessment reviews. These reviews 

may overlap with monitoring and assessments conducted by State Approving Agencies. 

Registered apprenticeship programs must maintain compliance with the standards for registered apprenticeship, whether they are registered with DOL or a DOLrecognized State Apprenticeship Agency. DOL and DOL-recognized State Apprenticeship Agenciescurrently register over 29,000 apprenticeship programs nationally 

with approximately 250,000 participating employers. Veterans comprise more than 

8% of the currently 449,000 registered apprentices. 


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DOL supports working with the VA and the Department of Education to assess 

both the similarities and the differences between the assessment components of the 

VA and DOL regulations and to determine how to further collaborate. In fact, the 

first such meeting between DOL and VA occurred on March 20, 2007, to discuss possible cooperative efforts. We look forward to continued collaboration with partners 

at VA and the Department of Education. 

DOL does not have any responsibility for, nor do we participate in, OJT programs 

for veterans in relation to the national apprenticeship system. Our enabling legislation, the National Apprenticeship Act 1937, deals specifically with registered apprenticeship. However, OJT is an allowable use of funds through other DOL authorizing statues, such as the Workforce Investment Act 1998. 

Thank you for the opportunity to discuss this important issue. I would be pleased 

to respond to any questions. 

f 

Statement of Carol A. Griffiths, 

Chief, Accrediting Agency Evaluation Unit, 

Office of Postsecondary Education, U.S. Department of Education 

Good afternoon Chairwoman Herseth-Sandlin, Ranking Member Boozman, and 

members of the Subcommittee. I appreciate the opportunity to appear before you 

today to share with you the Department of Education’s activities related to the accreditation of postsecondary education institutions and programs. My testimony will 

describe the U.S. Secretary of Education’s accrediting agency recognition process—

providing you with a snapshot of the type and breadth of accrediting agencies currently recognized by the Secretary and the components of the recognition process, 

as well as—highlighting some of the criteria for recognition and the role of the Secretary’s Advisory Committee in the recognition process. 

The Department of Education relies on accreditation by recognized accrediting 

agencies and State approval agencies as a primary factor in establishing the eligibility of institutions to participate in federal student financial aid programs authorized by Title IV of the Higher Education Act 1965 (HEA). Other Federal departments also rely on the Secretary’s recognition of accrediting agencies as an eligibility factor for participation in various programs they administer. In the context 

of the recognition process, State approval agencies are units within State Departments of Education that have responsibility for the oversight of postsecondary vocational education. 

Authority 

Since 1952, the Secretary of Education has published a list of recognized accrediting agencies that the Secretary determines are reliable authorities of the quality 

of education and training provided by the institutions and programs they accredit. 

The initial authority for this was in the Servicemen’s Readjustment Act; the recognition authority is now part of the HEA, which establishes the requirements for recognition of accrediting and state agencies. 

Currently the Secretary recognizes 62 institutional and programmatic accrediting 

agencies. There are 4 types of institutional accrediting agencies, though the distinctions between them are diminishing. 

National institutional accreditors—as the name suggests—accredit schools 

throughout the United States. Historically, they’ve accredited private for-profit institutions offering predominantly non-degree, vocational technical education programs. 

However, their recognized accrediting activities have expanded to include accreditation at all educational levels, including doctoral degrees and the accreditation of private non-profit institutions. Their emphasis remains, however, on the accreditation 

of institutions providing professional, technical, and occupational education programs. 

Regional institutional accreditors, as the label implies, accredit in a specific geographic region of the U.S. There are 6 regional accrediting associations—New England, Middle States, North Central, Northwest, Western, and Southern. Historically, 

the regional accrediting associations accredited public and private-nonprofit degreegranting institutions of higher education. Again, as for-profit education has expanded into the degree-granting realm, regional accreditors have expanded their accreditation activities to include accreditation of for-profit institutions. Also, as public 

and private degree-granting institutions have expanded their offerings to include 

non-degree programs, regional accreditors have augmented accrediting activities to 

include these non-degree programs. 


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The New York State Board of Regents is the sole accrediting body in a third category of institutional accreditor. The Board of Regents is, by federal statute, eligible 

to seek recognition for its accreditation of a limited universe of degree-granting institutions (24 institutions) in New York seeking to participate in HEA programs. 

The fourth type of institutional accreditor is the specialized, programmatic 

accreditor that accredits single-programs and single-purpose institutions, so that 

those schools may be eligible to participate in the federal student financial aid programs. These include accreditors of free-standing schools of osteopathic or podiatric 

medicine, free-standing schools of music, dance, or theater, or schools of mortuary 

science. These specialized accreditors accredit a specific type of educational program 

and are usually closely associated with, or part of, an association of individuals employed in that profession. 

The Secretary’s recognition process also includes 5 State approval agencies in 4 

States (New York, Oklahoma, Pennsylvania, and Puerto Rico) that have sought and 

received recognition for their oversight of public, postsecondary, vocational-technical 

education in their respective States to enable those programs to participate in student aid programs authorized by Title IV of the HEA. These agencies are a part 

of the State educational agency in their respective States, and this recognition enables access to Federal student aid by adults enrolled in programs usually offered 

through the adult vocational education program of the local K–12 school district. 

The Recognition Process 

The recognition process is voluntary. The Secretary’s recognition is not required 

for accrediting agencies to exist, or to accredit. However, recognized accreditation is 

a requirement for institutions’ and programs’ participation in the Title IV student 

aid programs and in many other Federal programs. 

Also, since the 1992 reauthorization of the HEA, an accreditor must demonstrate 

a Federal purpose for seeking the Secretary’s recognition. The accreditor must establish that its accreditation is necessary to enable one or more of its accredited institutions or programs to participate in a Federal program. Therefore, not all 

accreditors, even those that may desire to submit to the Secretary’s review process, 

are eligible for recognition. 

Components of the Recognition Process 

To some extent, the components of the recognition process parallel the accreditation process. Like the accreditation process, the recognition process includes an 

agency self-review, Department review of the agency’s policies, standards, procedures and practices, solicitation of public input, a review by the Secretary’s National 

Advisory Committee on Institutional Quality and Integrity (NACIQI), a Committee 

representative of the higher education community, and a decision by the Secretary. 

Each agency is reviewed at least once every 5 years (4 years for State approval 

agencies). 

Eligible accrediting agencies seeking recognition must demonstrate their compliance with the criteria for recognition published in 34 CFR Part 602. As a first step 

of the process, an accreditor conducts a self-review of its compliance with the Secretary’s criteria for recognition and submits a statement of its requested scope of 

recognition along with a narrative describing its compliance with each of the 18 criteria for recognition and documentation evidencing that compliance. The agency also 

submits to observations of its activities and reviews of its files by Department staff. 

State approval agencies must demonstrate compliance with 34 CFR Part 603 in the 

same manner. 

The requested scope of recognition includes the range of accrediting activities for 

which the Secretary recognizes an accreditor. This includes the types of accrediting 

activity—institutional or programmatic, types of degrees or certificates, geographic 

area of accreditation, type of pre-accreditation if any, and activities related to distance education, if any. Accreditors may, and many do, conduct activities outside 

their recognized scope of accreditation. For example, a number of U.S. accreditors 

also accredit foreign institutions, but as the Secretary’s recognition authority is limited to U.S. institutions, the Secretary does not evaluate an accreditor’s activities 

in relation to the foreign institutions and this aspect of an accreditor’s activities is 

not included in the agency’s recognition. 

The 18 recognition criteria are used to examine an accrediting agency’s organizational structure and administrative and fiscal responsibilities; the agency’s standards and their application, enforcement and review; and the agency’s operations regarding monitoring and oversight of its accredited institutions and programs. There 

are also criteria that address an agency’s adherence to due process, conflict of interest practices, and its practices regarding its responsiveness to complaints and the 

public notice of its accreditation decisions. 


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An agency’s organizational structure is evaluated with a focus on the ability of 

the agency to demonstrate that its accrediting activities and decisions are separate 

and independent from influence by related, associated, or affiliated trade or membership organizations. 

The agency must demonstrate its administrative capability to conduct its accreditation activities by evidencing the composition and competency of staff, evaluators 

and decisionmakers who are free of conflicts of interest. It must also demonstrate 

its financial viability to carry out its accrediting functions. 

The agency must demonstrate that its standards are sufficiently rigorous, and 

adequate to measure the quality of the education and training of the institutions 

or programs it accredits, and that they continue to be relevant to the education and 

training needs of students. The areas for which the accreditor must have standards 

are outlined in statute and include an evaluation of curriculum, faculty, fiscal/administrative capacity, admissions, recruiting and publications, student services, facilities and resources, and the institution or program’s success with respect to student achievement. 

The agency must demonstrate that its accreditation decisions are consistent, 

based on its published standards, made without conflict of interest, that its institutions and programs are provided due process, and that the agency has processes for 

evaluating change and for monitoring its accredited institutions or programs. 

