NACUBO Provides Additional Details on DOD's Tuition Assistance MOU
June 2, 2014
UPDATE (7/10/14): On July 7, DOD made an edit to its May 2014 MOU. Now titled "Change 3," the edit adds a paragraph heading at 4.f.2, "Educational institutions will comply with these requirements for the return of TA funds." Even though this additional text does not change the content or intent of the MOU, DOD is giving institutions until 11:59 p.m. EDT September 5 to sign the new version.
Institutions that have already signed the May 2014 MOU do not need to sign this new version; however, they are required to sign a certification statement acknowledging they are aware of the change. Certification statements are also due to DOD by 11:59 p.m. EDT September 5.
Additionally, the FAQs on the MOU Web site have been updated.
Original News Item:
Colleges and universities that wish to participate in the Department of Defense's (DoD's) voluntary education programs have until July 23 [Note: this date was subsequently changed to September 5] to sign the newly revised memorandum of understanding (MOU). The final version was included as an appendix to final rules published in the May 15 Federal Register, along with several service-specific addenda. Many of the new provisions in the rules and MOU stem from President Obama's 2012 Executive Order 13607, "Principles of Excellence for Educational Institutions Serving Servicemembers, Veterans, Spouses, and Other Family Members."
Last year, DoD released a revised MOU for participation in the voluntary education programs, including Tuition Assistance, but warned at that time that a new version incorporating the Principles of Excellence would be forthcoming. Regardless of any previously signed versions, all institutions wishing to participate in the TA program must sign this new MOU, which will remain in effect for five years.
The Federal Register notice does not specifically set the deadline for signing the new MOU, just that it will be no earlier than 60 days after publication. DoD sets July 23 [Note: this date was subsequently changed to September 5] as the deadline in its FAQs. The president of the home campus of each educational institution must sign the revised DoD MOU.
This clears up some confusion, as the text in the final rules did not match the text of the MOU. NACUBO's interpretation is that the text in the rules applies to the first signing of the new MOU, while the text within the MOU relates to subsequent renewals and signings, as DoD intends for the text of the MOU to remain unchanged for several years.
Tuition and Fees
While not mentioned directly in the MOU itself, the final rules note that covered charges only include tuition, not fees. In the preamble, DoD acknowledges the differences between institutions in how various charges are labeled and explains that it has modified the rule to promote transparency. "Educational institutions that bundle tuition, fees, or books into a consolidated cost must detail the charges of fees and books separately for servicemembers participating in the TA program," DoD explained in the rules. Fees are defined as charges not directly related to course instruction and examples are included. This restriction may impact community colleges and some low-cost public institutions. With the current cap set at $250 per credit hour, though, this may not have a practical effect at schools with higher charges.
The new rules also prohibit TA funds from being used to purchase books, including "textbooks, ebooks, CDs/DVDs, or reference or instructional materials."
Additionally, the MOU requires institutions to disclose tuition charges to the Service branches for each degree program. If there is a change in tuition, the institution must notify the Services at least 90 days before the change is implemented and provide an explanation. Understanding that tuition rates could be changed at public institutions at the last minute by state legislatures, the MOU allows those institutions to request a waiver, via dodmou.com.
Return of TA Funds
Originally, DoD had proposed that institutions adopt the Department of Education's Return to Title IV regulations when returning unearned TA dollars. NACUBO expressed concern with the complexity of this requirement in comments submitted to DoD when the rules were in draft form. In the final version, the department requires intuitions to return any unearned TA funds "on a proportional basis through at least the 60 percent portion of the period for which the funds were provided" when a servicemember fails to complete a course. DoD considers each course its own "enrollment period," so institutions would use the pro-rata refund on a course-by-course basis. Neither the MOU nor the regulations provide details on the procedures institutions should follow for returning funds to the Services; specific instructions will presumably be shared in the coming months.
Additionally, when a servicemember stops attending a course due to a service obligation, DoD asks institutions to "work with the affected servicemember to identify solutions that will not result in a student debt for the returned portion." While many NACUBO members already try to accommodate servicemembers in such scenarios, it is worth noting that this is new to the text of the MOU.
Other Administrative Requirements
As campus leaders consider signing the MOU, it is important to note that its requirements are quite expansive and will impact numerous campus offices, not just military affairs or the business office.
Provide Tools to Prospective Military Students
Institutions must provide prospective military students with several informational items prior to enrollment, including information to "locate, explain, and properly use" the College Scorecard, College Navigator, the Financial Aid Shopping Sheet, and the "Paying for College" Web site. The Financial Aid Shopping Sheet is of particular interest to a number of institutions that have not adopted it. The language does not specifically state that an institution is required to use the tool. NACUBO interprets this to mean that an institution satisfies the requirements in the MOU by simply directing prospective students to ED's Financial Aid Shopping Sheet Web site.
Evaluated Educational Plans
When a servicemember changes his or her educational goal or major and the Service's education advisor approves the change, the institution will need to "provide a new evaluated educational plan to the servicemember and the service within 60 days." Only courses listed in the servicemember's evaluated educational plan will be approved for TA. An "evaluated education plan" is an individualized document provided by an institution that articulates all degree/program requirements, identifies all courses required for graduation, and includes an evaluation of all successfully completed prior coursework - and evaluated credit for military training and experience - and other credit sources applied to the institutional degree requirements.
Academic and Student Support
Complying with Executive Order 13607, the MOU now requires institutions to provide academic and student support services specific to the institutions' programs to all enrolled servicemembers, spouses, and adult family members. A specific point of contact or office for academic and financial advising should be established, though the point of contact does not need to be exclusively dedicated to providing these services. Students may be referred to different offices or individuals that are better suited to assist the servicemember.
A potentially burdensome requirement was added in Appendix C, the addendum between the Army and institutions. The language calls for institutions to "adopt the GoArmyEd processes." These processes often change and institutions will need to stay current on the duties outlined which encompass academic advising, uploading catalogues and schedules, posting grades, and other activities. A similar requirement is in the Air Force addendum, Appendix B.
In the proposed language, the Air Force would have required institutions to accept the government purchase card for payment of TA, with no waivers allowed. The Air Force addendum in the final rules partially reinstates the waiver by requiring institutions to adopt procedures from the Academic Institution Portal for all payment processing but notes that institutions with a current waiver may be able to continue receiving payment by an alternative method at the discretion of the Air Force.
Senior Policy Analyst
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