Higher Education: More Information Could Help Education Determine the Extent to Which Eligible Servicemembers Serving on Active Duty Benefited from Relief Provided by Lenders and Schools
Released: 2006-11-01T00:00:00

Letter

Background

Congress has demonstrated its commitment to providing education benefits to members of the armed forces who are interested in pursuing postsecondary education since the enactment of the Servicemen’s Readjustment Act of 1944, also known as the GI Bill of Rights. Since that time other programs have been implemented to meet the educational needs of servicemembers, including the current Montgomery GI Bill, which provides education assistance to veterans and active duty, Reserve, and National Guard servicemembers. As of fiscal year 2007, active duty servicemembers can receive up to $1,075 monthly for a maximum of 36 months, while Reservists can receive up to $309 monthly for a maximum of 36 months. In fiscal year 2005, another program, the Reserve Educational Assistance Program, was implemented to provide benefits for Reservists who are called or ordered to active duty in response to a war or national emergency. Those who meet the length of service requirement can receive up to $827 toward their education, per month for 36 months. Congress has also given the Army, Navy, Marines, Air Force, and Coast Guard the ability to provide tuition assistance to active duty servicemembers and members of the Reserves and National Guard. These servicemembers can currently receive up to $4,500 in tuition assistance benefits annually.

In addition to these targeted programs, servicemembers may be eligible to participate in the federal student financial aid programs authorized by Title IV of the Higher Education Act, which authorizes federal grant and loan programs for all eligible students. Specifically, if their military education benefits, income, and assets do not fully cover the estimated cost of attendance, servicemembers may be eligible for federal Pell grants, which do not have to be repaid, as well as federally subsidized Stafford and Perkins student loans, on which the federal government pays the interest while the borrower is in school. Servicemembers, like other borrowers, may also qualify for unsubsidized federal Stafford and PLUS loans if they do not demonstrate financial need. Because these loans are not subsidized by the federal government, borrowers are responsible for paying all of the interest that accrues on the loan from the time the loan is disbursed until it is paid in full.

The Higher Education Relief Opportunities for Students (HEROES) Act of 2003 was enacted to recognize the difficulties that postsecondary students and federal student financial aid recipients serving on active duty may experience in transitioning in and out of college and repaying their student loans. The law covers individuals who are serving on active duty, during a war, other military operation or national emergency, including members of the National Guard serving on full-time active duty and Reserves who are called to active duty. The law extends much of the relief that Congress initially provided in the HEROES Act of 2001, following the tragic events of September 11, 2001. Specifically, the HEROES Act of 2003 authorizes the Secretary of Education to waive or modify any statutory or regulatory provisions relating to federal student financial aid to minimize the financial impact and administrative requirements for individuals who are serving on active duty. The law requires Education to report to Congress on the impact of its efforts within 15 months of exercising its authority. While the law does not require postsecondary schools to assist students who leave for active duty service, it encourages them to provide tuition refunds for incomplete coursework and to minimize reapplication requirements.

Federal student financial aid provisions include a number of options designed to allow any federal student loan borrowers—whether serving on active duty in the military or not—to postpone repayment. For example, borrowers are not expected to make payments on their loans while enrolled in school on at least a half-time basis, while completing a graduate fellowship, or for the first 6 or 9 months after they have left school, known as the grace period. There are also options that allow borrowers to postpone repayment if they are having difficulty meeting their repayment schedule. Borrowers may qualify for a deferment if they have been unable to find full-time employment or can demonstrate economic hardship. Additionally, members of the armed forces may qualify for a military deferment while they are serving on active duty during a war, other military operation, or national emergency. Borrowers who are not eligible for any of the deferment options can request forbearance, a temporary period during which loan payments are either reduced or postponed. While borrowers do not have to make loan payments during in-school, grace, deferment, or forbearance periods, whether or not they are responsible for paying the interest that continues to accrue depends on the type of loan and postponement, as shown in table 1.

Education Has Issued Waivers and Modifications to Provide Relief for Aid Recipients Serving on Active Duty, but the Impact of These Changes Is Not Known

Education has implemented HEROES by waiving and modifying certain federal student financial aid provisions to ease the financial impact and administrative burden of meeting aid obligations for recipients serving on active duty. The extent to which servicemembers are benefiting from these waivers and modifications is not known, however, because Education has not collected key information that would allow it to assess the impact of these changes as required by HEROES.

