Federal Resources and Actions:

Veterans Education Success advocates for military-connected students by pressing federal agencies to do the right thing.  Below are some key federal agency rules for colleges (some of which we helped design) as well as our current advocacy at the agencies.

RULES FOR COLLEGES

VA Rules for Colleges & Resources

Defense Department Rules for Colleges

Defense Department rules for school participation in Tuition Assistance:  DOD MOU

Education Department Rules for Colleges

AGENCY ACTIONS

Veterans Education Success advocates for military-connected students when federal agencies like VA, the Defense Department, and the Education Department take action against colleges that have defrauded students.  Some examples of agency actions are listed here:

Consumer Financial Protection Bureau puts Military Lending Act at risk

The US Consumer Financial Protection Bureau (CFPB) reportedly plans to curtail the enforcement of the Military Lending Act (see National Public Radio:  White House Takes Aim at Financial Protections for Military and New York Times: Mulvaney Looks to Weaken Oversight of Military Lending). Veterans and military groups responded: 

  • Nearly 40 veterans and military service organizations call on the CFPB and US Defense Department to stop the rollback of servicemembers' rights under the Military Lending Act (Aug. 23, 2018) (click here) 

  • Resubmitted Sept. 5 with additional signatures (click here)

  • FULL PAGE NEWSPAPER AD nationwide (click here)

  • Sign the Citizens petition: KeepMilitaryProtections.Org

  • Same letter borrowed submitted by a smaller, additional coalition (click here)

  • US Senators also write to US Defense Department (click here)

  • US Defense Department response (click here)

  • American Legion’s Louisiana Commander confronts CFPB’s Mulvaney at a Louisiana Town Hall (click here)

  • Bipartisan group of 33 state Attorneys General wrote CFPB urging it to enforce the Military Lending Act and protect servicemembers (click here)

US Federal Trade Commission

Most of VES’ work with law enforcement agencies like the US Federal Trade Commission (FTC) is confidential. Here’s what’s public:

FTC’s Crackdown on Fake Military Websites

VES brought to FTC’s attention fake military websites that pretended to be where Americans could join the Armed Forces, but never gave the information to the Armed Forces, instead selling patriotic Americans’ personal information to bad actor colleges that bombarded them with deceptive and aggressive recruiting. Some of the websites even wrongly promoted certain bad actor colleges as endorsed by the military.

  • VES’ FOIA request to the US Federal Trade Commission requesting the names of colleges that participated in fake military websites (Nov. 28, 2018) (click here)

  • 28 Veterans and Military Leaders, led by VES, ask US Federal Trade Commission to release the names of the schools that participated in fake military recruiting websites (Nov. 19, 2018) (click here).

  • Veterans and Military Leaders, led by VES, ask US Congressional Armed Services Committees to ensure future military recruitment is not disrupted by fraudulent college lead generator companies (Nov. 20, 2018) (click here).

  • September 6, 2018:  Federal Trade Commission shuts down predatory fake military websites (Army.Com, Air-Force.com, ArmyEnlist.com, NavyEnlist.com, AirForceEnlist.com, MarinesEnlist.com, NationalGuardEnlist.com, AirGuardEnlist.com, and CoastGuardEnlist.com) (click here)

FTC’s Crackdown on “Military Friendly Schools”

VES brought to FTC’s attention the problem of a company’s “Military Friendly Schools” scheme, wherein it charged schools for the designation of “Military Friendly Schools” and also sent aggressive and deceptive e-mail solicitations to servicemembers and veterans on behalf of schools that paid.

VA Actions

VBA Policy Advisory to SAAs “Acceptance of Certifications by Other Appropriately Authorized Agencies or Offices that Applicable Standards Have Been Met” (Aug. 30 2018)

VA’s Obligation to Stop Colleges’ Deceptive Recruiting

VES has been pushing VA for years to stop colleges’ deceptive recruiting. VES helped bring to VA’s attention a Vietnam-era statute, 38 USC 3696, that requires VA to cut off GI Bill funding to schools that engage in deceptive recruiting. Since then, we continue to prod VA to comply with the law. One small step has been VA’s signing an agreement with the US Federal Trade Commission to get its help understanding deceptive recruiting.

VA Proposes to Waive Ethics Rule for VA Employees (September 14, 2017) (click here) and May 2018 revision (click here).  

When the Department of Veterans Affairs announced a rule to waive federal ethics rules to specifically allow for-profit colleges to give gifts, money, stock options, salaries and more to VA employees, Veterans Education Success alerted and worked closely with ethics experts, veterans & military groups, consumer and education groups, and the VA employees' labor union to organize opposition letters.

