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Report to the Ranking Minority Member, Committee on Veterans' Affairs, 
U.S. Senate: 

United States Government Accountability Office: 

GAO: 

March 2007: 

VA Student Financial Aid: 

Management Actions Needed to Reduce Overlap in Approving Education and 
Training Programs and to Assess State Approving Agencies: 

GAO-07-384: 

Contents: 

Letter: 

Appendix I: Briefing Slides: 

Appendix II: Comments from the Department of Veterans Affairs: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Abbreviations: 

Education: Department of Education: 
IHL: institution of higher learning: 
Labor: Department of Labor: 
NASAA: National Association of State Approving Agencies: 
OJT: on-the-job training: 
RPO: regional processing office: 
SAA: state approving agency: 
SAC: state apprenticeship council: 
VA: Department of Veterans Affairs: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 8, 2007: 

The Honorable Larry E. Craig: 
Ranking Minority Member: 
Committee on Veterans' Affairs: 
United States Senate: 

Dear Senator Craig: 

In fiscal year 2006, the Department of Veterans Affairs (VA) paid 
approximately $2.1 billion in education assistance benefits to more 
than 470,000 beneficiaries and about $19 million to state approving 
agencies (SAA) to assess whether schools and training programs offer 
education of sufficient quality for veterans to receive VA education 
assistance benefits when attending them. Qualified individuals-- 
veterans, service persons, reservists, and certain spouses and 
dependents--receive benefits through a number of education assistance 
programs for the pursuit of various types of programs, such as a degree 
program, vocational program, apprenticeship, or on-the-job training. In 
general, these programs must be approved by an SAA in order for 
qualified individuals to receive VA education assistance benefits. 
Under contracts with the VA, SAAs ensure that education and training 
programs meet federal VA standards through a variety of approval 
activities, such as evaluating course quality, assessing school 
financial stability, and monitoring student progress. 

The Departments of Education (Education) and Labor (Labor) also assess 
education and training programs for various purposes, primarily for 
awarding student aid and providing apprenticeship assistance. These 
assessments are based, in part, on evaluations against standards set by 
laws and regulations, such as those applicable to accrediting agencies. 
In 2006, under Title IV of the Higher Education Act, Education provided 
nearly $77 billion in student aid in the form of both grants and loans. 
The Department of Education assesses and certifies postsecondary 
institutions for participation in Title IV programs through various 
oversight functions to ensure that these schools meet federal 
administrative and financial requirements and that they are accredited 
and licensed. Similarly, under the National Apprenticeship Act of 1937, 
the Department of Labor is authorized to formulate and promote the 
furtherance of labor standards to safeguard the welfare of apprentices. 
To ensure programs comply with federal standards, Labor directly 
registers and oversees apprenticeship programs in less than half of the 
states and has given state apprenticeship agencies or councils in the 
remaining states such authority over their own programs. 

Given each agency's role, the potential of duplicative efforts among 
federal agencies has been a congressional concern. In 1995, GAO 
reported on this matter and concluded that there was a substantial 
amount of overlap between the efforts of SAAs and the other federal 
agencies.[Footnote 1] In light of continued congressional interest in 
this issue, we have now answered the following questions: (1) What 
changes have occurred in state approving agencies' duties and functions 
since 1995? (2) To what extent does the SAA approval process overlap 
with efforts by the Departments of Education and Labor? (3) What, if 
any, additional value do the SAA approval activities bring to VA 
education benefit programs? 

To address all three questions, we reviewed legislation, regulations, 
federal guidance, and other documents relevant to the approval 
processes for education and training programs. We also interviewed 
officials from each of the entities involved in the approval processes 
of VA, Education and Labor. Specifically, we interviewed federal 
officials from VA, Education, and Labor as well as officials 
representing three SAAs, three institutions of higher learning (IHL), 
and state apprenticeship councils in Connecticut, Maryland, and 
Washington. We also interviewed officials from one IHL that operates in 
multiple states and officials from the National Association of State 
Approving Agencies (NASAA), an accrediting agency (Accrediting 
Commission of Career Schools and Colleges of Technology), the 
Connecticut state licensing agency, and three apprenticeship programs 
(in Connecticut, Illinois, and Maryland). We selected Connecticut, 
Washington, Illinois, and Maryland based on VA's recommendation of 
knowledgeable SAA officials, to include both state and federally 
monitored states for apprenticeship programs, and geographic diversity. 
To identify the programs that were approved by the Departments of 
Veterans Affairs, Education, and Labor, we compiled and analyzed data 
on approved programs from each of the three agencies. To assess the 
reliability of the data, we talked with knowledgeable officials in each 
of the agencies, reviewed relevant documentation, and performed 
electronic testing of files. We determined that the data we have 
included in this briefing were sufficiently reliable for this purpose. 
We conducted our work from October 2006 to January 2007 in accordance 
with generally accepted government auditing standards. 

