An Increase in “Bad Paper” Discharges Since 9/11 Leaves Many War Veterans Without Help

New report highlights how veterans with higher needs may be adversely impacted

PROVIDENCE, R.I. [Brown University] – A new report released this week examines the lives of war veterans who are issued “bad paper,” or Other Than Honorable discharges from the military, leaving them ineligible to receive veterans’ benefits and support. Compiled by the Costs of War Project based at Brown University’s Watson Institute for International and Public Affairs , the report speaks to current policy reforms aimed at these veterans, and contends that current policy proposals will not go far enough to tackle the issue.

Other Than Honorable (OTH) discharges, while not the only type of “bad paper,” are the most common. They often result from minor forms of misconduct stemming from trauma sustained during military service, and they prevent veterans from receiving needed healthcare, education, housing support, and other resources from the U.S. Department of Veterans Affairs (VA). The research, conducted by Ali R. Tayyeb, PhD, a Navy veteran and Jonas Veterans Healthcare Scholar, and Watson Institute postdoctoral fellow Jennifer Greenburg, PhD, notes that such discharges “have seen a sharp spike since 9/11, with almost six percent of the entire veteran population of this era excluded from care.”

“Veterans with ‘bad papers’ in fact may be among those veterans with higher needs for postwar assistance, being over-represented in studies on veteran Post-Traumatic Stress Disorder, Traumatic Brain Injuries (TBI’s), suicide, drug and alcohol abuse, military sexual assault/trauma, and related problems of incarceration and homelessness,” Tayyeb and Greenburg write. “Advocacy by veteran and legal groups, a national spotlight focused on veteran suicide, and media coverage of the excluded population have all led to the VA’s admission of its improper exclusion of veterans and announcement of its intention to expand services.”

For years “bad paper” war veterans have been denied basic benefits and support after being released from the military. In March 2017, Secretary of Veterans Affairs David Shulkin announced measures to address this problem. However, Tayyeb and Greenburg argue, “reforms under consideration fall short of actually making the VA accessible to ‘bad paper’ veterans.” The proposed reforms are far too limited, focusing solely on emergency mental health services to the exclusion of basic healthcare and other support like housing, job training, and education. Moreover, the VA’s plans simply codify a number of things the VA already does for all veterans (even those with “bad paper”) experiencing mental health crises. This report sheds light on an often invisible policy that makes returning to civilian life far more difficult for war veterans.




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VCS Expresses Concern about End to VA Data Report

(Washington, DC – June 9, 2017) — In a news story published this week, Veterans for Common Sense expressed concern regarding plans by the U.S. Department of Veterans Affairs (VA) to end a national data report used internally and by veterans advocates to monitor progress achieving timely processing of veterans disability claims.

According to the Boston Herald story, the VA “has stopped updating a performance database that charts error rates at local offices — a system vets advocates say was a useful tool to hold the agency accountable, including at the Boston office.”

“The system, called ASPIRE, was introduced with fanfare in 2010 as a way to hold the VA up to a higher standard for avoiding the kinds of errors and oversights that cause wounded ex-warriors to get inaccurate disability ratings, denying them vital compensation.”   (“VA ditches error-rate database,” Boston Herald, June 6, 2017, Jack Encarnacao reporting).

VCS is quoted in the story:

“The ASPIRE report is just a very nice way to summarize some of the top-level data,” said Anthony Hardie, director of the D.C. advocacy group Veterans for Common Sense. “The ­ASPIRE report should not be going away unless it’s replaced by something better and far more comprehensive.”

“If we suddenly have the VA locking down data and not providing it anymore for whatever reason, then very quickly veterans are negatively affected,” Hardie said.

The VA announced ASPIRE in November 2010 as “part of the continuing effort of the federal government to become more transparent and accountable to the public.” In a post on its website announcing the system, the VA declared the “implications for the ASPIRE data reside in tomorrow, not today.”

According to the Herald reporting:

“Given how little ASPIRE has been used the last two years by our external customers, VA has no plan to repopulate it,” [a VA] spokeswoman said, pointing to a weekly VA summary, the Monday Morning Workload Report, that contains similar data. “Rather, we are considering other graphical approaches together with a possible modernization of the Monday MMWR.”

Read the full story here:

Read the full story as published in Government Technology:

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VCS Calls for Continued Defense Medical Research Funding

(Washington, June 8, 2017) – Veterans for Common Sense today joined with more than 100 organizations in calling on Congress to provide continued support for the “critical and highly successful defense health research programs” of the Congressionally Directed Medical Research Programs (CDMRP) directed and funded by Congress within the U.S. Department of Defense (DoD) budget.

CDMRP medical health research programs include the Gulf War Illness Research Program (GWIRP), a unique, nationally acclaimed program aimed at developing treatments for the complex, debilitating disease that affects as many as one-third of the veterans of the 1991 Gulf War following their exposure to combinations of military toxins.  VCS is the national leader in advocating for the GWIRP, including helping to ensure annual Congressional funding and enduring strong support among the nation’s veterans service organizations.  VCS also sponsors consumer reviewers involved in steering and advising the GWIRP.

VCS is also a strong advocate for the burn pit exposure research area within the CDMRP’s Peer Reviewed Medical Research Program.  VCS is strongly supportive of numerous other areas of key medical research funded by CDMRP, including cancers, neurological diseases, traumatic brain injury (TBI), post-traumatic stress disorder (PTSD), and many more.

Veterans for Common Sense (VCS) is a Washington, DC-based veterans education and advocacy organization.  VCS is also a leading member of the Defense Health Research Consortium (DHRC), a membership coalition of national patient advocacy organizations, medical provider organizations, professional medical societies, and veterans advocacy groups including VCS. Veterans and other patients represented by these groups have benefited significantly from the cutting-edge medical research funded by these defense health research programs.

The full text of today’s pair of letters to House and Senate appropriators is as follows:


The Defense Health Research Consortium

June 8, 2017

Senator Thad Cochran                                                 Senator Richard Durbin
Chairman                                                                        Ranking Member
Subcommittee on Defense                                           Subcommittee on Defense
Committee on Appropriations                                     Committee on Appropriations
122 Senate Dirksen Building                                      113 Senate Dirksen Building
Washington, DC 20510                                              Washington, DC 20510

Dear Chairman Cochran and Ranking Member Durbin:

The Honorable Kay Granger                                       The Honorable Peter Visclosky
Chair                                                                           Ranking Member
Subcommittee on Defense                                           Subcommittee on Defense
Committee on Appropriations                                     Committee on Appropriations
H-405 Capitol Building                                               1016 Longworth House Office Bldg
Washington, DC 20515                                              Washington, DC 20515

Dear Madame Chairman Granger and Ranking Member Visclosky:

As you begin work on the Fiscal Year 2018 (FY18) Defense Appropriations bill, we write to request your continued support for the critical and highly successful defense health research programs funded through the Congressionally Directed Medical Research Programs (CDMRP) at the Department of Defense (DoD).  We deeply appreciate your support in a challenging fiscal environment for these programs during the FY17 budget process.  As in previous years, you both exhibited extraordinary leadership in ensuring continuity in funding and operations for defense health research programs.

The highly innovative research portfolio supported by the CDMRP fuels scientific discovery by funding high impact research not sponsored by the National Institutes of Health (NIH), the Department of Veterans Affairs (VA) and other federal agencies. Many of the programs’ award mechanisms propel the exploration of revolutionary ideas and concepts, and focus on the potential of having a significant impact upon both their respective fields of research and support and treatment for members of the military.  Defense health research programs are worthy of continued federal support for the following reasons:

  • Directly relevant to DoD-prevalent conditions: The medical research programs at DoD directly impact the health and lives of the U.S. military, their families, veterans and the public. Programs provide groundbreaking research on psychological health, Gulf War Illness, spinal cord injury, and hearing and vision loss (which comprise a significant portion of current battlefield injuries). Research also focuses on infectious diseases that may threaten operational readiness and health security, and why diseases like ALS and multiple sclerosis occur at greater rates in those who have served in the military.  The DoD’s defense health research program has also funded the orthopedic research program that has resulted in new limb-sparing techniques to save injured extremities, avoid amputations, and preserve and restore the functions of injured extremities.