Department staff evaluate the written evidence, observe one or more accrediting 

agency activities, such as training sessions, agency evaluations of institutions or 

programs, accreditation decision meetings, file reviews, or appeal hearings. From 

this evaluation and observation, the staff draws conclusions of compliance and 

drafts a report of findings that is provided to the agency. The agency then may respond with further evidence of its compliance with the criteria. 

A concurrent step in the process, public input, is solicited via Federal Register notices inviting comments regarding the agency’s compliance with the Secretary’s criteria. 

National Advisory Committee on Institutional Quality and Integrity 

(NACIQI) 

The final step before reaching the Secretary is a review of the agency by the Secretary’s National Advisory Committee on Institutional Quality and Integrity 

(NACIQI). This is a 15-member committee authorized under the HEA and appointed 

by the Secretary to advise her on matters related to accreditation. This Committee, 

representative of the higher education community, meets twice a year (June and December) and, in a public forum, reviews each agency’s petition for recognition. In 

preparation for that review, the Committee members are provided all agency information and the Department staff analysis of the petition. After hearing from Department staff, the agency and any 3rd parties present at the meeting, the Committee deliberates and makes a recommendation to the Secretary to grant, defer, or 

deny recognition. For accrediting agencies, the period of recognition cannot exceed 

5 years. Decisions on agencies that have outstanding issues may be deferred and 

the agency given a limited window of 12 months in which to correct deficiencies. 

The agency may appeal the Committee’s recommendation to the Secretary. With or 

without an appeal, the Secretary makes the final decision. 

In conclusion, the Department of Education recognizes 62 accrediting agencies 

and 5 State approval agencies as reliable authorities of the quality of education provided by postsecondary institutions and programs. This recognition process is a critical part of the oversight needed on a variety of Federal programs that provide access to approximately 90 billion dollars annually by institutions of higher education, 

students, and their families. The recognition process is comprehensive and ongoing 

and includes input from entities both internal and external to the Federal government. I hope this information is useful to you, Madame Chairwoman, and I would 

be pleased to answer any questions you or any of the other members of the Committee may have. 

f 

Statement of Keith M. Wilson, Director, Education Service, Veterans 

Benefits Administration, U.S. Department of Veterans Affairs 

Good afternoon, Chairwoman Herseth-Sandlin, Ranking Member Boozman, and 

members of the Subcommittee. I appreciate the opportunity to appear before you 

today to discuss the Department of Veterans Affairs (VA) education benefit programs and the role of State Approving Agencies (SAAs). My testimony will highlight 

the vital role of SAAs in ensuring that veterans receive the maximum benefit from 

their educational programs. I will specifically address the program services, fraud 


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prevention, oversight, and outreach functions of the SAAs, and the legislatively 

mandated funding decrease scheduled to take effect in fiscal year 2008. 

VA and the SAAs work together to ensure the successful readjustment of veterans 

to civilian life through educational opportunities. VA administers educational assistance, generally in the form of monthly benefits, to eligible veterans and dependents, 

while the SAAs ensure the quality of the educational and vocational programs pursued and monitor the institutions providing education and training to veterans. 

Title 38 of the United States Code establishes the parameters for the relationship. 

Role of SAAs 

38 U.S.C. § 3671(a) requests that each state create or designate a state department or agency as the ‘‘State Approving Agency.’’ The SAAs are charged with approving courses in accordance with the provisions of chapters 34, 35 and 36 of title 

38 U.S.C., including apprenticeship programs. They also conduct outreach programs 

and provide outreach services to eligible servicemembers and veterans about education and training benefits available. Our relationship is a cooperative one and we 

consider the SAAs to be vital partners in fulfilling our mission. 

Under contracts with VA, SAAs ensure that education and training programs 

meet federal VA standards through a variety of approval activities, such as evaluating course quality, assessing school financial stability, and monitoring student 

progress. In 2001, the SAAs were also given responsibility to actively promote the 

development of apprenticeship and on-the-job training programs and to approve 

tests used for licensing and certification. 

The SAAs maintain regular contact with the educational institutions and other 

program facilities within their jurisdiction, keeping them informed of on-going activities and allowing them to monitor the institutions compliance with VA’s approval 

standards and enrollment restrictions. VA and the SAAs exchange information on 

activities of education institutions, paying particular attention to enforcement of approval standards, enforcement of enrollment restrictions, and possible fraudulent or 

criminal activities on the part of persons connected with educational institutions 

where veterans are enrolled. VA staff perform compliance site visits at participating 

institutions every three years, while SAA staff conduct site visits at many institutions annually. They are a critical component in reducing the opportunities for 

fraud, waste and abuse in the veterans educational assistance program. 

While it is true that some of the programs monitored and approved by SAAs are 

also reviewed by the Departments of Education and Labor, SAAs approve a number 

of programs that are not reviewed by other agencies. These programs include onthe-job training programs, cosmetology and massage training offered by 

unaccredited schools, and apprenticeship programs not approved by the Department 

of Labor. SAAs tend to conduct more frequent on-site monitoring than other governmental entities and, for less-established institutions and programs, they provide 

more extensive review to ensure the quality and integrity of the veterans’ learning 

experiences. 

The SAAs also assist school certifying officials in understanding and complying 

with the law and regulations governing payment of VA educational assistance. 

GAO Report 

A recent GAO report, ‘‘VA Student Financial Aid: Management Actions Needed 

to Reduce Overlap in Approving Education and Training Programs and to Assess 

State Approving Agencies’’ (GAO–07–384, March 2007), contained three major recommendations. First, VA should require SAAs to track and report data on resources 

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

cost-efficient manner. Second, VA should collaborate with other agencies to identify 

any duplicative efforts and use the agency’s administrative and regulatory authority 

to streamline the approval process. Finally, VA should establish outcome-oriented 

performance measures to assess the effectiveness of SAA efforts. 

VA generally agreed with all three recommendations. We are taking action to implement the first and third recommendations (resources expenditures and outcomeoriented performance measures) in cooperation with the National Association of 

State Approving Agencies (NASAA). 

VA diligently tracks SAA activities. SAAs report their activities to us quarterly 

including the number of programs approved, the number of programs disapproved, 

the number of supervisory visits conducted, and the number of outreach activities 

or visits conducted. However, based on the report findings, VA will review current 

tracking mechanisms to further ensure that resource allocation decisions for SAA 

activities are made efficiently and effectively. 

Regarding the second recommendation to collaborate with other agencies, we have 

already met with Department of Labor staff to discuss how we can improve our comVerDate Aug 31 2005 01:27 Apr 02, 2008 Jkt 035634 PO 00000 Frm 00057 Fmt 6604 Sfmt 6621 E:\HR\OC\35634.XXX 35634

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munication processes and coordinate our respective activities. We intend to hold 

similar discussions with the Department of Education in the near future. 

SAA Performance Evaluation Process 

Public Law 100–323 requires an annual Joint Peer Review Group (JPRG) to meet 

for the purpose of evaluating the performance of the individual State Approving 

Agencies during the preceding fiscal year. The JPRG is composed of eight members, 

four SAA representatives and four VA representatives. The President of the National Association of State Approving Agencies selects the SAA representatives. The 

VA representatives are the Chief Education Liaison Officers from the four Regional 

Processing Offices located in Buffalo, NY; Muskogee, OK; Atlanta, GA; and St. 

Louis, MO. 

For FY 2006, the JPRG reviewed self-evaluations from 59 SAAs and written assessment reports from 50 Education Liaison Representatives (ELRs) nationwide. 

These reports were reviewed by the JPRG to determine each SAA’s annual performance rating. There are three designated ratings: Satisfactory, Minimally Satisfactory 

or Unsatisfactory. For 2006, the JPRG assigned the following ratings: two SAAs received an ‘‘unsatisfactory’’ rating, three received a ‘‘minimally satisfactory’’ rating, 

and 54 agencies received a ‘‘satisfactory’’ rating. 

All SAAs received notices of their ratings in writing. SAAs with less than satisfactory ratings received written guidance on how to improve their job performance. For 

one SAA that was rated unsatisfactory, a ‘‘mentoring’’ relationship was developed 

with a neighboring SAA to improve performance during the remainder of this contract year. 

Funding for SAAs 

In fiscal year 2006, VA paid approximately $2.1 billion in education assistance 

benefits to more than 470,000 beneficiaries. In that year, VA also provided approximately $19 million in funding to the SAAs, and will pay a similar amount in fiscal 

year 2007. For fiscal year 2008, the amount of funding for SAAs will decrease to 

approximately $13 million, per section 301 of Public Law 107–330. SAA funding is 

not tied to the Consumer Price Index (CPI) which causes a continual erosion of 

funding for the SAAs. 

