This week, thirty-six veterans service organizations (VSO’s) and Military Service Organizations (MSO’s) including Veterans for Common Sense avocated with the U.S. Senate regarding the Higher Education Act and provisions important to veterans and military service members.
The letter, with earlier letters as attachments, is below.
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February 15, 2018
Chairman Lamar Alexander
U.S. Senate Committee on Health, Education, Labor and Pensions
Washington, DC 20510
Dear Chairman Alexander:
Thank you for the invitation to share our thoughts on Higher Education Act Reauthorization.
As we wrote in the attached letters to the Education Department in June and September of last year, veterans and military service organizations strongly oppose efforts to roll back student protections and laws that guard against fraud.
Those who have served their country deserve to be treated with honor and respect when they become college students, and to know that they can trust the federal government’s stamp of approval that a program is worth their hard-earned GI Bill benefits. This can be accomplished through higher quality standards and accountability measures. Veterans don’t really demand or require to go to the Military Campground camps whenever they’re hosted, they just ask for the most basic rights when it comes to education.
We understand there is discussion of eliminating safeguards in favor of a single measure of student debt repayment. We are concerned because such a single measure would not protect military-connected students who don’t have debt because of the GI Bill.
We would appreciate the opportunity to meet with your staff to share suggestions to protect military connected students from loans they don’t want, and to ensure deployed service members and disabled veterans receive their legal rights on student loans and receive their certification for veteran benefits. We also would like to share with you the importance of public service loan forgiveness to active duty servicemembers, veterans, and the Department of Veterans Affairs.
Sincerely,
Keith A. Reed
Headquarters Executive Director
Air Force Sergeants Association
Nichole King-Campbell
Air Force Women Officers Associated
Joseph Chenelly
Executive Director
AMVETS National Headquarters
Kevin Cochie
The Military Coalition Representative
Army Aviation Association of America
Rear Admiral Frederic Sanford (Ret.)
Acting Representative to The Military Coalition
Association of Military Surgeons of the United States
Gary E. Hall
National Executive Director
Association of the United States Navy
Kathy Roth-Douquet
CEO
Blue Star Families
Kristina Kaufmann
Executive Director
Code of Support Foundation
John R. Davis
Director, Legislative Programs
Fleet Reserve Association
Kristofer Goldsmith
President
High Ground Veterans Advocacy
Paul Rieckhoff
Founder & CEO
Iraq & Afghanistan Veterans of America
Luke Opyd
President
Ivy League Veterans Council
Paul D. Warner, Ph.D.
National Commander
Jewish War Veterans of the U.S.A.
Lyman Smith
Executive Director
Military Chaplains Association
Mary M. Keller, Ed.D.
President & Chief Executive Officer
Military Child Education Coalition
Lt. Gen. Dana T. Atkins, USAF (Ret.)
President and CEO
Military Officers Association of America
Neil Van Ess
National Commander
Military Order of the Purple Heart
Juliana Mercer
Managing Director
MVPvets
Tony Flores
President
National Association of Veterans’ Program Administrators
Joyce Wessel Raezer
Executive Director
National Military Family Association
Jon Ostrowski
Executive Director
Non Commissioned Officers Association
Carl Blake
Associate Executive Director
Paralyzed Veterans of America
Jeffrey E. Phillips
Executive Director
Reserve Officers Association
Lydia C. Watts, Esq.
CEO
Service Women’s Action Network
Deirdre Parke Holleman, Esq.
Washington Executive Director
The Retired Enlisted Association
Bonnie Carroll
President and Founder
Tragedy Assistance Program for Survivors
Ryan Manion
Vice President
Travis Manion Foundation
Jack Du Teil
Executive Director
United States Army Warrant Officers Association
Randy Reid, USCG (Ret.)