Equally important, this disease-specific approach includes important medical research programs related to several forms of cancer (breast, blood, colorectal, kidney, melanoma, pancreatic, brain tumors, lung, ovarian, prostate, stomach, liver and cancers related to radiation exposure) and other disorders (like neurofibromatosis and tuberous sclerosis complex) that have led to breakthroughs on nerve regeneration, traumatic brain injury (TBI) and post-traumatic stress disorder (PTSD).

  • Complementary – and not duplicative – of other federal research: Defense health research program grants neither duplicate nor supplant NIH or VA research efforts, but rather enhance those efforts. They fund highly innovative projects – support that is typically unavailable.  For example, programmatically related VA research funding is only available to VA employees (at least 0.625 full-time equivalent). CDMRP funds the best-qualified proposals from researchers and research teams at top research universities and medical centers.  The NIH and DoD medical research portfolios have symbiotic relationships, allowing NIH-funded basic research to serve as a foundation for ground-breaking, disorder-targeted research at DoD.  NIH and DoD program officers meet regularly to ensure collaboration and prevent duplication.
  • Cutting-edge and focused on cures: While the NIH funds primarily high-quality basic biomedical research, the defense health research programs provide essential emphasis on and support for finding innovative cures or new therapeutics for medical conditions.  For several disorders, DoD breakthroughs have led to new clinical trials, new drug products, and novel procedures that are making a difference in the everyday lives of affected patients and families.  For example, research funded by DoD led to the development of the only treatment for tuberous sclerosis complex approved by Food and Drug Administration. The ALS Research Program is supporting translational research and has developed four potential treatments for the disease, for which an effective treatment currently does not exist.
  • Agile, adaptable, and collaborative: Each of the separate programs is guided by a specific vision and mission statement, which in addition to incorporating Congressional direction, reflect rapid change in knowledge, address research gaps, and prevent overlaps.  Annual funding prevents out-year budget commitments, which in turn further enhances programmatic flexibility. Many DoD programs find (or even work to develop) and fund collaborative and consortium-based research, helping to bring unique, interdisciplinary, inter-institutional, collaborative efforts to bear on complex medical research issues unlikely to be solved though the inherent limits of individual researchers.
  • Competitive and unique peer review process: While Congress allocates funding through the annual Defense Appropriations Act to specific medical conditions, it does not direct the programs’ dollars to specific researchers.  These programs utilize an efficient multi-tiered process that includes multiple stages of peer review, including two levels of formal peer review of final proposals. Proposals are scored in a number of key areas such as scientific merit and impact for patients and the military, providing a robust comparative basis for helping accomplish the program’s mission of finding and funding the best research related to these important medical conditions.
  • Consumer review: All defense health research programs incorporate the full and equal participation of consumer reviewers at every stage of the multi-tiered review process – a novel and valuable practice in medical research funding. Consumers – people actually affected by the disease or medical condition – help ensure the program’s funded research will have the greatest impact on those who are affected.  Consumer reviewers also help inform and educate their disease advocacy communities and others.
  • Generating economic growth across the United States:  Research activities promote job growth and encourage long-term economic development through innovation.  It has been estimated that for every dollar awarded in biomedical research grants, more than $2 of additional business activity is created.  Defense health research grants are awarded to universities and institutes in every state in the country.

In short, the well-executed and efficient programs within the defense health research programs demonstrate responsible government stewardship of taxpayer dollars and benefit current and former military service members, the general patient population, and our nation’s economy.

Perhaps most importantly, DoD’s innovative approaches to funding biomedical research have led to a number of significant breakthroughs and achievements, contributing to national security and the health and welfare of U.S. Armed Forces personnel and their dependents.  Enclosed is a detailed white paper providing several examples.  Continued federal funding will only build on these successes.

Lastly, we are concerned about reports that Congress may not complete the fiscal year 2018 appropriations process and instead attempt to pass a long-term continuing resolution.  This approach would have devastating consequences for medical research, creating unnecessary instability and uncertainty in the grant solicitation, grant review, and grant making processes at DoD.  This will also delay the ability of DoD to most effectively convene programmatic panels to identify and implement programmatic changes, effectively convene peer-review panels to provide thorough review of grant applications, and conduct appropriate negotiations to ultimately award FY18 grants.

The undersigned respectfully request your support for FY 2018 funding of all programs within the defense health research programs.


Action to Cure Kidney Cancer
The ALS Association
American Brain Tumor Association
American Gastroenterological Association
American Lung Association
American Psychological Association
American Thoracic Society
American Urological Association
Aplastic Anemia & MDS International Foundation
Autism Speaks
Bladder Cancer Advocacy Network
Children’s Heart Foundation
Children’s Tumor Foundation
Coalition for National Security Research (CNSR)
Crohn’s & Colitis Foundation
Cure HHT
Debbie’s Dream Foundation: Curing Stomach Cancer
debra of America
Digestive Disease National Coalition
Dystonia Medical Research Foundation
Epilepsy Foundation
Fight Colorectal Cancer
FORCE: Facing Our Risk of Cancer Empowered
Foundation to Eradicate Duchenne
GBS|CIDP Foundation International
Hepatitis Foundation International
Indiana University
International Foundation for Functional Gastrointestinal Disorders
Interstitial Cystitis Association
Johns Hopkins University
LAM Foundation
Littlest Tumor Foundation
Living Beyond Breast Cancer
Lung Cancer Alliance
Lupus Foundation of America
Lupus Research Alliance
Lymphoma Research Foundation
Malecare Cancer Support
The Marfan Foundation
Melanoma Research Foundation
The Michael J. Fox Foundation for Parkinson’s Research
National Alliance for Eye and Vision Research
National Autism Association
National Multiple Sclerosis Society
NephCure Kidney International
Neurofibromatosis Midwest
Neurofibromatosis Network
Ovarian Cancer Research Fund Alliance
Pancreatic Cancer Action Network
Parent Project Muscular Dystrophy (PPMD)
Penn State University
Pulmonary Hypertension Association
Scleroderma Foundation
Susan G. Komen
Texas NF Foundation
Tuberous Sclerosis Alliance
University of Central Florida
University of Kansas
University of Pittsburgh
U.S. Hereditary Angioedema Association
Us TOO International Prostate Cancer Education & Support
Veterans for Common Sense
The Veterans Health Council
Vietnam Veterans of America
Weill Cornell Medicine
ZERO – The End of Prostate Cancer


cc: Members, Senate Appropriations Committee

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VA Claims Errors Leave One in Every Seven Veterans Shortchanged

(Washington – June 7, 2017) — The Boston Herald today reported higher than average error rates on veterans’ disability claims at one regional office of the U.S. Department of Veterans Affairs  (“Errors Leave Veterans Shortchanged“, June 7, 2017, by Jack Encarnacao).

The negative impact on veterans is evidenced by quotes from area veterans service organization leaders quoted in the story.

“Some of these veterans have gone through almost bankruptcy, had to sell their house or move, had to make other concessions, because they didn’t have the income to support their family properly,” said Dan Stack, who handles disability claims for the Massachusetts office of Disabled American Veterans, a nonprofit that helps wounded military vets.

The VA’s response claimed it was on part with the rest of the nation and touted its most recent 85.6 percent claims accuracy scores — an error rate of more than 14 percent leaves one in every seven VA claims adjudicated by the office in error.  As shown by VA’s most recent data, VA’s nationwide rate is indeed similarly bad for veterans.

Veterans for Common Sense was given the last word.