On February 1, 2007, we briefed your office on the results of our 
analysis. This report formally conveys information provided during that 
briefing, which is contained in appendix I. In summary, we reported the 
following findings: 

* Since 1995, legislative changes effective in 2001 created additional 
responsibilities for SAAs, including promoting the development of 
apprenticeship and on-the-job training programs, providing outreach 
services, and approving tests for occupational licensing.[Footnote 2] 
From fiscal years 2003 to 2006, SAA funding increased from $13 million 
to $19 million to expand services and support the additional 
responsibilities. However, funding is scheduled to decrease beginning 
in fiscal year 2008. 

* Many education and training programs approved by SAAs have also been 
approved by Education or Labor, and VA and SAAs have taken few steps to 
coordinate approval activities with these agencies. In addition, 
information is not available to determine the amount of resources spent 
on SAA duties and functions, including those that may overlap with 
other agencies and programs. 

* SAAs reportedly add value to the approval process for education and 
training programs through (1) a focus on student services for veterans 
and on the integrity of VA benefits, (2) more frequent on-site 
monitoring of education and training programs than provided by 
Education or Labor, and (3) assessments and approval of a small number 
of programs that are not reviewed by other agencies. However, VA's lack 
of outcome-oriented performance measures for evaluating SAAs makes it 
difficult to assess the significance of these efforts. 

In conclusion, while VA spends $19 million (less than 1 percent of the 
total benefit amount) to fund SAA duties and functions, it does not 
track the amount it spends on specific SAA activities, especially those 
that may also be performed by other agencies. Without knowing the 
amount of resources spent on specific duties and functions, VA does not 
have all relevant information for making resource allocation decisions 
and cannot determine if it is spending its federal dollars efficiently 
and effectively. In addition, VA, Education, and Labor have various 
standards and processes in place, in part to ensure that federal funds 
are being spent on quality education and training programs. While we 
have identified some overlap in approval efforts across agencies, the 
full extent of the overlap between SAA duties and other agencies' 
oversight efforts is unknown. It is important that VA work with other 
federal agencies to determine how the scope of the approval process 
could be streamlined to reduce overlap and ensure that federal dollars 
are spent efficiently. Finally, it is difficult to assess the 
effectiveness of SAA activities, in part because VA does not have 
outcome measures in place to fully evaluate SAA performance. Evaluating 
the effectiveness of VA's approval process is vitally important in 
order to manage the program and improve program results. 

To help ensure that federal dollars are spent efficiently and 
effectively, we are recommending that the Secretary of the Department 
of Veterans Affairs take steps to monitor SAA spending and identify 
whether any resources are spent on activities that duplicate the 
efforts of other agencies. The extent of these actions should be in 
proportion to the total resources of the program. Specifically: 

* VA should require SAAs to track and report data on resources spent on 
approval activities such as site visits, catalog review, and outreach 
in a cost-efficient manner; and: 

* VA should collaborate with other agencies to identify any duplicative 
efforts and use the agency's administrative and regulatory authority to 
streamline the approval process. 

In addition, we are recommending that the Secretary establish outcome- 
oriented performance measures to assess the effectiveness of SAA 
efforts. 

We provided a draft of this report to officials of the U.S. Department 
of Veterans Affairs for review and comment. In addition, we provided a 
draft of this report to officials of the U.S. Departments of Education 
and Labor for their technical review. In written comments on a draft of 
this report, VA agreed with our findings and recommendations and stated 
that it will (1) establish a working group with the SAAs to create a 
reporting system to track and report data for approval activities with 
a goal of implementation in fiscal year 2008, (2) initiate contact with 
appropriate officials at the Departments of Education and Labor to 
identify any duplicative efforts, and (3) establish a working group 
with the SAAs to develop outcome-oriented performance measures with a 
goal of implementation in fiscal year 2008. While VA stated that it 
will initiate contact with officials at Education and Labor to identify 
duplicative efforts, it also noted that amending its administrative and 
regulatory authority to streamline the approval process may be 
difficult due to specific approval requirements of the law. We 
acknowledge these challenges and continue to believe that collaboration 
with other federal agencies could help VA reduce duplicative efforts. 
In addition, VA may wish to examine and propose legislative changes 
needed to further streamline its approval process. 