VA Actions to Mitigate the Impact of the SAA Funding Reduction 

The outreach activities which were added to the SAA’s roles in 2001 may be impacted by the reduction in SAA funding. However, we have taken steps to mitigate 

this impact. Information concerning VA education benefits is mailed three times to 

servicemembers while they are on active duty and again at separation. Information 

is also provided annually while veterans are using their education benefits. VA’s 

Transition Assistance Program (TAP), as well as benefit briefings for demobilizing 

National Guard and Reserve members, provides information on education benefits 

available to these members. VA has participated in the training of the newly created 

State Benefits Advisors. State Benefits Advisors are Department of Defense (DoD) 

employees located within the Adjutant General’s office of each state. They assist in 

the dissemination of benefits information to National Guard and Reserve units. Despite these efforts, a reduction in SAA funding may negatively impact our efforts 

to promote the use of VA education benefits, particularly the promotion of OJT and 

apprenticeship programs with employers. The extent to which these efforts would 

be impacted is difficult to predict. 

We will continue to monitor the performance of SAAs in conducting program approvals, fraud prevention, oversight, and outreach. If SAAs operating at the new 

funding levels are unable to perform these services, then the Department will reallocate existing VA staff and resources to cover the services previously provided by the 

SAAs. Our ultimate concern is always for the effective administration of educational 

benefits to our veterans. If it is determined that increased resources are required, 

appropriate budget requests will be made. 

Madame Chairwoman, this concludes my statement. I would be pleased to answer 

any questions you or any of the other members of the Committee may have. 

f 


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SUBMISSIONS FOR THE RECORD 

Statement of Ronald F. Chamrin, Assistant Director, 

Economic Commission, American Legion 

Chair Herseth Sandlin and members of the Subcommittee, the American Legion 

appreciates this opportunity to share its views on State Approving Agencies (SAA) 

and the impact they have regarding the veterans’ education benefits. 

STATE APPROVING AGENCIES 

The American Legion is deeply concerned with the timely manner that veterans, 

especially returning wartime veterans, receive their education benefits. Annually, 

approximately 300,000 servicemembers (90,000 of them belonging to the National 

Guard and Reserve) return to the civilian sector and use their earned education 

benefits from the Department of Veterans Affairs (VA). 

Any delay in receipt of education benefits or approval of courses taken at institutions of higher learning can adversely affect a veteran’s life. There are time restrictions on most veterans’ education benefits, significantly, the National Guard and Reserve in which they must remain in the Selected Reserve to use their earned benefits. 

The American Legion believes that every effort should be made to ensure that the 

Montgomery GI Bill (MGIB) and related veterans’ education benefits are delivered 

without problems or delays. Furthermore, veterans are unique in that they volunteer for military service; therefore, these educational benefits are earned as the 

thanks of a grateful nation. The American Legion believes it is a national obligation 

to provide timely oversight of veterans’ education programs to assure they are administered in a timely, efficient, and accurate manner. 

A recent Government Accountability Office (GAO) Report entitled ‘‘VA Student Financial Aid; Management Actions Needed to Reduce Overlap in Approving Education and Training Programs and to Assess State Approving Agencies’’ (GAO–07– 384) focuses on the need to ‘‘ensure that Federal dollars are spent efficiently and 

effectively.’’ GAO recommends that VA should require SAA to track and report data on resources spent on approval activities, such as site visits, catalog review, and outreach 

in a cost-efficient manner. The American Legion agrees. Additionally, GAO recommended that VA establish outcome-oriented performance measures to assess the 

effectiveness of SAA efforts. The American Legion fully agrees. In response, VA Deputy Secretary Mansfield plans to establish a working group with SAA to create a 

reporting system for approval activities and develop outcome-oriented measures 

with a goal of implementation in the FY 2008 budget cycle. 

Finally, GAO recommended that VA should collaborate with other agencies to 

identify any duplicate efforts and use the agency’s administrative and regulatory authority to streamline the approval process. The American Legion agrees. VA Deputy 

Secretary Mansfield responded that VA will initiate contact with appropriate officials at the Departments of Education and Labor to help identify any duplicate efforts. 

SEC. 301 of PL 107–330 created increases in the aggregate annual amount available for state approving agencies for administrative expenses from FY 2003–FY 

2007 to the current funding level of $19 million. The American Legion fully supports 

reauthorization of SAA funding. 

The American Legion opposes the President’s budget request for SAA funding at just $13 million for FY 2008. The American Legion believes this is totally inadequate, especially for a nation at war, and strongly recommends keeping SAA funding at $19 million in FY 2008 to assure current staffing and activities. 

SERVICES TO VETERANS 

State Approving Agencies have the function of ensuring that qualified educational 

institutions and vocational training establishments (offering apprenticeship and 

other on-the-job training) meet and maintain acceptable approval standards for enrollment of eligible VA educational beneficiaries. State Approving Agencies currently 

provide qualified personnel with extensive knowledge in education administration 

and a full understanding of the laws and regulations that govern VA education benefits. 

Receiving earned educational benefits under the Montgomery GI Bill usually 

takes 30 days. For veterans previously enrolled, current law authorizes VA to backdate the approval for up to one year, depending on the start date of the veteran’s training. This usually covers most delays in the approval process. 

After receipt of the veteran’s original visit and submission of the approval package, SAA will request annual updates of the approval package. This is required 


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when the school publishes a new catalog. Also, for veterans enrolled for the fiscal 

year (October–September), SAA will conduct an annual supervisory visit to the 

learning facility to check veterans’ records. The approval to train an eligible veteran 

is strictly voluntary on the part of the training facility and can be withdrawn upon 

the participating veteran’s request at any time. 

State Approving Agencies operate under contract with VA. As such, SAA have 

their foundations in Federal law, Title 38, United States Code (USC). SAA operate 

as part of the government of the State and maintain the State’s authority to approve or disapprove veterans’ education and training programs. They also serve to 

prevent abuses and promote equality in veterans’ education by evaluating and monitoring education and training programs. 

The Code of Federal Regulations [38 CFR 21.4151(b)] summarizes SAA responsibilities: 

• to inspect and supervise schools and training establishments within the State, 

• to determine those programs of education and training which may be approved 

for veterans and other eligible students, 

• to determine whether a school or training establishment at all times complies 

with established standards relating to the approved programs, and 

• to render services and obtain information necessary for VA to approve or disapprove programs offered by any agency or instrumentality of the Federal government within the State. 

The USC further requires SAA to cooperate with VA and pay particular attention: 

• to enforcing approval standards, 

• to enforcing enrollment restrictions, and 

• to identifying fraudulent and other criminal activities by persons connected 

with educational institutions and training establishments where veterans are 

enrolled. 

As a part of the State government, SAA are also responsible for enforcing standards set by the various branches and licensing agencies of the State. 

For eligible veterans to receive their Montgomery GI Bill education benefits, they 

must be matriculated in a SAA approved program, and attend training during a period of time (semester, term, etc.) under which the training has been approved. It 

is the responsibility of the institution to maintain current approvals. SAA assist institutions with maintaining updated program information and approval. Institutions 

are required to send SAA four copies of the catalog every time a new edition is published, or at least once every three years. Institutions are also expected to keep the 

SAA informed on a change of ownership, change in policy, new programs, program 

changes, and current or projected term dates. 

VETERANS’ HIGHER EDUCATION ADVOCACY 

For such an important benefit, the ratio of support to overall benefit SAA provides 

to America’s veterans is quite astonishing. In this current era of high speed Internet 

and electronic data sharing, the temptation to believe the need for staff is dwindling, especially as advanced technology is increasing. However, The American Legion believes that personal interaction is imperative and cannot be replaced. 

The American Legion believes on-site visits to institutions of higher learning and 

vocational training facilities, interface with school officials, and one-on-one personal 

interaction with veterans is irreplaceable. 

SAA act as monitors or ‘‘watchdogs’’ to higher education academia in that by SAA 

very presence helps to assure that veterans are being afforded the same opportunities compared to the larger non-veteran student population. Our country’s history 

has not always been kind and welcoming to recently separated veterans into the 

classroom. Through the tireless efforts of veterans’ advocates and other interest 

groups, such as SAA, higher education has gained valuable insight and now seems 

to welcome veterans into their culture. SAA continue to be visible instruments of 

veterans’ advocacy and any diminishing of their presence would adversely affect currently enrolled veterans, as well as future generations of veterans. 

The American Legion recognizes the importance to assure that veterans’ education programs are beneficial to veterans and not just universities, colleges, and 

vocational training facilities. Administrators and other educational officials are constantly striving to morph, advance, expand, and explore new avenues of research 

and education, but must never forget the veterans’ portion of their student population. SAA oversee and inform universities, on-the-job-training and apprenticeship 

programs when their courses do not meet the required standards for entitlement to 

veterans’ education benefits. 