Executive Director
U.S. Coast Guard Chief Petty Officers Association & Enlisted Association
Carrie Wofford
President
Veterans Education Success
Anthony Hardie
Director
Veterans for Common Sense
Robert Muth
Managing Attorney
Veterans Legal Clinic, University of San Diego
Matthew Boulay
Executive Director
Veterans Student Loan Relief Fund
Bethany Keirans
Director
VetsFirst, a program of United Spinal Association
John Rowan
President
Vietnam Veterans of America
René C. Bardorf
Senior Vice President, Government & Community Relations
Wounded Warrior Project
ATTACHMENT 1
Ms. Wendy Macias September 20, 2017
U.S. Department of Education
400 Maryland Ave., SW
Room 6C111
Washington, DC 20202.
By e-mail: Wendy.Macias@ed.gov
RE: Docket: ED-2017-OS-0074-0001
Dear Ms. Macias:
Please include the following public comment in Docket # ED-2017-OS-0074-0001:
PUBLIC COMMENT FROM VETERANS SERVICE ORGANIZATIONS &
MILITARY SERVICE ORGANIZATIONS
As we wrote to you in the attached July 12, 2017, public comment, veterans and military service organizations strongly oppose efforts to roll back student protections at the Education Department.
Instead of undermining the rules that protect students and taxpayers, we urge the Department to strengthen all Department rules and mechanisms that guard against fraud, including borrower defense, gainful employment, program participation agreements, program integrity rules, enforcement of the 90/10 and incentive compensation bans, and cracking down on colleges that manipulate their reporting numbers to evade compliance.
As you know, service members, veterans, and their families and survivors are specifically targeted for fraud and seen “as nothing more than dollar signs in uniform”1 by unscrupulous colleges. Often, the lowest quality education programs are those that engage in the most consumer fraud of veterans.
1 Consumer Financial Protection Bureau, (2011). “Seeing servicemembers as ‘dollar signs in uniform’”. https://www.consumerfinance.gov/about-us/blog/seeing-servicemembers-as-dollar-signs-in-uniform/
The Education Department must do all it can to ensure that American heroes who have served their country are treated with honor and respect when they become college students, and that they can trust the federal government’s stamp of approval that a program is worth their hard-earned GI Bill benefits. The Department should push for higher quality and better gatekeeping.
Sincerely,
Denise Hollywood
Executive Vice President
Air Force Association
Keith A. Reed
Headquarters Executive Director
Air Force Sergeants Association
Nichole King-Campbell
Air Force Women Officers Associated
Michael V. Reilly
Executive Director
American Association of Collegiate Registrars
and Admissions Officers
Joseph Chenelly
Executive Director
AMVETS National Headquarters
Gary E. Hall
National Executive Director
Association of the United States Navy
Kathy Roth-Douquet
CEO
Blue Star Families
Kristina Kaufmann
Executive Director
Code of Support Foundation
Anthony P. Carnevale
Director and Founder
Georgetown University Center on
Education and the Workforce
Lauren Augustine
Director of Government Relations
Got Your 6
Kristofer Goldsmith
President
High Ground Veterans Advocacy
Paul Rieckhoff
Founder & CEO
Iraq & Afghanistan Veterans of America
Peter James Kiernan
President
Ivy League Veterans Council
Paul D. Warner, Ph.D.
National Commander
Jewish War Veterans of the U.S.A.
Mary M. Keller, Ed.D.
President & Chief Executive Officer
Military Child Education Coalition
Lt. Gen. Dana T. Atkins, USAF (Ret.)
President and CEO
Military Officers Association of America
Neil Van Ess
National Commander
Military Order of the Purple Heart
Juliana Mercer
Managing Director
MVPvets
Keith Glindemann
President
National Association of Veterans’ Program Administrators
Joyce Wessel Raezer
Executive Director
National Military Family Association
Jon Ostrowski
Executive Director
Non Commissioned Officers Association
Carl Blake
Associate Executive Director
Paralyzed Veterans of America
Jeffrey E. Phillips
Executive Director
Reserve Officers Association
Jared Lyon
President & CEO
Student Veterans of America
Deirdre Parke Holleman, Esq.