Labor provided technical comments and we incorporated them into this 
report where appropriate. 

We are sending copies of this report to relevant congressional 
committees and other interested parties and will make copies available 
to others upon request. In addition, this report will be available at 
no charge on GAO's Web site at www.gao.gov. If you or your staff have 
any questions about this report, please contact me at (202) 512-7215 or 
scottg@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. GAO staff that made major contributions to this report are 
listed in appendix III. 

Sincerely, 

Signed by: 

George A. Scott: 
Acting Director: 
Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Briefing Slides: 

VA Student Financial Aid: Management Actions Needed to Reduce Overlap 
in Approving Education and Training Programs and to Assess State 
Approving Agencies: 

Briefing for Staff of Senator Larry Craig, Ranking Member Committee on 
Veterans' Affairs United States Senate: 

February 01 , 2007: 

Objectives: 

Since the 1940's, the Department of Veterans Affairs (VA) and its 
predecessor agencies have contracted with state approving agencies 
(SAAs) to assess whether schools and training programs offer education 
of sufficient quality for veterans to receive VA education assistance 
benefits. SAAs are created or designated by state governments but are 
federally funded and responsible for enforcing federal law. Concerns 
have been raised about whether SAA approval activities are duplicative 
of efforts conducted under other federal programs. 

Key questions: 

What changes have occurred in State Approving Agencies' duties and 
functions since 1995. 

To what extent does the SAA approval process overlap with efforts by 
the Departments of Education and Labor? 

What, if any, additional value do the SAA approval activities bring to 
veterans' education benefit programs? 

Scope and Methodology: 

To address our key questions, we: 

Reviewed legislation, regulations, federal guidance, and other 
documents relevant to the approval processes for education and training 
programs. 

Compiled and analyzed data on approved programs from the Departments of 
Veterans Affairs, Education, and Labor (DOL). 

Interviewed federal officials from VA, Education, and DOL. 

Interviewed officials representing 3 SAAs, 3 institutions of higher 
learning (IHL), and state apprenticeship councils in Connecticut, 
Maryland, and Washington. We also interviewed one IHL that operates in 
multiple states. 

Interviewed officials from the National Association of State Approving 
Agencies (NASAA), an accrediting agency (Accrediting Commission of 
Career Schools and Colleges of Technology), Connecticut state licensing 
agency, and 3 apprenticeship programs (in Connecticut, Illinois, 
Maryland). 

Our work was performed from October 2006 to January 2007 in accordance 
with generally accepted government auditing standards. 

Summary of Findings: 

Since 1995, legislative changes effective in 2001 created additional 
responsibilities for SAAs, including promoting the development of 
apprenticeship and on the job training programs, providing outreach 
services, and approving tests for occupational licensing. 

Many education and training programs approved by SAAs have also been 
approved by Education or Labor and VA and SAAs have taken few steps to 
coordinate approval activities with these agencies. 

SAAs reportedly add value to the approval process for education and 
training programs, but the lack of outcome-oriented performance 
measures makes it difficult to assess the significance of their 
efforts. 

Background: 

VA Funding for Educational Assistance Programs and SAAs: 

In fiscal year 2006, VA provided over $2.1 billion in educational 
assistance benefits to more than 470,000 beneficiaries. 

In the same year, SAAs received $19 million to assess the quality of 
schools and training programs for veterans. 

Program*: Montgomery GI Bill (Chapter30); 
Beneficiaries: 313,766; 
Expenditures: $1,909,014,605. 

Program*: Reserve Educational Assistance Program (Chapter 1607); 
Beneficiaries: 23,747; 
Expenditures: $151,397,610. 

Program*: Educational Assistance for the Selected Reserve (Chapter 
1606); 
Beneficiaries: 65,145; 
Expenditures: $48,716,031. 

Program*: Dependents and Survivors Educational Assistance Program 
(Chapter 35); 
Beneficiaries: 74,532; 
Expenditures: $38,787,332. 

Program*: Veterans Educational Assistance Program (Chapter 32); 
Beneficiaries: 575; 
Expenditures: $59,113. 

Total; 
Beneficiaries: 477,765; 
Expenditures: $2,147,974,691. 

* No payments for the National Call to Service program were made in 
fiscal year 2006. 

Source: VA. 

[End of table] 

Background: 

VA Educational Assistance Programs: 

Benefits are designed to assist individuals in gaining access to 
postsecondary education or training for a specific occupation. Benefits 
can be used to pursue a degree program, vocational program, 
apprenticeship and on-the-job training. 

