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DoD: New TA oversight process to focus on correcting, not punishing, colleges

March 10, 2017 (Photo Credit: Lifetouch Special Events)
Randomly selected colleges, as well as those whose tuition assistance programs appear to differ significantly from other schools, will be scrutinized by auditors, under a new Defense Department plan.

DoD stressed that its primary goal is to identify potential problems and make corrections when needed — not to punish schools or ban them from the TA program.

The new process will be “emphatically and unequivocally about remediation,” and not enforcement, said Jonathan Woods, deputy chief of DoD Voluntary Education Programs. “We want to get you back on course. We don’t want to take your driver’s license away.”

School officials at the Council of College and Military Educators annual conference, where the new procedure was unveiled, reacted with a mix of cautious optimism and skepticism.

University of Maryland University College has for years been the second-most-popular destination for TA users. Kelly Wilmeth, vice president of stateside military operations for the school, said she was impressed with the changes made to the review process.

“I think it’s going to be a process and a program that we’re going to easily be able to participate in. It appears to be data-driven, objective and definitely streamlined from the previous compliance and assessment programs,” Wilmeth said.

The new process

Auditing firm PwC, also known as PricewaterhouseCoopers, will annually evaluate 250 of the more than 2,000 schools that enroll active duty service members from the military branches. Of those, 200 will be chosen at random, with no consideration for their status as public, private or for-profit institutions, PwC said.

The remaining 50 will be selected based on how they compare to other schools  in six areas:

  • The overall number of classes taken using TA at institutions
  • Big changes in the number of classes taken using TA at institutions
  • Rates of course completion for TA students
  • Formal complaints lodged against institutions
  • Graduation rates relative to costs
  • Big changes in graduation rates
Officials said that these factors would be given equal weight in the risk-measurement process, and no one factor would “overly sway the results.”

The 250 institutions will be given an initial review. After a compliance tutorial, self-assessment, student surveys and an outside review of publicly available content on school websites, auditors will narrow the list of institutions down to 25 that merit a closer look. Depending on the results of that secondary, more rigorous, review, up to five institutions will be subject to on-campus reviews, if that is deemed necessary, officials said.

Any schools found to be in violation of DoD standards at the end of the process will have six months to resolve the problems.

PwC is currently in the process of collecting data on the first batch of schools that will be evaluated this year.


Jonathan Woods, deputy chief of DoD Voluntary Education Programs, presents changes to the department's process of reviewing schools that educate students using tuition assistance benefits.
Photo Credit: Lifetouch Special Events

A history of controversy

DoD’s Woods said the changes are designed to foster a “culture of compliance” and to ensure quality and rigor at the institutions educating military students. There hasn’t been a comparable outside review of TA schools since 2014, when the DoD ditched an assessment process that the Government Accountability Office said lacked transparency and required institutions and military installations to do more legwork.

Not mentioned during the announcement of the new oversight regime – but likely in the thoughts of some listening to the presentation – was DoD’s action in late 2015 against the University of Phoenix, a huge for-profit school that is among the most popular TA schools and is, by far, the most popular school for students using the Post-9/11 GI Bill.

Citing previous – and already corrected – logo usage and base access violations, DoD placed Phoenix on probation Oct. 7 of that year, immediately barring the school from enrolling new TA students. That restriction continued as Phoenix appealed, and as Arizona Sen. John McCain, the powerful Republican chairman of the Senate Armed Services Committee, denounced DoD’s action against the institution based in McCain’s home state.

By mid-January of the following year, just a few months later, DoD reversed course and lifted the ban.

Woods said that DoD will still monitor schools’ actions outside of the framework of the new review process, as it did with Phoenix. But he went to great lengths to emphasize that the Department’s approach now is to try to work with institutions that run afoul of the rules, rather than immediately punishing them.

The University of Phoenix did not respond to requests for comment by press time.  

Concerns and praise

The action against Phoenix came in the middle of a years-long effort by some Democratic lawmakers and federal officials in the Obama administration to crack down on for-profit institutions, some of which have faced scrutiny and were even forced to shut down amid charges of deceptive recruiting, excessive costs and poor academic quality.

American Military University, a for-profit institution that has for years been the most popular destination for TA users, has largely avoided such criticism.

John Aldrich, associate vice president of military relations at American Military University, said he commends the DoD’s efforts to improve the tuition assistance program. But he also cast doubt on whether DoD should be regulating schools in the first place, pointing to a statement from Peter Levine, a DoD acting under secretary, that department staff are not experts in education and that the program is outside of the DoD’s “wheelhouse.”

Asked if he thought DoD should be regulating schools, Aldrich said it’s “difficult to determine” and “time will tell.”

As DoD officials focus on making sure schools are serving military students well, Aldrich noted a different concern: a very large drop in the number of tuition assistance users over the past several years. Aldrich said he hopes to “collaboratively resolve how to stop the staggering reduction in the number of service members getting an education.”

UMUC, meanwhile, had been assessed under a previous DoD review system, and Wilmeth said the process required staff to provide accreditation letters, school catalogues, policies and other items that they had already submitted to the DoD. Based on her understanding of the new system, Wilmeth said, it seems like the DoD is hoping to identify risk factors that could potentially affect students and isn’t out to get schools.

“With this one, I feel like they’re not out to catch you in the act of being (non)compliant,” she said. “They’re out to find out if any of us have a risk factor ... that could potentially affect student success, without it being punitive. How can we work together so students won’t be negatively impacted?”
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