order to provide personalized financial advising will be exceptionally challenging to implement. full access to information to require all aid alternatives. at present eligibility information is generally not provided directly to institutions, and we must rely on student veterans to furnish us with such information. navpa has long advocated for direct access to information from the va, for example, and we will continue to do. so the timing of institutional and agency practices will make implementation of this requirement difficult. students cannot even apply for such benefits such as army tuition assistance until after they have already enrolled in classes. schools cannot predict in advance how much funding might be provided or even veterans affairs education benefits require to enrollment, application to tags and benefit authorization. furthermore, many benefits are based on actual enrollment levels, actual institutional charges and the receipt of other

financial rewards. many financial rewards must be adjusted whenever a student receives other financial rewards. the post-9/11 gi bill is a perfect example of a net cost which must be readjusted when any other rewards are received. navpa supports efforts to better inform students about their financial benefits, but we recognize the challenges involved with implementing the services involved in this executive order. we hope and expect as policies are developed we might contribute to the conversation how best to provide the initial needed by perspective student veterans and their families. regarding student outcomes, all schools are interested in assessing the success of their students. it will be critical to define success appropriately for each educational environment and develop data collection methods that are robust, accurate and meaningful. we hope and expect that educational institutions and the organizations that represent them, including navpa will be involved in developing these desired outcomes and metric. we support efforts to improve information resources for

perspective students, absolutely. we also encourage continued efforts to provide schools access to data about individual students, benefits and eligibility so we can then accomplish the tasks required of us. navpa fully supports efforts to ensure veterans are appropriately recruited, advised and supported in school. requiring disclosure by schools should not be substitute for solid oversight, however. the agency administering these programs are in need of further resources to provide training to enforce the executive order as well as the current regulations. the va needs assistance with compliance tasks now that the bill has become so complex. diverting resources to the rule has proven problematic and leaves no one to fulfill the saa's historic role of providing training to institutions on broader education issues there are varying roles within the arena and tasks should be distributed to the agencies best suited and situated to accomplish them.

mr. chairman, this concludes navpa's statement. as a veteran, and on behalf of the members of navpa, i would like to thank you and the members of the subcommittee for your leadership on an issue of critical importance to america's veterans. >> mr. nasserian, you are recognized for five minutes. >> thank you, distinguished members of the committee. my name is barmak nassirian. i'm associate executive director with the american association of collegiate registrars and admissions officers, which we mercifully have reverted to aacrao. we are delighted to be able to participate in this discussion. i have submitted a written testimony for the record. but i'd like to take this opportunity to in plain language raise four specific issues for the subcommittee's attention. and i shall do so doingatically because of the shortness of time. but we can certainly talk about the underlying reasons.

one, the for profit sector in higher education has a significant and pervasive problem with waste, fraud, and abuse. this is not anything against the profit motive. we endorse the profit motive. the building we sit in presumably was built by somebody who was doing it for a profit and did a good job. but when you compare how we put up buildings in the country with building codes and inspections and heavy penalties if somebody undersizes the beams, we understand that the profit motive needs to be framed with proper oversight. i'm here to suggest to you as somebody who spent almost a quarter century looking at this stuff we have a lot of procedural and very burdensome regulations. we do not have substantive safeguards to ensure that an entity purporting to be a college or a university is

actually doing any teaching. and that is equivalent to buildings falling on people's heads on a daily basis. and the basic reason here is simple. when you put a building up or you take a color tv home, there are very obvious performance tests on the basis of which you know what you got. education is a life-time experiential service. you can show people all kinds of promises on the front end that they will only learn 20 years later didn't actually pan out. so that's one point. i raise an issue that has been raised before by my other colleagues about the 90-10 rule. this subcommittee should pay particular attention to that because what the 9010 rule does it is makes every dollar of va benefits worth $9 extra of title 4 money. therefore vets today are walking around with big target signs on

their backs because their dollars are the means by which these entities which have almost no other purchaser, this is really the issue. what are they selling that nobody else is willing to reach into their pocket and put a dollar of hard-earned cash on the table for? now veterans earned their benefits. but these are federal benefits. and these benefits are being used to leverage other federal benefits. so the notion of for profit, i'm for market-based profit making the right way. but it's a funny kind of capitalism we're talking about. is capitalism consisting of 100 cents on the dollar coming from the feds there is something wrong there. my colleagues from the vso talked about the glut of data in the navigator. i ameccally challenged. when i buy a car, all i want to know is where the key goes and where the gas goes. i can't even take to it the oil level being right. so that's the reason unless you want to get a ph.d in mechanical

engineering, we consult consumer reports and attempt to understand what car is right for us. very tough to do with education. disclosures are not a substitute for gate keeping. when i go to the supermarket, i don't want to have toxic food on the shelves with a ph.d dissertation hanging on each item as to whether it's going to kill me or it's edible. we should take toxic programs off the table so vets and service members are not victimized. and finally, with regard to the executive order, we support it as an imperfect substitute for what we believe only you can do. you are the folks who write these laws. you have done so with leadership and with the best of intentions, and i believe if this committee takes a look at the situation and addresses gatekeeping, we could simplify a lot of things that we have to do circuitously otherwise. i appreciate the opportunity and look forward to any questions.