Qualified individuals include veterans, service persons, reservists, 
and certain spouses and dependents. 

Background: Veteran Enrollment by Program Type in Fiscal Year 2006: 

[See PDF for image] 

Source: GAO analysis of VA enrollment data. 

[End of figure] 

Background: Agencies Responsible for the Approval Process for Education 
and Training Programs: 

[See PDF for image] 

Source: GAO Analysis. 

[End of figure] 

Background: VA's Approval Process: Purpose and Responsible Entities: 

Purpose - To ensure education and training programs meet VA standards 
for receipt of veteran education assistance benefits. 

Entities, Roles and Responsibilities: 

* VA national office oversees the 4 regional processing offices (RPOs) 
and national contract with SAAs. 

* RPOs administer the education assistance programs and process 
benefits for veterans. 

* SAAs review education and training programs to determine which 
programs should be approved and ensure schools and training providers 
are complying with VA standards. 

- Duties and functions-SAAs have 6 core duties:1) Approval of programs, 
2) Visits to facilities, 3) Technical assistance to individuals at 
facilities, 4) Outreach, 5) Liaison with other service providers, and 
6) Contract management. 

- Structure - 60 SAAs exist in the 50 states, the District of Columbia, 
and Puerto Rico. Eight states have two SAAs. SAAs are usually part of a 
state's department of education (31 SAAs). In some states, SAAs are 
organizationally located in other departments such as labor (9 SAAs) or 
veterans' services (19 SAAs).*: 

* The Washington, DC SAA office is overseen by VA. 

Background: Education's Approval Process: Purpose and Responsible 
Entities: 

Purpose -To ensure schools meet federal Education standards to 
participate in the student financial aid programs. As part of 
Education's approval process, the state licensing agencies, accrediting 
agencies, and certain offices within Education are responsible for 
various approval activities. 

Entities, Roles and Responsibilities: 

* State licensing agencies grant legal authority to postsecondary 
institutions to operate in the state in which they are located. Each of 
the states has its own agency structure, and each state can choose its 
own set of standards. 

* Accrediting agencies develop evaluation criteria and conduct peer 
evaluations to assess whether or not those criteria are met by 
postsecondary institutions. Institutions and/or programs that meet an 
agency's criteria are then "accredited" by that agency. As of November 
2005, there are 60 recognized private accrediting agencies of regional 
or national scope. 

* Office of Postsecondary Education evaluates and recognizes 
accrediting agencies based on federal requirements to ensure these 
agencies are reliable authorities as to the quality of education or 
training provided by the institutions of higher education and the 
higher education programs they accredit. 

* Office Federal Student Aid determines the administrative and 
financial capacity of schools to participate in student financial aid 
programs, conducts ongoing monitoring of participant schools, and 
ensures participant schools are accredited and licensed by the states. 

10: 

Background: Labor's Approval Process: Purpose and Responsible Entities: 

Purpose - To establish and promote labor standards to safeguard the 
welfare of apprentices. 

Entities, Roles and Responsibilities: 

* Department of Labor establishes standards and registers programs that 
meet the standards. Labor directly registers and oversees programs in 
23 states but has granted 27 states, the District of Columbia, and 3 
territories authority to register and oversee their own programs, 
conducted by State Apprenticeship Councils (SACs). Labor reviews the 
activities of the SACs. 

* SACs ensure that apprenticeship programs for their respective states 
comply with federal labor standards, equal opportunity protections, and 
any additional state standards. 

Objective One: Changes in SAA duties and functions: 

Legislative Changes Effective in 2001 Created Additional 
Responsibilities for SAAs, Including Promoting the Development of 
Apprenticeship and On the Job Training Programs, Providing Outreach 
Services, and Approving Tests for Occupational Licensing: 

In 2001, SAAs received additional responsibility for: 

Actively promoting the development of apprenticeship and on the job 
training programs. 

Conducting more outreach activities to eligible persons and veterans to 
increase awareness of VA education assistance. 

Approving tests used for licensing and certification, such as tests to 
become a licensed electrician. (For those tests that have been 
approved, veterans can use VA benefits to pay for testing fees.) 

From fiscal years 2003 to 2006, SAA funding increased from $13 million 
to $19 million to expand services and support the additional 
responsibilities. Funding will begin to decrease in fiscal year 2008. 

Objective Two: Overlap in Approval Efforts: 

Many Education and Training Programs Approved by SAAs Have Also Been 
Approved by Education or Labor and VA Has Taken Few Steps to Coordinate 
Approval Activities with These Agencies. 

