Congress Upgrades the GI Bill® Comparison Tool, a Student-Veteran 'Feedback' System
- Combat Veterans of America
- 2 days ago
- 5 min read
The U.S. Department of Veterans’ Affairs GI Bill Comparison Tool is scheduled to receive a significant upgrade following enactment of the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act in early 2025 (Public Law 118-210).
The Comparison Tool serves as a public repository of key information about institutions of higher education and employers and currently functions as a feedback mechanism for veterans servicemembers, and their dependents regarding institutional compliance with the Principles of Excellence, an Obama-era executive order (13607), which has stood the test of time. The Principles were established to set baseline standards for how colleges and universities serve military-affiliated students, a population that expressly includes a growing constituency of eligible family members, such as dependents using Chapter 35 benefits.
Combat Veterans of America Founder and National Commander, Brandon M. Barron, J.D., states, “Veterans earned these education benefits through service, and they deserve clear, honest information before making decisions that will shape the rest of their lives. The GI Bill should be a true pathway to opportunity and reintegration. Modernizing the GI Bill Comparison Tool is not about bureaucracy for its own sake, but about transparency, accountability, and consumer protection, ensuring veterans have the same straightforward disclosures any American should expect when investing in education.”
With the recent enactment of the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act, the VA has now been directed by Congress—as opposed to what was previously just an executive order—to formally maintain and substantially modernize the GI Bill Comparison Tool as a central, true accountability mechanism, not merely a place for veterans to submit feedback.
The statute (38 U.S.C. § 3698 note) requires that, by January 2027, VA:
First, to ensure that historical institutional data reported through the GI Bill Comparison Tool remains easily and prominently accessible on benefits.va.gov (or a successor site) for no less than six years from initial publication.
Second, to expand and standardize outcome-based disclosures. The statute significantly expands required disclosures to include program costs (average annual and total), completion outcomes (degrees, certificates, licenses), time to completion, employment rates, and median earnings at two and five years post-graduation, with multiple disaggregation requirements.
Third, to retain, publish, and prominently display student 'feedback' and institutional responses for at least six years, requires accessibility to both beneficiaries and the general public, and ensures 'feedback' is integrated directly into the GI Bill Comparison Tool.
In 2020, a law review article in the Veterans Law Journal, published by the Court of Appeals for Veterans Claims Bar Association, addressed the long overdue need for veterans, servicemembers, and their families to benefit from real legal recourse when institutions of higher education breach the Principles of Excellence, titled Reimagining Servicemembers Rights in Post-Secondary Education by Matthew Feehan, J.D. He wrote, "a right without a remedy is not a right . . . Telling [student-servicemembers] and [student-veterans] they have the right to provide 'feedback' is not a right, unless [they] have a remedy."
Matt’s criticism of the GI Bill Comparison Tool—specifically its failure to provide meaningful administrative or legal remedies—was articulated as early as 2020 and remains salient today. While Congress has now revisited the tool, it did so by further entrenching the concept of “feedback” rather than explicitly adopting “complaint” language rooted in traditional administrative enforcement. When read alongside the Administrative Procedure Act, the newly enacted statutory note raises serious questions about how far Congress intended VA to go in moving beyond the tool’s historically thin, metric-based disclosures. (seen below).
"(C) In providing information pursuant to subsection (b)(5), the Secretary [of Veterans Affairs] shall maintain the anonymity of individuals described in subsection (a) and, to the extent that a portion of any data would undermine such anonymity, ensure that such data is not made available pursuant to such subsection.''
Read plainly, this language suggests more than the publication of binary or aggregated data points. Anonymity safeguards are unnecessary where only numerical counts are disclosed. The instruction to withhold only “a portion of any data” that would undermine anonymity implies that Congress contemplated publication of the substantive content of feedback itself, subject to appropriate sanitization. The unresolved question is whether VA will continue to publish mere numerical indicators, or whether it will give effect to this expanded congressional intent by publishing meaningful, anonymized feedback. That distinction has real consequences—not only for military-affiliated students making enrollment decisions, but also for advocates, congressional staff, litigators, and even caregivers who rely on transparent institutional records to assess patterns of conduct and accountability.
Under EO 13607, educational institutions receiving funding from federal military and veterans’ educational benefits programs, including the Post-9/11 GI Bill and the Department of Defense Tuition Assistance Program, are required, in part, to end fraudulent and unduly aggressive recruiting practices both on and off military installations. The Order specifically targets misrepresentation, the payment of incentive compensation, and failures to meet state authorization requirements, consistent with Department of Education regulations at 34 C.F.R. §§ 668.71–668.75, 668.14, and 600.9.
In addition, EO 13607 requires the “Secretaries of Defense, Veterans Affairs, and Education to develop a comprehensive strategy for developing service member and veteran student outcome measures that are comparable, to the maximum extent practicable, across Federal military and veterans educational benefit programs, including, but not limited to, the Post-9/11 GI Bill and the Tuition Assistance Program.”
Unfortunately, that mandate was never meaningfully implemented.
Nor was the promised “strong enforcement system through which to file complaints when institutions fail to follow the Principles” ever created—particularly one that would have routed complaints through a centralized process and involved the U.S. Department of Justice. To date, the Department of Justice does not include education-related rights within its Servicemembers and Veterans Initiative, despite a direct presidential order in April 2012 instructing it to do so.
This legislative upgrade to the GI Bill Comparison Tool represents a significant development in both veterans’ affairs and higher education policy. For the first time, it will generate program-level, outcome-based disclosures—including program costs, completion rates, employment outcomes, and median earnings—that meaningfully capture how institutions actually perform for military-affiliated students. That data is essential not only for student decision-making, but for the administrative professionals charged with designing, implementing, and evaluating federal education policy, including Department of Education staff and participants in negotiated rulemaking committees.
Equally important, these disclosures will address a long-standing blind spot in federal higher-education data. As acknowledged by the Department of Education during the AHEAD Committee rulemaking sessions, existing accountability frameworks rely heavily on Title IV loan and repayment metrics and therefore fail to account for an estimated 53 percent of military-affiliated students who do not borrow through Title IV programs (data requested by Primary Veterans Negotiator). Instead, these students finance their education primarily through GI Bill benefits and other non-loan sources, rendering them effectively invisible in many of the datasets that currently inform regulatory and legislative decision-making. This, again, is why the GI Bill Comparison Tool's upgrade is long overdue.
By expanding the Comparison Tool to include standardized, outcome-driven information untethered from Title IV borrowing alone, Congress has taken a meaningful step toward closing that data gap. The result is a more accurate and complete evidentiary foundation for policymakers—one that allows regulators, legislators, and their staffs to assess institutional performance across the full population of military-affiliated students, rather than a partial proxy subset. In that sense, this reform does not merely improve transparency for individual beneficiaries; it equips the executive and legislative branches with the kind of empirically grounded insight that has been structurally unavailable in prior years and is necessary for responsible oversight and durable policy reform.
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