DOD has voluntary education programs in place to facilitate educational opportunities for service members to pursue postsecondary education during off-duty time. Program oversight for voluntary education programs is the responsibility of the Undersecretary of Defense for Personnel and Readiness. In addition, the military services are responsible for establishing, maintaining, operating, and implementing the programs at 350 education centers on military installations worldwide. Education centers are managed by an education services officer (ESO) and staff, such as education guidance counselors. Service members must meet certain requirements in order to participate in the program. These requirements include consulting with a counselor in order to develop an education goal and degree plan, maintaining a 2.0 grade point average (GPA) for undergraduate-level courses, and maintaining a 3.0 GPA for graduate-level courses. In accordance with DOD policy, tuition assistance covers up to $250 per credit hour, with a maximum of $4,500 per year. In fiscal year 2009, the military services’ TA program expenditures were $517 million, as shown in figure 1. In order to receive TA funds, DOD requires postsecondary institutions to be accredited by an agency recognized by Education. Accreditation is a peer review evaluative process that compares a school against its accrediting agency’s established standards. The accrediting agency conducts institutional reviews to assess the school in its entirety, including its resources, admissions requirements, and services offered, and the quality of its degree programs. The schools’ accreditation is then periodically reevaluated every 3 to 10 years, depending on the accrediting agency. Schools may lose accreditation if their accrediting agency determines that they no longer meet the established standards. Since 1972, SOC has enhanced educational opportunities for service members. SOC, a consortium of approximately 1,900 colleges and universities, is funded by DOD through a contract with the American Association of State Colleges and Universities (AASCU). SOC functions in cooperation with 15 higher-education associations, DOD, and active and reserve components of the military services to expand and improve voluntary postsecondary education opportunities for service members worldwide. SOC criteria stipulate that school policies and practices be fair, equitable, and effective in recognizing the special conditions faced by military students, such as trouble completing college degrees because of their frequent moves. Colleges and universities within SOC must have policies that meet four SOC criteria relating to transfer of credit, academic residency requirement, credit for military training and experience, and credit for nationally recognized testing programs. In addition, they must also follow SOC’s three principles: (1) service members should share in the postsecondary educational opportunities available to other citizens; (2) educational programs for service members should rely primarily on programs, courses, and services provided by appropriately accredited institutions and organizations; and (3) institutions should maintain a necessary flexibility of programs and procedures, such as recognition of learning gained in the military and part-time student status. Since 1991, DOD’s Military Installation Voluntary Education Review (MIVER) process has provided an independent third-party assessment of the quality of postsecondary education programs offered to off-duty service members at military installations around the world. DOD contracted with the American Council on Education (ACE) to administer the MIVER. The MIVER had two purposes: (1) to assess the quality of selected on-installation voluntary education programs and (2) to assist in the improvement of such education through appropriate recommendations to institutions, installations, DOD, and the military services. To assess the quality of education programs offered by schools on installations and to ensure that these program are comparable to those offered at a school’s other campuses, MIVER assessed schools’ missions, education programs, program administration, resources, and program evaluation. The MIVER also examined the installations’ mission statements and command support, program management and leadership, student services, resources, and the voluntary education program plans to determine the quality of their education programs and services. A visiting team composed of college and university professors selected by the contractor evaluated the quality of educational services and support provided by the installation’s education center and servicing institutions. The MIVER provided installations and schools with commendations for their areas of strength, and recommendations for areas needing improvement. It also provided the military services with observations on issues that require the military services’ attention. MIVERs were for the purpose of quality assessment and enhancement only; these reviews were not intended to replace institutional accreditation. The MIVER contract with ACE expired on December 31, 2010, and DOD elected not to renew the contract because it is expanding the scope of these reviews, but DOD is currently in the process of obtaining a new contract for its reviews. According to DOD, a contractor will be selected in 2011 and the new third-party review process will commence on October 1, 2011. On August 6, 2010, DOD published a proposed rule for its voluntary education programs in the Federal