Madam Chairwoman, Ranking Member, and members of the subcommittee, on behalf of Iraq and Afghanistan Veterans of America (IAVA), thank you for the opportunity to submit written testimony for this hearing on the status of implementing the Post 9/11 GI Bill. From legislative drafting to cutting tuition checks, IAVA has been closely monitoring and engaging in the evolution of this new benefit. IAVA strongly believes that the Post 9/11 GI Bill will help chart the course of the next great generation if implemented effectively.
Madam Chairwoman, Ranking Member, and members of the subcommittee, on behalf of Iraq and Afghanistan Veterans of America (IAVA), thank you for the opportunity to submit written testimony for this hearing on the status of implementing the Post 9/11 GI Bill. From legislative drafting to cutting tuition checks, IAVA has been closely monitoring and engaging in the evolution of this new benefit. IAVA strongly believes that the Post 9/11 GI Bill will help chart the course of the next great generation if implemented effectively.
We commend the VA’s decision to issue emergency checks to veterans who were desperately awaiting their education benefits. However, these checks are merely a stopgap measure. The VA and Congress must address the underlying problems with processing of Post 9/11 GI Bill claims before another round of delayed checks leave veterans in the lurch. IAVA recommends the following short term and long term fixes to address these issues:
How serious is the check backlog?
Over 30,000 veterans, nearly half of all Post 9/11 GI Bill users, are still waiting for their education benefits due to no fault of their own. These veterans were promised that the new GI Bill would pay their tuition and fees charges up front. “You go to school and the VA will pick up the tab” has been promised to millions of veterans as one of the key components of this new GI Bill. Now these veterans are relying on the patience and gratitude of their schools and universities to defer their tuition payments. Sadly, some veterans have been told that their school will not grant veterans “any special treatment” (e.g., deferred tuition) and they were forced to pay out of pocket or risk being kicked out of their classes.
These same thirty thousand students were promised a healthy living allowance, allowing them to make school their top priority. Most veterans did not know that living allowance checks were paid at the end of each month. When they learned this hard fact they were forced to borrow and scrimp to cover food and rent. Veterans are resourceful and many could cover a month’s living expenses if they could be assured their checks would come at the end of the month. Unfortunately, when these veterans called the GI Bill hotline they were put on hold upwards of an hour and often greeted with phone message saying benefits were being delayed 6-8 weeks. Veterans who did get through were told to call back in a month or so to check on their claim. For many this was a month longer than they could wait.
Not knowing how you can afford your next meal or whether you can afford to buy your textbooks before midterm exams is an serious and disruptive pressure to place on any student. Veterans are now being forced to wrestle with the VA and their schools just to get by, when many veterans just want to be normal students and focus on their education. These GI Bill check delays frustrate the primary purpose of GI Bill benefits: a meaningful opportunity for returning veterans to readjust to civilian life and build a sound economic future (The Servicemens’ Readjustment Act of 1944”).
Why do we have a backlog?
Last year the average processing time for Montgomery GI Bill (MGIB) claims was 14-17 days. Currently the VA is stating the average processing time for a Post 9/11 GI Bill claim is 35 calendar days. The VA often writes a check to a veteran, on average, 35 days after the veteran and their school complete their paperwork. Unfortunately, the VA rarely receives completed paperwork from the schools at the beginning of each academic term; a veteran starting classes on September 1st may not receive their first check until the end of October or early November.
Processing of a Post 9/11 GI Bill claim is a lengthy and laborious two-step process. The first step is to determine the veteran’s eligibility for the benefit. The processor must determine:
Claims processors review veterans’ claims for benefits using three separate sources of information to determine the length of qualifying service: the veteran’s DD214 and DoD and VA Databases). Ironically, according to claim processors, the VA database is the least reliable source of information. Collected information is then inserted into a number of separate forms that calculate each part of the benefit. The processor then needs to “print screen” each form and save it to the veteran’s file. This is the only way to track how that particular veteran’s benefit was determined. After an hour of manual processing the veteran is issued a certificate of eligibility (CoE).
The second step, requires that schools certify the veteran’s enrollment to the VA. A low paid school official certifies to the VA that:
These certifications are filed electronically to the VA for review via a system called VA ONCE. The VA claims processor then reviews each of the school’s certifications and begins determining the appropriate tuition and fee payments, yellow ribbon payments, living allowance rates, and the book stipend. These calculations take another hour to process.
To complete all required steps take two hours per Post 9/11 GI Bill claim. The VA recently hired 760 new claims processors to handle the increased workload. IAVA believes the VA grossly underestimated the time needed to process each Post 9/11 claim and did not adequately hire enough staff to process claims. We are concerned that many of these new claims processors have not yet been fully trained and therefore are not authorized to process claims individually, requiring twice the work force to process one claim.
