Overview
Title
Agency Information Collection Activity Under OMB Review: Statement of Assurance of Compliance With 85 Percent Enrollment Ratios; Statement of Assurance of Compliance With 85 Percent Enrollment Ratios Continuation Sheet
Agencies
ELI5 AI
The government wants to make sure that less than 85% of students at certain schools get help paying for school from one place, like the Veterans Affairs. This helps to make sure they don't give out too much money and now, they are asking people to share their thoughts about this plan.
Summary AI
The Department of Veterans Affairs is seeking public comments on an information collection activity related to student enrollment ratios in educational institutions. Under the Paperwork Reduction Act, they want to ensure that no more than 85% of students in approved programs are receiving financial support from the institution or the VA. This compliance, known as the 85/15 Rule, helps prevent overpayment of VA educational assistance. Comments are open until January 2, 2025, and institutions must periodically submit data to confirm compliance.
Abstract
In compliance with the Paperwork Reduction Act (PRA) of 1995, this notice announces that the Veterans Benefits Administration (VBA), Department of Veterans Affairs, will submit the collection of information abstracted below to the Office of Management and Budget (OMB) for review and comment. The PRA submission describes the nature of the information collection and its expected cost and burden, and it includes the actual data collection instrument.
Keywords AI
Sources
AnalysisAI
The document in question, published by the Department of Veterans Affairs (VA) and found in the Federal Register, invites public commentary on a particular information collection process. This process revolves around ensuring compliance with the "85/15 Rule," a policy limiting the percentage of students receiving financial support from educational institutions or the VA to 85% within approved programs. This measure is to avoid overpayments of VA educational benefits.
General Overview
The primary goal of this notice is to gather input regarding the burden and efficacy of information collection associated with the 85/15 Rule. The Veterans Benefits Administration (VBA) requires educational institutions to supply data confirming compliance. Feedback is requested by January 2, 2025. This input is pivotal for the VA's administrative practices under the Paperwork Reduction Act (PRA) of 1995, aiming to balance necessary oversight with minimizing undue paperwork.
Significant Issues and Concerns
Several issues arise from the document:
Technical Language: Terms like "85/15 Rule", "IHLs" (Institutions of Higher Learning), and "NCD" (Non-College Degree training institutions) are used without comprehensive definitions. This could lead to confusion among those not familiar with educational finance regulations.
Comment Submission Process: Instructions for submitting comments through www.reginfo.gov are somewhat convoluted. This complexity may deter meaningful public participation due to the lack of a direct, user-friendly method.
Burden Estimation: The estimated average time to complete the required forms is pegged at 60 minutes per institution, which might underestimate the actual time for those unfamiliar with the process or lacking administrative support.
Scope of Respondents: With only 1,814 respondents anticipated, the collection might not comprehensively represent all affected educational entities, potentially limiting the feedback's utility in assessing nationwide compliance.
Consequences of Non-compliance: The document does not adequately outline potential repercussions for institutions failing to meet the 85/15 Rule requirements, which could otherwise underline the importance of participation.
Impact on the Public
Broadly, this document seeks to ensure that educational benefits are judiciously administered, preventing undue financial strain on the VA's resources. For veterans relying on educational support, maintaining a balance prevents institutions from disproportionately benefitting from such support without accountability.
Impact on Specific Stakeholders
Educational Institutions might face administrative burdens due to form submissions and ensuring compliance. For some, particularly those with limited resources, the reporting requirements may pose challenges. Conversely, it helps safeguard the integrity of educational benefits provided to veterans, ensuring a fair allocation.
For veterans and their families, the adherence to the 85/15 Rule assures that educational programs remain accessible and publicly funded benefits are preserved for appropriately vetted uses.
In summary, while the notice serves a critical oversight function, the technical presentation and response processes present barriers that could diminish its effectiveness if not addressed. The VA may benefit from clearer communication strategies and a more streamlined comment process to truly capture a wide array of stakeholder insights.
Issues
• Document uses technical terms like '85/15 Rule' and 'IHLs and NCD training institutions' without providing comprehensive definitions or explanations for lay readers.
• The instructions for submitting comments using 'www.reginfo.gov' are presented in a format that may not be intuitive for all users, potentially complicating participation in the review process.
• The actual burden of 60 minutes per respondent might be underestimated, especially if the respondent does not fully understand the requirements or the forms, leading to a potential for non-compliance.
• The estimated number of respondents (1,814) suggests a limited scope of response, which might not capture the full picture of compliance across all institutions.
• The document lacks a clear explanation of the consequences of non-compliance with the 85/15 Rule for educational institutions, which could provide better context for why these forms are necessary.