Washington Executive Director
The Retired Enlisted Association
Bonnie Carroll
President and Founder
Tragedy Assistance Program for Survivors
Ryan Manion
Vice President
Travis Manion Foundation
Randy Reid, USCG (Ret.)
Executive Director
U.S. Coast Guard Chief Petty Officers Association & Enlisted Association
Carrie Wofford
President
Veterans Education Success
Anthony Hardie
Director
Veterans for Common Sense
Christopher Neiweem
Director
VetsFirst, a program of United Spinal Association
Ted Daywalt
President
VetJobs
Robert Muth
Managing Attorney
Veterans Legal Clinic, University of San Diego
Matthew Boulay
Executive Director
Veterans Student Loan Relief Fund
John Rowan
President
Vietnam Veterans of America
René C. Bardorf
Senior Vice President, Government & Community Relations
Wounded Warrior Project
ATTACHMENT 2
July 12, 2017
Ms. Wendy Macias
U.S. Department of Education
400 Maryland Ave., SW.
Room 6C111
Washington, DC 20202.
By e-mail: Wendy.Macias@ed.gov
RE: Public Comment: Docket # ED-2017-OPE-0076
Dear Ms. Macias:
Please include the following public comment in Docket # ED-2017-OPE-0076:
PUBLIC COMMENT FROM VETERANS SERVICE ORGANIZATIONS &
MILITARY SERVICE ORGANIZATIONS
On June 9, 2017, 31 veterans and military organizations wrote the attached letter to Congress and Secretary DeVos requesting no delay in implementation of the Borrower Defense rule, which offers student loan forgiveness for students who have been defrauded, protects students from forced arbitration, thereby enabling them to seek relief in the courts if they’ve been defrauded, and requires financial responsibility triggers and warnings by colleges.
These protections are important to our organizations because service members, veterans, and their families are specifically targeted for fraud by unscrupulous colleges because of the 90/10 loophole in the Higher Education Act, as has been widely documented. The former head of the Office of Servicemember Affairs at the Consumer Financial Protection Bureau (CFPB), Holly Petraeus, explained that the 90/10 loophole incentivizes predatory colleges “to see service members as nothing more than dollar signs in uniform, and to use aggressive marketing to draw them in.”2
2 Consumer Financial Protection Bureau, (2011). “Seeing servicemembers as ‘dollar signs in uniform’”. https://www.consumerfinance.gov/about-us/blog/seeing-servicemembers-as-dollar-signs-in-uniform/
As you know, when predatory college recruiters defraud servicemembers, veterans, and their families, they frequently also load the students up with student loans, sometimes without the students’ knowledge. Large numbers of veterans and servicemembers are affected: According to survey data from the Department of Education’s (ED) “Beginning Postsecondary Students” survey, about 37{cd9ac3671b356cd86fdb96f1eda7eb3bb1367f54cff58cc36abbd73c33c82e1d} of veterans who began college in 2012 had student loans as of 2014. Similarly, a 2012 survey by the Financial Industry Regulatory Authority reported that 38{cd9ac3671b356cd86fdb96f1eda7eb3bb1367f54cff58cc36abbd73c33c82e1d} of military service members indicated that their households currently had student loans.
We were disappointed ED’s announcement on June 14, that it plans to revise the Borrower Defense rule. As you undertake a revision, please ensure that defrauded service members, veterans, and their dependents, families, and survivors receive loan forgiveness, and please ensure that the many pending applications at the Education Department are quickly granted relief under the current regulations. Please also maintain defrauded students’ access to the courts and their right to financially sound colleges through the financial responsibility triggers and warnings. To do otherwise would be an affront to those who have served their country.