Appealing a VA disability rating is an arduous process, and it can be hard to secure a lawyer. In 2015, it took an average of three years for a VA rating appeal to be resolved, five years if it reached an appeal board.

That’s time struggling vets simply can’t afford, said Anthony Hardie, director of the D.C. advocacy group Veterans for Common Sense.

“The terrible experiences they’ve had because the VA simply couldn’t get their claim right the first time around,” Hardie said, “that’s just beyond unacceptable.”

Read the full Boston Herald article here.

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VCS Urges a Strong Borrower Defense Regulation to Protect Veterans and Servicemembers

(Washington, June 6, 2017) – Veterans for Common Sense today joined with nearly 30 national veterans service organizations and other education coalition allies in calling on Congress that the Borrower Defense Regulation not be watered down or delayed. The regulation, scheduled to be implemented in less than 30 days, provides student loan forgiveness for defrauded students.  The letter asks Congressional education committee leaders to urge U.S. Department of Education Secretary Betsy DeVos to ensure the regulation not be watered down because defrauded veterans deserve the loan forgiveness they are entitled to under Borrower Defense.

For-profit schools frequently target current and former (veterans) military service members for their federal G.I. Bill benefits.  Many also receive large amounts of their funding from taxpayer-financed federal financial aid, including federally-backed student loans.  Some poorly regulated for-profit schools have left their students — including countless thousands of veterans — with coursework that isn’t transferrable to other schools, unaccredited degrees, worthless transcripts, G.I. Bill benefits that can not be recouped, and mountains of student loan debt to repay.

Veterans for Common Sense, a Washington, DC-based veterans education and advocacy organization, is an active participant in the Education Coalition, an ongoing coordinated effort between numerous veterans service organizations, education advocacy groups, and other non-profit organizations focused on protecting students, particularly student veterans.

The full text of today’s letter is as follows:


June 6, 2017

The Honorable Lamar Alexander                    The Honorable Patty Murray
Chairman                                                               Ranking Member
Senate Committee on Health, Education,      Senate Committee on Health, Education,
Labor & Pensions                                                Labor & Pensions
U.S. Senate                                                           U.S. Senate

The Honorable Virginia Foxx                      The Honorable Bobby Scott
Chairwoman                                                   Ranking Member
House Committee on Education & the     House Committee on Education & the
Workforce                                                       Workforce
U.S. House of Representatives                    U.S. House of Representatives

Dear Chairmen Alexander and Foxx, and Ranking Members Murray and Scott,

In February 2017, 16 national organizations representing our nation’s military servicemembers, veterans, survivors, and military families wrote to you to urging that the Borrower Defense Regulation not be watered down or delayed. The regulation, scheduled to be implemented in less than 30 days, provides student loan forgiveness for defrauded students. Service members, veterans, and their dependents, families, and survivors are targeted for fraud because of the 90/10 loophole, as has been widely documented.  As you know, predatory college recruiters not only defraud veterans but also load them up with student loans, sometimes without the veterans’ knowledge.  Defrauded veterans deserve the loan forgiveness they are entitled to under Borrower Defense.

On Monday, Politico reported that the administration is eyeing an implementation delay in the Borrower Defense regulation. The Education Department had already committed to granting relief to veterans (and other students) who were defrauded by Corinthian and ITT Tech, because of the amount of evidence that those schools had defrauded students.  But veterans’ applications for relief remain stalled. We are attaching testimonials from some of those defrauded veterans whose applications remain pending. Please urge Secretary DeVos to implement the regulation immediately and start processing veterans’ applications. Any delay is an affront to defrauded servicemembers, veterans, survivors, and military families.

Thank you for your time and attention.


Carl Blake                                                                   Matthew Boulay
Associate Executive Director                                      Executive Director
Paralyzed Veterans of America                                   Veterans Student Loan Relief Fund

Bonnie Carroll                                                             Joseph Chenelly
President and Founder                                                Executive Director
Tragedy Assistance Program for Survivors                AMVETS National Headquarters

John R. Davis                                                             Ted Daywalt
Director, Legislative Programs                                    President
Fleet Reserve Association                                           VetJobs

Kristopher Goldsmith                                                 Gary E. Hall
President and Chairman                                              National Executive Director
High Ground Veterans Advocacy                               Association of the United States Navy

Anthony Hardie                                                          Deirdre Parke Holleman, Esq.
Director                                                                       Washington Executive Director
Veterans for Common Sense                                      The Retired Enlisted Association

Anna Ivey                                                                   Kristina Kaufman
Co-Founder                                                                 Executive Director
Service to School                                                        Code of Support Foundation

Mary M. Keller, Ed.D.                                                Peter James Kiernan
President and Chief Executive Officer            President
Military Child Education Coalition                              Ivy League Veterans Council

Michael S. Linnington, LTG (ret), U.S. Army            Jared Lyon
Chief Executive Officer                                               President & CEO
Wounded Warrior Project                                           Student Veterans of America

Juliana Mercer                                                             Robert Muth
Managing Director                                                      Managing Attorney
MVPVets                                                                    Veterans Legal Clinic, University of

Christopher Neiweem                                                 Jon Ostrowski
Director                                                                       Director, Government Affairs
VetsFirst, a program of United Spinal Association     Non Commissioned Officers Association

Jeffrey E. Phillips                                                        Paul Rieckhoff
Executive Director                                                       Founder & CEO
Reserve Officers Association of the United States      Iraq and Afghanistan Veterans of America

Robert Puskar                                                             Joyce Raezer
National Commander                                                  Executive Director
Military Order of the Purple Heart                              National Military Family Association

Randy Reid, USCG (ret)                                             Kathy Roth-Douquet
Executive Director                                                       CEO
U.S. Coast Guard Chief Petty Officers                       Blue Star Families
Association & Enlisted Association

John Rowan                                                                Keith A. Reed
National President                                                       Headquarters Senior Director
Vietnam Veterans of America                         Air Force Sergeants Association

Carrie Wofford
Veterans Education Success

cc: Betsy DeVos, U.S. Secretary of Education

Examples of veterans with Borrower Defense applications currently pending at the Department of Education

C.W.; North Vernon, Indiana; attended ITT Tech;

“I have a so-called degree from ITT Tech and found that most employers laugh at it. During my time there I had accrued a fair amount of debt from this fraudulent ‘school, and am having issues staying above water with the interest payments they require. The school representatives were not very clear on what debt or what money was going where. At the time of my schooling I was going through spinal surgery, and wanted to do something to keep my mind off of the stress and down time I had during this phase of my life. I was made aware after the fact, that there is a large amount of lawsuits still pending against ITT Tech for fraud in Indiana and other states. To me this should be an indicator as to their fraudulent behavior. Currently I am unemployed and live with my family. I was a Marine corpsman who did 2 combat tours with 1st MarDiv. I have been out of service since 2012. I am hoping I can get some help with this. I did finish school but because of some issues I still don’t have my degree. Thanks.”


W.F.; Wendell, North Carolina; attended ITT Tech

“I was first drawn to ITT Tech because of their ads that discussed how they would help students with job placement. They also used posters that listed the salaries that supposedly corresponded with different degrees from the university. Once I was there, though, the school did nothing to help place me in a job. I attempted to find employment on my own but have never found work or even landed an interview in what I studied.”


R.S.; Jeffersonville, Indiana; attended ITT Tech;

“I was recruited by ITT tech for a degree in IT. After almost a year I learned that none of my credits would transfer to other schools and that a few places I asked about getting a job with told me that ITT was not an accredited school. After that I left the school and started attending ivy tech in Indiana. Now I have about 6k in student loans for credits that are worthless. I am a disabled vet.”