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Interpersonal relationships between SAA staff and veterans ensure that an individual enters a program that will lead to productive educational and/or developmental goals. Also, notification of changes in veterans’ benefits, in addition to technical assistance for education, is relayed from SAA officials to veterans. Students 

are usually so engrossed in collegiate activities that they are too busy to know 

events outside of scholastic life. Acting as veterans’ counselors, SAA fill an important role in the lives of veterans utilizing their earned educational benefits. 

INCREASE IN USE OF VETERANS’ EDUCATION BENEFITS 

Starting in 2001, the total use of education benefits by veterans continues to increase. The following graphs reflect the changes from 2001–2006. Chart 1 shows the 

increasing trend in usage of all VA education benefits programs. Chart 2 shows the 

increasing trend of the MGIB. 

In FY 2006, approximately 470,000 individuals received education benefits. This 

equates to approximately 3 million courses taken by veterans. Such an astronomical 

number for such a minute unit of measurement emphasizes the importance of timely and accurate oversight of VA’s education benefits. 

The National Association of State Approving Agencies (NASAA) states that there 

are currently 200,000 approved programs. These programs are evaluated on a rotational basis, with new, old, and failed programs contributing to their tally. 

With the current increasing rate of eligible veterans and the increasing quantity 

of discharged veterans, the need for assistance and implementation of all elements 

of veterans’ benefits will continue to rise. At the very least, maintaining the current 


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58 

level of SAA programs and staff will provide a baseline for oversight of VA’s education programs. 

CONCLUSION 

Historically, The American Legion has encouraged the development of essential 

benefits to help attract and retain servicemembers into the Armed Services, as well 

as to assist them in making the best possible transition back to the civilian community. The Servicemen’s Readjustment Act 1944, the ‘‘GI Bill of Rights’’ is a historic 

piece of social legislation, authored by The American Legion, that enabled millions 

of veterans to purchase their first homes, to attend college, obtain vocational training, receive quality health care and start private businesses. 

The role from SAA is especially critical in providing wise counsel, moral support 

and technical expertise in the seamless transition from honorable military service 

to classroom academics. In a time of war, every effort to promote and facilitate the 

use of veterans’ education benefits must be a national priority. 

The American Legion believes that honorable military service, combined with improved education and vocational training opportunities, enhances an individual, increases diversity, and betters society as a whole. The education pillar is continuous 

and ever evolving. Diminishment in support for education and ability to gain knowledge for veterans will harm the nation as a whole, decrease the ability to recruit 

new servicemembers, and unfairly subject veterans to barriers of benefits that they 

have earned. 

State Approving Agencies are instrumental in the education process. The American Legion fully supports all efforts to maintain and enhance veterans’ education 

benefits and recommends that State Approving Agencies remain funded at $19 million in FY 2008. 

The American Legion appreciates the opportunity to present this statement for 

the record. 

f 

Statement of Jean Avnet Morse, President, 

Middle States Commission on Higher Education, 

on behalf of the Council of Regional Accrediting Commissions 

Mr. Chairman and Members of the Committee, I appreciate the opportunity to 

submit testimony on the issue of whether the work of accreditors and state approval 

agencies (SAAs) overlaps. This issue was raised in the March 2007 GAO report on 

VA Student Financial Aid, and I have been asked to comment. 

Summary 

Regional accreditors already cooperate with state licensing agencies to prevent duplication. It is not likely that accreditors’ general review of all areas overlaps with 

the areas relating specifically to veterans. The research that would be required into 

the varying practices of 60 accrediting agencies and specific requirements for SAAs 

would probably be extensive. 

The Role of Regional and Other Accreditors 

I am the president of the Middle States Commission on Higher Education of the 

Middle States Association of Colleges and Schools. The Commission has a membership of more than 500 colleges and universities located in Delaware, Maryland, New 

Jersey, New York, Pennsylvania, the District of Columbia, Puerto Rico, the U.S. Virgin Islands, and in other countries. 

I am testifying on behalf of the Council of Regional Accrediting Commissions, 

known as C–RAC. It includes the seven U.S. regional accreditors that accredit institutions enrolling over 16,000,000 students. Regional accrediting agencies have assured the quality of higher education in the United States for over 100 years, providing self-regulation and shared assistance for improving education. For the past 

50 years, these agencies have supported federal funding functions: when an agency 

is ‘‘recognized’’ by the U.S. Department of Education, the students of institutions accredited by that agency are eligible for federal grants and loans under Title IV of 

the Higher Education Act. 

1. There is not a single type of accreditation review. Although all 

accreditors review the areas required by the Higher Education Act and 

USED regulations, the review varies among 3 different types of accreditors 

within types of accreditors. 


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59 

The three types of accreditors are ‘‘regional,’’ ‘‘national,’’ and ‘‘specialized.’’ Of the 

60 accreditors mentioned in the March 2007 GAO report, most are specialized 

accreditors. 

Seven regional accreditors (such as mine—the Middle States Commission on 

Higher Education) accredit only degree-granting institutions of higher education. 

There are over 3,000 regionally accredited institutions. 

National accreditors (such as ACCSCT, which was interviewed by the GAO) accredit institutions across the U.S. that may or may not grant college degrees and 

that have historically fallen within specific types of categories (distance learning, 

etc.). They are expanding their coverage. 

Specialized accreditors accredit specific programs, such as law or medicine, rather 

than whole institutions. 

Some accreditors of each type are ‘‘recognized’’ by the U.S. Department of Education. These are ‘‘gatekeeper’’ accreditors whose accreditation allows students at accredited institutions to receive federal grants and loans. Unrecognized accreditors 

are not governed by the federal regulations for ‘‘recognized’’ accreditors. 

My testimony relates to regional accreditors. 

2. Accreditors review and monitor colleges and universities at no cost to 

taxpayers. 

Evaluators, task force members, and other experts virtually volunteer their time. 

A small permanent staff is supported by dues and fees. Training and other activities 

are paid for by attendees. 

Therefore, even if there were overlap between SAAs and accreditors, the government would not be paying twice. 

3. Accreditors do not typically interact with SAAs. 

The GAO report notes that the reviews conducted by the SAAs and accreditors 

might overlap. However, because accreditors rarely work directly with SAAs, it is 

difficult for us to determine this based upon actual experience. When accreditors 

work with a state agency, it is typically its Department of Education (the ‘‘licensing’’

agency described on p. 10 of the GAO report). (See #6, 7, & 8 below for how overlap 

is prevented between licensing and accreditation.) However, the Department of Education only serves as the SAA in 31 states. Even in those 31 states, the personnel 

who handle SAA matters are not always the licensing personnel with whom 

accreditors work. 

4. For the six core duties of SAAs described briefly by the GAO on page 9, 

a careful review of the statutes and regulations governing SAAs would be 

required to determine how they relate to the federal regulations for ‘‘recognized’’ accreditors and the actual practices of accreditors. 

(a) ‘‘Approval of Programs’’: Accreditors approve some, but not all programs. The 

federal criteria for review by ‘‘recognized’’ accreditors do not relate to veterans. 

(b) ‘‘Visits to Facilities’’: Accreditors visit facilities in some, but not all, cases. 

Again, the federal regulations for visits from ‘‘recognized’’ accreditors do not refer 

specifically to veterans. 

(c) ‘‘Technical Assistance to Individuals at Facilities’’: Accreditors require that accredited institutions provide student support services, but the federal regulations for 

student services requirements by ‘‘recognized’’ accreditors do not specifically refer to 

the ‘‘technical assistance to individuals’’ required of SAAs. 

(d) ‘‘Outreach’’: Accreditors do outreach, but not specifically to veterans. 

(e) Liaison with Other Service Providers: Accreditors ‘‘liaise’’ with other service 

providers, but my agency’s standards to not specifically relate to veterans. 

(f) Contract Management: Accreditors review institutional contracts in some cases, 

but probably not in the areas required of SAAs. 

5. The GAO states that ‘‘similar categories of standards exist across agencies, but the specific standards within each category vary and the full extent is unknown.’’ This is correct. 

Accreditors certainly address 6 of the 7 areas listed on page 15 of the GAO report. 

However, interests and coverage of state and federal agencies differ from those of 

accreditors. The GAO report gives examples of how SAA requirements may exceed 

those of accreditors (p. 15). 

Those areas are: student achievement; curricula, program objectives, and faculty; 

facilities, equipment, and supplies; recruiting and admissions practices; and record 

of student complaints. 


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60 

6. Many states in our region require both initial and ongoing accreditation 

as a pre-condition for licensing institutions of higher education. 

This reflects their practice of relying on accreditation to ensure compliance and 

monitoring in areas that states do not evaluate themselves. This is done to avoid duplication. 

7. Accreditors and state agencies in the Middle States region have also established other methods of preventing duplication. 

Middle States convenes periodic meetings with state licensing agencies to compare 

practices and to avoid duplication. 