Where are we now?
Over the past few weeks the VA has released some confusing numbers regarding their status of processing GI Bill checks. Although the VA will undoubtedly be releasing the most recent numbers, we would like to explain what those numbers actually mean to veterans. As of October 6th:
Step One: Eligibility
Step Two: Enrollment
According to the VA, each day they are still receiving an additional 2,000 enrollment certifications from schools and are processing 3,000 backlogged enrollment certifications. On average that means that the VA is processing 1,000 more claims then they are receiving. With a current backlog of 30,000 veterans awaiting checks, the VA will likely close this gap in a little over a month.
How did the VA respond to the delays?
The VA acted boldly when they agreed to issue emergency $3,000 checks to veterans awaiting their GI Bill payments. In just one week the VA issued more emergency checks (36,161) than Post 9/11 benefits that they had completely processed during the past five months (34,000 veterans had received checks). The VA notified VSOs of their emergency plan and we responded in force, leveraging our varied strengths. The VFW and American Legion enlisted local posts to drive veterans to their closest regional offices and IAVA notified tens of thousands of Iraq and Afghanistan veterans through a mass email and web video. We continue to update veterans and schools through our well trafficked newgibill.org.
The VA publishes almost daily workload reports and welcome feedback. When banks put holds on the handwritten checks from the VA, the VA quickly addressed the problem by working with several banks to cash these checks immediately. The VA also issued letters to banks verifying the checks authenticity. This past weekend the VA reached out to veterans soliciting their feedback and asked VSOs to tell our veterans that these calls were coming. Because of this joint effort, IAVA recently received the following email from a school official:
I have a student who got out of the Army after 4 years. He has no family here nor did he have a place to live. He has been in a shelter for the last month. When you guys told me via your website about this $3000 check advance I had to see if he could get it a week before school. The VA just gave him the check as well as money to get home (he had walked to the VA – to say the least it is a few miles). This is a tribute to what you guys have done as well as the VA being able to come through for our vets. The VA also wrote a letter for another student stating that he was getting 1531 a month so that he could get an apartment.
IAVA believes that this stage of the VA’s response to the backlog should serve as a model for future problem solving efforts. The VA:
IAVA is grateful to the VA for impressive effort to stand up this type of emergency program. We look forward to working with the VA on the last stage of any problem solving effort, developing a long term solution.
Sadly, this commendable effort was not was the VA’s first response to the backlog crisis. Initially the VA publically and privately deflected responsibility on the backlog on two key points that IAVA feels still need to be addressed. The VA has claimed that delays in submitting enrollment certifications by schools have contributed to the backlog. IAVA believes schools that fail to submit timely enrollment certificates ensure that their veterans will receive delayed checks. Schools that have not yet submitted their paperwork must do so immediately. However, these delayed enrollment certifications did not create the backlog. In fact they spread out the stream of applications coming into the VA, reducing the average processing time for each claim. If every enrollment certification had been submitted on the first day of school the VA would have been buried under all the paperwork and would be no further ahead in cutting checks.
IAVA has received a number of complaints from school officials stating that the VA substantially changed the certifying process well after these officials had received their training and began certifying enrollments. Their specific complaint focused on VA guidance that required schools, that offer state grants, to wait to certify tuition and fee amounts until the state grants had been finalized. Last minute changes to the procedures and regulations have made schools nervous about certifying enrollments too early in the process. Realistically, most schools will not certify enrollments until at least after the first week of classes. This is because, if a a school certified a veteran who does not show up to school the school is responsible for refunding tuition and fees payments to the VA. Additionally, if a veteran adds or drops a class after the enrollment certification is submitted, additional paperwork is required. These changes may place the veteran in an overpayment situation resulting in a bill from the VA. Many schools wait until the add/drop period is completed to reduce their paperwork and ensure veterans aren’t receiving bills from the VA. Delayed certifications is an issue that must be addressed for future academic terms, but they are not responsible for the current claims backlog.
Secondly, the VA did a poor job managing veterans’ expectations by failing to communicate critical information in a clear and concise manner. In fact, the VA blamed veterans’ lack of knowledge of when their checks should be arriving and the public’s misconception of how long it takes to process claims for a disproportionate “perception” of a backlog. Many veterans, new to the GI Bill, reasonably did not know that monthly living allowance payments are paid in arrears, at the end of the month. IAVA believes that establishing realistic expectations for when benefits will be paid and how much those benefits will be is the responsibility of the VA and any VSO talking about this new GI Bill. However,
Additionally, IAVA acknowledges that GI Bill claims are seasonal and it is natural that the VA’s processing time slows down during the Fall when veterans apply for general eligibility and schools submit enrollment certifications. However, IAVA believes that an average 35 days processing time is more than a natural slow down and is wholly unacceptable regardless of when it occurs because it places an undue burden on our veterans.