VES also engaged with the Congressional Veterans Affairs Committees on a bipartisan legislative solution, which cleared Congress in September 2018, as section 302 of S.3469 (click here).

Opposition letters to VA Proposals:

  • 42 federal ethics experts, national veterans and military service organizations, and consumer protection and education experts (June 20, 2018) (click here)

  • 21 national veterans and military service organizations (Oct. 13, 2017) (click here)

  • Individual veterans at for-profit colleges share their experiences and object to VA's proposal (click here)

  • Veterans Education Success (providing important historical and legal information) (Oct. 13, 2017) (click here)

  • 21 education, civil rights, and consumer organizations (Oct. 13, 2017) (click here)

  • Walter Shaub, former Director of the Office of Government Ethics, and Campaign Legal Center (Oct. 12, 2017) (letter here)

  • Center for Responsible Ethics in Washington, signed by the White House Ethics Directors for George W. Bush and Barack Obama, and others (Oct. 12, 2017) (click here)

  • American Federation of Government Employees, representing VA employees (Oct. 12, 2017) (click here)

  • Service Women's Action Network (click here)

  • Consumer organizations (Oct. 11, 2017) (press release here; letter here)

  • Student Veterans of America (Oct. 9, 2017) (click here)

  • Veterans Student Loan Relief Fund (Oct. 14, 2017) (click here)

  • U.S. Senators Murray, Brown, Durbin and Warren (Oct. 5, 2017) (news release here, letter here)

  • U.S. Senator Carper (Oct. 6 2017) (click here)

  • The Century Foundation (Oct. 5, 2017) (click here)

Ashford University

Veterans Education Success is closely monitoring Ashford University's attempts to maintain GI Bill access in light of Ashford's significant consumer fraud against students and attempts to deceive VA:

  • VA’s suspension of California as a State Approving Agency, based in part on California’s refusal to act on Ashford and on California’s disapprovals of other schools (Sept. 6, 2019) (click here)

  • California’s response to VA regarding the need to act on Ashford’s application (Jan. 2019) (click here)

  • VA letter to California regarding the need to act on Ashford’s application (Jan. 2019) (click here)

  • California declines to act on Ashford’s second request for approval to serve GI Bill students (Dec. 14, 2018) (click here)

  • Ashford petitions US Court of Appeals for the Federal Circuit for an extension of time to file a motion while negotiations with VA continue over state approval (Dec. 7, 2018) (click here)

  • VA’s letter to California regarding its performance as a State Approving Agency especially regarding its disapproval of some schools (Aug 24, 2018) (click here)

  • VA’s policy advisory to all State Approving Agencies directing them to not change a school’s approval status based on accreditor probations and other interim government actions (Aug. 30, 2018) (click here)

  • California response to VES’ FOIA request showing US Department of Veterans Affairs employees who have a conflict of interest because they are also on payroll at Ashford (April 4, 2018) (click here)

  • California declines to act on Ashford's request for approval to serve GI Bill students (Feb. 21, 2018) (click here)

  • California Attorney General sues Ashford for deceptive recruiting and marketing and abuses of students in financial products (Nov. 29, 2017) (click here)

  • Ashford sues VA (Nov. 21, 2017) (click here)

  • Senators' Letter urging Defense Secretary Mattis to warn Servicemembers attending Ashford and to cease new enrollments (Nov. 21, 2017) (click here)

  • Senators' Letter urging VA Secretary Shulkin to warn GI Bill students attending Ashford (Nov. 21, 2017) (click here)

  • Student Veterans of America cautions students about continued enrollment at Ashford University (Nov. 20, 2017) (click here)

  • VA Announces Potential Probation of Ashford (Nov. 9, 2017) (click here)

  • VA Letter to Ashford Denying Arizona as "main campus" (Nov. 9, 2017) (click here)

  • VA Notice to GI Bill Students at Ashford (Nov. 9, 2017) (click here)

  • VES Report: Ashford’s Fight to Maintain GI Bill Access Raises Questions about the Enforcement and the Adequacy of Statutory Requirements (Nov. 9, 2017) (click here)

  • VES Compilation of a Sampling of Ashford Student Veteran Complaints (click here)

  • Chronicle of Higher Education expose: "Inside the Scramble to Save Ashford U: How Political Maneuvering Kept GI Bill Funds Flowing to a For-Profit University" (Nov. 9, 2017) (click here) (pdf here)

  • Bridgepoint Company response to VA action (Nov. 9, 2017) (click here). Bridgepoint SEC filing (Nov. 14, 2017) (click here).