We invite representatives from state agencies to join our visiting teams, in order 

to prevent duplication. 

Conversely, Middle States’ policies state that institutions may submit materials 

prepared for state agencies to satisfy Middle States’ requirements. 

Thank you for the opportunity to submit testimony about these issues. 


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61 

MATERIAL SUBMITTED FOR THE RECORD 

U.S. Government Accountability Office 

Report to the Ranking Minority Member, 

Committee on Veterans’ Affairs, U.S. Senate, March 2007 

VA STUDENT FINANCIAL AID—Management Actions Needed to Reduce 

Overlap in Approving Education and Training Programs and to Assess 

State Approving Agencies, GAO–07–384 

Contents 

Letter 

Appendix I—Briefing Slides 

Appendix II—Comments from the Department of Veterans Affairs 

Appendix III—GAO Contact and Staff Acknowledgements 

Abbreviations 

Education—Department of Education 

IHL—institution of higher learning 

Labor—Department of Labor 

NASAA—National Association of State Approving Agencies 

OJT—on-the-job training 

RPO—regional processing office 

SAA—state approving agency 

SAC—state apprenticeship council 

VA—Department of Veterans Affairs 

U.S. Government Accountability Office 

Washington, DC. 

March 8, 2007 

The Honorable Larry E. Craig 

Ranking Minority Member 

Committee on Veterans’ Affairs 

United States Senate 

Dear Senator Craig: 

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

$2.1 billion in education assistance benefits to more than 470,000 beneficiaries and 

about $19 million to state approving agencies (SAA) to assess whether schools and 

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

education assistance benefits when attending them. Qualified individuals—veterans, 

service persons, reservists, and certain spouses and dependents—receive benefits 

through a number of education assistance programs for the pursuit of various types 

of programs, such as a degree program, vocational program, apprenticeship, or onthe-job training. In general, these programs must be approved by an SAA in order 

for qualified individuals to receive VA education assistance benefits. Under contracts with the VA, SAAs ensure that education and training programs meet federal 

VA standards through a variety of approval activities, such as evaluating course 

quality, assessing school financial stability, and monitoring student progress. In fiscal year 2006, the Department of Veterans Affairs (VA) paid approximately $2.1 billion in education assistance benefits to more than 470,000 beneficiaries and about 

$19 million to state approving agencies (SAA) to assess whether schools and training programs offer education of sufficient quality for veterans to receive VA education assistance benefits when attending them. Qualified individuals—veterans, 

service persons, reservists, and certain spouses and dependents—receive benefits 

through a number of education assistance programs for the pursuit of various types 

of programs, such as a degree program, vocational program, apprenticeship, or onthe-job training. In general, these programs must be approved by an SAA in order 

for qualified individuals to receive VA education assistance benefits. Under contracts with the VA, SAAs ensure that education and training programs meet federal 


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62 

1GAO, VA Student Financial Aid: Opportunity to Reduce Overlap in Approving Education and 

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

VA standards through a variety of approval activities, such as evaluating course 

quality, assessing school financial stability, and monitoring student progress. 

The Departments of Education (Education) and Labor (Labor) also assess education and training programs for various purposes, primarily for awarding student 

aid and providing apprenticeship assistance. These assessments are based, in part, 

on evaluations against standards set by laws and regulations, such as those applicable to accrediting agencies. In 2006, under Title IV of the Higher Education Act, 

Education provided nearly $77 billion in student aid in the form of both grants and 

loans. The Department of Education assesses and certifies postsecondary institutions for participation in Title IV programs through various oversight functions to 

ensure that these schools meet federal administrative and financial requirements 

and that they are accredited and licensed. Similarly, under the National Apprenticeship Act 1937, the Department of Labor is authorized to formulate and promote the 

furtherance of labor standards to safeguard the welfare of apprentices. To ensure 

programs comply with federal standards, Labor directly registers and oversees apprenticeship programs in less than half of the states and has given state apprenticeship The Departments of Education (Education) and Labor (Labor) also assess education and training programs for various purposes, primarily for awarding student 

aid and providing apprenticeship assistance. These assessments are based, in part, 

on evaluations against standards set by laws and regulations, such as those applicable to accrediting agencies. In 2006, under Title IV of the Higher Education Act, 

Education provided nearly $77 billion in student aid in the form of both grants and 

loans. The Department of Education assesses and certifies postsecondary institutions for participation in Title IV programs through various oversight functions to 

ensure that these schools meet federal administrative and financial requirements 

and that they are accredited and licensed. Similarly, under the National Apprenticeship Act 1937, the Department of Labor is authorized to formulate and promote the 

furtherance of labor standards to safeguard the welfare of apprentices. To ensure 

programs comply with federal standards, Labor directly registers and oversees apprenticeship programs in less than half of the states and has given state apprenticeship agencies or councils in the remaining states such authority over their own programs. 

Given each agency’s role, the potential of duplicative efforts among federal agencies has been a congressional concern. In 1995, GAO reported on this matter and 

concluded that there was a substantial amount of overlap between the efforts of 

SAAs and the other federal agencies.1 In light of continued congressional interest 

in this issue, we have now answered the following questions: (1) What changes have 

occurred in state approving agencies’ duties and functions since 1995? (2) To what 

extent does the SAA approval process overlap with efforts by the Departments of 

Education and Labor? (3) What, if any, additional value do the SAA approval activities bring to VA education benefit programs? 

To address all three questions, we reviewed legislation, regulations, federal guidance, and other documents relevant to the approval processes for education and 

training programs. We also interviewed officials from each of the entities involved 

in the approval processes of VA, Education and Labor. Specifically, we interviewed 

federal officials from VA, Education, and Labor as well as officials representing 

three SAAs, three institutions of higher learning (IHL), and state apprenticeship 

councils in Connecticut, Maryland, and Washington. We also interviewed officials 

from one IHL that operates in multiple states and officials from the National Association of State Approving Agencies (NASAA), an accrediting agency (Accrediting 

Commission of Career Schools and Colleges of Technology), the Connecticut state licensing agency, and three apprenticeship programs (in Connecticut, Illinois, and 

Maryland). We selected Connecticut, Washington, Illinois, and Maryland based on 

VA’s recommendation of knowledgeable SAA officials, to include both state and federally monitored states for apprenticeship programs, and geographic diversity. To 

identify the programs that were approved by the Departments of Veterans Affairs, 

Education, and Labor, we compiled and analyzed data on approved programs from 

each of the three agencies. To assess the reliability of the data, we talked with 

knowledgeable officials in each of the agencies, reviewed relevant documentation, 

and performed electronic testing of files. We determined that the data we have included in this briefing were sufficiently reliable for this purpose. We conducted our 

work from October 2006 to January 2007 in accordance with generally accepted government auditing standards. 


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

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

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

report formally conveys information provided during that briefing, which is contained in appendix I. In summary, we reported the following findings: 

• Since 1995, legislative changes effective in 2001 created additional responsibilities for SAAs, including promoting the development of apprenticeship and onthe-job training programs, providing outreach services, and approving tests for 

occupational licensing.2 From fiscal years 2003 to 2006, SAA funding increased from $13 million to $19 million to expand services and support the additional 

responsibilities. However, funding is scheduled to decrease beginning in fiscal 

year 2008. • Many education and training programs approved by SAAs have also been approved by Education or Labor, and VA and SAAs have taken few steps to coordinate approval activities with these agencies. In addition, information is not 

available to determine the amount of resources spent on SAA duties and functions, including those that may overlap with other agencies and programs. • SAAs reportedly add value to the approval process for education and training 

programs through (1) a focus on student services for veterans and on the integrity of VA benefits, (2) more frequent on-site monitoring of education and training programs than provided by Education or Labor, and (3) assessments and approval of a small number of programs that are not reviewed by other agencies. 

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

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

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

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

on specific SAA activities, especially those that may also be performed by other 

agencies. Without knowing the amount of resources spent on specific duties and 

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

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

effectively. In addition, VA, Education, and Labor have various standards and processes in place, in part to ensure that federal funds are being spent on quality education and training programs. While we have identified some overlap in approval 

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

agencies’ oversight efforts is unknown. It is important that VA work with other federal agencies to determine how the scope of the approval process could be streamlined to reduce overlap and ensure that federal dollars are spent efficiently. Finally, 

it is difficult to assess the effectiveness of SAA activities, in part because VA does 

not have outcome measures in place to fully evaluate SAA performance. Evaluating 

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

the program and improve program results. 

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

recommending that the Secretary of the Department of Veterans Affairs take steps 

to monitor SAA spending and identify whether any resources are spent on activities 

that duplicate the efforts of other agencies. The extent of these actions should be 

in proportion to the total resources of the program. Specifically: 

• VA should require SAAs to track and report data on resources spent on approval activities such as site visits, catalog review, and outreach in a cost-efficient manner; and • VA should collaborate with other agencies to identify any duplicative efforts and 

use the agency’s administrative and regulatory authority to streamline the approval process. 