thank you. >> thank you. i'm sorry dr. gibraltar, you're recognized for five minutes. >> chairman stutzman, ranking member braley and distinguished members of the subcommittee, i'm dr. jonathan gibraltar. at state university in maryland. we're a rural university in western maryland and part of the university system of maryland's 11 campuses. i'm here today testifying on behalf of the american association of state colleges and universities, commonly known as aascu which represents over 400 public institutions and university systems. thank you for holding this hearing. i would also encourage members to review my written statement for further detail and explanation of this testimony. frostburg serves the majority of veterans and active military connected to our region's national guard and reserve units. the number of veterans we serve varies significantly from year

to year. our overall enrollment right now is about 5500 students. we're currently serving about 102 veterans. our growing online programs in particular are accredited mba and our new bachelor of science and nursing are proving particularly popular with veterans since these programs are designed to be very flexible. aascu, which also serves as the administrative agent for the servicemen's opportunity colleges supports the intent of the issued executive order. our nation's veterans and military personnel should be able to obtain quality information about institutions and their programs. aascu and its member institutions, including my own campus value the perspective and experience that service members and veterans bring to our institutions. as such, we take our commitment to providing them a quality educational experience very, very seriously.

as the conflicts in iraq and afghanistan wind down, and over two million troops are withdrawn from those areas, more and more veterans will be arriving on college campuses to use the educational benefits they've earned serving our country. in addition, our activity duty military are combining service to the country with higher education. the text of the executive order as written raises a number of concerns for aascu institutions regarding implementation. those of us on the ground are also most aware of the human issues of the individuals that we work with. for example, as there is no requirement that students identify themselves as veterans, some choose not to do so, meaning they may be missing out on services that we can and should provide. the executive order requires the secretaries develop a comprehensive strategy for developing service member and veteran student outcome measures

that are comparable across federal, military and veterans educational benefit programs. while aascu appreciates the order's statement that, quote, to the extent practicable, the student outcome measures should rely on executiving administrative data to minimize the reporting burden on institutions participating in these benefit programs, end quote, there is considerably more burden to finding available data to meet these measures than meets the eye. the issues of data definition and collection raised by the executive order's requirement to develop national level outcome measures become even more significant for institutions. first, the federal government does not collect veterans and military students' specific data from institutions. second, institutions and states vary in their ways of defining veteran and military students based on what data is available to them. given the complexity of data

identification and collection on this topic, higher education institutions will inevitably be asked for data that may or may not be possible to obtain. this leads to another concern that of the reporting burden and associated costs. in 2010, the government accountability office completed an analysis of the burden placed on institutions to comply with expanded mandatory ipeds reporting. among other issues, the gao found that schools reported time burdens ranging from 12 to 590 hours compared with the 19 to 41 hours education estimated. gao further reported that institutions incurred a total estimated salaries and computer costs of over $6 million. the call for specific comparable outcome measures in the executive order would be an expansion of current reporting requirements and may require institutions to incur considerable back office costs.

another key concern that was mentioned earlier was the complaint system outlined in the executive order that would create a centralized complaint system for students receiving military and veterans educational benefits. instituting a complaint system without first determining whether an individual has already attempted to resolve their complaint with the university or college's veterans affairs office represents a concern. too often complaints raised to the highest level when in fact they may be better resolved on the campus. we strongly suggest that higher education stakeholders have significant input into the conceptualization of the centralized complaint system. in closing, frostburg state university and other aascu institutions are eager to continue meeting the needs of our military members and veterans, as well as their families. our experience is that these returning military become solid students and campus leaders.