Education’s Waivers and Modifications under HEROES Aimed at Relieving Financial and Administrative Burden for Student Financial Aid Recipients Serving on Active Duty

To help federal student financial aid recipients who are serving on active duty avoid negative financial consequences, such as loan default, Education has expanded opportunities to avoid or postpone repayment of federal student grants and loans. Students who leave school for active duty service no longer have to return or repay federal grant funds for academic terms they were unable to complete. Moreover, students who leave school for active duty service are considered to be still enrolled in school, which means that they do not yet have to begin repaying their student loans. Similarly, Education has expanded opportunities to postpone repayment for borrowers serving on active duty who are out of school or enrolled less than half-time. Specifically, under the HEROES waivers, if borrowers were in a grace period at the time of departure, lenders are required to maintain loans in a grace period for up to 3 years while the borrower is performing active duty service and provide borrowers with a full 6-month or 9-month grace period once they return, depending on the type of loan. Borrowers in repayment no longer have to provide their lender written documentation of active duty service to have loan repayment suspended for up to 1 year. Instead, under the HEROES waivers, lenders must suspend loan payments based on verbal notification from borrowers or another reliable source. Figure 1 illustrates the options available to suspend or postpone loan repayment for federal student loan borrowers serving on active duty.

Education’s waivers and modifications also cover borrowers who had already defaulted on their student loans at the time of departure. Specifically, Education has waived the provisions that require schools and guaranty agencies to attempt to collect on defaulted loans while the borrower is performing active duty service. Education has also waived requirements related to getting loans out of default. Specifically, once a borrower has defaulted on a loan, he or she can usually “rehabilitate” it by making 12 consecutive on-time payments. To ensure that borrowers on active duty service are not penalized, Education has waived the requirement so that any payments that are missed during active duty service or during a 3-month transition period upon return will not be treated as an interruption.

The waivers and modifications also encourage schools to use their professional judgment in determining financial need for students whose family income has been affected by active duty service, regardless of whether the student or the student’s parent or spouse is serving on active duty. Education’s waivers and modifications allow financial aid administrators to consider more current financial information than what students typically submit when applying for federal student financial aid if it reduces the amount the student and his or her family would be expected to pay toward the cost of attendance. For example, the expected family contribution for the 2006-2007 academic year would typically be calculated using financial information from the 2005 calendar year, but the waivers and modifications allow financial aid administrators to use financial information from the 2006 calendar year for those serving on active duty and their spouses and dependents. Financial aid administrators need not make this adjustment if doing so will provide no financial benefit to the student, such as in cases in which active duty service leads to an increase in income.

Education’s waivers and modifications also ease the administrative, or “paperwork,” burden federal student financial aid recipients may experience when they are serving on active duty. For example, Education has made allowances for borrowers who have to depart quickly by requiring lenders to accept notification from someone acting on the borrower’s behalf, such as a spouse or parent. Education has also relaxed the requirement that postsecondary schools obtain written authorization from a borrower regarding the disbursement of financial aid when military service would make complying with this requirement difficult. Under the waivers and modifications, borrowers serving on active duty also have more time to cancel a student loan. While borrowers normally have 14 days from receiving notification from their school that their loan has been credited to their account to cancel all or a portion of their student loan, borrowers serving on active duty have 60 days.

Education officials told us that when they developed the waivers and modifications, they began by considering which federal student financial aid provisions could have negative financial consequences for individuals eligible for relief under HEROES and then conducted internal brainstorming sessions to identify options for relief. The officials said the process was guided by the understanding that Education was charged with waiving and modifying existing statutory and regulatory provisions, not creating new regulations or spending additional funds. Prior to issuing the waivers and modifications, Education officials reached out to industry groups, such as the National Association of Student Financial Aid Administrators and the National Council of Higher Education Loan Programs, to discuss the changes being considered and elicit additional ideas on how to best assist students and federal student financial aid recipients serving on active duty. Additionally, Education officials said the Department of Defense was instrumental in helping Education understand the deployment process, in particular how quickly deployment can occur and how little time servicemembers may have to attend to personal matters. One Education official said that understanding the nature of deployment was important in helping Education work through concerns about program integrity. Specifically, there were concerns that if administrative requirements were reduced by waiving written documentation requirements and allowing someone else to act on the borrower’s behalf, program integrity might be adversely affected. Education decided that minimizing the obstacles to obtaining relief to ensure that borrowers did not inadvertently default on their student loans outweighed these concerns. Additionally, the official noted that the risks to the federal government are minimal since borrowers can only obtain 1 year of assistance without additional documentation, and they will eventually have to repay the remaining balance of their loans.