In addition, we are recommending that the Secretary establish outcome-oriented 

performance measures to assess the effectiveness of SAA efforts. 

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

Affairs for review and comment. In addition, we provided a draft of this report to 

officials of the U.S. Departments of Education and Labor for their technical review. 

In written comments on a draft of this report, VA agreed with our findings and recommendations and stated that it will (1) establish a working group with the SAAs 

to create a reporting system to track and report data for approval activities with 

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

officials at the Departments of Education and Labor to identify any duplicative efforts, and (3) establish a working group with the SAAs to develop outcome-oriented 

performance measures with a goal of implementation in fiscal year 2008. While VA 

stated that it will initiate contact with officials at Education and Labor to identify 


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duplicative efforts, it also noted that amending its administrative and regulatory authority to streamline the approval process may be difficult due to specific approval 

requirements of the law. We acknowledge these challenges and continue to believe 

that collaboration with other federal agencies could help VA reduce duplicative efforts. In addition, VA may wish to examine and propose legislative changes needed 

to further streamline its approval process. 

Labor provided technical comments and we incorporated them into this report 

where appropriate. 

We are sending copies of this report to relevant congressional Committees and 

other interested parties and will make copies available to others upon request. In 

addition, this report will be available at no charge on GAO’s Web site at 

www.gao.gov. If you or your staff have any questions about this report, please contact me at (202) 512–7215 or scottg@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. 

GAO staff that made major contributions to this report are listed in appendix III. 

Sincerely, George A. Scott 

Acting Director 

Education, Workforce, and Income Security Issues 

Appendix I: Briefing Slides 

VA Student Financial Aid: Management Actions Needed to Reduce Overlap 

in Approving Education and Training Programs 

and to Assess State Approving Agencies 

Briefing for Staff of Senator Larry Craig, Ranking Member, 

Committee on Veterans’ Affairs, United States Senate 

February 01, 2007 

Objectives: 

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

agencies have contracted with state approving agencies (SAAs) to assess whether 

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

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

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

Concerns have been raised about whether SAA approval activities are duplicative 

of efforts conducted under other federal programs. 

Key questions: 

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

since 1995. 

• To what extent does the SAA approval process overlap with efforts by the Departments of Education and Labor? 

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

education benefit programs? 

Scope and Methodology: 

To address our key questions, we: 

• Reviewed legislation, regulations, federal guidance, and other documents relevant to the approval processes for education and training programs. 

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

Veterans Affairs, Education, and Labor (DOL). 

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

• Interviewed officials representing 3 SAAs, 3 institutions of higher learning 

(IHL), and state apprenticeship councils in Connecticut, Maryland, and Washington. We also interviewed one IHL that operates in multiple states. 

• Interviewed officials from the National Association of State Approving Agencies 

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

Colleges of Technology), Connecticut state licensing agency, and 3 apprenticeship programs (in Connecticut, Illinois, Maryland). 

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

generally accepted government auditing standards. 

Summary of Findings: 

• Since 1995, legislative changes effective in 2001 created additional responsibilities for SAAs, including promoting the development of apprenticeship and on 


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the job training programs, providing outreach services, and approving tests for 

occupational licensing. 

• Many education and training programs approved by SAAs have also been approved by Education or Labor and VA and SAAs have taken few steps to coordinate approval activities with these agencies. 

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

programs, but the lack of outcome-oriented performance measures makes it difficult to assess the significance of their efforts. 

Background: 

VA Funding for Educational Assistance Programs and SAAs 

• In fiscal year 2006, VA provided over $2.1 billion in educational assistance benefits to more than 470,000 beneficiaries. 

• In the same year, SAAs received $19 million to assess the quality of schools and 

training programs for veterans. 

Programs * Beneficiaries Expenditures 

Montgomery GI Bill (Chapter 30) 313,766 $1,909,014,605 

Reserve Educational Assistance Program (Chapter 1607) 23,747 $151,397,610 

Educational Assistance for the Selected Reserve 

(Chapter 1606) 65,145 $48,716,031 

Dependents and Survivors Educational Assistance 

Program (Chapter 35) 74,532 $38,787,332 

Veterans Educational Assistance Program (Chapter 32) 575 $59,113 

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

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

Source: VA. 

VA Educational Assistance Programs: 

• Benefits are designed to assist individuals in gaining access to postsecondary 

education or training for a specific occupation. Benefits can be used to pursue 

a degree program, vocational program, apprenticeship and on-the-job training. 

• Qualified individuals include veterans, service persons, reservists, and certain 

spouses and dependents. 


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Veteran Enrollment by Program Type in Fiscal Year 2006: 

Source: GAO analysis of VAN enrollment data. 

Agencies Responsible for the Approval Process for Education and Training 

Programs 

Source: GAO Analysis. 

VA’s Approval Process: Purpose and Responsible Entities 

• Purpose—To ensure education and training programs meet VA standards for receipt of veteran education assistance benefits. 

• Entities, Roles and Responsibilities: 

• VA national office oversees the 4 regional processing offices (RPOs) and national contract with SAAs. 

• RPOs administer the education assistance programs and process benefits for 

veterans. 


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* The Washington, DC SAA office is overseen by VA. 

• SAAs review education and training programs to determine which programs 

should be approved and ensure schools and training providers are complying 

with VA standards. 

• Duties and functions—SAAs have 6 core duties: (1) Approval of programs, 

(2) Visits to facilities, (3) Technical assistance to individuals at facilities, 

(4) Outreach, (5) Liaison with other service providers, and (6) Contract 

management. 

• Structure—60 SAAs exist in the 50 states, the District of Columbia, and 

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

department of education (31 SAAs). In some states, SAAs are organizationally located in other departments such as labor (9 SAAs) or veterans’ services (19 SAAs).* 

Education’s Approval Process: Purpose and Responsible Entities: 

• Purpose—To ensure schools meet federal Education standards to participate in 

the student financial aid programs. As part of Education’s approval process, the 

state licensing agencies, accrediting agencies, and certain offices within Education are responsible for various approval activities. 

• Entities, Roles and Responsibilities: 

• State licensing agencies grant legal authority to postsecondary institutions to 

operate in the state in which they are located. Each of the states has its own 

agency structure, and each state can choose its own set of standards. 

• Accrediting agencies develop evaluation criteria and conduct peer evaluations 

to assess whether or not those criteria are met by postsecondary institutions. 

Institutions and/or programs that meet an agency’s criteria are then ‘‘accredited’’ by that agency. As of November 2005, there are 60 recognized private 

accrediting agencies of regional or national scope. 

• Office of Postsecondary Education evaluates and recognizes accrediting agencies based on federal requirements to ensure these agencies are reliable authorities as to the quality of education or training provided by the institutions 

of higher education and the higher education programs they accredit. 

• Office Federal Student Aid determines the administrative and financial capacity 

of schools to participate in student financial aid programs, conducts ongoing 

monitoring of participant schools, and ensures participant schools are accredited 

and licensed by the states. 

Labor’s Approval Process: Purpose and Responsible Entities: 

• Purpose—To establish and promote labor standards to safeguard the welfare of 

apprentices. 

• Entities, Roles and Responsibilities: 

• Department of Labor establishes standards and registers programs that meet 

the standards. Labor directly registers and oversees programs in 23 states but 

has granted 27 states, the District of Columbia, and 3 territories authority 

to register and oversee their own programs, conducted by State Apprenticeship Councils (SACs). Labor reviews the activities of the SACs. 

• SACs ensure that apprenticeship programs for their respective states comply 

with federal labor standards, equal opportunity protections, and any additional state standards. 

Objective One: Changes in SAA duties and functions: 

Legislative Changes Effective in 2001 Created Additional Responsibilities 

for SAAs, Including Promoting the Development of Apprenticeship and On 

the Job Training Programs, Providing Outreach Services, and Approving 

Tests for Occupational Licensing 

In 2001, SAAs received additional responsibility for: 

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

programs. 

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

awareness of VA education assistance. 

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

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

VA benefits to pay for testing fees.) 


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

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

begin to decrease in fiscal year 2008. 

Objective Two: Overlap in Approval Efforts: 

Many Education and Training Programs Approved by SAAs Have Also Been 

Approved by Education or Labor and VA Has Taken Few Steps to Coordinate Approval Activities with These Agencies 

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

• Similar categories of approval standards, such as student achievement and institutional capacity (e.g. fiscal stability), exist across agencies, but the specific 

standards within each category vary and the full extent of the overlap is unknown. 

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

other federal agencies. 

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

duties and functions, including those that may overlap with other agencies. 

Many Education and Training Programs Approved by SAAs Have Also Been 

Approved by Education And Labor 

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

certified by Education. 

