The New DoD MOU
Background and Impact on Institutions and Students.
After what seemed an interminable amount of time writing, and re-writing, internal DoD coordination, and staffing and re-tweaking the document with input from the Services and the requisite legal communities, DoD now has the MOU with its partner institutions on the street. Institutions offering programs to service members on campus, on base, on ship, and at a distance must now sign and comply with the MOU by Jan 1, 2012 … or they will no longer be able to collect military tuition assistance from their military students.
DoD had been moving with due diligence to get the MOU on the street. After analyzing public comment provided via the federal register, DoD added final touches to the document that just recently hit the streets. Kudos to their dedication and perseverance in moving processes through requisite channels that sometimes slow down bringing programs of substance to completion.
In 2005, it became apparent that, due to recurring deployments, and changing technology, increasing numbers of service members attending college programs using military tuition assistance (TA) were opting to take coursework at a distance. John Molino, then Deputy Under Secretary of Defense for Military Community and Family Policy (DUSD (MCFP)), convened a Task Force to help DoD develop quality practices for distance programs being offered by institutions with no physical presence on military installations. The reason DoD was concerned was that schools, which were receiving about 10% of their tuition assistance income from distance programs in the early 90s, were creeping up on 25% by the mid 90s, and he and his staff anticipated further growth in that participation rate as distance technology improved. That percentage is now edging past 60%. That is a huge part of a tuition program now topping out at just below $600 million annually.
Thus Molino’s concern. He wanted to get ahead of the curve and make sure that the Department was not embarrassed by the lack of quality oversight of its distance program as it had been in the late 70s and early 80s when higher academe published exposes that showed DoD had little to no consistent review process for the academic programs being offered to military personnel on installations across the country and overseas. DoD was justifiably dinged then and he wanted to make sure it didn’t happen again.
Mike Lambert, Executive Director for the Distance Education & Training Council (DETC), and Dr. Susan Aldridge, President of the University of Maryland University College(UMUC), were asked to co-chair a special task force convened to review existing DoD guidance on distance learning, benchmark existing institutional distance education guidance, and develop recommended criteria that could be folded into existing DoD regulations. Members of the Task Force were senior representative of two year, four year and graduate public, private and for-profit institutions offering programs to service members world wide.
Over a period of a year or more, The Task Force developed quality principles that were tailored to the needs of the military community. Its intent was to define parameters of excellence mirrored in the civilian education sector, help enhance the legitimacy of distance education as a method of delivery of academic programs for the military, and help ensure the quality of these programs for the military.
The Task Force recommended that (1) the Principles of Good Practice be incorporated into DoD regulations, (2) all institutions receiving military TA sign a memorandum of understanding agreeing to follow this guidance, (3) all institutions receiving military TA should be folded into DoD’s third party review process.
Beyond Distance Learning
As the DoD Voluntary Education staff took the criteria developed by the Task Force and began writing and staffing the outcome of those efforts, it quickly became apparent that the criteria could be applied to any form of course delivery, whether that be in a university classroom, an on-base or on-ship classroom or a distance learning classroom. A course was a course and a classroom was a classroom, regardless the modality. In that light, a determination was made to take the basic recommendations of the Task Force and fold them into the new DoD MOU to ensure the quality of the DoD education program as a whole.
Unbeknownst to most, DoD does not unilaterally establish and implement policy for any of the programs for which it has responsibility. In this particular instance, as in all, DoD coordinates policy development with what is now the DoD Interservice Voluntary Education Board, consisting of DoD and Service voluntary education leadership. In their own right, leadership of the individual Service Voluntary Education Programs does not approve evolving policy outright. They help mold and shape wording and policy compromises that must pass muster with leadership within their own Services. Plans that come out of the Vol Ed Board are then staffed through Service leadership and counsel, as well as DoD leadership and counsel. That process can be and is laborious and time consuming. As more and more time passed, members of the DoD Task Force continued to ask what had happened to their recommendations. DoD Vol Ed leadership continued telling them that the process was time-consuming and that they needed to be patient.
The outcome of those efforts came to fruition in March 2011, when the new DoD Instruction 1322.25, which governs the implementation and operation of the Voluntary Education Program that provides academic programs to the military, was published. That regulation included the new MOU that each institution partnering in the military voluntary education program must now sign if it expects to participate in the military tuition assistance program.
