November 3, 2021
U.S. Department of Veterans Affairs
Education Service
810 Vermont Avenue NW
Washington, DC 20420
via electronic submission
Re: State Approving Agency Jurisdiction Rule, RIN 2900-AQ89
To Whom It May Concern:
We, the undersigned organizations, thank the Department of Veterans Affairs (VA) for the opportunity to comment on its proposed rule regarding State Approving Agency (SAA) jurisdiction. We share VA’s goal of establishing clearer standards for programs approved under the GI Bill.
However, redefining the terms “independent study” and “distance learning” reaches into an area governed by Congress under 38 U.S.C. §3680A, which sets accreditation and credential requirements in law. We firmly believe that any significant or substantive proposed changes to the statutory framework should originate in Congress.
We urge VA instead to focus on defining key terms in 38 U.S.C. §3676, such as quality, teacher qualifications, financial soundness, deceptive advertising, and good character. This would strengthen oversight within existing authority and better protect veterans.
Sincerely,
American GI Forum of the United States
Army Aviation Association of America
Commissioned Officers Association of the US Public Health Service
Fleet Reserve Association
Jewish War Veterans of the United States of America
Military Chaplains Association
Military Officers Association of America
National Military Family Association
No Greater Sacrifice
Paralyzed Veterans of America
Service to School
Swords to Plowshares
Tragedy Assistance Program for Survivors
Veterans Education Success
Veterans for Common Sense