VA Principles of Excellence Request Raises Concerns
June 4, 2012
The Department of Veterans Affairs has started sending letters asking institutions to commit to comply with the "Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members" outlined in an Executive Order issued in May. The letter is being sent out by the agency's network of state approval agencies. It is not clear whether it is addressed to the college or university president or to the VA certifying official on campus. The VA letter directs institutions to send an email message by June 30 indicating whether or not the school agrees to comply by the end of 2012-13 academic year. Institutions with multiple or branch campuses may send a single, consolidated response from the main campus. A list of institutions agreeing to comply with the principles will be posted on the VA Web site.
NACUBO believes that this request is premature. The Executive Order directs the relevant federal agencies to develop principles of excellence and was not written in sufficient detail to serve as compliance requirements. NACUBO recommends that colleges and universities hold off on responding until clarification is provided. The VA has scheduled webinars for June 7 and 8.
NACUBO's concerns with the Executive Order were laid out in recent testimony before a House subcommittee. Specifically, the testimony highlighted the need for further clarification on the Executive Order's requirements to:
- Provide prospective students who are eligible to receive VA and DOD tuition benefits, prior to enrollment, an individualized standard form with cost and financial aid information (using a prototype of the standardized financial aid award letter being drafted by the Department of Education (ED) and the Consumer Financial Protection Bureau (CFPB)).
- Take steps to accommodate short term absences and allow service members and reservists to be readmitted to a program if they are temporarily unable to attend class.
- Agree to an institutional refund policy aligned with the rules for unearned student aid promulgated by ED. It is not clear whether this would apply to all charges or just to VA benefits.
- Provide educational plans for all individuals using federal military and veterans' educational benefits.
Until additional guidance is provided on these issues, NACUBO recommends institutions delay any action. The consequence of declining to commit at this time appears to be omission from the list on the VA Web site of institutions that have agreed to comply. NACUBO, in concert with other associations representing institutions, will continue to seek further clarification from VA and the other federal agencies involved.
The Department of Defense, VA, ED, CFPB, and the Federal Trade Commission have scheduled webinars on June 7 and 8 to provide further details on the principles of excellence. Participants will be able to submit questions to the presenters in advance. Each webinar is limited to 1,000 participants, so institutions should register as soon as possible.
Due to high demand, an additional webinar has been scheduled for Friday, June 15th from 10:00am-11:30 Eastern. Advance registration is required. Attendees are encouraged to log in to the webinar early on the 15th to make sure they can properly connect.
Vice President, Regulatory Affairs
Senior Policy Analyst
- NACUBO Expresses Concerns with ED Proposal to Expand Federal Financial Responsibility Rules
- IRS Proposes Modifications to 1098-T Reporting
- ED Policy to Require Annual Student Aid Compliance Audits Beginning FY17
- 2016 Planning and Budgeting Forum
September 19-20, 2016
- 2016 Big Opportunities for Small Institutions
September 20-21, 2016
- 2016 Tax Forum
September 25-27, 2016
- ON-DEMAND: The CBO's Role in Diversity and Inclusion on Campus
- ON-DEMAND: The Clery Act: Strategic Planning to Mitigate Institutional Risk
- ON-DEMAND: Title IX: Key Issues Surrounding Institutional Compliance
- ON-DEMAND: NACUBO Live! Higher Education Accounting Forum
- ON-DEMAND: Responsibility Center Management: Two Different Perspectives