Audit of the Education Service’s Compliance Surveys
Report Information
Summary
The VA Office of Inspector General (OIG) conducted this audit to determine how the Veterans Benefits Administration (VBA) manages compliance surveys of education and training institutions that receive VA benefits. These surveys are required by law and help prevent fraud, waste, and abuse. The OIG team reviewed surveys from October 1, 2022, through September 30, 2025 (fiscal years 2023, 2024, and 2025).
The OIG found that during these fiscal years, 646 of the 7,669 institutions (8 percent) with individuals enrolled under Education Service–administered programs that required a compliance survey were not scheduled for one and did not have a waiver excluding them from being scheduled. Therefore, VBA did not meet 38 U.S.C § 3693 statutory requirements for compliance surveys in fiscal years 2023–2025. VBA also did not consider students using benefits under Chapter 31 (Veteran Readiness and Employment) when deciding which institutions needed surveys, even though this is required by law. VBA did not meet the statutory requirement because the Education Service lacked documented or standard processes and procedures to identify institutions and assign surveys.
The OIG also found that survey workload among VBA staff and contractors was uneven, communication between regions was limited, and quality checks on completed surveys were weak. Finally, the OIG found that VBA approved payments to a compliance survey contractor without fully verifying its performance. Because of this, the OIG questioned over $19 million paid to the contractor for fiscal years 2023 through 2025.
Without better processes, there is a continued risk that institutions may receive improper payments or fail to comply with applicable statutes and regulations, increasing the chance of education benefits fraud. The OIG made six recommendations to improve how VBA manages, schedules, and reviews these surveys; VBA concurred with all recommendations.
Update the appropriate manual to ensure all statutorily required VA educational benefit programs are included in active student counts.
Ensure contractor performance is measured in accordance with the contract and that a quality assurance surveillance plan is developed for future contracts for compliance surveys with clear roles and responsibilities of Veterans Benefits Administration staff and with measurable, documented surveillance procedures and outcomes.
Develop, document, and implement procedures for identifying, waiving, and assigning compliance survey workload to ensure all education and training institutions are scheduled and surveyed as required, and update the Veterans Benefits Administration Manual 22‑4 as necessary.
Evaluate the effectiveness of quality control activities for Veterans Benefits Administration and contracted compliance survey specialists and implement improved or additional controls where needed.
Ensure continued focus on collaboration and communication between Approvals, Compliance, and Liaison regions and evaluate the organization’s regional structure to ensure compliance surveys are consistently and effectively scheduled and assigned.
Ensure Approvals, Compliance, and Liaison leaders develop and continue to implement policy and procedures for using waivers for compliance surveys and develop metrics to evaluate record of compliance criteria so waivers maintain the intent of the statute.