December 16, 2025

Mr. Chris McCaghren
Deputy Assistant Secretary, Higher Education Programs
Office of Postsecondary Education
U.S. Department of Education
400 Maryland Ave SW, Washington, DC 20024
via email

Re: Military-Connected Student Deserve Better Federal College Search Tools

Dear Mr. McCaghren,

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 College Scorecard to Ensure It Meets Its Promise for Military-Connected Students

The College Scorecard is one of the most well-known federal tools for students to compare their higher education options. Although it is an important source of information on college outcomes in general, there are several ways the tool could be improved to be more useful to prospective students:

  • Show Cause Orders. The College Scorecard does not flag when an accreditor has issued a “show cause” order, the most serious warning short of loss of accreditation and a clear signal that a school’s continued existence is uncertain. This leaves prospective students unaware that credits or degrees may be rendered meaningless if a school collapses. ED should require that all accreditors show cause orders be clearly flagged on the Scorecard.
  • HCM2 Notices. The Scorecard is often slow to post Heightened Cash Monitoring 2 designations, even though ED issues these notices in response to financial instability, compliance failures, or fraud concerns. Delayed disclosure allows students to enroll without knowing a school is under severe financial strain, undermining the Scorecard’s role as a safeguard. ED should ensure that HCM2 notices are displayed on the College Scorecard promptly.
  • Outcome Transparency. ED is to be commended for the recent innovation of displaying earnings data and low-earning warnings to students completing the FAFSA, reflecting the judgment that outcome information belongs in students’ hands as they choose a college. That same information should appear directly on the College Scorecard. ED should incorporate FAFSA-linked earnings warnings and College Scorecard data consistently across platforms.
  • Data Integration. The College Scorecard can be significantly strengthened by implementing the Financial Value Transparency framework, including program-level metrics such as debt-to-earnings ratios, earnings premiums, program length, total cost of attendance, and median student loan debt. ED should also develop standardized veteran data definitions and add a veteran status field to IPEDS so the Scorecard can produce veteran-specific earnings and outcome data.

 These improvements would close critical disclosure gaps, strengthen the credibility of the College Scorecard, and ensure students, including veterans, have access to timely and meaningful information when making enrollment decisions.

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

DOW_School Search Tools Letter
 ED_School Search Tools Letter
 VA_School Search Tools Letter