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Proposed MOU would require TA schools to be eligible for civilian financial aid program


Navy Times.  Jan 16, 2013.

The Pentagon is pushing a quality-control proposal that would shut out of the military tuition assistance program any colleges and universities that are ineligible for civilian federal financial aid.

Most traditional public and private nonprofit schools would not be affected, but such a change would rock some distance, technical and for-profit institutions that don’t take part in civilian federal aid programs commonly called Title IV, including Pell Grants and subsidized federal loans.

The proposal is garnering mixed reviews.

A coalition of 11 veterans and military advocacy groups — including Student Veterans of America, Iraq and Afghanistan Veterans of America and the Association of the U.S. Navy — not only praised the idea but said it should also apply to the MyCAA education program for military spouses.

But the Distance Education and Training Council, which oversees many nontraditional schools, said the change would make 88 of the 102 distance education schools that it accredits ineligible for TA.

“Restricting eligibility for the TA program to only students who enroll in Title IV participating institutions would unfairly restrict the options service members have to enroll in quality distance education programs,” the group’s executive director, Leah Matthews, wrote in public comments on the proposal.

The restriction was included in expansive rules proposed by the Defense Department in the third incarnation of its memorandum of understanding, or MOU, for schools participating in TA. The rules were put out for public comment, and a final version is expected to be released in the spring, DoD spokeswoman Joy Crabaugh said.

When that happens, schools will have to sign on in order to remain eligible for TA.

Seeking 'quality assurance'

Crabaugh said the federal financial aid restriction was included for “quality assurance” and because a White House executive order indicated schools must offer the aid and make sure students know about its availability. Schools will have 18 months from the MOU’s final release to complete the application and approval process for Title IV, she added.

“Quality assurance includes not only the delivery of quality programs by institutions of higher learning, but also the meeting of minimum requirements in the areas of financial/fiscal responsibility and administrative capability that demonstrate program integrity and the continued support for quality,” Crabaugh said in a written statement.

DoD released its first MOU nearly three years ago, in the midst of a long-running debate over the proliferation and quality of for-profit schools in the military education arena. That initially would have required schools — in order to remain eligible for TA — to sign on to rules established by the Servicemembers Opportunity Colleges group related to transferring credits from other schools, accepting academic credit for military training and other issues.

The backlash came not so much from for-profits as from some traditional four-year schools that said the rules would threaten their academic independence and integrity, forcing them to pull out of TA.

In response, DoD released a second MOU that merely required schools to disclose what their standards were with regard to the policies in the first MOU.

Schools had the option to sign either the first or second versions in order to maintain eligibility for TA. Representatives of some institutions that signed the first were critical of DoD’s about-face, saying the revised MOU lacked teeth.

The third MOU is to be based on the principles of excellence for military education, outlined in an April 2012 executive order from the White House. The proposal includes requirements for schools, military branches and DoD itself.

It requires that schools not use “unfair, deceptive and abusive recruiting practices,” provide academic and student support to troops and their families, and give “meaningful information to students about the financial cost.”

Meanwhile, DoD and the military would have to:

■ Undergo an annual review process, and provide notification, prior to changing TA cost and credit-hour limits.

■ Put a complaint system in place for troops to report problems with institutions.

■ Add restrictions to what school representatives and information would be allowed on bases.

■ Provide joint services transcripts to service members.

No 'show stoppers'

James Cronin, vice president for military partnerships at University of Maryland University College, the second-most-popular TA school across the military in fiscal 2012, said there were aspects of the MOU that he thought needed to be described in greater detail, and he sent questions to DoD. But he voiced no strong objections to the proposal.

“I didn’t think anything in there was a show stopper,” he said in a telephone interview.

Like UMUC, American Military University, the nation’s top TA school, is eligible for Title IV civilian financial aid and would not be affected by that part of the MOU.

In fact, in an environment where schools are competing for a limited number of students, rules that effectively “thin out the field” of eligible institutions work to AMU’s advantage, Jim Sweizer, the school’s vice president for military programs, told Military Times.

But Sweizer said he is still against the restriction. “We’ve always been an advocate and a proponent of opportunity for service members,” he said. “If the school is nationally or regionally accredited ... it shouldn’t matter whether they participate in the Title IV program.”

'Bureaucratic idiocy'

A school must adhere to a host of regulations, as well as report detailed information about its operations to the Education Department, to become Title IV eligible.

Martinsburg College, a for-profit distance learning school in West Virginia, which specializes in technical certificate and certification programs, is one example of a non-Title IV school that would have to either become eligible for the civilian aid or lose TA eligibility.

Paul Viboch, the school’s president, said attaching such a requirement to TA is “bureaucratic idiocy.”

The relatively low cost and short completion time of his school’s programs make such aid unnecessary, he said. And many of the rules associated with Title IV are already in place or proposed elsewhere in the new MOU.

“This has nothing to do with the quality of education,” Viboch told Military Times. “It’s the literal paperwork, forms and things you have to keep and comply to in order to be a participating institution that are very, very significant.”

Judith Eaton, president of the Council for Higher Education Accreditation, wrote in a public comment on the proposal that it would offer no additional protection for students and could harm them by restricting the availability of low-cost education programs.

The Commercial Vehicle Training Association went further, asking DoD to let schools that have no accreditation participate in TA.

Meanwhile, one anonymous public comment on the proposal landed at the opposite end of the spectrum, reading simply: “Do not allow for-profit universities on military installations.”

More regulation or less?

In their joint public comment, the 11 veteran and military groups said they “applaud” the Title IV limitation, adding that TA and MyCAA dollars should not go “to programs that the Education Department refuses to recognize.”

The groups also praised the proposal for seeking to establish a complaint system, but they called for stricter limits on marketing and recruiting.

“Deceptive marketing continues today — in call centers and on websites and printed materials by some predatory schools,” they said.

But for-profit schools, including AMU, and that industry’s trade group, the Association of Private Sector Colleges and Universities, said the proposed rules go too far.

Their public comments argued that restrictions on marketing would prevent troops from getting important information on degree plans, base access limitations could keep employees from improving a school’s educational offerings and the complaint system could be unfair to schools.

“Institutions should have, and the MOU should outline, the due process available to institutions in the complaint process to protect them from unfounded allegations,” wrote Steve Gunderson, the trade group’s president.

The American Council on Education, one of the country’s largest higher education groups, suggested several changes to the MOU in its public comments, including altering a proposal that would allow TA to cover school tuition but not fees. What are classified as “fees” at one institution are included in tuition costs at another. This could result in radically different out-of-pocket costs for troops.

“A service member should not decide which institution to attend or courses to take based on how an institution chooses to categorize costs,” the group said.