In fiscal year 2009, the military services’ TA  program expenditures were $517 million, as shown in figure 1. 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. DOD Takes Steps to Enhance Its Oversight of Schools Receiving TA Program Funds, but Areas for Improvement Remain

audit reports and may impose penalties or other sanctions on schools  found in violation of Title IV requirements. DOD’s Oversight Policies and Procedures Vary by Schools’ Level of Program Involvement but Could Benefit from a Systematic Risk-Based Approach

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. Schools offering classes on an installation are subject to additional  oversight measures. DOD’s Education Quality Review Process Was Narrow in Scope and Needed Increased Accountability

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, DOD officials said that schools will be  selected for the MVER process based on the amount of TA funds they  receive. Given that there was  no DOD-wide requirement to track the outcomes of MIVER  recommendations and some of the military services did not require  schools and installations to formally respond to MIVER findings, it is  unclear to what extent recommendations that could improve the quality of  education services offered at schools and installations were addressed. DOD Has Several Ways to Receive Reports of Problems but Needs a Centralized System to Track Complaints

While DOD has several mechanisms for service members to report  problems associated with their TA funding, it lacks a centralized system to  track these complaints and how they are resolved. DOD’s Limited Coordination with Accreditors and Education May Hinder Its Efforts

		DOD Coordinates with Accrediting Agencies but Does Not Use Information about Schools That Have Been Sanctioned or Have Unapproved Changes

While DOD coordinates with accrediting agencies, it does not use  accrediting agencies’ monitoring results or consider schools’ unapproved  substantive changes as it carries out its oversight. DOD’s oversight process does not take into account accrediting agencies’  monitoring results of schools that could negatively affect students and  service members. Schools can be sanctioned by accrediting agencies when  they fail to meet established accrediting standards, such as providing  sound institutional governance, providing accurate information to the  public, and offering effective educational programs. DOD does not currently require schools to have their substantive changes  approved by their accrediting agency in order to receive TA funds. The  extent of DOD’s coordination with Education has generally been limited to  accreditation status. However,  DOD does not utilize information from Education’s monitoring reviews to  inform its oversight efforts. Education determines schools’ initial  eligibility to participate in federal student aid programs through eligibility  reviews and continuing eligibility through program reviews, compliance  audits, and financial audits. The results of these oversight measures can provide DOD and its military  services with additional insight into a school’s ability to provide a quality  education and services to students. DOD may be able to leverage information from Education’s  ongoing efforts in this area. Increased oversight is needed to remedy gaps in the accountability of the  quality review process and the process to address complaints against  schools. DOD could further enhance its oversight efforts by leveraging resources  and information that accrediting agencies and Education already collect. To improve the accountability of DOD, its military services, their  installations, and participating postsecondary schools in developing its  new third-party review process, require all schools, installations, and the military services to formally  respond in writing to related recommendations pertaining to them, and   develop a process to track and document the status of all  recommendations for improvement. 2. 3. In doing so, the Undersecretary of Defense for  Personnel and Readiness should consider the following:   developing a more systematic risk-based approach to oversight by  utilizing information from accrediting agencies and Education to better  target schools,   modifying its proposed standard MOU to include an explicit prohibition  against school conduct that may adversely affect service members,  such as misrepresentation, and reviewing Education’s recently promulgated requirements for state  authorization of schools and coordinate with Education to determine  the extent to which these requirements are useful for overseeing  schools receiving TA funds. 4. 5.
Why GAO Did This Study

In fiscal year 2009, the Department of Defense's (DOD) Military Tuition Assistance (TA) Program provided $517 million in tuition assistance to approximately 377,000 service members. GAO was asked to report on (1) DOD's oversight of schools receiving TA funds, and (2) the extent to which DOD coordinates with accrediting agencies and the U.S. Department of Education (Education) in its oversight activities. GAO conducted site visits to selected military education centers and interviewed officials from DOD, its contractors, Education, accrediting agencies and their association, and postsecondary institutions.

What GAO Found

DOD is taking steps to enhance its oversight of schools receiving TA funds, but areas for improvement remain. Specifically, DOD could benefit from a systematic risk-based oversight approach, increased accountability in its education quality review process, and a centralized system to track complaints. DOD does not systematically target its oversight efforts based on factors that may indicate an increased risk for problems, such as complaints against schools or the number of service members enrolled at a school. Instead, DOD's oversight policies and procedures vary by a school's level of program participation, and schools that operate on base are subject to the highest level of oversight. DOD plans to implement more uniform oversight policies and procedures, but they are not expected to take effect until 2012. In addition, the process DOD used to review the academic courses and services provided by schools and military education centers was narrow in scope and lacked accountability. The review was limited to schools offering traditional classroom instruction at installations and did not include distance education courses, which account for 71 percent of courses taken in fiscal year 2009. The contract for these quality reviews expired on December 31, 2010, and DOD plans to resume its reviews on October 1, 2011, when a new contractor is selected. DOD is developing an expanded quality review process and plans to select schools based, in part, on the amount of TA funds received. With regard to accountability, DOD's review process provided recommendations that could improve educational programming, but there is no DOD-wide process to ensure that these recommendations have been addressed. Furthermore, DOD lacks a system to track complaints about schools and their outcomes. As a result, it may be difficult for DOD and its services to accurately identify and address any servicewide problems and trends. DOD's limited coordination with accreditors and Education may hinder its oversight efforts. DOD verifies whether a school is accredited; however, it does not gather some key information from accreditors when conducting its oversight activities, such as whether schools are in jeopardy of losing their accreditation. Accreditors can place schools on warning or probation status for issues such as providing inaccurate information to the public and poor institutional governance. Schools can experience various problems within the 3- to 10-year accreditation renewal period, and these problems can negatively affect students, including service members. Additionally, DOD does not require schools to have new programs and other changes approved by accrediting agencies in order to receive TA funds. Currently, students enrolled in unapproved programs or locations are ineligible to receive federal student aid from Education, but can receive TA funds. DOD's coordination with Education has generally been limited to accreditation issues and Education's online resources about schools and financial aid. DOD does not utilize information from Education's school-monitoring activities to inform its oversight efforts. Education's findings from program reviews and financial audits of schools provide insights about schools' financial condition, level of compliance, and governance. Collectively, this information could provide DOD with information that can be used to better target schools for review or inform other oversight decisions.

What GAO Recommends

GAO recommends that DOD (1) improve accountability for recommendations made by third-party quality reviews, (2) develop a centralized process to track complaints against schools, (3) conduct a systemic review of its oversight processes, (4) take actions to ensure TA funds are used only for accreditor-approved courses and programs, and (5) require and verify state authorization for all schools.