T.M.; Princeton, New Jersey; attended ITT Tech

  • “Was explicitly told that ITT would find her a job upon completion of her Associates Degree but Career Services did absolutely nothing; although she is working in her field now, she was not able to right after graduation—only after [she] did a lot of independent study”
  • “Expected to receive a good education but would rank the quality of classes below that of any community college.”
  • ‘Was told that [she] had no GI Bill benefits remaining and was forced to take out federal and private loans (loans arranged by ITT and private loans were through them)
  • “Was led to believe that credits would transfer to another university and they did not; had to start over completely at a new university.”
  • “Owe $40,000 and have nothing to show for it. Could not find a job, could not make payments, and this has adversely affected [my] credit rating.”


C.H.; Mulvane, Kansas; attended ITT Tech

“I was told my credits would transfer to any four year college. They would not. . . . The quality of the education on the technical side was substandard. I realized this after getting a job as a technical support engineer at NetApp. It turned out I was unprepared for a job of that nature based on my education. . . . My two biggest complaints about ITT Tech are the inability to transfer credits to most colleges and the cost per credit hour.”


S.L.; Des Moines, Iowa; attended ITT Tech

“Insufficient faculty for Bachelors program; single instructor expected to teach multiple subjects and was often not qualified to teach a specific subject.”

  • “Expected that [I] had enough loans to finish associates degree, then found out had to take more.”
  • “[School] represented that ITT degree would lead to employment; found out it was practically useless”
  • “After Associates degree, tried to transfer to a less expensive community college and found out credits would not transfer; had to stay at ITT for Bachelors.”


C.P.; New Orleans, Louisiana; attended ITT Tech

“I attended ITT Tech and graduated in December 2010. I later found out that the cost of tuition was much more than that of the community colleges in my area. I also I found that the credits earned there were non-transferrable. Their job placement assistance was not what they said it would be because they did not help me find employment upon completion of the course. I am stuck with a loan debt that I have to struggle to pay.”


R.W.; Coatesville, Pennsylvania; attended ITT Tech

  • “Had plaques on the wall showing all the great jobs that you could get with an Associates degree; found out it was a lie—no one would hire with an ITT degree.”
  • “Quality of instruction was overall bad; example: class in Transportation Security Admin, I learned nothing about TSA; instructor told stories about his life, his dancing hobby.”
  • “[I] never understood how program would be paid for. Said would be paid for by GI Bill, but then suddenly had to take out loans.”
  • “Realized midway through the program that it was a scam, the degree was worthless, and then could not transfer the credits.”
  • “[The school] promised help with job placement; program that was supposed to help develop his portfolio never met, head of it left, wasn’t replaced.”


H.S.; Parlin, New Jersey; attended ITT Tech

  • “Was actively recruited to attend ITT Tech, promising good jobs with an Associates. Completed Associates degree with a GPA of 3.4. I could not even find an entry level job. ITT advisers suggested to go on to complete a bachelors degree. I refused to take the bachelor path since the tuition was too much to handle.”
  • “The job fairs in school were not relevant to the program that I was enrolled in and in most cases, the job required 4 year degree.”
  • “I feel the price that I paid for the education did not meet the quality of experience that was required for the jobs. Took out substantial student loans to complete program and now unable to borrow more to get a real education.”


R.B.; Riverdale, Georgia; attended Devry

“My main complaint is that I took an enormous amount of loans which has me in deeply in debt by about $110,000 but I am not getting the jobs or job interviews that were promised as a part of their recruitment. They said an average of 92 percent of graduates would be working in their field of study or at least close to it within 6 months of graduating. I’ve graduated with my BS in 2008 and my MBA and MPM in 2010 and 2011 and still have not found anything.”


E.L.; Lackawanna, New York; attended Devry

“They said 95% of graduates were able to get a degree just because of the school’s reputation. Also that they would assist in finding a job which they didn’t. What they told me was a grant turned out to be a loan. After graduating I still had no idea how to do what I was ‘trained’ to do.”


J.S.; Merrillville, Indiana; attended University of Phoenix

“Tuition jumped from $750/3cr class to $1500, poor teaching quality, could not find a job despite promises at outset of 83% employment, had to repeat whole degree at different college to get a job; doesn’t list UOP on resume anymore.”


M.M.; Paramount, California; attended Brown Mackie

“I was recruited for pharmacy tech and never told that my credits couldn’t transfer. Then I was harassed when I had to move to be closer to my parents due to their health issues. Now they are saying I owe student loans totaling 16K when I used my GI Bill to pay for schooling.”


H.P.; Felton, Delaware; attended Colorado Tech

“I was sent an email by CTU about their online degree program. I filled out the form for more information and was contacted by phone within a few hours. They told me how the application process worked and helped me get everything set up. The cost was not covered during any of the conversations as far as I remember. The program was accelerated so I could get my degree in 18 months instead of two years. I was working full time so it seemed like a great opportunity to earn my degree and not have to sacrifice any hours at work. The loans I received went directly to the school and I never actually had access to any of the money or disbursements that were listed on my financial information page. I didn’t even know that the disbursements were intended to help cover my personal cost while gaining a higher education. I ended up with over $13000 in student loan debt and a worthless degree that no one takes legitimately.”


R.G.; Duluth, Georgia; attended Colorado Tech University

“After being contacted by CTU, I was told that their program was accepted by the state of Georgia in the psychology program. I was later informed by the licensing board in Georgia that it was not. There were certain courses that I would have to retake, which would cost me extra money.  During my enrollment at CTU, I felt that my time was wasted. Although I maintained a 3.8 GPA, I felt as if I did not learn anything. Being a Psychology major, after over a year of higher education, I felt that I knew just as much then as I know now. I have not learned anything since I was enrolled at CTU. When I questioned my advisors about this matter, they quickly brushed me off and told me that they would get back with me. I recently withdrew from CTU because I’m scheduled to graduate next year. But as I mentioned earlier, I feel as if I have not learned anything while enrolled at this institution. The money spent at this college does not represent the education I received. Enrolling at CTU was one of the biggest career mistakes I ever made.”


J.R.; Apple Valley, California; attended Colorado Tech University

“Was told that cost of program would be covered but it wasn’t….[school] represented that credits would transfer to other schools and they did not….This is a school that’s just worried about money and not the students.”


J.W.; Loranger, Louisiana; attended Grand Canyon University

“After receiving a veterans discount on tuition, using my GI Bill, and receiving a Pell Grant (undergrad only), I still found myself roughly $50,000 in debt with student loans as I near the end of my postgraduate education. How did this get so expensive over a four-and-a-half year period? After undergrad graduation, I left law enforcement to pursue a career in management. Two years later I’m barely making more than I did in law enforcement and few companies seem to care about a bachelors or master’s degree from GCU.”


J.R.; Belleville, New Jersey; attended University of Phoenix

  • “[The school] represented that credits would transfer to other schools and they did not.”
  • “Was told that costs of programs would be covered but it wasn’t. Took out private and federal student loans, was led to believe they were adequate for program, had to drop out of program briefly and when tried to re-enroll was told that [I] owed them money and couldn’t re-enroll.”
  • Employers tell him his time spent there was worthless.
  • Can’t make payments, can’t go to another school until his past debt is paid, has gone to collections and is adversely affecting his credit rating.
  • Transferred to another school and had to retake several classes.


S.T.; Chesapeake, Virginia; attended American InterContinental University

  • “[AIU] promis[ed] but fail[ed] to provide support in finding and landing a job.”
  • “[AIU] falsely claim[ed] that the school had the proper accreditation to allow its graduates to take a particular licensing exam—I didn’t really understand the process of accreditation prior to enrolling. I learned after the fact that AIU was not regionally accredited.”
  • “[AIU] treat[ed] grants and loans as if they were the same thing.”
  • “[AIU] refus[ed] to disclose loan terms of allow review of loan documents.”
  • “I thought I was using my GI Bill and Tuition Assistance/Top Up. I could have used my GI Bill because I still had it at the time of enrollment.”
  • “My credits would not transfer when I tried applying to other schools to complete a Masters program.”


