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Audit of Controls at Military Installations for Schools Participating in the DoD Tuition Assistance Program DODIG-2019-122

Audit

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Publically released: September 12, 2019

Objective

We determined whether military installations had implemented controls for the DoD Tuition Assistance Program that were designed to ensure that educational institutions with authorized access to DoD installations complied with DoD policies and partnership memorandums of understanding (MOUs) to prevent improper recruitment of service members.

Background

Advocacy Organization Concerns. In November 2017, a veterans education advocacy organization contacted the DoD Office of Inspector General to raise concerns it had observed with the DoD’s administration of the DoD Tuition Assistance Program. Among other concerns, the advocacy organization stated that it believed that military installations’ contracts (sponsorship agreements) with for-profit colleges may encourage improper practices for recruiting and collection of service members’ data in violation of the DoD’s MOU with educational institutions. The advocacy organization also raised concerns related to:

  • for-profit educational institutions manipulating the Higher Education Act 90-percent Federal funding cap, which limits for-profit educational institutions from deriving more than 90-percent of their revenues from Title IV Federal student aid programs;
     
  • the quality of educational institutions participating in the DoD Tuition Assistance Program; and
     
  • an online school ranking tool and advertisements for “Military-Friendly Schools” (allegedly made available on many military bases) that were deceptive because they did not disclose that the recommended schools paid to be promoted.

These topics were either overseen by the Department of Education or not part of the Tuition Assistance Program. In Appendix B we discuss the advocacy organization’s concerns and our analysis of these concerns. In short, we found that the:

  • Department of Education monitored and reported annually on for-profit educational institutions compliance with the Higher Education Act 90-percent Federal funding cap and that the schools that violated the cap were not eligible to receive DoD Tuition Assistance Funds.
     
  • 29 educational institutions included in our review were accredited—meaning that a Department of Education‑approved accrediting agency assessed the educational institution to ensure that it meets acceptable levels of quality. Therefore, the 29 educational institutions that we reviewed met Department of Education quality standards because they were accredited.
  • Federal Trade Commission took action to correct the online school ranking tool by requiring the publisher to disclose all material connections between the endorser and the schools.

Tuition Assistance Program. To examine the advocacy organization’s key concerns related to the DoD, we analyzed the controls at military installations to prevent improper practices by educational institutions.

The DoD Tuition Assistance Program provides eligible active duty and Reserve Component service members funding for tuition costs for courses at accredited colleges, universities, and vocational or technical institutions. The Tuition Assistance Program funds classroom and distance learning courses taken towards completing academic certificates or associate, undergraduate, and graduate degrees. In FY 2017, 255,729 service members received $485.5 million in Tuition Assistance Program funding.

Educational institutions that want to participate in the Tuition Assistance Program must sign an MOU with the Under Secretary of Defense for Personnel and Readiness in which the institution commits not to use improper recruiting practices. According to DoD Instruction 1322.25, improper recruiting practices include:

  • using unfair, deceptive, abusive, or fraudulent devices, schemes, or artifices (including misleading advertising or sales literature); and
     
  • engaging in unfair, deceptive, or abusive marketing tactics, such as marketing during unit briefings or assemblies, engaging in open recruiting efforts, or distributing marketing materials on DoD installations or at DoD events without approval and monitoring by the responsible education adviser.

To execute the DoD Tuition Assistance Program, the Army, Air Force, and Marine Corps operate education centers on their installations, and the Navy operates a consolidated virtual education center for all naval installations in the continental United States.

Finding

At the five military installations we visited, Military Service officials had implemented Tuition Assistance Program controls, which sought to ensure that educational institutions with authorized access to DoD installations complied with DoD instructions and partnership MOUs to prevent improper recruitment of service members. We found that DoD education center or morale, welfare, and recreation (MWR) personnel had approved and monitored sponsorship and advertising agreements, and approved installation access requests for educational institutions, to seek to ensure that educational institutions met the requirements of DoD instructions and partnership MOUs. In addition, Military Services required service members to meet with an education counselor to discuss their academic and career goals and identify potential institutions or education programs that fit their goals before being approved to receive tuition assistance funds.

Sponsorship Agreements. These agreements allowed educational institutions to display banners and logos, and provide promotional items at sponsored events, such as air shows and organized runs. Specifically, the five installations we visited had 12 sponsorship agreements valued at $63,300, to sponsor 23 events, of which we reviewed 11 agreements. (Only 1 of the 12 sponsorship agreements was with a for‑profit educational institution.) We verified that the 11 sponsorship agreements between the installation MWR office and the educational institution required, in accordance with DoD guidance, that agreements be reviewed by legal and education offices.

In addition, the installation legal office, MWR personnel, and education center personnel reviewed and approved the agreements. Furthermore, education center and MWR personnel at installations we visited stated that they monitored educational institution sponsored events for prohibited recruiting practices by attending and monitoring the event.

Advertising Agreements. These agreements allowed educational institutions to advertise on installation MWR websites, digital marquee signs, digital slides on monitors at MWR facilities, and in a bi-monthly base magazine. Specifically, at the five installations we visited, we reviewed a nonstatistical sample of 11 advertising agreements, valued at $50,175. (None of the 11 advertising agreements were with a for-profit educational institution.) We verified that, in accordance with DoD guidance, the 11 advertising agreements between the installation MWR office and the educational institutions stated that the advertisements must contain the required disclaimer that Federal endorsement is neither implied nor intended. We reviewed advertisements placed on the five installations by educational institutions and determined that the advertisements we reviewed contained the DoD-required disclaimers. In addition, MWR and education center personnel told us that, before the advertisements were published or posted on the installations, education advisers reviewed and approved the advertisements.

Installation Access Requests. Educational institutions interested in providing education, guidance, and training opportunities, or participating in education fairs on a DoD installation, must request access to the installation through the education adviser. The education adviser is required to review and analyze these requests on behalf of the installation commander to ensure that educational institutions are complying with DoD guidance. Specifically, at the five installations we visited, we reviewed a nonstatistical sample of 17 installation access requests. (Of the 17 requests, 4 requests were from for-profit educational institutions.) We verified that, in accordance with DoD guidance, the 17 installation access requests were reviewed and approved by the Service’s education center advisers.

Counseling Sessions. The Military Services required service members to meet with an education counselor before being approved to receive tuition assistance funds. At the five installations we visited, the education counselors met with service members to discuss the service members’ academic and career goals and to identify potential institutions or education programs that fit the service members’ goals before the counselor approved the service member to receive tuition assistance funds. During the counseling sessions, service members were referred to the Tuition Assistance DECIDE website, which provides information about programs and degrees and the cost of attendance at the educational institutions the service member is interested in attending. We surveyed 60 service members at six installations to determine whether they received counseling; 57 responded that they had met with an education counselor and 3 service members did not respond to the survey question. Of the 57 service members who met with a counselor, 51 responded that a counselor reviewed all the information they needed to make an informed decision. In addition, 51 of the 60 service members surveyed responded that counselors discussed financial aid, course tuition, and fees during their sessions. Counseling represents another tuition assistance control.

Conclusion

We determined that Military Service officials implemented controls designed to ensure that educational institutions with authorized access to DoD installations complied with DoD policies and partnership MOUs for sponsorship and advertising activities and base access. In addition, the Military Services required service members to meet with an education counselor before the members were permitted to select an institution or education program.

While we believe that the implemented controls provided reasonable assurance that educational institutions complied with DoD policies and partnership MOUs, there is always a risk that an educational institution could circumvent implemented controls and use unfair, deceptive, abusive, or fraudulent practices to recruit service members.

This report is a result of Project No. D2018-D000RK-0103.000.