Many education and training programs approved by SAAs have also been 
approved by Education and Labor. 

Similar categories of approval standards, such as student achievement 
and institutional capacity (e.g. fiscal stability), exist across 
agencies, but the specific standards within each category vary and the 
full extent of the overlap is unknown. 

VA and SAAs have made limited efforts to coordinate approval activities 
with other federal agencies. 

Information is not available to determine the amount of resources spent 
on SAA duties and functions, including those that may overlap with 
other agencies: 

Many Education and Training Programs Approved by SAAs Have Also Been 
Approved by Education And Labor: 

69% of all programs approved by SAAs are offered by institutions that 
have been certified by Education. 

78% of SAA approved programs in institutions of higher learning (e.g. 
colleges and universities) have been certified by Education. 

64% of SAA approved non-college degree programs are in institutions 
that have been certified by Education. 

Less than 2% of all programs approved by SAAs are apprenticeship 
programs. VA and SAA officials reported that many of these programs 
have also been approved by Labor. 

Similar Categories of Standards Exist Across Agencies, but the Specific 
Standards within Each Category Vary and the Full Extent of Overlap is 
Unknown: 

Similar categories of standards exist across agencies.[1]  

Categories of approval standards: Student achievement; 
SAA[2,3]: IHL/NCD: X; 
SAA[2,3]: IHL/NCD non-accredited: X; 
SAA[2,3]: Apprenticeship: X; 
SAA[2,3]: On the job Training: X; 
Education[4]: Education's certification: [Empty]; 
Education[4]: Federal Standards for Accrediting Agencies: X; 
Education[4]: Connecticut state licensing agency: X; 
Labor: Apprenticeship: X. 

Categories of approval standards: Curricula, program objectives, and 
faculty; 
SAA[2,3]: IHL/NCD: X; 
SAA[2,3]: IHL/NCD non-accredited: X; 
SAA[2,3]: Apprenticeship: X; 
SAA[2,3]: On the job Training: X; 
Education[4]: Education's certification: X; 
Education[4]: Federal Standards for Accrediting Agencies: X; 
Education[4]: Connecticut state licensing agency: X; 
Labor: Apprenticeship: X. 

Categories of approval standards: Facilities, equipment, and supplies; 
SAA[2,3]: IHL/NCD: X; 
SAA[2,3]: IHL/NCD non-accredited: X; 
SAA[2,3]: Apprenticeship: X; 
SAA[2,3]: On the job Training: X; 
Education[4]: Education's certification: [Empty]; 
Education[4]: Federal Standards for Accrediting Agencies: X; 
Education[4]: Connecticut state licensing agency: X; 
Labor: Apprenticeship: X. 

Categories of approval standards: Institutional objectives, capacity, 
and administration; 
SAA[2,3]: IHL/NCD: X; 
SAA[2,3]: IHL/NCD non-accredited: X; 
SAA[2,3]: Apprenticeship: [Empty]; 
SAA[2,3]: On the job Training: [Empty]; 
Education[4]: Education's certification: X; 
Education[4]: Federal Standards for Accrediting Agencies: X; 
Education[4]: Connecticut state licensing agency: X; 
Labor: Apprenticeship: X. 

Categories of approval standards: Student support services; 
SAA[2,3]: IHL/NCD: [Empty]; 
SAA[2,3]: IHL/NCD non-accredited: [Empty]; 
SAA[2,3]: Apprenticeship: [Empty]; 
SAA[2,3]: On the job Training: [Empty]; 
Education[4]: Education's certification: [Empty]; 
Education[4]: Federal Standards for Accrediting Agencies: X; 
Education[4]: Connecticut state licensing agency: X; 
Labor: Apprenticeship: [Empty]. 

Categories of approval standards: Recruiting and admissions practices; 
SAA[2,3]: IHL/NCD: X; 
SAA[2,3]: IHL/NCD non-accredited: X; 
SAA[2,3]: Apprenticeship: [Empty]; 
SAA[2,3]: On the job Training: [Empty]; 
Education[4]: Education's certification: X; 
Education[4]: Federal Standards for Accrediting Agencies: X; 
Education[4]: Connecticut state licensing agency: X; 
Labor: Apprenticeship: X. 

Categories of approval standards: Record of student complaints; 
SAA[2,3]: IHL/NCD: [Empty]; 
SAA[2,3]: IHL/NCD non-accredited: [Empty]; 
SAA[2,3]: Apprenticeship: [Empty]; 
SAA[2,3]: On the job Training: [Empty]; 
Education[4]: Education's certification: [Empty]; 
Education[4]: Federal Standards for Accrediting Agencies: X; 
Education[4]: Connecticut state licensing agency: [Empty]; 
Labor: Apprenticeship: X. 