  • VA Letter to Ashford re: Iowa and Arizona facility codes (Sept. 13, 2017) (click here)

  • VA Letter to Arizona SAA denying approval of Ashford (Aug. 3, 2017) (click here)

  • VA Letter to Arizona SAA continuing to deny approval of Ashford (Aug. 17, 2017) (click here).

  • Arizona SAA approval of Ashford (July 6, 2017) and VA's response (click here)

  • Arizona's Application Form for an Out of State License (click here) (Arizona's licensure procedure and requirements, click here)

  • VA Alert to Students: Ashford University Update -- You can continue to attend Ashford beyond August 16th (Aug. 4, 2017) (click here).

  • Ashford e-mail to students (July 26, 2017) (click here). Other Ashford e-mails to students here.

  • VA Alert to Students: Critical Information for Students Attending Ashford University on the GI Bill (July 20, 2017) (click here).

  • Iowa District Court Rejects Ashford University's Claims, Effectively Pushing it Out of GI Bill (July 17, 2017) (click here)

  • VA Alert to Students: Information for Students Attending Ashford University on the GI Bill (June 6, 2016) (click here)

  • Ashford CA SAA Application (table of contents click here) (full contents, click on each Part #: Part 1, Part 2, Part 3, Part 4, Part 5, Part 6, Part 7, Part 8, Part 9, Part 10, Part 11, Part 12, Part 13, Part 14, Part 15, Part 16, Part 17, Part 18, Part 19, Part 20, Part 21, Part 22, Part 23, Part 24, Part 25, Part 26)

  • 2015 Consent Order by US Consumer Financial Protection Bureau for Ashford's deceiving students about its institutional loan scheme (click here).

ECPI:

ITT Tech:

DeVry

University of Phoenix:

Other Schools:

Other News:

VA Outreach

Veterans Education Success was pleased to be invited to collaborate with VA on VA's important video "Know Before You Go"

Defense Department Tuition Assistance Actions

University of Phoenix Placed on Probation (2015)

  • Letter from veterans and military organizations thanking the Defense Department and urging strong enforcement of DOD rules for colleges (click here)

Education Department Actions

Disabled veterans’ right to student loan forgiveness: VES has been pushing the US Education Department to honor disabled veterans’ statutory (legal) right to student loan forgiveness.

  • VES sent a Freedom of Information Act request to the US Education Department. The Department’s answer is here. It shows that half of disabled veterans who are eligible for loan forgiveness are already in default. This means the Education Department is wrongly allowing disabled veterans to go into default on student loans that should rightfully have already been erased. Even worse, once a disabled veteran is in default, VA can withhold the veteran’s monthly disability living allowance.

  • Letter from VES and other veterans and military organizations to the US Education Department requesting automatic loan forgiveness for disabled veterans (click here).

Students’ Rights to Loan Relief if They Were Defrauded by a School: VES fights for defrauded veterans to get their student loans forgiven by the Education Department, and their Pell Grants restored.

  • September 2018: US Federal Court Orders US Education Department to stop delaying and diminishing student loan relief for defrauded students (click here. More information on the case here)

  • Fall/Winter 2017-2018: VES Research Director Walter Ochinko was an official negotiator representing veteran and military students on the negotiated rulemaking panel on Borrower Defense (click here), just as he was on the 2016 panel.

  • October 4, 2017 Public Hearing on Regulatory Reform at the Education Department:

  • Testimony of Tanya Ang, Veterans Education Success (written testimony here and video here and here)

  • Testimony of Will Hubbard, Student Veterans of America (written testimony here and video here and here)

  • Testimony of Bethany Keirans, Vietnam Veterans of America (written testimony here and video here)

  • Testimony of Melissa Bryant, Iraq and Afghanistan Veterans of America (written testimony here and video here and here)

  • Testimony of Sean Marvin, Veterans Education Success (written testimony here and video here)

  • Testimony of Heather Donnithorne, Blue Star Families (written testimony here)

  • September 2017 Nomination Letter from 29 Leading Veterans & Military Service Organizations for the Veterans/Military Representatives on the US Education Department's Borrower Defense & Gainful Employment Rulemaking Panels (click here)

  • September 2017 Public Comment from 34 Leading National Veterans & Military Service Organizations Urging Betsy DeVos Not to Rollback Student Protections (click here)

  • Public Comment from 33 Leading National Veterans Service Organizations and Military Service Organizations (click here)

  • July 10 and July 12, 2017 Public Hearings on Education Department Announcement to Cancel and Revise Student Protections:

    • Testimony of Sean Marvin, Legal Director, Veterans Education Success (written testimony here and video here at minute 00:31:33)

    • Testimony of Army veteran Ryan Clark (written testimony here and video here at minute 00:29:00)

    • Testimony of Navy veteran Kevin Thompson (written testimony here, video here, and interview here)

