Higher Education Associations Comment on Proposed Changes to DOD MOU
October 3, 2013
On September 30, NACUBO, ACE, and several other higher education associations submitted comments to the Department of Defense regarding the agency's proposed changes to rules for its voluntary education programs, including a new version of the Memorandum of Understanding. A signed MOU is required for institutions to participate in the Tuition Assistance (TA) program, as well as other service-related tuition support programs. The draft MOU continues DOD efforts to incorporate the "Principles of Excellence" that President Obama outlined in Executive Order 13607.
The NACUBO-ACE letter addresses several areas of concern, including:
- DOD's proposal that would require institutions to return TA funds using a calculation similar to the Department of Education's Return to Title IV rules.
- The requirement for institutions to follow ED's rules on misrepresentation, incentive compensation, and state authorization.
- The ban on the use of third-party lead generators.
- DOD paying only for "tuition" rather than "tuition and fees."
- Consumer information provided to service members.
NACUBO and ACE also asked for clarification on certain terms used in the MOU, including "academic institution, "degree requirements," and "evaluated educational plan."
Once DOD has reviewed all submitted comments, the agency will publish the final version of the MOU. All institutions intending to participate in the TA program, regardless of previously signed MOUs, will need to sign the final version.
Senior Policy Analyst
Vice President, Regulatory Affairs
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