• 78% of SAA approved programs in institutions of higher learning (e.g. colleges 

and universities) have been certified by Education. 

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

been certified by Education. 

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

and SAA officials reported that many of these programs have also been approved 

by Labor. 

Similar Categories of Standards Exist Across Agencies, but the Specific 

Standards within Each Category Vary and the Full Extent of Overlap is Unknown 

Similar categories of standards exist across agencies.1

Apprenticeship Categories of approval standards 

SAA 2,3 Education4 Labor 

IHL/NCD 

accredited 

IHL/NCD 

nonaccredited Apprenticeship 

On the 

job 

training 

Education’s 

certification 

Federal 

Standards 

for accrediting 

agencies 

Connecticut 

state licensing 

agency 

Student 

achievement X X X X X X X 

Curricula, program objectives, 

and faculty X X X X X X X X 

Facilities, 

equipment, 

and supplies X X X X X X X 

Institutional 

objectives, 

capacity, and 

administration X X X X X X 

Student support 

services X X 

Recruiting and 

admission 

practices X X X X X X 

Record of student 

complaints X X 

Process related 

requirements 

(e.g. application 

requirements) X X X X X X X 

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


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

approval process involves different sets of standards used by different entities, such as accrediting agencies. Labor has one set of standards that is applicable to apprenticeship programs. 2 By statute, courses must meet certain criteria. These relate to: (1) recordkeeping of student 

progress; (2) recordkeeping of students’ previous education; (3) quality, content and length of 

courses; (4) qualifications of administrators and instructors; and (5) equipment, space, and instructional materials. We categorized the first two criteria as student achievement, criteria (3) 

and (4) as Curricula, Program Objectives and Faculty, and criterion (5) as Institutional objectives, capacity, and administration. 3SAA approval requirements for non-accredited courses encompass a number of additional criteria, such as having a tuition refund policy and enrollment limitations. 4 Connecticut’s standards may not be representative of standards across the country. 

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

agencies. 

Specific standards within each category vary across agencies. 

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

for student achievement, the New England Association of Schools and Colleges, 

an accrediting agency, requires that students demonstrate competence in various areas such as writing and logical thinking and VA does not have this requirement. 

• Also under student achievement, VA requires schools to give appropriate credit 

for prior learning while Education does not have such a requirement. 

While agencies have the same standards in some instances, the interpretation and 

application of these standards may differ. For examples: 

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

equipment and instructor personnel to provide quality training, but the definition of adequacy differs in the level of specificity. 

• VA and accrediting agencies require that schools have policies related to student achievement such as minimum satisfactory grades, but the requirement 

differs in the level of specificity. 

VA and SAAs Have Made Limited Efforts to Coordinate Approval Activities 

with Education and Labor 

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

related to student financial aid and apprentices’ skill requirements, it believes 

increased coordination is needed for approval activities in order to determine 

the extent of duplicative efforts. 

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

with SACs to register apprenticeship programs in their states. 

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

including providing a list of registered apprenticeship programs. 

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

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

Information Is Not Available to Determine the Amount of Resources Spent 

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

Other Agencies 

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

they spend on specific approval activities. 

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

is conducting inspection and supervisory visits of schools and training facilities. 

• Lack of data on resource allocation prevented us from determining what portion 

of funds spent by SAAs were for approval activities that may overlap with other 

agencies. 

Objective Three: Value of SAA Services: 

SAAs Reportedly Add Value to the Approval Process for Education and 

Training Programs, but the Lack of Outcome-oriented Performance Measures Makes it Difficult to Assess the Significance of Their Efforts 

• SAA and other officials reported that SAA activities add value because they provide enhanced services to veterans and ensure program integrity. 

• VA uses output measures rather than outcome-oriented performance measures 

to evaluate SAA performance and progress. 


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SAA and Other Officials Reported that SAA Activities Add Value Because 

They Provide Services to Veterans and Ensure Program Integrity 

SAA and Other Officials Reported SAAs’ added value includes: 

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

• More frequent on-site monitoring of education and training programs than Education and Labor; and 

• Assessments and approval of a small number of programs that are not reviewed 

by other agencies. 

The SAA Approval Activities Focus on Student Services for Veterans and 

on VA Benefits 

SAA approval activities: 

• Ensure that veterans are taking courses consistent with occupational goals and 

program requirements. 

• Ensure that schools and training programs have evaluated prior learning and 

work experience and grant credit as appropriate. 

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

comply with policies required by VA educational assistance through technical 

assistance. 

States, schools, and apprenticeship officials we spoke with reported that without 

SAAs, the quality of education for veterans would not change; however, their receipt 

of benefits could be delayed and the time required to complete their education and 

training programs could increase. 

SAAs Generally Conduct More Frequent On-Site Monitoring of Education 

and Training Programs Than Education and Labor 

Oversight of veterans assistance is generally more frequent than oversight by 

Education and Labor, which may prevent fraud, waste, and abuse. 

• Some officials reported that SAAs’ frequent visits were beneficial because they 

ensure schools properly certify veterans for benefits, ensuring that benefits are 

distributed accurately and quickly. 

• Officials from one school reported that SAAs’ visits were unnecessary because 

many schools are sufficiently monitored by their accreditors and Education. 

Entity Frequency of site visits to each school 

SAA 1–3 years 

VA’s RPOs 3 years 

Education Only schools that have performance issues are visited 1

Accrediting agencies 2–10 years 2

Labor 1–3+ years 3

1 Education also performs ongoing monitoring by reviewing schools’ annual compliance audits and financial statements. 2 Accrediting agencies’ frequencies vary depending on whether the agency is a national or regional agency. 3Labor—See Registered Apprenticeship Programs: Labor Can Better Use Data to Target Oversight, GAO–

05–886 (Washington D.C.: August 29, 2005). 

SAAs Approve a Small Number of Programs that Are Not Reviewed by 

Other Agencies 

SAAs approve a small number of programs that are not reviewed by other agencies: 

• Programs, such as cosmetology and massage training, offered by unaccredited 

schools. 

• On-the-job-training programs. 

• Apprenticeship programs not approved by Labor. 

VA Uses Output Measures Rather Than Outcome Measures to Evaluate SAA 

Performance and Progress 

Although VA does have some output measures in place, such as the number of 

supervisory visits SAAs conduct, it does not have outcome-oriented performance 

measures to evaluate the overall effectiveness and progress of SAAs. 


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Examples of Existing VA Output 

Measures 

Examples of Potential Outcome 

Measures 

Percentage of visits to facilities for supervisory Amount of benefit adjustments resulting 

and inspection purposes completed within from SAA’s review of school certification 

VA specified timeframes transactions 

Number of times technical assistance provided Error rate of certification transactions 

to interested parties such as individuals and identified by SAA’s schools 

Output Measures: Number of approved Completion rates of beneficiaries 

facilities with approved programs 

Source: GAO analysis. 

Conclusions: 

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

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

activities, especially those that may be performed by other agencies. Without 

knowing the amount of resources spent on specific duties and functions, VA 

does not have all relevant information for making resource allocation decisions 

and cannot determine if it is spending its federal dollars efficiently and effectively. 

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

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

training programs. While we have identified some overlap in approval efforts 

across agencies, the full extent of the overlap between SAA duties and other 

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

federal agencies to determine how the scope of the approval process could be 

streamlined, such as to determine the extent to which SAAs could rely on recognized accreditors’ assessments of institutions’ policies on student achievement 

to reduce overlap and ensure that federal dollars are spent efficiently. 

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

not have outcome measures in place to fully evaluate SAA performance, such as the 

outcomes of site visits. Under the Government Performance Results Act, federal 

agencies must report on their results in achieving their agency program goals. Outcome-oriented performance measures are should be used to assess program activity. 

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

to manage the program and improve program results. 

Recommendations for Executive Action: 

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

recommending that the Secretary of the Department of Veterans Affairs take steps 

to monitor its spending and identify whether any of its resources are spent on activities that duplicate the efforts of other agencies. The extent of these actions 

should be in proportion to the total resources of the program. Specifically: 

• VA should require SAAs to track and report data on resources spent on approval activities such as site visits, catalog review, and outreach in a cost-efficient manner. 

• VA should collaborate with other agencies to identify any duplicative efforts and 

use the agency’s administrative and regulatory authority to streamline the approval process. 

In addition, we are recommending that the Secretary establish outcome—oriented 

performance measures to assess the effectiveness of SAA efforts. 

Appendix II: Comments from the Department of Veterans Affairs 

The Deputy Secretary of Veterans Affairs 

Washington, DC 

February 27, 2007 

Mr. George Scott 

Acting Director 

Education, Workforce, and Income Security Issues 

441 G Street, NW 

Washington, DC 20548 

Dear Mr. Scott: 


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72 

The Department of Veterans Affairs (VA) has reviewed the Government Accountability Office’s (GAO) draft report, VA Student Financial Aid: Management Actions 

Needed to Reduce Overlap in Approving Education and Training Programs and to 

Assess State Approving Agencies (GAO–07–384). VA agrees with your findings and 

concurs with your recommendations. The enclosure details VA’s actions to implement Government Accountability Office’s recommendations. 