    • Testimony of Walter Ochinko, Veterans Education Success (written testimony here and video here at minute 00:00:40)

    • Testimony of Will Hubbard, Student Veterans of America (written testimony here and video here)

    • Testimony of John Kamin, The American Legion (written testimony here and video here)

    • Testimony of Congressman Mark Takano, Member of the House Veterans Affairs Committee (written testimony here and video here at minute 00:41:00)

    • Testimony of Bethany Keirans, Vietnam Veterans of America (written testimony here and video here at minute 00:58:10)

    • Testimony of Heather Donnithorne, Blue Star Families (written testimony here and video here at minute 1:52:00)

    • Testimony of Anthony Hardie, Veterans for Common Sense (video here at minute 2:22:00)

Integrity and Minimum Quality by Colleges: Some authorities seek to make it easier for bad actor colleges to bilk taxpayers and students. VES fights back for rules requiring colleges to abide by basic integrity and honesty rules and to meet minimum quality standards.

  • March 25, 2019, Public Testimony at Education Department Negotiated Regulatory Rulemaking Panel regarding minimum quality control rules and student protections:

    • Testimony of Tom Corbett, former Campus President for ITT Technical Institutes and Air Force Veteran (testimony here; video of testimony Part I here and Part II here, and preview video here)

    • Testimony of Student and Army Veteran Stephanie Stiefel (testimony here; video of testimony here and preview video here)

  • February 20 and 21, 2019, Public Testimony at Education Department Negotiated Regulatory Rulemaking Panel regarding minimum quality control rules and student protections:

    • Testimony of Luke Opyd, Veterans Education Success (tweet here and video here)

    • Testimony of Travis Horr, Iraq and Afghanistan Veterans of America (tweet here)

    • Testimony of Ashlynne Haycock, Tragedy Assistance Program for Survivors (tweet here and video here)

    • Testimony of John Kamin, The American Legion (tweet here and here; video here)

  • Public Comment by VES against the Education Department’s proposal to completely rescind the requirement that career college programs meet minimum Gainful Employment metrics (Sept. 13, 2018) (click here)

  • Find out which colleges “fail” the minimum gainful employment standards: Visit https://studentaid.ed.gov/sa/node/274, then click on "Download the debt-to-earnings data spreadsheet,” then filter the column that has PASS/FAIL/ZONE in it to show the failing programs. 

  • Public comment from 28 veterans and military service organizations urging the Department to maintain strong integrity rules against waste, fraud, and abuse, and to expand competency-based education (Sept. 14, 2018) (click here)

  • Testimony at Education Department public hearing in Washington, DC (Sept. 6, 2018):

    • Testimony of VES Vice President Tanya Ang (click here) (photo here) (video here)

    • Testimony of Army veteran Jarrod Thoma (click here) (video and tweets here)

    • Testimony of military spouse Mindy Thoma (click here) (video and tweets here)

  • Testimony at Education Department public hearing in New Orleans, Louisiana (Sept. 11, 2018):

    • Testimony of VES Legal Advocacy Director Mike Saunders (click here) (photo and tweet here; video tweet here)

    • Testimony of Army Sgt Renee Seruntine (click here) (video and tweets here)

  • Testimony at Education Department public hearing in Wisconsin (Sept. 13, 2018):

    • Testimony of VES Veteran Engagement Director Tyson Manker (click here) (video and tweets here)

Summer 2018:  State Oversight Rules:  VES' public comment urging the Education Department not to postpone implementation of State Authorization rules (June 2018) (click here)

Accreditation and Accreditors: VES fights for high quality standards by accreditors and exposes lax accreditors for approving fraud mills posing as colleges.

  • Spring 2018:  Accreditor oversight:  VES submits public comment regarding oversight of college accreditors to US Education Department's National Advisory Committee on Institutional Quality and Integrity (May 2018) (click here)

  • The Accrediting Council for Independent Colleges and Schools (ACICS):

ITT Technical Institutes: VES represented veterans who were defrauded by ITT Tech. The Education Department finally acted in 2016 against ITT’s frauds:

Education Dept. Data

U.S. Education Department Integrated Post-Secondary Education Data System (IPEDS):  Decision regarding Collecting Data from Colleges on Veteran Enrollment (Technical Review Panel #36: Collecting Data on Veterans)

U.S. Education Department announces data-sharing with US Department of Veterans Affairs (Nov. 10, 2016) (here)

 

Matt Mitchell, a student veteran, and Sara nolan collins, legal services director, testify at naciqi meeting concerning acics accreditation

Matt Mitchell, a student veteran, and Sara nolan collins, legal services director, testify at naciqi meeting concerning acics accreditation