S.S.; Littlerock, California; attended International Academy of Design and Technology

  • “Recruiter stated that they had a career placement department that would assist in finding a job after graduation. They would highlight recent or prior graduates that had landed jobs in well-known firms and companies in the industry and indicate that IADT had helped them get the position. The only assistance I received was having someone edit my resume”
  • “IADT represented its program as being accredited, but when I tried to transfer my credits to a community college, none of the credits would transfer (including my basic education requirements like math, English, writing and speech courses).”
  • “Every quarter or semester, we would go in to speak with our financial aid counselor, who would provide me with a pre-printed packet and just present it to me to sign without explanation. I was led to believe that I needed to sign the paperwork in order to continue in the program. Periodically, I would be given roughly $3,000-$5,000 labeled as a ‘refund’ check. No one told me that this was money from the loans I had taken out. It was also never clear to me how much the program would cost. I had no idea that I would need to take out the amount of loans that I did in order to complete the program”
  • “My loans exceeded $160,000 in the end. I have made timely payments since completing the program in 2009, and it seems like I’ve barely made a dent in the total amount I owe. I’m 31, I have good credit, but I can’t afford to buy a home because of the amount of student loan payments.”


F.A.; Ellenwood, Georgia; attended American InterContinental University

“For the longest students found out that the University was not accredited, they got it years later but was lied to when we signed up. I believe that my refund check was stolen from me the first three years of going to the university. The never helped me with any leads for jobs after I graduated, and they could not teach me hands on anymore than I already knew.”


T.H.; Mount Vernon, Ohio; attended Sanford Brown

  • “They definitely told us they would be there to help us, but as soon as I graduated, the school shut down and no one called or contacted me. They didn’t give us any job placement help before I graduated, but when they recruited me they said they would help. They gave board passage and job placement rates in the 90s when they recruited me. I wanted to be a physician assistant but none of my credits transferred and I basically would have had to start over but I couldn’t afford to. They had also told me that my credits would transfer when they were recruiting me but not one of them did. Of the 18 of us that graduated in our program, only 2 have jobs in the field.”
  • “They told us that we would be certified to take both registration exams to be a cardiac sonographer, but it turned out we were only certified to take one of the exams. In addition, they misled us about exam passage rates, saying they were in the 90% range.”
  • “The school shut down shortly after I graduated but they never mentioned anything that was going on. When I graduated, they basically just kicked us out the door—no graduation ceremony or anything. Teachers were quitting left and right, but they never told us they were closing until about a month before graduation. At one point, we only had one instructor left.”
  • “I wanted to go back to school at Ohio Dominican but I couldn’t because I found out my credits wouldn’t transfer and I couldn’t afford to start all over again. Plus it took about $36,000 out of my GI Bill (18 months). I had a family to support and had already wasted too much time on an education that turned out not to be worth anything.”
  • “When I went on job interviews, I heard many times from employers that they frowned on Sanford Brown. The school was already shut down at this point. So it definitely hurt my job search.”


J.M.; Barstow, California; attended Sanford Brown

“During meetings with the recruiter/advisor/counselor when I signed up for the program, I was presented with a balance sheet showing the cost of the entire program and the amounts that I would periodically get back as a check (without explaining that it was part of my loan). They asked me how much I was making at McDonald’s, which they calculated as an annual salary of $21,000 to $22,000, and said that the average income for their graduates in my program was $42,000 to $50,000. I wasn’t even able to get a job using the degree that I obtained from Sanford Brown, and they didn’t provide the job placement assistance that they promised either. I eventually went back to work for McDonald’s, and wasn’t able to make my loan payments and went into default on my loans. Since 2006, my federal income tax refunds have been garnished to make the loan payments. I was also homeless for a period of time before I went into the military.”


D.T.; Pennsauken, New Jersey; attended University of Phoenix

  • “I was recruited to attend University of Phoenix and was told that GI Bill would cover costs, accreditation on part with top schools in the nation, and that the learning atmosphere would prepare me for the corporate world. I finished an Associates Degree, then a Bachelor’s Degree, then an MBA—I kept trying to make my education worth something. No effective job placement assistance.”
  • “I was misled about the costs and was led to believe that GI Bill would cover everything and I wound up taking out substantial loans. I have been unable to make loan payments, have tried to consolidate and defer. This has had serious adverse effect on credit rating.”
  • “Employers who have heard about UoP’s illegal practices will not even recognize my MBA. The only positions available to me were entry level.”



C.W.; Newport News, Virginia; attended American InterContinental University

  • “AIU did all of the following through emails: Citing false or misleading statistics about job placement rates; promising inflated salaries; promising but failing to provide support in finding and landing a job.”
  • “Falsely claim[ed] that it offered the classes necessary to achieve employment and/or certification in the IT field.”
  • “Cit[ed] misleading statistics about the pass rate of students on requiring licensing or certification exams in the IT field.”
  • “Refus[ed] to disclose loan terms or allow review of loan documents.”
  • “Having American InterContinental University on a resume repels employers who have heard about its illegal practices.”
  • “I thought my GI Bill was paying the full cost. I was never told that I was applying for loans. I thought the FAFSA was related to enrollment.”


S.K.; San Diego, California; attended Colorado Tech

“When I was enrolled at Colorado Technical University, I was told it was an accredited school. However, when I signed my Navy contract, when my transcripts showed I had enough credits to come in as an E-3, the Navy told me they weren’t full credits and only counted as half. Also, when I reenrolled for the second year, their financial aid department got all my documentation and told me I was all set. However, when I disenrolled, they told me my financial aid never went through and I would have to pay $2,800 in order to get my transcripts. On top of that, I still had the 12,000 in student loans from the previous year to worry about. All in all, when I return to college in the near future, I will never return there and I would never recommend them to anyone.”


K.W.; Newport News, Virginia; attended American InterContinental University

  • “AIU sent numerous emails citing false or misleading statistics about job placement rates. They also promised inflated salaries.”
  • “Promis[ed] but fail[ed] to provide support in finding and landing a job by email. They provided unhelpful webinars occasionally.”
  • “[AIU] understat[ed] the total cost of the program.”
  • “[AIU] understat[ed] the amount of loans necessary.”
  • “[AIU] treat[ed] grants and loans as if they were the same thing.”
  • “[AIU] treat[ed] federal and private loans as if they were the same thing.”
  • “[AIU] refus[ed] to disclose loan terms or allow review of loan documents.”
  • “I explained that I was interested in corporate training at the time I enrolled at AIU and I was advised that the degree pursued would be a good entry degree. I learned after the fact that this was not true.”
  • “I have spoken to registrars at other universities, including Kennesaw State University, and I was told that my credits for my incomplete masters program would not transfer.”
  • “I graduated in 2007 and could not find work in my field. I got a job that wasn’t in my field that lasted from 2007-2009. I was unemployed between Feb 2009 – March 2014. I did not find full time employment until March 2014.”


R.D.; Ashville, North Carolina; attended Ashford

“I was encouraged to take out student loans for my degree at Ashford. The representative stated that the G.I Bill would not cover everything. She also stated that the BA in social science would help me find work in the social work field. They also suggested that I take out student loans while I waited for my credits to transfer so I can start school. She stated that Ashford would assist me in finding placement in my area in jobs related to the social work field. Once I was going to graduate I was constantly harassed. They stated that prior students of Ashford would get a reduced rate and they wanted me to continue using my G.I Bill and that’s when they said I would qualify for the post 9-11 bill but again I would have to take out student loans to cover the costs that my veteran payments did not. The representative stated that I could get my MBA in Information Systems and I would again get assistance in obtaining employment with various technology companies after I graduate. I didn’t really have a break between my BA and Master’s degree and at the time I felt that many of my teachers offered zero help and didn’t even grade my papers. They just gave me As. After graduation I was told my degree wasn’t suitable for any employment within the I.T. field and multiple companies with business positions did not see my MBA as a creditable MBA. Many companies stated that my degree did not have an actual accreditation that is needed for a career within the business world. I feel that I was personally targeted as a veteran. I’ve always regretted both of these degrees because I felt like I had been misled into getting help with job placement and the accreditations do not hold up when I’ve applied to these jobs. Degrees from Ashford are looked at as a joke and seen as fake degree to many employers.”


