February 11, 2026

Ms. Kendra McCleave,
Veterans Benefits Administration
submitted via regulations.gov

RE: Application For Veteran Employment Through Technology Education Courses
RIN: 2900–NEW

Dear Ms. McCleave,

Veterans Education Success (VES) submits this comment on the proposed information collection associated with VA Form 22–10297[1] for the VET TEC 2.0 program. We previously submitted comments to Congress on the education provisions of the Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act, including Section 212 establishing VET TEC 2.0.[2] While the statutory framework is now settled, those comments remain relevant context for the heightened attention VA should give to implementation and oversight, including the design of this information collection.

Our comments focus primarily on questions (1) and (3) as outlined in the notice; we will address whether the proposed collection is necessary to properly perform VBA’s functions and whether it will produce information of sufficient quality, utility, and clarity to support the responsible administration of the program going forward.

Necessity and Practical Utility of the Information Collection

VA explains that this collection is needed to allow veterans to apply, to select a specific provider and program, and to enable VA to track participation levels. These are baseline administrative functions, and we agree they are necessary to operate the program.

However, necessity under the Paperwork Reduction Act should be understood in functional terms, not simply procedural ones. The practical utility of this collection will depend on whether it equips VA to manage VET TEC 2.0 responsibly as the program unfolds. We strongly believe that enrollment tracking alone is insufficient, as demonstrated by the track record of mismanagement associated with the program.[3] For a nontraditional, short-term program operating outside the standard higher education framework, VA’s ability to monitor performance in real-time is essential to fulfilling its oversight responsibilities.

As such, the information collected from the application should be designed to support more than intake. It should serve as the foundation for VA’s ability to understand who is enrolling, in what types of programs, with which providers, and at what scale. Without that foundation, VA risks repeating a familiar pattern in which participation grows faster than the agency’s capacity to assess whether the program is delivering meaningful value to veterans.

Enhancing the Quality, Utility, and Clarity of the Information Collected

For this information collection to be useful, it must allow VA to link each participant to a specific training provider and program and to evaluate performance over time, rather than simply recording enrollment. Without that linkage, VA can track participation but cannot meaningfully assess program performance or identify where veterans are being served poorly.

The distinction is especially important for VET TEC, which is structured for short-term, non-degree programs operating outside the traditional higher education framework; these programs often vary widely in-terms of structure, cost, and results. Therefore, the application functions as more than an intake mechanism. The data should directly facilitate the oversight providers and assessment of taxpayer funds being used to offer real economic benefit for veterans. To improve the quality, utility, and clarity of the information collected, VA should ensure the application captures additional data elements such as:

  • Provider Program. Require standardized identifiers for the specific training provider and program selected to enable monitoring, comparison, and intervention when performance concerns arise.
  • Program Modality. Capture whether the program is online, hybrid, or in person, and whether instruction is instructor-led or self-paced, to support meaningful comparisons across programs.
  • Credential Outcome. Identify whether the program leads to an industry-recognized license or certification and who awards it, to distinguish substantive training from programs that offer only certificates of completion.
  • Program Cost Scope. Collect total charges to VA, required out-of-pocket costs, program length, and expected weekly time commitment to assess instructional substance, completion risk, and full cost exposure.
  • Baseline Earnings. Collect current employment status and income range at application to allow later assessment of whether participation is associated with increased earnings.

Finally, VA should clearly explain how the information collected through this form will be used to support required reporting and internal oversight. Collecting information without a defined use weakens both the value of the data and confidence in the program’s administration.

Conclusion

VET TEC 2.0 is now transitioning from statutory authorization to programmatic operations. The associated information collection is one of the earliest and most important implementation choices VA will make. If designed well, it can support effective oversight, early problem identification, and responsible program management. If designed narrowly, it risks becoming an enrollment mechanism divorced from performance and outcomes.

Veterans Education Success urges VA to strengthen this collection accordingly and appreciates the opportunity to provide these comments.

Sincerely,

William Hubbard
Vice President for Veterans & Military Policy

[1] Veterans Benefits Administration, “Application for Reimbursement of Preparatory (Prep) Course for Licensing or Certification Test,” VA Form 22-10272 (Jan. 2025), https://www.vba.va.gov/pubs/forms/VBA-22-10272-ARE.pdf.

[2] Veterans Education Success, “Our Letter to Congress on the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act,” (May 17, 2024), https://vetsedsuccess.org/our-letter-to-congress-on-the-senator-elizabeth-dole-21st-century-veterans-healthcare-and-benefits-improvement-act/.

[3] John Sawyer, “Veterans Employment: VA Should Address Human Capital Needs and Other Issues in High-Tech Training,” Government Accountability Office, (Sept. 30, 2025), https://www.gao.gov/assets/gao-25-106876.pdf

 

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