What are the long-term issues that need to be addressed?
In truth, the VA and veterans across the country dodged a bullet with the Post 9/11 GI Bill. The VA had initially projected upwards of 400,000 veterans seeking benefits under this great new program. Less than a quarter of that projected population began going to school this year. This was the result of general confusion and the VA’s decision to grant veterans, who had begun using Chapter 30 (MGIB) benefits, an additional 12 months of benefits under the new GI Bill. However, they could only take advantage of the New GI Bill after they had exhausted their entire MGIB benefits. This resulted in hundreds of thousands of veterans continuing to use their MGIB benefits. They did not transfer over to the new GI Bill and did not add additional load to the system. If all the projected veterans had applied for their Post 9/11 benefits and given the VA’s inability to process current claims quickly, IAVA believes that the wheels would have fallen off of the truck.
As stated before, IAVA does not believe that the VA hired enough claims processors to handle the new GI Bill. The VA needs to immediately reassess their processing capacity and make a realistic recommendation to Congress for additional staff. Mandatory overtime is not a sustainable solution to ensuring GI Bill checks get out the door on time. The VA must also finish training all their claims processors in order to maximize the work accomplished from their current processing staff.
The VA also needs to aggressively outreach to and educate veterans on this new program to promote the generous new benefits and establish realistic expectations. While the VA has done an excellent job conducting outreach with the emergency checks, the VA continues to rely on a passive “pull” presence on the web to explain a complicated and lucrative new benefit program overall. The VA does not have the internal capacity to mount the large-scale outreach campaign required for a program of this magnitude. I have personally witnessed Keith Wilson crisscrossing this country attending countless GI Bill forums trying to spread the word. There are not just not enough people within the VA with Keith Wilson’s ability to tell the GI Bill story. Even the GI Bill Call Center, the “one stop shop” the VA has been directing all veterans with GI Bill question to, has been overrun by veterans’ calls. Wait times can be over 45 minutes because half of the operators were pulled to help process claims. The VA needs what the military calls a force multiplier, a plan to teach others to spread the word and answer questions. This can be accomplished by enlisting veteran service organizations, schools, and a cadre of trained GI Bill experts to multiply the number of people pushing out good information.
In the long term the VA continues to implement their plan to automate the processing of Post 9/11 GI Bill claims by January 2010. However, the VA’s most recent experience should raise some red flags. The new GI Bill rules keep changing and they will likely continue to change for the foreseeable future any automated system must be fluid enough to manage these changes. While Congress has only changed the Post 9/11 GI Bill once since its passage (the MSGT Fry Scholarship program), the VA has issued a steady stream of dramatic changes since the final regulations have been published in January. For example they created separate tuition and fees caps; granted an additional 12 months of benefits to MGIB users; changed transferability requirements and altered tuition/fee caps well after the August 1st deadline. Unfortunately, the contract for the development of this new automated system is predicated on a Post 9/11 GI Bill that remains static and unchanged over an academic year. IAVA is deeply concerned that the VA’s contract to automate these claims does not offer the flexibility required to handle necessary upgrades to the Post 9/11 GI Bill.
At a macro level, there is general agreement that there are too many GI Bill benefit programs (Chapters 30, 1606, 1607 and 33) to be effectively administered by the VA or understood by veterans. IAVA concurs with other VSOs that there should be one “Total Force” GI Bill and we believe that it should modeled on a streamlined version of the Post 9/11 GI Bill. This streamlined new GI Bill should include all veterans who were excluded under the new GI Bill (Fulltime National Guard servicemembers and Vocational/OJT/Apprenticeship students). We also believe the tuition and fees portion of the benefit has become thoroughly confusing and unwieldy to implement and therefore needs to be simplified. Lastly, distance learners should not be discriminated against by denying them a living allowance. We believe that the Post 9/11 GI Bill, if effectively implemented, will change history and we continue to reap benefits for generations to come.
[1] In FY 2008 the VA issued 461,259 veterans education benefits. Already this year alone the VA is poised to pay 551,923 veterans education benefits, only 10% of which are Post 9/11 GI Bill users.
Links:
[1] http://iava.org/category/committee/house-veterans-affairs-
[2] http://iava.org/category/committee/patrick-campbell