Categories of approval standards: Process related requirements (e.g. 
application requirements); 
SAA[2,3]: IHL/NCD: X; 
SAA[2,3]: IHL/NCD non-accredited: X; 
SAA[2,3]: Apprenticeship: X; 
SAA[2,3]: On the job Training: X; 
Education[4]: Education's certification: X; 
Education[4]: Federal Standards for Accrediting Agencies: [Empty]; 
Education[4]: Connecticut state licensing agency: X; 
Labor: Apprenticeship: X. 

Source: GAO analysis of VA, Education, and Labor Standards: 

Note: GAO constructed these categories to encompass the numerous and 
broad range of standards used by agencies. 

[1] SAA has different sets of standards for each program type (e.g. IHL 
and NCD). Education's approval process involves different sets of 
standards used by different entities, such as accrediting agencies. 
Labor has one set of standards that is applicable to apprenticeship 
programs. 

[2] By statute, courses must meet certain criteria. These relate to: 
(1) record-keeping of student progress; (2) record-keeping of students' 
previous education; (3) quality, content and length of courses; (4) 
qualifications of administrators and instructors; and (5) equipment, 
space, and instructional materials. We categorized the first two 
criteria as student achievement, criteria (3) and (4) as Curricula, 
Program Objectives and Faculty, and criterion (5) as Institutional 
objectives, capacity, and administration. 

[3] SAA approval requirements for non-accredited courses encompass a 
number of additional criteria, such as having a tuition refund policy 
and enrollment limitations. 

[4] Connecticut's standards may not be representative of standards 
across the country. 

[End of table] 

Similar Categories of Standards Exist Across Agencies, but the Specific 
Standards within Each Category Vary and the Full Extent of Overlap is 
Unknown: 

Specific standards within each category vary across agencies. 

For example, while VA and Education's approval standards have 
requirements for student achievement, the New England Association of 
Schools and Colleges, an accrediting agency, requires that students 
demonstrate competence in various areas such as writing and logical 
thinking and VA does not have this requirement. 

Also under student achievement, VA requires schools to give appropriate 
credit for prior learning while Education does not have such a 
requirement. 

Similar Categories of Standards Exist Across Agencies, but the Specific 
Standards within Each Category Vary and the Full Extent of Overlap is 
Unknown: 

While agencies have the same standards in some instances, the 
interpretation and application of these standards may differ. For 
examples: 

VA, accrediting agencies, and Labor require that facilities have 
adequate space, equipment and instructor personnel to provide quality 
training, but the definition of adequacy differs in the level of 
specificity. 

VA and accrediting agencies require that schools have policies related 
to student achievement such as minimum satisfactory grades, but the 
requirement differs in the level of specificity. 

VA and SAAs Have Made Limited Efforts to Coordinate Approval Activities 
with Education and Labor: 

VA reported that while it has coordinated with Education and Labor on 
issues related to student financial aid and apprentices' skill 
requirements, it believes increased coordination is needed for approval 
activities in order to determine the extent of duplicative efforts. 

Most of the SAA officials we spoke with reported that they have 
coordinated with SACs to register apprenticeship programs in their 
states. 

Labor reported that it coordinated with VA's national office in several 
instances including providing a list of registered apprenticeship 
programs. 

Education reported that it does not have formalized coordination with 
VA but has had some contacts to inform VA of its concerns regarding 
specific institutions. 

Information Is Not Available to Determine the Amount of Resources Spent 
on SAA Duties and Functions, Including Those That May Overlap with 
Other Agencies: 

VA does not require SAAs to collect information on the amount of 
resources they spend on specific approval activities. 

The SAA officials we spoke with said that their most time consuming 
activity is conducting inspection and supervisory visits of schools and 
training facilities. 

Lack of data on resource allocation prevented us from determining what 
portion of funds spent by SAAs were for approval activities that may 
overlap with other agencies. 

Objective Three: Value of SAA Services: 

SAAs Reportedly Add Value to the Approval Process for Education and 
Training Programs, but the Lack of Outcome-oriented Performance 
Measures Makes it Difficult to Assess the Significance of Their 
Efforts: 

SAA and other officials reported that SAA activities add value because 
they provide enhanced services to veterans and ensure program 
integrity. 

VA uses output measures rather than outcome-oriented performance 
measures to evaluate SAA performance and progress. 