J.B.; Fort Polk, Louisiana; attended Colorado Tech

“They pushed themselves as a military friendly school. None of my military credits were ever taken into consideration. There are at least 3 college courses I took with CTU that were in my ATRRS. Also, whenever I had to put in a break in time because of going to the field or TDY, when I would return 2 months later, and my degree plan was no longer available. I would have to start a new course of study. That’s why I graduated with almost 300 semester hours and only a bachelor’s degree.”


D.M.; Newport News, Virginia; attended American InterContinental University;

“I was trying to obtain employment with my associates degree and looking forward to getting a BA. AIU committed the following: Falsely claiming that it offered the classes necessary to achieve employment and/or certification to obtain a job in the civil service or educational setting/people instruction; citing misleading statistics about the pass rate of students on required licensing or certification exams.”


K.H.; Springfield, Massachusetts; attended Porter and Chester Institute

From borrower defense application, submitted by attorney: “The coursework was for a ‘B’ electrician certification, but they sent him to an employer for his apprenticeship that was not properly licensed to qualify him for a ‘B’ license. That employer was only high enough level to qualify people for a ‘D’ license (the difference is that ‘B’ is for everything including high voltage work, but ‘D’ is only for low voltage). Neither student/apprentice or employer knew that he wasn’t also qualified to get the ‘D’ license (everyone thought it was a lesser included certification). When he applied to the licensing board, they told him that his 600 hours of course work was for the wrong license and didn’t count toward getting a ‘D’ license. Only 75 hours of his credits were transferable and he had to go back to school for the rest. He has had to work for 4 years without the license he was supposed to get and has been going to night school for two more years while working full time during the day.”


Posted in Legislative News, Veterans for Common Sense News | Leave a comment

VCS Calls on Education Secretary for For-Profit School Reforms

(Washington, May 4, 2017) – Veterans for Common Sense today joined with more than two dozen veterans service organizations and other education coalition allies in calling on U.S. Department of Education Secretary Betsy DeVos to provide openness, transparency, and an opportunity for public comment regarding for-profit school transactions.

For-profit schools frequently target current and former (veterans) military service members for their federal G.I. Bill benefits.  Many also receive large amounts of their funding from taxpayer-financed federal financial aid, including federally-backed student loans.  Some poorly regulated for-profit schools have left their students — including countless thousands of veterans — with coursework that isn’t transferrable to other schools, unaccredited degrees, worthless transcripts, G.I. Bill benefits that can not be recouped, and mountains of student loan debt to repay.

Veterans for Common Sense, a Washington, DC-based veterans education and advocacy organization, is an active participant in the Education Coalition, an ongoing coordinated effort between numerous veterans service organizations, education advocacy groups, and other non-profit organizations focused on protecting students, particularly student veterans.

The full text of today’s letter is as follows:


May 4, 2017

The Honorable Betsy DeVos
Secretary of Education
U.S. Department of Education
400 Maryland Avenue SW
Washington, DC 20202

Dear Secretary DeVos:

We write regarding a proposal from the Education Management Corporation (EDMC) for a change of ownership involving campuses of Argosy University, South University, and the Art Institutes. EDMC proposes to sell these schools to the Dream Center Foundation, which intends to place them in a newly-created subsidiary, Dream Center Education Holdings, LLC. The CEO of the new subsidiary, Brent Richardson, would provide a portion of the financing for the transaction through a family trust, as would Najafi Companies, the current co-owners of the University of Phoenix.

Congress has vested authority in you, as the Secretary of Education, to approve changes in ownership and control for institutions of higher education that wish to continue to participate in federal student loan and grant programs. Given the deeply troubling past performance of EDMC, the proposed transaction should not be rubber stamped behind closed doors. To ensure that the ultimate decision and conditions are in the public interest, we request that you solicit written comment on any proposed provisional program participation agreement and hold a public hearing prior to any final determination. Public hearings and comment periods are standard practice for other federal agencies when considering changes in ownership of regulated entities such as federal bank charters and telecommunications licenses.

While it is questionable that approval is warranted given the lack of demonstrated administrative capability of the new owners, your approval should be conditioned on a favorable determination on three separate questions: (1) whether the operations of the schools going forward are likely to avoid the predatory practices that plagued the company previously, (2) whether the claim of a nonprofit control structure is justified and will set and maintain a path for the schools that is in the best interests of students and taxpayers, and (3) whether taxpayers are adequately protected against financial insolvency that could trigger immense public costs.

The Schools Need to Break from Their Problematic Past

Over a decade or more, EDMC engaged in practices that provided low value for students and taxpayers, including:

Emphasizing rapid growth over serving students. In just the four years between 2006 and 2010, enrollment at EDMC schools nearly doubled from 80,000 to 158,000. In 2010, the company employed 5,669 recruiters but only 321 career services employees and 1,187 student services employees. The U.S. Department of Justice 1 accused EDMC of running a “high pressure sales business” rather than a school. In announcing a $95.5 million settlement of a federal lawsuit alleging that EDMC defrauded taxpayers, Attorney General Loretta Lynch said: “Operating essentially as a recruitment mill, EDMC’s actions were not only a violation of federal law but also a violation of the trust placed in them by their students – including veterans and working parents – all at taxpayer expense.”

Targeting inexperienced customers. Company recruiters, by focusing on high-need students with little or no family experience with paying for college, could minimize serious consideration of price or value by the customer. Internal documents show that EDMC recruiters were trained to avoid answering questions about tuition by focusing instead on the “out of pocket expense,” which could be zero with federal aid. As a result, some EDMC schools received upwards of 90 percent of their revenue from federal aid.2

Shortchanging teaching and learning. Data from 2009 indicates EDMC spent less than a quarter of its revenue on instruction, less than the amount spent on marketing. Most of the revenue came from tuition paid by taxpayer-financed grants and loans.3

Gaming the student loan default rate. Rather than educate students well and place them in jobs so that they could repay their loans, EDMC hired firms to cajole former students into “forbearance” status on their federal loans, reducing the school’s default rate but not addressing the real problem.4

Encouraging additional debts that students would not be able to repay. EDMC arranged for students to take out institutional loans in addition to federal loans, even though an estimated 42 percent were expected to default. After a coalition of state attorneys general cited the company for unfair and deceptive recruitment and enrollment practices, EDMC agreed to forgive debts totaling $102.8 million for more than 80,000 borrowers.

The EDMC schools need to change, revamping their entire approach to recruitment, pricing and instruction. A transfer of ownership could, theoretically, shift the schools’ focus to become positive forces in their communities. Inexplicably, however, the purchaser seems unaware of the need for change, declaring that “the Dream Center will continue to operate these institutions as they have operated.” That is alarming and unacceptable.

Even if the Dream Center were aware, or becomes aware, of the need for a serious change in the operational model, its options may be severely limited by financing arrangements that require ongoing payments to financiers, including the CEO. The Dream Center could discover that it has acquired a predatory model of operations, but be bound by its financing to continue it, while the CEO of the schools, meanwhile, has a financial conflict of interest due to his partial financing of the purchase.

If the change of ownership is approved, it should be only on a provisional basis. The Secretary has wide latitude to condition provisional participation on conduct and outcome standards. To ensure that the EDMC schools operate in the best interest of students and taxpayers following their acquisition, any proposed provisional program participation agreement should include the following conditions:

1. No provisions in enrollment agreements forcing students to bring any disputes to private arbitration or banning class action lawsuits.

