Student Veterans and the 90/10 Rule

Veterans and service members receive education benefits that are administered through the U.S. Department of Defense (DoD) and U.S. Department of Veterans Affairs (VA).⁠^[1] These benefits can include tuition assistance toward a degree, trade certification, or professional development; stipends for books and supplies; housing allowances; and reimbursement for certification exams. DoD’s Tuition Assistance Program provides funding for active and reserve component service members to attend off-duty education programs, and VA administers the Post-9/11 GI Bill (PGIB), the Montgomery GI Bill—Active Duty (MGIB-AD), and the Montgomery GI Bill—Selected Reserve (MGIB-SR), each having its own eligibility criteria.⁠^[2]

In fiscal year 2024, VA distributed almost $10.0 billion in PGIB benefits payments to 573,732 beneficiaries; almost $161.8 million in MGIB-AD benefits to 16,711 beneficiaries; and almost $118.5 million in MGIB-SR to 35,634 beneficiaries (VA, undated). For-profit institutions (FPIs) received a little more than one-quarter (27 percent) of the total amount VA paid to educational institutions for beneficiaries receiving PGIB benefits and 39 percent of the total amount paid by DoD for tuition assistance (Kamarck and Levy, 2025; VA, 2024).

During the 117th Congress, the American Rescue Plan Act of 2021 (Public Law 117-2, 2021) included provisions to strengthen oversight of FPIs by making changes to what is known as the 90/10 Rule. Prior to that act, the 90/10 Rule (Public Law 110-315, 2008) stipulated that FPIs can derive no more than 90 percent of their revenue from federal Title IV funds, such as Pell Grants, federally subsidized loans, and federal work-study (Hegji, 2021). Meeting this restriction meant that enough students were willing to pay out-of-pocket to attend FPIs, demonstrating the ability of FPIs to succeed in the market.

The PGIB initially counted toward the 10-percent nonfederal percentage of the FPI revenue rule. This fact may have encouraged FPIs to view veterans as a reliable source of revenue (Veterans Education Success, 2025) and motivated some FPIs to engage in fraudulent and wasteful behavior (Salemme, 2017). Provisions in the American Rescue Plan Act of 2021 effectively closed this gap by expanding the 90-percent federal funding category to also include the PGIB and DoD’s tuition assistance benefits and Title IV funds (Public Law 117-2, 2021).

In this work, I offer an overview of FPIs in the United States, discuss the 90/10 Rule and its evolution over three decades, and explain why it matters for student veterans. Stakeholders, including staff and administration at FPIs and veteran advocacy groups, should find the insights in this work helpful and informative. I conclude by recommending future research that might inspire a deeper understanding of the 90/10 Rule’s unknown impact on student veterans. More research is necessary to understand the 90/10 Rule’s effects on students and improve its ability to hold institutions accountable to federal expectations.

For-Profit Institutions Expanded in the Late 20th Century

FPIs have a long history in U.S. higher education, existing as early as the 17th century and responding to growing demands for education and opportunity (Geiger, 2016). FPIs often stood in stark contrast to the large majority of U.S. colleges and universities by focusing on technical skills (e.g., bookkeeping, trades) and opening their doors to students from a variety of social and economic backgrounds (Thelin, 2019). In 1972, Congress reauthorized the HEA of 1965 that made FPIs eligible to participate in federal student aid programs, giving students more options to pursue their goals (New America, undated).

FPIs experienced remarkable growth in the latter half of the 20th and into the early 21st centuries (National Center for Education Statistics, 2024a) (see Figure 1).⁠^[3] FPIs were heavily influenced by the rise of internet-based distance education and corporate-owned institutions (Kinser, 2006). Between the 1996–1997 and 2013–2014 school years, the number of FPIs more than doubled. But the sector then shrank, likely as a result of the Obama administration’s Gainful Employment regulation that required FPIs to “meet certain debt-to earnings rations to remain eligible for federal student aid programs” (Cellini, 2021, p. 12).

The x-axis represents different school years, ranging from 1976–1977 through 2022–2023, with labeled intervals: 1976-1977, 1982-1983, 1988-1989, 1994-1995, 2000-2001, 2006-2007, 2012-2013, 2018-2019.

The y-axis measures the number of for-profit institutions, with tick marks at 0, 200, 400, 600, 800, 1,000, 1,200, 1,400, and 1,600.

• The number remains below 200 from 1976–1977 to 1988–1989, then increases gradually.
• Starting in the mid-1990s, the number rises more sharply, exceeding 400 around 1994–1995 and continuing to rise substantially after 2000.
• The number peaks just above 1,400 around the 2012–2013 school year.
• After 2012–2013, the number of for-profit institutions falls rapidly, dropping below 600 by 2018–2019, before leveling off.

SOURCE: Features data from National Center for Education Statistics, 2024a.

NOTE: Data were not available for the 1977–1978, 1979–1980, 1981–1982, 1982–1983, 1983–1984, and 1985–1986 school years.