SAA and other officials reported that SAA Activities Add Value Because 
They Provide Services to Veterans and Ensure Program Integrity: 

SAA and Other Officials Reported SAAs' added value includes: 

A focus on student services for veterans and on VA benefits; 

More frequent on-site monitoring of education and training programs 
than Education and Labor; and: 

Assessments and approval of a small number of programs that are not 
reviewed by other agencies. 

The SAA Approval Activities Focus on Student Services for Veterans and 
on VA Benefits: 

SAA approval activities: 

Ensure that veterans are taking courses consistent with occupational 
goals and program requirements. 

Ensure that schools and training programs have evaluated prior learning 
and work experience and grant credit as appropriate. 

Ensure that school or program officials know how to complete paperwork 
and comply with policies required by VA educational assistance through 
technical assistance. 

States, schools, and apprenticeship officials we spoke with reported 
that without SAAs, the quality of education for veterans would not 
change; however, their receipt of benefits could be delayed and the 
time required to complete their education and training programs could 
increase. 

SAAs Generally Conduct More Frequent On-Site Monitoring of Education 
and Training Programs Than Education and Labor: 

Oversight of veterans assistance is generally more frequent than 
oversight by Education and Labor, which may prevent fraud, waste, and 
abuse. 

Some officials reported that SAAs' frequent visits were beneficial 
because they ensure schools properly certify veterans for benefits, 
ensuring that benefits are distributed accurately and quickly. 

Officials from one school reported that SAAs' visits were unnecessary 
because many schools are sufficiently monitored by their accreditors 
and Education. 

Table: 

Entity: SAA; 
Frequency of site visits to each school: 1-3 years. 

Entity: VA's RPO; 
Frequency of site visits to each school: 3 years. 

Entity: Education; 
Frequency of site visits to each school: Only schools that have 
performance issues are visited[1]. 

Entity: Accrediting agencies; 
Frequency of site visits to each school: 2-10 years[2]. 

Entity: Labor; 
Frequency of site visits to each school: 1-3+ years[3]. 

Source: GAO analysis. 

[1] Education also performs ongoing monitoring by reviewing schools' 
annual compliance audits and financial statements. 

[2] Accrediting agencies' frequencies vary depending on whether the 
agency is a national or regional agency. 

[3] Labor -See Registered Apprenticeship Programs: Labor Can Better Use 
Data to target Oversight, GAO-05-886 (Washington D.C: August 29,2005). 

[End of table] 

SAAs Approve a Small Number of Programs that Are Not Reviewed by Other 
Agencies: 

SAAs approve a small number of programs that are not reviewed by other 
agencies: 

Programs, such as cosmetology and massage training, offered by 
unaccredited schools: 

On-the-job-training programs: 

Apprenticeship programs not approved by Labor: 

VA Uses Output Measures Rather Than Outcome Measures to Evaluate SAA 
Performance and Progress: 

Although VA does have some output measures in place, such as the number 
of supervisory visits SAAs conduct, it does not have outcome-oriented 
performance measures to evaluate the overall effectiveness and progress 
of SAAs. 

Table: 

Examples of Existing VA Output Measures: Percentage of visits to 
facilities for supervisory and inspection purposes completed within VA 
specified timeframes; 
Examples of Potential Outcome Measures: Amount of benefit adjustments 
resulting from SAA's review of school certification transactions. 

Examples of Existing VA Output Measures: Number of times technical 
assistance provided to interested parties such as individuals and 
schools; 
Examples of Potential Outcome Measures: Error rate of certification 
transactions identified by SAA's. 

Examples of Existing VA Output Measures: Number of approved facilities 
with approved programs; 
Examples of Potential Outcome Measures: Completion rates of 
beneficiaries. 

Source: GAO analysis. 

[End of table] 

Conclusions: 

While VA spends $19 million (less than 1 % of total benefit amount) to 
fund SAA duties and functions, it does not track the amount it spends 
on specific SAA activities, especially those that may be performed by 
other agencies. Without knowing the amount of resources spent on 
specific duties and functions, VA does not have all relevant 
information for making resource allocation decisions and cannot 
determine if it is spending its federal dollars efficiently and 
effectively. 

VA, Education, and Labor have various standards and processes in place, 
in part to ensure that federal funds are being spent on quality 
education and training programs. While we have identified some overlap 
in approval efforts across agencies, the full extent of the overlap 
between SAA duties and other agencies' oversight efforts is unknown. It 
is important that VA work with other federal agencies to determine how 
the scope of the approval process could be streamlined, such as to 
determine the extent to which SAAs could rely on recognized 
accreditors' assessments of institutions' policies on student 
achievement to reduce overlap and ensure that federal dollars are spent 
efficiently. 