After the passage of HEROES, Education announced limited waivers to statutory and regulatory provisions in May 2003 and announced more comprehensive waivers and modifications in December 2003. As required by HEROES, Education published the waivers and modifications in the Federal Register, which also provided guidance to help postsecondary schools, lenders, and guaranty agencies understand the changes. The waivers and modifications announced as a result of HEROES update and expand much of the guidance Education issued to the higher education community through Dear Colleague Letters immediately following the terrorist attacks of September 11, 2001, and again in March 2003. The initial Dear Colleague Letters focused on providing relief for students and federal student loan borrowers affected by the terrorist attacks, including military personnel. In October 2005, Education extended these waivers and modifications through September 2007. (See fig. 2.)

See appendix II for a full list of the waivers and modifications.

Education Has Not Assessed the Impact of Waivers and Modifications on Students and Federal Student Financial Aid Recipients, as Required

Education has not assessed the impact of waivers and modifications on federal student financial aid recipients and Title IV federal student financial aid programs as mandated by Congress. Specifically, both the 2001 and 2003 HEROES Acts required Education to report to Congress on the impact of its waivers and modifications within 15 months of first exercising its authority to waive or modify federal student financial aid provisions. Based on Education’s issuance of comprehensive waivers and modifications in December 2003, a study should have been completed no later than March 2005. While HEROES does not specify how Education should go about assessing the impact of its waivers and modifications, Education officials interpreted the Act as requiring a rigorous experimental design that they say would be costly and cannot currently be supported with Education’s data systems. Therefore, Education currently has no plans to complete the required study.

Currently, Education does not have a mechanism for identifying the total number of federal student financial aid recipients who have been provided assistance under HEROES within its data systems. Education maintains a central database of all federal student loans and Pell grants through its National Student Loan Data System, which tracks the status of loans and grants through their life cycle. The database collects required information on federal student aid recipients’ enrollment status from schools and the status of their loans from lenders and guaranty agencies. Based on current reporting requirements, the system can only be used to identify two types of assistance provided to borrowers based on their military service, military deferment and military grace periods, which are coded uniquely in the system and existed prior to HEROES. Education officials told us that the system would have to be reengineered to identify other types of borrowers who received assistance under HEROES, such as those with loans in forbearance, because there are no additional codes in the system to explain what made the loan eligible for assistance, such as military service or financial difficulty.

When Education announced waivers and modifications, it included a provision requiring postsecondary schools and lenders to document their use of the waivers and modifications in such a way that they could report on their effect to Education upon request. However, the announcement did not include any specific guidance on what types of data Education wanted and how schools and lenders should collect it to ensure Education could use the data. Education officials told us that they thought the requirement went largely unnoticed and that lenders generally do not collect information on this population in such a way that would be reportable. For example, the officials said that while lenders maintain information on the reasons for forbearance in a borrower’s individual loan record, they would not have a mechanism for running a query to identify every borrower granted forbearance based on active duty service. In our discussions with lenders we found that three of the nine could provide us some data on the number of borrowers whose loan payments had been suspended through forbearance as a result of military service. Moreover, these lenders could provide some data on borrowers whose loans had been maintained in an in-school period while serving on active duty.

Education has not explored other data sources that might be used in combination with its data systems to complete the congressionally required study. For example, the Department of Defense (DOD) has data that may be used in conjunction with Education’s data to assess the number of federal student financial aid recipients who have been assisted by HEROES. DOD told us that it has extensive information on servicemembers, including mobilizations and deployments, through its Defense Manpower Data Center. DOD officials said it would be possible to conduct a match using common data points, such as Social Security numbers and dates of birth, with Education’s National Student Loan Data System, to identify servicemembers who were participating in federal student financial aid programs at the time they were deployed. Once the target population has been identified, additional analysis to determine the extent to which these servicemembers received some relief might be possible. Education officials agreed that such a match would be possible, but said they would have concerns about being responsible for sensitive national security data of this nature. Additionally, they thought resources could be another limitation to such a match, since Education would likely have to provide funds to cover the work if it entered into a memorandum of understanding with DOD.

