December 16, 2025
Mr. Kenneth Smith
Director, Education Service
Veterans Benefits Administration
U.S. Department of Veterans Affairs
1800 G St. NW, Washington, DC 20006
via email
Re: Military-Connected Student Deserve Better Federal College Search Tools
Dear Mr. Smith,
As you know, service members, veterans, and their families represent a unique group of prospective students who often approach higher education without the same support systems or experience as traditional students. Many are first-generation students navigating an unfamiliar, complex process, making clear, trustworthy information imperative.
The College Scorecard, GI Bill Comparison Tool, and TA DECIDE give prospective students access to federal data on costs, quality, and outcomes. They also help counter the growing influence of deceptive private sites that exist to capture personal data rather than inform. These federal tools were created in response to a long history of schools preying on veterans and service members, using deceptive marketing and false promises to exploit access to federal benefits.
Our new report, “Evaluation of Federal College Search Tools for Veterans, Service Members, and their Families,” examines what federal college choice tools are doing well and where they are falling short. It offers practical recommendations to strengthen data accuracy, timeliness, and coordination across agencies. The goal is not to criticize what exists, but to make it better and more user-friendly. With stronger coordination among the Departments of Education (ED), Veterans Affairs (VA), and War (DOW), these tools can deliver the reliable information that military-connected students deserve.
Suggestions for Improving the GI Bill Comparison Tool to Ensure It Meets Its Promise for Military-Connected Students
The GI Bill Comparison Tool was designed to give GI Bill students clear and reliable information as they decide where to use their earned benefits. As it stands today the tool does fall short. Below we provide easy changes you could make to the Comparison Tool with minimal effort, to the immediate benefit of student veterans:
- Veteran Outcome Data. Despite VA’s stated goal of helping veterans make informed choices, the GI Bill Comparison Tool contains no veteran-specific outcome data and no longer displays College Scorecard graduation, retention, or earnings data, following VA’s 2019 decision to narrow transparency in response to institutional concerns. VA should restore outcome transparency by incorporating veteran-specific outcomes where possible and, at a minimum, include ED’s new low-earning warning data already presented to students during the FAFSA process.
- Complaint History. VA’s policy of limiting visible complaints, first to 24 months and now to six years, benefits schools with long complaint histories and deprives veterans of relevant context, contrary to the purpose of the School Feedback Tool established under the Principles of Excellence Executive Order and codified in statute. VA should return to its original practice of displaying a school’s full complaint history in the GI Bill Comparison Tool.
- Complaint Outcomes. While VA already manages the complaint process and receives school responses, the Comparison Tool does not show whether a school responded, whether the response was timely, or whether the veteran was satisfied, nor does it allow veterans to make complaint narratives public. VA should adopt a CFPB-style model by displaying response status, satisfaction indicators, and reviewed narrative complaints, with appropriate PII redaction, to provide meaningful context rather than summary totals.
- Caution Flags. Caution flags are a powerful disclosure tool but are not consistently posted for oversight and enforcement actions, including SAA findings and FTC settlements, as illustrated by multiple DeVry locations and cases such as Wheeling University, ASA College, and Bay State College. VA should ensure that policies and procedures require caution flags to be posted for all oversight and enforcement actions across all affected locations.
- OPEID and Facility Codes. An ongoing source of confusion is the mismatch between ED’s OPEID numbers and VA’s facility codes, which were created for different purposes and are maintained in separate systems, leading students to see conflicting information across the GI Bill Comparison Tool and College Scorecard. VA and ED should conduct an annual or biannual crosswalk of OPEIDs and VA facility codes to align datasets, reduce discrepancies, and give students a consistent picture of postsecondary institutions.
If implemented, these changes would strengthen the GI Bill Comparison Tool as a decision-making resource and better align VA’s practices with the transparency veterans reasonably expect when choosing where to use their earned benefits.
Overarching Recommendations Across the Agencies
As federal agencies continue to improve college choice tools, clearer coordination and stronger data sharing are necessary to ensure those tools present accurate and complete information to military-connected students, including the following:
- Interagency Data Integration. All three tools should establish a pathway toward full data integration or be directly linked, beginning with ED and VA, including automatic sharing of metrics between ED’s College Scorecard and VA’s GI Bill Comparison Tool and use of a shared data interface drawing from verified federal sources.
- NCES Data Gaps. NCES lacks routine access to personally identifiable data and relies on surveys that capture benefit use only during the survey year, do not capture whether a veteran ever used benefits, and do not identify which GI Bill benefit was used.
- Veteran Outcome Reporting. To close data gaps, ED and VA should ensure institutions report outcomes specific to military and veteran students, display those results alongside civilian data in federal tools, and move the veteran status question earlier in the FAFSA skip pattern.
- Lead Generator Disclosure. A uniform federal requirement should mandate disclosure of financial relationships between lead generators and institutions, or allow funding agencies to prohibit participation by institutions that recruit through non-disclosing lead generators.
Taken together, these steps would make the tools more reliable and provide clearer transparency for service members, veterans, and their families deciding where to use their hard earned benefits.
Conclusion
The federal government has made steady progress in helping veterans, service members, and their families find reliable information about where to use their education benefits, with the College Scorecard, GI Bill Comparison Tool, and TA DECIDE reflecting a genuine effort to promote transparency and accountability.
The challenge is not resources but coordination, as existing data should be shared and presented consistently across agencies so these tools operate as a unified, reliable system. The framework is already in place, and what remains is a focused commitment to deliver on the promise of transparency that veterans and their families deserve.
If you have any questions, please feel free to reach out by phone or email at 703-379-3822 or will@vetsedsuccess.org.
Sincerely,
William Hubbard
Vice President for Veterans & Military Policy