SUBJECT: Commonsense Suggestions re: 38 USC 3696
June 18, 2020
Dear Under Secretary Lawrence,
On April 9, Veterans for Common Sense was among 33 veterans organizations that co-signed the attached letter to Secretary Wilkie regarding improper GI Bill payments to ineligible colleges, especially those that should not be approved for GI Bill under 38 U.S.C. 3696.
In that letter, we collectively provided the following commonsense recommendations to the Secretary to help determine whether schools in violation of 38 U.S.C. 3696 have demonstrated sufficient “corrective action” to restore GI Bill eligibility:
- Faced sufficient deterrence commensurate with the harm against veterans;
- Is a repeat law-offender;
- Put in place an independent auditor to verify future recruiting and advertising practices;
- Replaced the executives responsible for the illegal conduct;
- Removed pressure on recruiters to enroll students at all costs; and
- Undergone a risk-based review by the State Approving Agency.
Also attached is a fact sheet entitled, “Many Corporate School Chains Repeatedly Settled Lawsuits for Misleading Advertising, High-Pressure Recruiting, and False Certifications.” This fact sheet was developed by Veterans Education Success, which we have been proud to closely partner with since its inception and continue to very strongly support in collaborative efforts to preserve and enhance veterans’ federally-funded education programs and to protect veterans from predatory entities and practices. As the title of the fact sheet implies, it shows that many of these schools under consideration are repeat offenders in these regards.
As the Department of Veterans Affairs makes these crucial determinations relative to protecting veterans from these predatory institutions, we want to take this opportunity to again highlight these recommendations and the attached documents.
Thank you for your reasoned consideration of these matters, which stand to impact countless veterans.
On behalf of Veterans for Common Sense and with appreciation for your efforts on behalf of veterans,
National Chair & Director
Veterans for Common Sense
1140 3rd St. NE, Spc 2138
Washington, DC 20002-6274