I appreciate the opportunity to comment on your draft report. 

Sincerely Yours, Gordon H. Mansfield 

Enclosure 

Department of Veterans Affairs (VA) 

Comments to the Government Accountability Office (GAO) 

Draft Report, VA Student Financial Aid: Management Actions Needed to 

Reduce Overlap in Approving Education and Training Programs and to 

Assess State Approving Agencies 

(GAO–07–384) 

To ensure that federal dollars are spent efficiently and effectively, 

GAO recommends that the Secretary of the Department of Veterans 

Affairs take steps to monitor its spending and identify whether any 

of its resources are spent on activities that duplicate the efforts of 

other agencies. The extent of these actions should be in proportion 

to the total resources of the program. Specifically: 

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

spent on approval activities, such as site visits, catalog review, 

and outreach in a cost-efficient manner. 

Concur—VA will establish a working group with the SAAs to create a reporting system for approval activities with a goal of implementation in the FY08 budget cycle. 

• VA should collaborate with other agencies to identify any duplicate efforts and use the agency’s administrative and regulatory 

authority to streamline the approval process. 

Concur—VA will initiate contact with appropriate officials at the Department of 

Education and Labor to identify any duplicative efforts. However, amending the 

agency’s administrative and regulatory authority to streamline the approval process 

may be difficult due to the specific approval requirements of the law. 

• VA should establish outcome-oriented performance Measures to 

assess the effectiveness of SAA efforts. 

Concur—VA will establish a working group with the SAAs to develop outcome-oriented measures with a goal of implementation in the FY08 budget cycle. 

Appendix III: GAO Contact and Staff Acknowledgments 

GAO Contact: George A. Scott (202) 512–7215 or scottg@gao.gov. 

Staff Acknowledgments: In addition to the contact named above, Heather 

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

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

made key contributions to this report. 

f 

National Association of State Approving Agencies 

Winthrop, ME. 

April 27, 2007 

The Honorable John Boozman 

United States House of Representatives 

1519 Longworth House Office Building 

Washington, DC 20515 

Congressman Boozman: 

Thank you for the opportunity to discuss the functions of State Approving Agencies (SAAs) and other related issues. We appreciate your support of SAAs and look 


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forward to working with you on the funding issue so that we can continue to provide 

the kind of service that our nation’s veterans deserve. 

During the hearing on April 19th you asked us to provide further detail on the 

matrix that is located on page 20 of the recent GAO report. We are in the process 

of expanding the matrix and expect to be able to provide this information to you 

in a couple of weeks. 

We also would like to take this opportunity to supplement the response to the 

question that you posed during the hearing about the differences in approval activities. We provide this information because the issue of differences or overlap appears 

to be critical in the analysis of the value of State Approving Agencies to the success 

of the ‘‘GI Bills.’’ We respectfully request that this supplemental information be officially entered into the Congressional record of the proceedings connected to the 

hearing and therefore, have submitted the information as an enclosure to this letter. 

We are prepared to submit an electronic copy of the enclosure and meet any other 

requirements as well. 

Thank you again for your interest in and support of State Approving Agencies. 

Thank you also in advance for accepting and placing into the record the enclosed 

supplemental information in response to your question about differences in approval 

activities. 

Sincerely, 

C. Donald Sweeney 

Legislative Director 

C: Chairwoman Herseth Sandlin 

Congressman Donnelly 

Congressman Hall 

Selected Congressional Staff 

f 

SUPPLEMENTAL STATEMENT FOR THE RECORD 

IN SUPPORT OF RESPONSE TO QUESTION ASKED BY 

CONGRESSMAN JOHN BOOZMAN 

AT HEARING ON STATE APPROVING AGENCIES ON APRIL 19, 2007 

PROVIDED BY JOAN RYAN AND DONALD SWEENEY 

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES 

APRIL 27, 2007 

Question—Provide details of how State Approving Agencies differ from other 

agencies performing similar functions. 

Preface—The following comments are limited to a comparison between the approval activities of State Approving Agencies (SAAs) for institutional programs and 

accreditation which is the primary component of the certification process used by 

the federal Department of Education for Title IV, Student Financial Aid. The comments are limited to this comparison because the majority of veterans using GI Bill 

benefits are enrolled in programs at accredited educational institutions and the differences between the work of State Approving Agencies and accrediting agencies appear to be the area of greatest misunderstanding. The comments are further limited 

to a comparison between regional accreditation and SAAs due to the fact that the 

vast majority of veterans are enrolled in programs that fall under this type of institutional accreditation. 

1. SAAs are under contract with the VA and are state governmental entities. 

Regional accrediting agencies are voluntary, private sector organizations. 

2. The SAA process is a quality control mechanism, protecting the veteran and 

taxpayer. SAAs have the authority to approve or disapprove within a reasonably short period of time. 

Accrediting agencies are a quality enhancement process. ‘‘They cannot mandate compliance or control behavior except by persuasion and peer influence.’’

‘‘The accreditation process is designed primarily to encourage and assist the institution to evaluate itself objectively and then for the accrediting body to validate what the institution has said about itself.’’

3. SAAs review and reevaluate programs for compliance with approval criteria 

every year or two. 


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Regional accrediting agencies re-evaluate institutions as a whole, not each specific program, generally once every 10 years for established institutions with 

a 5-year interim report submitted by the institution to the accrediting agency. 

4. Although not a perfect analogy and without consideration to the frequency of 

re-evaluations for established institutions (2 years versus 10), the two processes could be compared to a real estate salesperson who lives a few towns 

away from the location of the home that they are selling and the home inspector that lives in the town where the home is located. 

The salesperson’s responsibilities are to describe the home as reported by the 

homeowner and to conduct a review to ensure that the statements made by 

the homeowner appear to be factual. The home is a 22 year old, two story 

modified cape with one and a half baths, three bedrooms, wood siding, asphalt 

shingled roof, baseboard hot water heat, 100 amp electrical service, 200 foot 

drilled well, on site septic system with leaching field and a two car garage. The 

home is located on one and half acres and was recently painted inside and out. 

It is aesthetically appealing. 

The home inspector will be able to determine that the life expectancy of the 

boiler is twenty-five years and that since the home is located in a cold climate, 

has 2 by 4 studs and blown in insulation, the boiler is probably due for replacement. The inspector can also determine that carpenter ants have eaten away 

the sills on one side of the home which will need to be replaced along with 

one floor joist, some sheathing and siding. Although recently painted, some of 

the lower wood siding on another side of the home has sustained water damage 

and should be replaced before further damage occurs. Although the owner has 

said that there has never been any water in the basement, the inspector sees 

lime stains on the basement walls approximately 3 inches from the floor which 

could indication some seepage from the high water table in the area and the 

potential for water damage later, the installation of a sub pump is advisable. 

When inspecting the roof from the attic, the inspector sees water stains on one 

of the roof rafters and leakage around the chimney that has led to some damage to the sheetrock sealing over one of the bedrooms that is currently not visible from the inside of the room. This leakage has the potential to cause greater 

damage if not repaired soon. The inspector finds that the septic tank has not 

been pumped for almost 10 years which means that the leaching field may 

have sustained some damage so a qualified technician should be consulted, especially since the area has a high water table throughout the entire year. 

We could go on, but hopefully the comparison is helpful to a better understanding the differences between the evaluative activities of SAAs and accreditation which is the heart of the DOE process. 

In conclusion, we disagree with the GAO statements that many programs approved 

by SAAs are already approved by the Department of Education and the statement 

that SAAs approve a small number of programs that are not reviewed by other 

agencies. From these erroneous conclusions, the GAO then implies that there is significant overlap in the approval functions. We disagree. 

Even if one assumes that there is considerable overlap between the SAA 

approval process and regional accreditation (which there is not), this overlap will occur every 10 years. The institution submits an interim report to the 

accrediting agency at the five-year point, but unless the agency sees a problem in 

the report—there is no further review or investigation—the report is filed. Beyond 

the fact that a 10-year cycle does not provide adequate opportunity for the VA or 

SAAs to ensure that the requirements of Title 38 are being met, is this really the 

kind of service that we want to give to our veterans? Who will respond to veterans’ requests for detailed information on approved programs and requests to 

evaluate new programs of education and training? Who will work with school officials to ensure that veterans receive credit for prior learning and advanced standing 

at the institution and are meeting the requirements of Title 38 for proper payment 

of benefits? Who will provide training to school officials on VA certification procedures and other relevant matters? These are just a few of the questions that are 

pertinent to the work of SAAs with educational institutions. 

Æ 


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