2. All marketing calls should be recorded and subject to federal and state monitoring.

3. Continue gainful employment regulation standards, disclosures and consequences to all programs for the duration of any financing arrangements for the transaction, plus two years. More than 150 EDMC programs failed the gainful employment standards.

4. Prevent unchecked federally-funded enrollment increases in programs that are not demonstrating value and market viability through the enrollment of students funded by employers, family earnings or savings, and private scholarship programs. For example, in programs offered online or in multiple locations (making rapid enrollment increases possible), federal aid to additional students could be dependent on enrolling at least 15 percent of students who are not using federal aid of any type.

5. If in the first three years the new owner wants Title IV funds to be disbursed by the “advanced payment” (rather than “reimbursement” method), require the new owner to demonstrate that it has set aside enough funds to cover refunds equal to at least 50% of Title IV receipts for the applicable schools in the prior fiscal year.

The Nonprofit Control Structure Must Be Real, Without Conflicts

The Dream Center is asking that the colleges it is purchasing be treated as nonprofit after the sale. The principle underlying the use of a nonprofit control structure is to change the enterprise’s behavior by altering the financial incentives. Eliminating financiers from institutional governance and requiring all revenue to be re-invested is what generally causes nonprofit institutions to be less focused on rapid growth and more inclined to spend resources on instruction and student support. That model would help shift EDMC schools from their past problematic behaviors. Indeed, EDMC web sites currently say “We’re going non-profit…Invest in minds, not profits.”5

The method of financing this purchase, however, combined with the planned governance structure, could negate the intended effect of the nonprofit control structure. The Dream Center plans to operate the schools through a partnership run by one of the financiers, with an employment contract that has not been disclosed, answerable to seven board members who have not been disclosed. The arrangement may well violate the Department’s requirement that nonprofit schools be “owned and operated by one or more nonprofit corporations or associations, no part of the net earnings of which benefits any private shareholder or individual” (emphasis added).

“Nonprofit” tells consumers that an institution has a control structure that, without a conflict of interest, can balance the school’s need for money with its educational or charitable goals. If it allows schools with financial conflicts built into their governance to be treated as nonprofit institutions for purposes of federal higher education laws, the Department would be facilitating a deception of consumers and exposing taxpayers to heightened risk.

We ask that you examine the proposed EDMC transaction carefully to ensure that, if the former EDMC schools are to be treated as nonprofit institutions, they in fact have a control structure without financial conflicts of interest. No tentative or final approval of the change of ownership should be approved until the details of the proposed transaction, governance, and plan of operation are reviewed, including:

1. The governance structure of the Dream Center and the proposed governance of Dream Center Education Holdings, LLC.

2. The details of the employment agreement with Brent Richardson.

3. The terms and conditions of the financing arrangement with the Richardson Family Trust and the Najafi Companies.

4. The details of any other financing for the transaction.

5. Any existing, or plans for, real property purchases or lease agreements involving the EDMC campuses and people associated with the Dream Center.

Nonprofit institutions are awarded certain freedoms under the Higher Education Act because of the significant governance and spending restrictions by which they must legally abide as nonprofit entities. The Department must ensure that institutions seeking the benefits of the nonprofit label actually have the accountability of a valid nonprofit control structure. As you gather more information regarding the Dream Center’s plans and the contents of the agreements, we ask that you make the information public, and hold a public hearing, so that we and others can provide input based on a more complete record. There is no reason to conduct these reviews behind closed doors, denying the agency the benefit of outside expertise and analysis.

This proposed transaction presents an opportunity for the Department to prevent another repeat of scandalous mistreatment of students and taxpayers. Thank you in advance for your careful attention to this matter.


Americans for Financial Reform
Association of the United States Navy
Blue Star Families
Center for Responsible Lending
Children’s Advocacy Institute
Consumer Action
Consumer Federation of America
Consumer Federation of California
Consumers Union
David Halperin, Attorney
East Bay Community Law Center
Generation Progress
Higher Ed Not Debt
Ivy League Veterans Council
League of United Latin American Citizens
Maryland Consumer Rights Coalition
National Consumer Law Center (on behalf of its low-income clients)
Project on Predatory Student Lending of the Legal Services Center of Harvard Law     School
Public Counsel
Public Law Center
Robert Shireman, The Century Foundation Senior Fellow
The Institute for College Access and Success
U.S. Coast Guard Chief Petty Officers Association & Enlisted Association
U.S. Public Interest Research Group
Veterans Education Success
Veterans for Common Sense
Veterans Student Loan Relief Fund
Vietnam Veterans of America
Young Invincibles

cc: Relevant accreditors, state agencies, Congressional committees, and federal officials



1  United States Senate, Committee on Health, Education, Labor and Pensions, For Profit Higher Education: The Failure to Safeguard the Federal Investment and Ensure Student Success, 2012 (hereafter, Senate HELP). EDMC section available at:

2  In 2012, South University had an estimated 94 percent federal funds (Defense, Education, and Veterans combined) and the Art Institute of Phoenix 91 percent, according to data released by the U.S. Department of Education.

3  Senate HELP.

4  Senate HELP.

5  See, for example,

Posted in Legislative News, Veteran Education Issues, Veterans for Common Sense News | 1 Comment

BOSTON HERALD: “VA errors ‘an absolute travesty’”

(Washington, April 30, 2017) — The first of a Boston Herald two-part series published today highlighted ongoing errors in processing of veterans’ service-connected disability claims at the U.S. Department of Veterans Affairs (VA) Regional Office in Boston, Mass.

According to the Herald’s chief investigative reporter, Jack Encarnacao, the Boston VARO, “has bungled traumatic brain injury claims at an alarming rate, flunking inspections and cutting inaccurate disability checks — shortchanging some local war heroes out of thousands of dollars,” and, “…a 2015 inspection of the Boston VA Regional Office, the most recent one conducted, found an “unacceptable” error rate in assessing the degree of disability in traumatic brain injury claims — one in six of the cases the VA inspector general reviewed that year — despite a warning four years earlier to add more oversight and safeguards.”

Veterans for Common Sense assisted with and was quoted in the story:

Anthony Hardie, director of the D.C. advocacy group Veterans for Common Sense, called the bungled benefits “an absolute travesty.”

“Unfortunately, the veterans who are worst off — the veterans who are the most disabled, who have the most complex claims — they’re the ones that suffer the most when claims staff are not properly trained,” Hardie said. “They’re truly suffering and they’re dependent on VA to get it right quickly, accurately and compassionately.”

In 2011, the Boston VA Regional Office was found to have incorrectly processed 11 of 30 TBI claims randomly selected for review, or 37 percent. The rate had improved to 5 of 30 reviewed cases in 2015, but was still condemned by the VA’s inspector general.

“Despite refresher training and implementation of a second-level review for TBI claims, the current inspection still showed an unacceptable TBI claims processing error rate,” reads the 2015 inspection.

These errors led to mistaken calculations that were used to determine how much a veteran receives in monthly disability benefits

In one case, Boston staff evaluated a veteran’s TBI-related symptoms as only 70 percent disabling, when a review of exams showed they should have been deemed 100 percent disabling. The vet was underpaid by $31,797 over two years.


Read the full Boston Herald story here:


Coming tomorrow: A local Marine’s struggle to get the VA to correctly diagnose his TBI-related seizures.