we support the administration's efforts to ensure that service members and veterans can make the best informed educational choices. thank you for the opportunity to speak about this legislation. >> thank you. and i'll begin the questions. i'm going start with ms. baechtold. if you could describe to us the average student veteran at iu, what is their experience like in transitioning to college life compared to an average 18-year-old freshman coming into school? >> mr. chairman, i would be hard-pressed to define an average student veteran. every one of them is so unique in their situation, in their needs, in their experiences, and how those experiences have impacted them and what that means for them as they now transition into their civilian life that it -- we really think of them across an entire

spectrum of experiences. we do find that as they come to school they have a greater focus on education. they have a different value on edge indication than perhaps the average traditional 18-year-old freshman student might have. they tend to be very interested in their success there. they tend to be very concerned about their finances. they tend to be fairly reticent to seek assistance, even when they know they need it because they come from a tradition where that is not necessarily looked on as being a positive value, to reach out and ask for help. and we work hard to try to provide that assistance so those who need it and never assume that those who are doing fine are somehow just concealing a need that we're not aware of. so, again, it runs the full gamut of students who walk in our door once, sign up for classes and they are good to go and no different than any other

student to someone who spends most of three days aweek in the office because they have a need to reconnect with other veterans because they have a need to seek out other support services, or because they just feel lost in a school of 42,000 students. so i'm afraid that's not a very good answer other than to say there is not an average one out there. every one of them is unique and special and different. >> sure, sure. that's probably the case for every individual. every individual is looking for something maybe different in one way or the other. mr. gunderson, given all of the variables and the student demographics, the availability of jobs, is it reasonable to use data such as salaries to judge the qualities of a school's education? could you just discuss a little bit about the variables and what you see and also if you could follow up on the question that i asked ms. baechtold as well. >> yeah, when you asked the first panel that question, i

actually put down some notes of some things that i think would be very helpful on college navigator to the typical veteran who is trying to make a decision. one of them is a placement in employment. >> microphone. it's on? >> it's on. >> okay, try again. still not working? maybe try someone else's. >> there we go. okay. all right. >> in terms of -- the second would be -- that way all colleges equally would be able

to look at from ftd. [ audio difficulties ] looking at. third, take a look at -- for example, i had mentioned to you earlier, they literally associate degrees -- so let's look at the sheet. for veterans working part-time -- >> thank you. this is for anyone off the panel. college navigator -- talking about earlier. how many of you are with the executive order -- and what

would the current date ethat is valuable -- to any extent will this order create additional administrative burden for schools? if you could touch on that. is that information valuable for students then looking to apply and enroll? >> well, it certainly is an enormous amount of data. and when we're all settled, you look at the voluntary system of accountability that many participate in, you'll find there is a lot of really useful and unique information for anyone, including veterans. i think the issue that i care to discuss today is the information, but it's also the issue of promoting those systems

of accountability for veterans so that it's more readily available to them. so i think it's in part not necessarily how many -- there, it came back on. not necessarily how many items are added, but how you present that to veterans it sounds like is an important issue. >> okay. thank you. mr. braley? >> dr. gibraltar, let me start with you. yourself identified as working at a rural university. >> that's right. >> to mr. stutzman and i, rural america isn't a policy, it's where we are from. >> yes. >> and rural america as a disproportionate contribution to the defense of this country. so when we have young men and women returning, looking for educational opportunities, we have a moral obligation to reward that sacrifice by giving them an educational experience that moves them on the way to fulfilling their career and educational goals.

i don't think you disagree with that. >> i absolutely agree. >> but one of your statements confused me where you said there is no requirement for students to identify themselves as veterans. >> right. >> and yet we're talking about funding from the gi bill and military tuition assistance benefits. so how can colleges and universities not identify that that is a veteran when they're receiving those benefits? >> i think you're talking about two different issues. i think that where we struggle is that there are students who are on our university campuses who don't ever tell us or indicate in any way that they are veterans. they don't want themselves to be known. that is what i'm talking about. i am not talking about those students who are therefore also receiving benefits. if they're receiving benefits, sir, we do know about it. >> and you also raised a point that i alluded to in my opening remarks. that is, everybody -- if you ask

100% of the population whether you think there is too much government red tape, you're going to get 100% yes. to the average person, the average business, that's twofold problem. one is the conduct that is being regulated and whether it should be regulated in the first place, and the other is if that regulation or the documents that communicate with people about their expected behavior are written in incomprehensible gobbledygook so people waste their time trying to understand what is expected of them. and i know that you are all intelligent, highly educated people. but if you're telling us that you are dealing with federal regulations that are incomprehensible gobbledygook to you, we have a big problem. and that's why i introduced the plain language in government regulations bill to get to the root cause of what we're talking about.