Lenders Are Assisting Borrowers as Required by Education and Some Are Providing Additional Benefits

Lenders have a variety of policies and practices in place designed to provide relief for federal student loan borrowers serving on active duty, many of which are required under Education’s waivers and modifications. To minimize the financial impact on borrowers, lenders provide them with options to suspend or postpone repayment on their student loans. For example, borrowers who were enrolled in school on at least a half-time basis before leaving for active duty service are eligible to have their loans maintained in an in-school status period, which means that they do not enter repayment while they are serving on active duty and are provided additional time to reenroll after completing their service. For borrowers who are repaying their loans, lenders said they will suspend repayment through a military deferment or forbearance during active duty service.

Because borrowers are responsible for paying the interest that accrues on loans in forbearance, lenders consider forbearance as the last option for suspending repayment on a loan when borrowers are not eligible for any other type of assistance.

Lenders also told us about policies or practices they have to minimize the financial impact on borrowers that go beyond the requirements of HEROES. Some lenders we interviewed reported practices to minimize the amount of interest that accrues while a loan is in forbearance during active duty service. While borrowers are not required to make any payments during a forbearance period, the interest on these loans continues to accrue, and ultimately the borrower is responsible for paying it. If the borrower elects not to pay any of the interest that has accrued during the forbearance period, the interest will eventually be capitalized by adding the accrued interest to the remaining principal balance. From that point on, interest will be assessed on the new, higher principal balance. Federal student financial aid provisions allow lenders to capitalize the interest that accrues on loans in forbearance either quarterly or at the end of the forbearance period, depending on when the loan was originally disbursed. However, three lenders told us that they do not capitalize the interest on loans in forbearance as a result of active duty service, which reduces the total amount of interest that borrowers serving on active duty must pay. Additionally, one Pennsylvania-based lender has extended benefits beyond the requirements of HEROES by offering loan forgiveness for servicemembers who have lived in Pennsylvania or attended college there. The program provides a one-time loan-forgiveness benefit of $2,500 for members of the armed forces who have been in an active duty status between September 11, 2001, and December 31, 2006.

Lenders also follow Education’s waivers and modifications designed to reduce the administrative burden for borrowers serving on active duty, for example, by providing immediate assistance to borrowers based on verbal notification of their active duty service. A representative from one of the lenders we interviewed told us that the simplified documentation requirements allowed under the HEROES waivers and modifications have made it easier for lenders to quickly respond to borrower needs. She said that without this assistance, borrowers might have become delinquent on their loans—which could adversely affect their credit rating—while waiting to be approved for forbearance because of the documentation requirements.

Lenders told us that with these simplified procedures, they could help servicemembers with just one short telephone call. For example, all the lenders we interviewed have toll-free numbers that borrowers can call to obtain information about or request assistance with their loans, and borrowers only need to contact the lender once to receive assistance, such as military deferment or forbearance. Lenders said the borrower is typically the one who contacts the lender about his or her active duty service, but they will also accept notification from someone acting on the borrower’s behalf, such as a spouse, parent, or other reliable source. Three lenders explained that individuals who notify the lender must have sufficient information about the borrower’s account to be considered a reliable source. During the initial contact, a customer service representative will determine what benefits the borrower is eligible for based on his or her individual circumstances. According to several lenders, this stage of the process can usually be completed in 5 to 10 minutes, and any changes that are made to the loan status will be processed within 3 to 5 days, at which time a notice is mailed to the borrower confirming the changes that were made and the time periods these changes will remain in effect.

The process is similar when borrowers return. However, since borrowers may not contact the lender when they return from active duty service, lenders said that they rely on information documented in the borrower’s account to determine the length of the benefit period. Lenders send borrowers a notice by mail before the benefits lapse to inform them of what will happen to the loans at the end of the period, along with contact information should the borrower need additional assistance with their loans. For example, a borrower with a loan in forbearance would receive a notice indicating when the forbearance period is scheduled to end along with repayment terms, such as when the borrower will have to begin making payments and how much he or she will have to pay each month. The advance notice is designed to allow sufficient time for borrowers who are continuing to serve on active duty to submit copies of military orders to extend the assistance they are receiving with their loans. Borrowers need not take any action when they receive notification from the lender if they have returned from active duty service and do not require further assistance with their loans.