It is difficult to assess the effectiveness of SAA activities, in part 
because VA does not have outcome measures in place to fully evaluate 
SAA performance, such as the outcomes of site visits. Under the 
Government Performance Results Act, federal agencies must report on 
their results in achieving their agency program goals. Outcome-oriented 
performance measures are should be used to assess program activity. 
Evaluating the effectiveness of VA's approval process is vitally 
important in order to manage the program and improve program results. 

Recommendations for Executive Action: 

To help ensure that federal dollars are spent efficiently and 
effectively, we are recommending that the Secretary of the Department 
of Veterans Affairs take steps to monitor its spending and identify 
whether any of its resources are spent on activities that duplicate the 
efforts of other agencies. The extent of these actions should be in 
proportion to the total resources of the program. Specifically: 

VA should require SAAs to track and report data on resources spent on 
approval activities such as site visits, catalog review, and outreach 
in a cost-efficient manner. 

VA should collaborate with other agencies to identify any duplicative 
efforts and use the agency's administrative and regulatory authority to 
streamline the approval process. 

In addition, we are recommending that the Secretary establish outcome- 
oriented performance measures to assess the effectiveness of SAA 
efforts. 

[End of section] 

Appendix II: Comments from the Department of Veterans Affairs: 

The Deputy Secretary Of Veterans Affairs: 
Washington: 

February 27, 2007: 

Mr. George Scott: 
Acting Director: 
Education, Workforce, and Income Security Issues: 
U. S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Scott: 

The Department of Veterans Affairs (VA) has reviewed the Government 
Accountability Office's (GAO) draft report, VA Student Financial Aid: 
Management Actions Needed to Reduce Overlap in Approving Education and 
Training Programs and to Assess State Approving Agencies (GAO-07-384). 
VA agrees with your findings and concurs with your recommendations. The 
enclosure details VA's actions to implement Government Accountability 
Office's recommendations. 

I appreciate the opportunity to comment on your draft report. 

Sincerely Yours, 

Signed by: 

Gordon H. Mansfield: 

Enclosure: 

Department of Veterans Affairs (VA) Comments to the Government 
Accountability Office (GAO) Draft Report, VA Student Financial Aid: 
Management Actions Needed to Reduce Overlap in Approving Education and 
Training Programs and to Assess State Approving Agencies (GAO-07-384): 

To ensure that federal dollars are spent efficiently and effectively, 
GAO recommends that the Secretary of the Department of Veterans Affairs 
take steps to monitor its spending and identify whether any of its 
resources are spent on activities that duplicate the efforts of other 
agencies. The extent of these actions should be in proportion to the 
total resources of the program. Specifically: 

* VA should require SAAs to track and report data on resources spent on 
approval activities, such as site visits, catalog review, and outreach 
in a cost-efficient manner. 

Concur - VA will establish a working group with the SAAs to create a 
reporting system for approval activities with a goal of implementation 
in the FY08 budget cycle. 

* VA should collaborate with other agencies to identify any duplicate 
efforts and use the agency's administrative and regulatory authority to 
streamline the approval process. 

Concur - VA will initiate contact with appropriate officials at the 
Department of Education and Labor to identify any duplicative efforts. 
However, amending the agency's administrative and regulatory authority 
to streamline the approval process may be difficult due to the specific 
approval requirements of the law. 

* VA should establish outcome-oriented performance Measures to assess 
the effectiveness of SAA efforts. 

Concur - VA will establish a working group with the SAAs to develop 
outcome-oriented measures with a goal of implementation in the FY08 
budget cycle. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George A. Scott (202) 512-7215 or scottg@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Heather McCallum Hahn, 
Assistant Director, Tranchau T. Nguyen, Jacqueline Harpp, Cheri 
Harrington, Richard Burkard, Susannah Compton, John Mingus, and Jim 
Rebbe made key contributions to this report. 

FOOTNOTES 

[1] GAO, VA Student Financial Aid: Opportunity to Reduce Overlap in 
Approving Education and Training Programs, GAO/HEHS-96-22 (Washington, 
D.C.: Oct. 30, 1995). 

[2] Veterans Benefits and Health Care Improvement Act of 2000, Pub. L. 
No. 106-419 (2000); and Veterans Education and Benefits Expansion Act 
of 2001, Pub. L. No. 107-103 (2001). 

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