and mr. nasserian, you mentioned that thankfully in your opening comments. but this gets to the greater problem. when you have companies like turbotax that can greatly simplify the time it takes the average veteran college student to do their tax return, and if you give them those same tax forms and the booklet that is 150 pages long that tells them how to do the same thing, we have a lot to learn on how we process information and get you the data you need in the least inconvenient format possible. and that's what trust rates me. so how do we get there? >> i -- i think that these conversations need to continue. and i think we need to be involved and continue to be involved in the conversation. and, you know, i would use as a reference the voluntary system of accountability that at least initially colleges and universities did not have to participate in, but many chose

to. i think if you really look at that, you'll see at least from my view, a much more easily understandable interface that students can get information about, you know, acceptance rates, graduation rates, percentage of students that get financial aid, any number of data points about colleges and universities. >> mr. gunderson, welcome home. >> thank you very much. >> i'd like to remind you that iowa used to be part of wisconsin territory, but we beat you into the united states by two years. and i won't get into that. but i wasn't clear from your testimony whether your concerns are that on behalf of your member institutions, you are opposed to the executive order in itself or you are opposed to the implementation of the executive order. >> great question because i'm not sure we're opposed to either. i mean i was disappointed that an executive order would preempt

all the bipartisan efforts to reach consensus here on the hill. that was my disappointment. second, what i have lifted up is that the executive order, if it is developed with all of us and all of you and working out the kinks and the issues that need to be defined, this could be good, but we've got to deal with the two big issues, a complaint process and a calculation of the information for the veteran on graduation rates, academic achievement, et cetera, in ways that works for the veterans and works for higher education. if we do that together, this is a win-win for everybody. if we don't do it, it's a disaster for everybody, the veteran, the schools, you all trying to get the information, and the general public. the verdict on whether it's good or bad is yet to be determined. but we only got 60 days left before that 90-day window is to be concluded and this goes into effect. and like i said, i talked to my colleagues at the american council on ace on monday. and i said we haven't been asked and we were promised by the

white house we're going to be asked. have you been asked? no, we haven't been asked. no one has been asked to come to the table and help work out these issues. >> i think one of the things that all of us would tell you is that an executive order lasts only as long as the person who signs it is in office, as a practical matter. and chairman stutzman and i, other members of the subcommittee are actively engaged because we know that ultimately there has to be a legislative solution that takes into account the best interests of the veterans, the people receiving these funds around the u.s. taxpayers and the institutions who have to administer them. so we look forward to working with you. and we encourage you to continue to engage with all the veteran service organizations who have testified today and members of congress. and with that, mr. chairman, i'll yield back. >> thank you. mr. walls? >> thank you, mr. chairman and ranking member, and thank all of you for your testimony and your expertise in helping us understand this. i'm very proud of the work we

did on the post-9/11 gi bill. it's sorely needed. it's going to open up and has opened up countless opportunities. and ecoms back again we have a couple major requirements in this committee making sure we provide all of the earned benefits that our warriors so rightfully deserve while at the same time making sure that as stewards of the taxpayer dollars we get them there. and i think for you i see that very similar mission. you're trying to deliver and make the opportunities available. i want to be very clear that as we do things, that we're making sure that we're not contracting the opportunities that the gi bill offers, that we're not making it more difficult for the bulk of our warriors to get their benefits because of a few bad actors that are in this. and would you all characterize it as a few bad actors, or is this a systemic problem that truly, truly did need an executive order? anybody want to try at that one?

go ahead, mr. nassirian. >> surprised the politically correct thing to say is that it's a few bad apples. the data argue otherwise. you're looking at 11% of all enrollments, consuming a quarter of pell grant dollars, accounting for half of all student loan defaults, capturing 50% of the dod tuition assistance funding, 37% of all va benefits. the numbers, you know, you can bring -- the plural of anecdote is not dated. the data speaks to a systemic issue. >> can i respond to that, mr. chairman? >> certainly. sure. >> i appreciate that, because i respect everybody's right to disagree with the concept of private sector education. i think, though, that we ought to understand exactly who private sector colleges and universities happen to serve in america today, and what would happen if they didn't exist

thankful tends to be career-oriented education. the reality is that today 94% of all the students who attend private sector colleges and universities in this country are eligible for title 4 student financial aid assistance. we ought to be commending the school for serving students that otherwise would not have access to post secondary education, the skills, the jobs, the incomes and the middle class families that they are able to obtain through that when i hear people who criticize us because we serve a disproportionate number of veterans or active duty military, you got this all mixed up. you ought to commend these schools for the design and delivery of academic programs that serve the needs of today's veteran. don't blame these schools, congratulate them in that regard. >> mr. gunderson, you think this was a chainsaw then instead of a scalpel that should have been used on this? because you had something interesting in your testimony i would follow up on you.