ACE, the National Association of College and University Business Officers, and a group of nine higher education associations submitted comments Sept. 30 on the Department of Defense’s (DoD) proposed rule for its Tuition Assistance (TA) program memorandum of understanding (MOU).
Once finalized, higher education institutions will need to sign the MOU to participate in the TA program.
The comments reiterate the associations’ strong belief in the fundamental tenets of the Obama administration’s April 2012 “Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses and Other Family Members,” which serve as a basis for the changes to the MOU. The associations share DoD’s goal of ensuring that service members have the information, support and protections they need to receive a quality postsecondary education, as well as ensuring proper oversight of TA dollars.
At the same time, the associations note there are concerns that some of the MOU’s provisions may need clarification or modification to ensure that institutions can continue to participate in the TA program.
The comments address, among other topics:
- The proposal that institutions return TA dollars in a manner aligned with the Department of Education’s rules for returning Title IV funds.
- Clarification of the MOU’s Title IV participation requirements for signers, including those focused on incentive compensation, misrepresentation and state authorization.
- The proposal to limit the use of TA funds solely to tuition, as opposed to current rules, which all allow these funds to be used for tuition and fees.
- Clarification of the types of consumer information that need to be provided to service members.
DoD is expected to release the final MOU in the coming months, along with a timeline for institutions to sign.