Additional Guidance Provided on Principles of Excellence
July 13, 2012
On July 13, the Department of Education issued a Dear Colleague letter (GEN-12-10) to answer questions about the expectations in Section 2 of Executive Order 13607 for colleges and universities enrolling veterans, service members, and their families. In addition, ED hosted an informal meeting for representatives of the higher education associations and the departments of Defense and Veterans Affairs to discuss concerns with the Principles of Excellence laid out in the Executive Order.
In late June, the American Council on Education and NACUBO sent a letter to the agencies detailing a number of issues with the Principles and expressing concern about the VA's request for institutions to affirm their intent to comply by June 30. In response, the VA delayed the deadline to August 1.
Agency officials indicated at the July 13 meeting that, while a further deadline extension is unlikely, institutions submitting a confirmation after August 1 will then be added to the list of conforming schools on the VA website. They also confirmed that, at present, not agreeing to comply with the Principles of Excellence has only one consequence: the school will not be listed as such on the VA website.
The Dear Colleague letter provides answers to nine broad questions covering most of the concerns raised in the ACE/NACUBO letter. The answers, although fairly general, clarify earlier responses in most areas. For instance, to meet the requirement for providing students eligible for VA and/or DoD education benefits with detailed information about costs and aid, the guidance states that institutions will be expected to use the "Know Before You Owe" model student aid offer format being developed by ED and the Consumer Financial Protection Board. The format is expected to be released this summer. The letter also provides more specifics on the meaning of providing an "educational plan" to students.
Refund Provision Still Confusing
The letter expands upon the provision in the Principles about aligning the institution's refund policy with the ED's return of Title IV funds requirement. Specifically, its states, "Postsecondary institutions that participate in the Title IV student aid programs already meet this requirement with respect to Title IV funds provided to Title IV recipients. These postsecondary institutions should treat the funds provided from the Departments of Defense and the Veterans Administration [sic] received by non-Title IV recipients in the same manner in order to voluntarily comply with EO 13607."
However, the discussion at the July 13 meeting indicated considerable confusion still exists among the agencies about how to implement the provision and whether institutions would be expected to do anything differently on a voluntary basis. DoD expects to initiate a formal process to incorporate the EO's provisions into its Memorandum of Understanding (MOU) for schools participating in DoD programs. VA representatives were uncertain how such a change would comport with VA regulations and processes.
All agency representatives agreed on the overall goal: better alignment of policies pertaining to federal education benefits across agencies. NACUBO will continue to seek greater clarity on this issue, which remains a work in progress.
Vice President, Regulatory Affairs
Senior Policy Analyst
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