Ms. Samantha Erickson
SAA Director
Ohio Department for Veterans Services
77 South High Street, 7th Floor
Columbus, OH 43215
via email

Mr. Josh Jacobs
Acting Under Secretary for Benefits
Veterans Benefits Administration
810 Vermont Ave. NW
Washington, DC 20420
via email

Re: Eastern Gateway Community College

Dear Ms. Erickson and Mr. Jacobs,

Veterans Education Success respectfully requests that the Department for Veterans Affairs (VA) and the Ohio Department of Veterans Services State Approving Agency (OSAA) undertake a risk-based survey, as provided in 38 U.S.C. § 3673, of Eastern Gateway Community College (EGCC). On Monday, August 8, 2022, the US Department of Education notified EGCC that it is placing EGCC on Heightened Cash Monitoring 2 for method of payment.1 On November 4, 2021 EGCC’s accreditor, Higher Learning Commission, placed EGCC on probation because it, “determined that the institution does not meet HLC’s Criteria for Accreditation related to teaching and learning: quality, resources and support; and teaching and learning: evaluation and improvement.”2

Pursuant to 38 U.S.C. § 3673(e)(1)(C), a risk-based survey is required to be conducted under these circumstances. Specifically, subsection (e)(3)(A) requires a risk-based survey in the event of “receipt by an educational institution of payments under the heightened cash monitoring level 2 payment method”, and subsection (e)(3)(D) requires a survey in the event of “loss, or risk of loss, by an educational institution of an accreditation from an accrediting agency or association, including notice of probation….” According to the Department of Education’s letter to EGCC placing it on HCM2, the Department took the action “as a result of serious and systemic issues identified during the ongoing program review being conducted at [EGCC].”3 The Department identified “concerns that call into question EGCC’s ability to properly administer the Title IV programs and its ability to act in the capacity of a fiduciary….Further, inconsistencies in the data and documents provided to the Department have raised concerns regarding EGCC’s compliance with Title IV student eligibility requirements, satisfactory academic progress standards, and Title IV return requirements.”4

Over two hundred GI Bill students attended EGCC in 2021.5 We strongly encourage VA and OSAA to conduct a risk-based survey and take all appropriate action to protect the veterans’ GI Bill benefits and ensure that EGCC is delivering the quality education promised to the veterans.


Della M. Justice
Vice President for Legal Affairs

[1] Derek Steyer, Eastern Gateway Slapped With New Restriction by DOE, 21WFMJ News (Aug. 10, 2022)
Susan D’Agostino, Eastern Gateway Faces Increased Government Scrutiny, Inside Higher Ed (Aug. 12, 2022);
[2] Database of Accredited Postsecondary Institutions and Programs, Eastern Gateway Community College DAPIP ID: 135762/OPE ID: 00727500
[3] Letter to Michael Geoghegan, President, Eastern Gateway Community College, from Jeremy Early, Division Chief, School Participation Division-Chicago/Denver, U.S Dept. of Education Office of Federal Student Aid (Aug. 8, 2022), p. 1, embedded at
[4] Id.
[5] GI Bill Comparison Tool