While the benefits available to borrowers under HEROES end after the borrower has returned from active duty service and used any available transition period, most of the lenders we talked to said they would continue to work with any borrowers having difficulty making their monthly payment after returning from active duty service. For example, officials from one lender said they would offer borrowers other repayment alternatives, such as income-sensitive repayment to lower their monthly payment amount, or additional forbearance time as allowed under federal student financial aid provisions.

Most Schools Have Had Students Leave for Active Duty and Have Policies in Place to Aid Their Departure and Return

The majority of colleges and universities have had students who left school for active duty service before the end of their academic term and have policies to assist these students when they leave and when they return to school. Schools reported having policies covering refunds of tuition and room and board, grading, and changes to graduation and degree requirements that might occur while students are serving on active duty.

Most Colleges and Universities Have Had Students Leave for Active Duty

The majority of colleges and universities—about 80 percent—have had students leave school for active duty service prior to the end of their academic term, according to our survey, with a greater percentage of public schools having experience with such departures. For example, we estimate that 66 percent of 4-year private schools had students who left for the military compared to 96 percent of 4-year public schools (see fig. 3). Although the majority of schools had students who left for active duty service, most of these schools could not identify the number of students who left since HEROES was first enacted in January 2002. Officials at two of the universities we visited told us that more than 100 of their students had left and partly attributed the large number of departures to their campuses’ proximity to military bases and National Guard units.

Most Schools Have Policies in Place to Aid Students When They Leave for Active Duty Service and Return to School

We estimate that nearly three-quarters of schools have policies or practices for students who leave for active duty service prior to the end of the academic term. Schools with students who have left were more likely to report having policies. About two-thirds of schools reported that their policies were in place prior to the enactment of the first HEROES Act in 2001. For example, officials at one university we visited said the institution’s policies were developed in the 1990s in response to the many students who had to leave school for active duty service in Kuwait. Some of these schools’ policies may have been influenced by state law. Specifically, we identified 26 states that have laws to assist students who leave for active duty service (see fig. 4). Most of them apply only to public colleges and universities, and require schools to have nonpunitive withdrawal policies and issue tuition refunds for students who choose to withdraw. Both Texas and Florida, for example, require public colleges and universities to provide students with the option of receiving a full tuition refund for any course they withdraw from or completing it at a later date without penalty. Additionally, Texas provides professors with the flexibility to assign students a grade based on the work completed at the time of departure.

School Policies Address the Broad Range of Issues Confronting Students Who Must Leave for Active Duty Service

Most schools have policies in place to help students who leave for active duty service transition out of and back into school. Figure 5 illustrates the options that may be available to these students when they depart and return.

For students who leave for active duty service before completing an academic term, the majority of schools offer tuition refunds and various options for withdrawing from courses. We estimate that 70 percent of colleges and universities have tuition refund policies for students leaving for active duty service, and most of them provide a full tuition refund for these students (see fig. 6). The majority of schools that provide a partial refund prorate the refund based on how much of the term the student has completed.

Some schools also reported having policies that allow for the refund of room and board. Of the schools that offer campus housing, 52 percent reported having policies regarding room and board refunds. Of those, 82 percent reported that they provide a partial refund of room and board, usually based on the amount of the term completed, for students leaving for active duty (see fig. 7).

Most of the schools require documentation of active duty service, such as a copy of military orders, before students can receive a refund of tuition or room and board, although in some cases students may not have documentation before leaving. For example, officials at one university we visited said that their students who left for active duty service shortly after September 11, 2001, did not receive their military orders before departing, and as a result their tuition refunds could not be processed before they left.

Students may also risk failing courses or delaying graduation when they leave school before the term has been completed, but about two-thirds of schools have put in place policies to help them minimize the academic impact of leaving (see fig. 8). Almost all of these schools allow students leaving for active duty service to receive a grade of “incomplete”—giving them the option to finish the class later—or withdraw from a course without receiving a grade. Of the schools that allow a student to receive an incomplete in an unfinished course, 68 percent require the student to complete the coursework within specific time frames—anywhere from less than a month to 36 months—to receive a letter grade in the course. In addition, over half of schools that have policies to minimize academic impact allow instructors to assign a grade based on partially completed coursework.