Often, the lowest quality education programs are those that engage in the most consumer fraud of veterans. We were therefore disappointed by ED’s concomitant announcement that it would revise the Gainful Employment regulation, which enforces the Higher Education Act’s requirement that career education programs receiving federal student aid must “prepare students for gainful employment in a recognized occupation.” The rule requires career education programs at all types of colleges (public, nonprofit, and proprietary) to disclose basic information about program costs and outcomes and prevents funding for programs that consistently leave students with debts they cannot repay. As you know, several federal courts have already upheld the Gainful Employment metric of debt-to-earnings ratio to excise the worst performing programs. Because the rule eliminates funding for consistently failing programs, the Congressional Budget Office estimates that repealing the rule would increase spending by $1.3 billion over 10 years.
Veterans express anger when they discover the federal government knew a program produced lousy student outcomes or was under law enforcement action for defrauding students, but allowed them to waste their time and GI Bill benefits enrolled in it. The Departments of Defense and Veterans Affairs rely on leadership by Education Department in determining which education programs are worthy of federal student aid. Therefore, it is critical that the Education Department ensure programs meet the federal statutory requirement of gainful employment in a recognized occupation.
The Education Department must do all it can to ensure that American heroes who have served their country are treated with honor and respect when they become college students, and that they can trust the federal government’s stamp of approval that a program is worth their hard-earned GI Bill benefits. The Department must take a firm stand against the predatory targeting of those who have served their country.
Thank you for your time and attention.
Sincerely,
Keith A. Reed
Headquarters Senior Director
Air Force Sergeants Association
Nichole King-Campbell
Air Force Women Officers Associated
Joseph Chenelly
Executive Director
AMVETS National Headquarters
Gary E. Hall
National Executive Director
Association of the United States Navy
Kathy Roth-Douquet
CEO
Blue Star Families
Kristina Kaufmann
Executive Director
Code of Support Foundation
John R. Davis
Director, Legislative Programs
Fleet Reserve Association
Lauren Augustine
Director of Government Relations
Got Your 6
Kristopher Goldsmith
President and Chairman
High Ground Veterans Advocacy
Paul Rieckhoff
Founder & CEO
Iraq & Afghanistan Veterans of America
Peter James Kiernan
President
Ivy League Veterans Council
Carl Singer
National Commander
Jewish War Veterans of the USA
Mary M. Keller, Ed.D.
President & Chief Executive Officer
Military Child Education Coalition
Lt. Gen. Dana T. Atkins, USAF (Ret.)
President and CEO
Military Officers Association of America
Hershel Gober
National Commander
Military Order of the Purple Heart
Juliana Mercer
Managing Director
MVPVets
Joe Wynn
President
National Association for Black Veterans
Joyce Raezer
Executive Director
National Military Family Association
Jon Ostrowski
Director, Government Affairs
Non Commissioned Officers Association
Carl Blake
Associate Executive Director
Paralyzed Veterans of America
Jeffrey E. Phillips
Executive Director
Reserve Officers Association
Deirdre Parke Holleman, Esq.
Deirdre Holleman
Washington Executive Director
The Retired Enlisted Association
Jared Lyon
President & CEO
Student Veterans of America
Bonnie Carroll
President and Founder
Tragedy Assistance Program for Survivors
Randy Reid, USCG (Ret.)
Executive Director
U.S. Coast Guard Chief Petty Officers Association & Enlisted Association
Anthony Hardie
Director
Veterans for Common Sense
Carrie Wofford
President
Veterans Education Success
Matthew Boulay
Executive Director
Veterans Student Loan Relief Fund
Christopher Neiweem
Director
VetsFirst, a program of United Spinal Association
Ted Daywalt
President
VetJobs
Robert Muth
Managing Attorney
Veterans Legal Clinic, University of San Diego
John Rowan
National President
Vietnam Veterans of America
René C. Bardorf
Senior Vice President, Government & Community Relations
Wounded Warrior Project
Damon Berg has taken initiatives in reducing the problems of veterans and make them happy.He has been such kind person who has tried to help the veterans in his major portion of life. Let it be from the distribution of clothes and food, providing medicines and jobs etc. Damon Berg has also launched several campaigns where he has invited people to come forward and make their possible bit of contribution.