Do you have a story to tell about your dealings with the Boston VA Regional Office?  Email the Boston Herald at


Read the actual Inspector General reports here:  

1)  2009 IG Report.  U.S. Department of Veterans Affairs, Office of the Inspector General, Office of Audits and Evaluations, VAOIG-09-00189-81:  “Review of VA Regional Office Compensation and Pension Benefit Claim Receipt Dates,” February 27, 2009,


  • “We initiated the review after an investigation by Veterans Benefits Administration’s (VBA) Administrative Investigation Board (AIB) concluded that VARO New York had intentionally reported inaccurate claim receipt dates for 220 (56 percent) of 390 claims reviewed. The objectives of our review were to determine if: (1) other VAROs reported inaccurate claim receipt dates; (2) inaccurate claim receipt dates caused veterans or their beneficiaries to receive incorrect benefit payments; and (3) inaccurate claim receipt dates caused VBA to report incorrect claim-processing times to stakeholders, such as veterans or members of Congress.” (p.i)
  • VARO Boston had an inaccuracy rate of 10 percent, which was significantly higher than the other three VAROs’ rates.” (p.i)
  • “…because VARO Boston had a higher inaccuracy rate, the reliability of its receipt date data needs additional management attention.” (p.10)

2) 2011 IG Report.  VAOIG 10-03564-86:  “Inspection of the VA Regional Office Boston, Massachusetts,” February 11, 2011,


  • “VARO Boston management concurs with the VAOIG finding that 25 claims from the sample of 30 claims reviewed during the audit were processed in error.” (p.20)

  • “VARO staff incorrectly processed 11 (37 percent) of 30 TBI claims. Five of the 11 processing inaccuracies affected veterans’ benefits—2 involved underpayments totaling $41,283 and 3 involved overpayments totaling $30,946.” (p.4)
  • “VARO staff incorrectly processed …20 percentof … herbicide [Agent Orange] exposure-related claims reviewed.” (p.5)
  • “…mailroom staff did not always date stamp mail the same day it arrived in the mailroom as required. This delay occurred because the Support Service Division management and mailroom staff were unaware of VBA’s policy. As a result, beneficiaries may not have received accurate benefit payments.”  (p.12)”
  • …staff did not always manage search mail according to VBA policy. For …13 percent… staff did not properly … ensure timely processing and adequate control of it…. As a result, beneficiaries may not receive accurate payments.” (p.14)
  • “…staff did not always handle original Service Treatment Records (STRs) according to VBA policy.  …27 percent… had claims for benefits either pending or decided without the RVSR reviewing the original STRs. VBA policy requires review of original STRs as part of claims processing. In one example, an RVSR denied service connection for all of the veteran’s claimed conditions without considering the original STRs which were improperly stored.” (p.14)
  • “We recommend the Boston VA Regional Office Director conduct refresher training to ensure Rating Veterans Service Representatives properly evaluate disabilities related to traumatic brain injuries and herbicide exposure-related claims.” (p.21)
  • “We recommend the Boston VA Regional Office Director implement a plan to provide an additional level of review prior to finalizing decisions on traumatic brain injury and herbicide exposure-related claims to ensure accurate benefit payments.” (p.21)

3) 2015 BIG Report.  VAOIG 14-02689-122: “Inspection of the VA Regional Office Boston, Massachusetts,” February 24, 2015,


  • “Overall, VARO staff did not accurately process 21 (23 percent) of 90 disability claims we reviewed.” (p.i)
  • “VARO staff incorrectly processed 10 of 30 temporary 100 percent disability evaluations we reviewed.” (p.3)

  • “…the veteran was underpaid approximately $6,399 over a period of 1 year and 7 months.” (p.3)
  • “We determined VARO staff incorrectly processed 5 of 30 TBI claims—1 of the errors affected a veteran’s benefits. In that case, an RVSR used an incorrect date to establish benefits for a headache condition associated with TBI. As a result, the veteran was underpaid $7,440 over a period of 1 year and 4 months. The remaining four cases had the potential to affect veterans’ benefits.” (p.5)
  • “VARO staff incorrectly processed 6 of 30 veterans’ claims involving SMC and ancillary benefits—5 errors affected veterans’ benefits and resulted in 100 improper monthly payments totaling approximately $253,379 from May 2010 through May 2014. VARO management agreed with our assessments in all six of the cases.” (p.8)


Posted in VA Claims, VCS In The News | Leave a comment

VCS Supports the Veterans Back to Work Act

(Washington – April 25, 2017)  — Veterans for Common Sense today authored the following letter in support of legislation to help reduce veteran unemployment.   The bill is authored by Rep. Ted Poe (R-Tex.).


April 25, 2017

The Honorable Ted Poe
2132 Rayburn House Office Building
U.S. House of Representatives
Washington, DC  20515

SUBJECT:  VCS Supports The Veterans Back to Work Act (H.R. 1600)

Dear Representative Poe,

Veterans for Common Sense (VCS) stands in strong support of your legislation, The Veterans Back to Work Act (H.R. 1600), which makes key changes to the Work Opportunity Tax Credit (WOTC) pilot program for businesses that hire qualified unemployed and underemployed veterans.

Not only would this legislation make permanent the WOTC incentive for hiring qualified veterans, but it would also simplify the process and improve the incentives for employers hiring qualified veterans.  These changes will undoubtedly make it more likely for employers to hire qualified unemployed and underemployed veterans.

As you know, recent data on veteran employment from the Bureau of Labor Statistics show some concerning trends.  In 2016, the unemployment rate for younger male recent veterans aged 25 to 34 was substantially higher than among similarly aged nonveterans: 6.6 versus 4.9 percent.  And, women veterans overall (5.0 vs. 4.6%) and some older Hispanic and Latino veterans (6.6 vs. 5.6%) have higher unemployment rates than their nonveteran counterparts, among other areas of concern.

And, according to a VCS analysis of 2016 BLS data, fifteen states and the District of Columbia have veteran unemployment rates that exceed their nonveteran unemployment rates – some far exceeding, by as much as 57 percent.

We are sincerely grateful for your support for our veterans. We deeply appreciate your leadership in working to ensure the permanency and enhancement of the WOTC that is an important part of reducing veteran unemployment and underemployment.  We are pleased to express our strong support for this bill and your efforts to enact it.



Anthony Hardie
Veterans for Common Sense

Rep. Phil Roe, M.D., Chair, HVAC
Rep. Tim Walz, Ranking Member, HVAC

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VCS Praises Passage of VA Choice Program Extension

(Washington – April 5, 2017) — Veterans for Common Sense, a national veterans education and advocacy organization, today praised the Congressional passage of The Veterans Choice Program Improvement Act.

“We thank the leaders and members in both houses of Congress for extending the VA Choice Program in a thoughtful, bipartisan, veteran-focused manner.  Continuing the Choice Program — while retaining and modernizing VA’s healthcare infrastructure — is part of the long-term solution to meeting veterans’ healthcare needs,” said Veterans for Common Sense in a statement posted today on the organization’s website.

The bill passed today by the U.S. House of Representatives is the the Senate companion to a bill authored by Rep. Phil Roe, M.D. (R-TN) to eliminate the sunset date of the VA’s Choice program.  The Senate bill, led by Senators Johnny Isakson (R-Ga.), John McCain (R-Ariz.) and Jon Tester (D-Mont.), eliminates the impending sunset date for the VA Choice Program until the original funding has been expended.

“By eliminating the sunset date of the Choice Act, Congress is ensuring veterans have certainty and continuity of care while we work with the Trump administration to develop a strategic plan that addresses the need for a veteran-centric, coordinated network of care that utilizes the strengths of both VA and community health providers. I am proud of the bipartisan, bicameral support for this effort and look forward to seeing President Trump sign this important bill into law,” said Roe in a statement.


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VCS Statement on Passage of VA Choice Program Extension

(Washington – April 5, 2017) — Veterans for Common Sense, a national veterans education and advocacy organization, today issued the following statement following Congressional passage of The Veterans Choice Program Improvement Act.  

““We thank the leaders and members in both houses of Congress for extending the VA Choice Program in a thoughtful, bipartisan, veteran-focused manner.  Continuing the Choice Program — while retaining and modernizing VA’s healthcare infrastructure — is part of the long-term solution to meeting veterans’ healthcare needs.”

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