Register for public comment. Included in this rule, among other things, are guidelines for establishing, maintaining, and operating voluntary education programs, including instructor-led courses offered on and off installations, distance education courses, and the establishment of a DOD Voluntary Education Partnership Memorandum of Understanding (MOU) between DOD and all educational institutions receiving TA funds. DOD estimates that this new rule will become effective at the beginning of 2012. While Education does not have a role in overseeing DOD education programs, it is responsible for the administration of the federal student aid programs under Title IV and oversees over 6,000 postsecondary institutions receiving these funds. Education determines which institutions of higher education are eligible to participate in Title IV programs, which include the following: Public institutions—institutions operated and funded by state or local governments, which include state universities and community colleges. Private nonprofit institutions—institutions owned and operated by nonprofit organizations whose net earnings do not benefit any shareholder or individual. These institutions are eligible for tax-deductible contributions in accordance with the Internal Revenue Code (26 U.S.C. § 501(c)(3)). For-profit institutions—institutions that are privately owned or owned by a publicly traded company and whose net earnings can benefit a shareholder or individual. audit reports and may impose penalties or other sanctions on schools found in violation of Title IV requirements. DOD policies and procedures to oversee schools receiving TA funds vary based on the school’s level of involvement in the program. While DOD monitors enrollment patterns and schools’ funding levels, and addresses complaints about postsecondary schools on a case-by-case basis, its oversight activities do not include a systematic approach that considers these factors when targeting schools for review. At a minimum, all postsecondary schools receiving TA funds are required to be accredited by an agency recognized by the Department of Education to ensure the quality of education programs being offered to its service members. Schools that are members of the SOC consortium or offer classes on an installation are subject to additional DOD oversight, as shown in figure 2. Schools that elect to become members of the SOC consortium must comply with SOC principles and criteria, which promote institutional flexibility with regard to transfer of credits, the development of programs and procedures appropriate to the needs of service members, and safeguarding the quality of educational programs offered to service members. SOC also reviews member schools’ student loan default rates and verifies their accreditation status every 2 years, according to a SOC official. In addition, SOC considers recruitment practices such as high- pressure promotional activities and “limited time only” enrollment discounts inappropriate activities for its member institutions to engage in. According to a SOC official, SOC will submit a formal complaint to the school’s accreditor when it becomes aware of serious violations of prohibited marketing practices. Schools offering classes on an installation are subject to additional oversight measures. Aside from accreditation and mandatory membership of SOC institutions that provide academic courses on military installations, schools are subject to additional oversight measures including state licensure, MIVER quality reviews, and the terms and conditions of an individualized MOU with the installation commander. The MOU governs the school’s operations on an installation; for example, it can cover reporting requirements on course offerings and the maintenance of student data such as course grades and degrees completed. Education center officials at two installations we visited reported that they stay in constant contact with on-installation schools and review relevant information such as school term schedules and class rosters to ensure that schools comply with their MOUs. If a school does not comply with the MOU requirements, the installation commander can require the school to leave the installation, according to education center officials at two of the installations we visited. In general, DOD and its military services’ oversight of schools is based on a school’s level of program participation rather than a risk-based approach. To address the varying levels of oversight and create a more uniform set of program oversight policies, DOD has developed a new standard MOU for all schools receiving TA funds. Under the new MOU, all schools will be required to, among other things, abide by SOC principles and criteria and provide an evaluated educational plan to service members. DOD estimates that this new rule will be implemented at the beginning of 2012. The MIVER was limited to institutions that offer face-to-face courses at military installations. While distance learning courses accounted for 71 percent of courses paid for with TA funds in fiscal year 2009, DOD did not have a review process in place to assess the quality of these institutions. In addition, quality reviews were not conducted at all installations. According to DOD officials, since the MIVER process was first initiated, in 1991, all Marine Corps installations were visited, while only a portion of installations of the other military services were reviewed (86 percent of Navy installations, 56 percent of Army installations, and 30 percent of Air Force installations).