Of the seven students we interviewed, one was able to work with his instructors to complete remaining coursework for a grade before leaving for active duty service, and five opted to withdraw from their classes. An undergraduate student in the Army National Guard we interviewed said that he withdrew from his classes as soon as he received the alert that his military unit would be deployed. He said that withdrawing from school allowed him to focus on ensuring that health insurance and medical care were in place for his son, who has a serious illness. A graduate student in the Marine Reserves who received 1 week advance notice of deployment withdrew from classes to allow time to handle financial obligations. While withdrawing from classes ensures that students will not have failing grades to contend with, two students expressed concern about how the withdrawals on their transcripts would be perceived by other postsecondary schools when applying for a transfer or graduate study. The university these students attend has since begun allowing students to get these withdrawals deleted from their records, which means there would be no record of the student having attempted the course on their transcript. One undergraduate student we spoke to reported difficulty withdrawing from his classes. He told us that while he was deployed multiple times for durations of 1 to 3 weeks, his university approved only one of his requests to withdraw. Even though his deployments were relatively short, he said it was difficult for him to keep up with the coursework and his academic performance suffered as a result.

In addition to allowing students to withdraw or receive a grade of incomplete, some of the colleges we visited provided other options for students leaving for active duty service to complete classes. Officials at one college we visited said that some students who have left school for active duty service have been able to complete a course by delivering remaining assignments to their professor by Email or completing a classroom course via the Internet when it is offered in an online version. One university we visited that has a large number of military students reported great increases in online course enrollment in 7 years, from 20,000 to 150,000 students. Also, a college based in Texas with campuses on military bases worldwide offers courses using such tools as prerecorded and live lectures displayed over the Internet, interactive online discussions that can facilitate student participation, and course materials provided on compact disc.

When students return to school from active duty service, most schools also have policies to ease their transition. Specifically, about half of schools with policies to minimize the academic impact of leaving for active duty service do not require students to reapply for admission (see fig. 9). Of those schools that require students to reapply, almost all guarantee readmission, and 84 percent waive application fees. Officials at one college we visited reported that students returning from active duty service are required to reapply just to ensure that the school has updated contact information for the students. Moreover, a student may return from active duty to find that degree requirements have been changed, such as courses required for a major, which could delay graduation. Sixty percent of schools with policies designed to minimize the academic impact of leaving for active duty service exempt returning students from changes in degree requirements that occurred during their absence (see fig. 9). Additionally, the majority of schools with polices to minimize academic impact reported having mechanisms that allow returning students to appeal failing grades and changes to degree requirements.

Conclusions

Our study showed that most colleges and universities have experienced military departures, and schools and lenders have marshaled behind servicemembers by putting in place policies and practices to minimize the impact of serving their country. Education issued waivers and modifications to federal student financial aid provisions to protect this population, and states also have laws in place to support them. However, critical information to gauge the usefulness of these waivers and modifications is missing. Specifically, Education does not have very basic information on the extent to which servicemembers are benefiting from the waivers and modifications. We know that more than 1.3 million servicemembers have been deployed since September 11, 2001, but information on the extent to which these individuals are college students or have federal student loans and are receiving relief under HEROES is unknown. While an impact study of HEROES as Education has interpreted the congressional requirement would be difficult and costly to undertake, important information such as this could be obtained without using a rigorous experimental design. Such information would be important to gauge the extent to which those eligible are taking advantage of HEROES and may provide Education with information about issues for future study.

Recommendation for Executive Action

To ensure that Congress knows the extent to which the waivers and modifications are being used, we recommend that the Secretary of Education undertake the congressionally mandated study to determine the extent to which eligible servicemembers are receiving assistance under HEROES.

Agency Comments

We provided copies of a draft of this report to the Department of Education and the Department of Defense for review and comment. In written comments, the Department of Education agreed with our findings. With respect to our recommendation, Education said it has merit and that it will explore options for completing the congressionally mandated study. Education commented that because highly sensitive national security data from DOD would be required, DOD should take the lead in extracting the data. Education said it would explore this possibility following discussions with Congress and DOD. As we stated and recommended in our report, the responsibility for conducting the study resides with Education. Education’s written comments are in appendix III. DOD had no comments on the draft report.

Copies of this report will be sent to the congressional committees and subcommittees responsible for the Higher Education Act, the Secretary of Education, the Secretary of Defense, and other interested parties. Copies will also be made available to others upon request. In addition, this report will be available at no charge on GAO’s Web site at http://www.gao.gov.

