Audit of VBA's Post-9/11 G.I. Bill Tuition and Fee Payments

OIG evaluated the Veterans Benefits Administration’s (VBA) oversight of Post 9/11 G.I. Bill tuition and fee payments to determine if payments were appropriate and accurate. Of the $5.2 billion in Post-9/11 G.I. Bill tuition and fee payments made for nearly 796,000 students during academic year 2013-2014 (August 1, 2013, to July 31, 2014), we reviewed more than $1.7 million in payments made to 50 statistically-selected schools for 225 students. We found VBA staff at the RPOs made 46 improper payments totaling just under $90,900. In addition, we identified 39 overpayments totaling just under $96,400 where the RPOs had not initiated recoupment actions. In total, 32 of the reviewed schools, including 19 for-profit schools, had improper payments and missed recoupments. Furthermore, 20 of the 32 identified schools lacked compliance surveys. Due to program design, VBA must make payments prospectively based on the enrollment information submitted by the schools. Many of these improper payments and missed recoupments occurred because School Certifying Officials’ (SCOs) submitted incorrect and/or incomplete information on students’ enrollment certifications. To help reduce improper payments and missed recoupments, VBA needed to: Improve the SCOs’ awareness of program requirements related to the submission of accurate and complete enrollment certifications; Refine the school selection process and ensure the completion of required compliance surveys to improve the verification and monitoring of tuition and fee certifications; Develop adequate guidance regarding allowable book fees and repeated classes; Verify and obtain supporting documentation for mitigating circumstances. From the more than $5.2 billion tuition and fee payments made for academic year 2013-2014, we projected that VBA made about $247.6 million in improper payments and more than $205.5 million in missed recoupments, annually. As a result, VBA may have an estimated $2.3 billion in improper tuition and fee payments and missed recoupments ($1.2 billion improper payments + $1 billion missed recoupments) over the next 5 academic school years if it does not strengthen program controls. We recommended VBA improve school outreach to ensure accurate and complete certifications are submitted, develop risk profiles for schools to periodically review and verify their certifications, incorporate risk factors into the prioritization and completion of compliance surveys, revise the SCO Handbook, and ensure that mitigating circumstances are properly verified and supporting documentation is obtained. Furthermore, we recommended VBA strengthen policies and controls related to the discontinuance and recoupment of payments, repeated classes, and satisfactory academic progress and that it take action, where appropriate, to recover identified improper payments and initiate recoupments.