Upon close review, it is apparent that the new MOU includes some of the criteria recommended by the DoD Task Force. Currently, only institutions operating on military installations are required to work under the auspices of an MOU with a base or Service. Heretofore, institutions not operating on military institutions have not been required to have an MOU with the base. Nor have they had to participate in a third party review process that congress had DoD establish in the 1980s to provide quality oversight of the then new and unique programs expanding on military installations around the world.
New Quality Review Requirements and Their Impact
Now though, things have changed.
As Carolyn Baker, Chief of DoD Voluntary Education Programs, noted in her July 12, 2011 release of guidance concerning the MOU, “The quality of education received by our service members is very important to DoD… The new DoD Voluntary Education Partnership MOU conveys the commitments and agreements between the educational institution and DoD (that will ensure that quality and that excellence).”
As a result of the Task Force’s effort, but due to a very great extent to the dedication and persistence of the DoD Voluntary Education staff, as well as input, insight and recommendations made by the Voluntary Education leadership of each of the Services, we have a new regulation and MOU that focuses on implementation of quality criteria now applicable to all providers of all military voluntary education programs, regardless of modality.
Off-base Institutions must now abide by DoD quality criteria if they want to offer distance programs to military personnel seeking to use military TA to attend their programs. They must agree to participate in the Military Voluntary Education Review (MVER), as do institutions operating on military installations under the auspices of a base or Service MOU. And all institutions providing programs to military personnel any where, any time that plan using military TA to pay for most of their course costs must now sign and comply with the DoD MOU.
Schools that partner with DoD in delivering academic programs to the military community must now review the new MOU, which is available at http://www.dodmou.com/, go over the application checklist, complete and submit the data and information requested and then submit the MOU application electronically. They must complete that process by January 1, 2012 if they want to continue offering programs to the military. For some unfamiliar with the process, this can be somewhat tedious, a pro forma requirement, but it is mandatory… and it ensures that DoD meets quality and oversight guidelines identified by the GAO and insisted upon by the Congress and the Senate.
What does an institution have to do now under the new MOU that it didn’t have to do before? While institutions still need to adhere to the SOC standards and be accredited by a regional or national accrediting agency, and while they have to continue providing enrollment data and grades and processing course invoices through central Service integrated systems management programs, they have to provide information that provides transparency and accountability across the system. Schools have to provide DoD, the Services, and the students information about its website, where all of its campuses are, what types of delivery methods it uses across its institution (classroom, individual study, distance learning, correspondence, etc.), as well as the names and contact information of leaders at the highest level responsible for the overall program. Although much of this information could be located via search of multiple sites hosted by the institution, it is now available in one location easily reviewable by all who need to know.
But the key differences that impact on all institutions involved initially touches on the basic recommendations made by the DoD Task Force in 2007. Institutions, whether on or off campus, must now sign a central MOU and agree to the criteria set forth therein. And they must agree to be party to the Military Voluntary Education Review (MVER).
In turn, DoD can now ensure the criteria suggested by its partners in higher academe, through the findings and recommendations like those of the Task Force, are now implemented, addressing the concerns of the Congress and the Senate, that DoD is now implementing and reviewing adherence to those quality practices.
The Leadership of the original Task Force is generally pleased with the overall outcome of this overall effort. Dr. Susan Aldridge, although “concerned with the amount of time it took to actually implement its recommendations,” is very “pleased that DoD moved forward with this important MOU.” Mr. Mike Lambert, noted that “It was gratifying to those of us who had a hand in helping create the (initial criteria) to see that so many of the concepts and protections suggested by the Task Force to protect the nation’s military were incorporated in the MOU.”
And the students, how is this all impacting them? The efforts and output of the Task Force, DoD and the Services have served them well. Movement to the quality criteria set forth in the new MOU, and the requirement to review the programs for compliance on an ongoing, recurring basis, will ensure that the military community has a verifiable method for ensuring quality programs are procured and implemented on behalf of our nation’s military, their families and for civilian personnel providing them key support around the country and around the world. After all, that is what this program, what these processes are all about … this is what Congress has been concerned about for decades now … that the DoD education community provides verifiable, quality, affordable academic and training programs to our troops, thus ensuring our military continues to be the best educated fighting force in the world.
Kudos to all who played a part in this very important process.
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