If you have any questions about this report, please contact me on (202) 512-7215. Key contributors to this report are listed in appendix IV.

Appendix I: Methodology for Survey of Colleges and Universities

To determine what policies or practices colleges and universities have in place to assist students serving on active duty, we designed a Web-based survey and distributed it to school administrators of 2-year public, 4-year public, and 4-year private, nonprofit postsecondary schools. The survey asked such questions as whether schools had students that left for active duty service prior to the end of an academic term and what their policies were for refunding tuition and room and board for this population of students. The survey included questions about the types of grading policies they had in place to accommodate students who left prior to the end of the academic term. The survey also asked respondents to report on how they assist students when they return from active duty service and resume their studies, such as whether the student needed to reapply and how the school handled changes in degree requirements. The survey was conducted between January and March 2006.

Sample Design and Errors

Our sample was drawn using the Department of Education’s 2002-2003 Integrated Postsecondary Education Data System (IPEDS), which contains the most comprehensive data on all postsecondary schools. Our sample consisted of 2-year public, 4-year public and 4-year private, nonprofit postsecondary schools that participate in Title IV programs and have an undergraduate enrollment of at least 100 students. We drew a stratified random sample of 274 schools from the population of 2,974 that met our criteria. We selected our sample from four strata defined by size (student enrollment) and institution type (2-year public, 4-year public, and 4-year nonprofit private schools). Each school had a known probability of being selected. We received completed surveys from 75 percent of the 274 colleges and universities in our sample. Two schools in the sample were considered out of scope because of changes to their institutional status. The response rate, adjusted for out-of-scope respondents and weighted to reflect the population size in each stratum, was 77 percent. The population, sample, and survey respondents by strata are shown in table 2. We excluded private, for-profit schools from our sample because they represent a relatively small percentage of all postsecondary schools.

Our probability sample of colleges and universities is only one of a large number of samples that we might have drawn. Because each sample could have provided different estimates, we express our confidence in the precision of the results from our sample in confidence intervals. We are 95 percent confident that each of the confidence intervals for the items we examined from our survey includes the population value. Unless otherwise noted, all percentage estimates from our sample have margins of error of plus or minus 10 percentage points or less. We weighted each sampled school in the analysis to represent all the members of the population, which allows us to generalize the survey responses to the types of higher education schools surveyed.

Nonsampling Errors

In addition to sampling errors, the practical difficulties of conducting any survey may introduce nonsampling errors. Examples of nonsampling errors include misinterpretation of questions and errors associated with manual data entry processes. We took several steps to minimize nonsampling errors. A draft of the survey was pretested with a number of postsecondary institution administrators to ensure that the questions were relevant, clearly stated, and easy to comprehend. On the basis of pretest findings, some slight changes were made to the instrument. All pretests were conducted between October and November 2005. Also, using a Web- based survey eliminated the errors associated with a manual data entry process by allowing school administrators to enter their responses directly into an electronic instrument, automatically creating a record in a data file for each respondent. While we did not fully verify the extent to which schools adhered to their reported policies or practices, we followed up with some respondents to obtain additional information about the policies they reported. We also contacted respondents, if necessary, to clarify answers. Based on these checks, we believe our survey data are sufficiently reliable to be used in determining the policies or practices schools have in place to assist students who are called to active duty. In addition, programs used to analyze the survey data and make estimations were independently verified to ensure the accuracy of this work. To increase the number of survey respondents, once the Web survey was deployed, we followed up with school administrators through e-mail and by phone to remind them about the survey.

To assess the completeness of the IPEDS data, we reviewed the National Center for Education Statistics’ documentation on how the data were collected and performed electronic tests to look for missing or out-of- range values. On the basis of these reviews and tests, we found the IPEDS data sufficiently reliable for defining our population of schools.

Appendix II: Waivers and Modifications

Appendix III: Comments from the Department of Education

Appendix IV: GAO Contact and Staff Acknowledgments

Staff Acknowledgments

Sherri Doughty, Assistant Director Summer Pachman, Senior Analyst In addition to those named above, Avrum Ashery, Susan Bernstein, Karen Burke, Nancy Hess, Kevin Jackson, Jean McSween, John Mingus, Jim Rebbe, and Rachael Valliere made significant contributions to this report.