Student veterans can choose to use their educational benefits (e.g., tuition assistance, stipends) at a variety of institutions, and 8 to 22 percent of student veterans enroll in FPIs to further their education and training, either through nondegree or degree programs (Radford et al., 2024). FPIs are an integral component of the U.S. higher education landscape, and studies have documented their strengths in supporting students. The structure of FPIs is often described as entrepreneurial and less bureaucratic than nonprofit institutions (NPIs), allowing the development and expansion of streamlined and accelerated pathways that minimize the administrative burdens on students. Academic programs and support services are often delivered to students through flexible, innovative, convenient methods that enable students to balance multiple obligations (Rosenbaum, Deil-Amen, and Person, 2009; Tierney and Hentschke, 2007).

How Has the 90/10 Rule Evolved?

Prior to the 90/10 Rule, Congress introduced the 85-15 Rule through the Higher Education Amendments of 1992 (Public Law 102-325, 1992), which capped the proportion of revenue that FPIs could receive from Title IV funds of HEA to 85 percent (Hegji, 2021). The remaining 15 percent had to come from non–Title IV and external resources (e.g., nongovernment loans), encouraging institutions to improve the quality of their offerings to attract sufficient students or they would risk closure. Congress then amended the cap through the Higher Education Amendments of 1998 by increasing the Title IV limit for institutional revenue to 90 percent (Ward, 2019).

In 2008, under the Higher Education Opportunity Act, Congress amended the 90/10 Rule and made it less restrictive for FPIs. First, the act required FPIs to report the amount of revenue received from both Title IV and non–Title IV funds. Second, the 90/10 Rule was no longer a condition for Title IV eligibility, meaning that FPIs that violated the rule “in a single year would no longer lose their Title IV eligibility immediately” (Hegji, 2021, p. 6). Rather, FPIs that failed to raise at least 10 percent of their revenue from nonfederal sources were subject to a period of provisional eligibility for two years. Institutions that violated the 90/10 Rule for two consecutive years would no longer be eligible to accept Title IV funds for at least two years. Third, FPIs could count non–Title IV eligible programs, including noncredit programs, toward the 10 percent.

Under the American Rescue Plan Act of 2021, Congress amended the 90/10 Rule to include all federal education assistance funds, effectively closing the gap that allowed FPIs to use non–Title IV funds, including GI Bill benefits and DoD’s Tuition Assistance Program, to meet the 10-percent requirement. This was a major win for veteran and military service organizations and advocacy groups that believed that the gap incentivized FPIs to heavily target and exploit veterans (Salemme, 2017).

In October 2021, the U.S. Department of Education started the negotiated rulemaking process that convened veteran advocacy groups, representatives from FPIs, and other relevant stakeholders (e.g., former students, accrediting agencies) to present their opinions and feedback on the details of the revised 90/10 Rule (U.S. Department of Education, 2021). Those representing FPIs framed their argument against the revision as a matter of college choice and access in the sense that the implementation of this revision would limit the number of career education opportunities for students, whereas representatives for the revision spoke about what they saw as FPIs’ exploitative behavior that harmed veterans.

In October 2022, the U.S. Department of Education published the final rule in the Federal Register. This rule expanded the list of federal assistance beyond Title IV of the HEA that counted as federal revenue, including educational assistance funds from DoD; the U.S. Departments Education, Health and Human Services, Labor, and Transportation; the Veterans Affairs; and the Nuclear Regulatory Commission (U.S. Department of Education, 2022). Advocates claimed that expanding the list of applicable funding would hold FPIs more accountable and discourage them from behavior that misrepresented their offerings to student veterans. The revised rule took effect in January 2023.

To enforce the 90/10 Rule, the U.S. Department of Education penalizes FPIs that violate the rule by making a FPI’s certification to participate in the Title IV programs provisional for up to two years (Hegji, 2021, p. 14–15). Under this provisional status, an FPI is required to meet additional conditions (e.g., additional reporting requirements). If the FPI fails to comply with the rule for two consecutive institutional fiscal years, it is no longer eligible to participate in the Title IV programs for at least two institutional fiscal years. Moreover, under the HEA, the U.S. Department of Education is required to publish the names of FPIs that are in violation of the rule on its College Navigator website (Hegji, 2021, p. 14–15). In effect, these consequences can push FPIs out of the higher education market.

Since the implementation of the 90/10 Rule, multiple Congresses have sought to amend the provision, including as recently as the first session of the 119th Congress. There were attempts to include a repeal of the 90/10 Rule in the 2025 reconciliation bill, colloquially referred to as the One Big Beautiful Bill Act (OBBBA), by some members of Congress to minimize market regulation and expand college choice, but this was met with strong opposition by veteran advocacy groups and was ultimately not included in the enacted Public Law 119-21. However, on July 7, 2025, the U.S. Secretary of Education reinterpreted the 90/10 Rule by allowing the inclusion of revenue from distance education programs that are ineligible for Title IV funding to count toward the 10 percent proportion of revenue from non-federal sources (U.S. Department of Education, 2025b). Although this modification does not alter the essence of the 90/10 Rule, it makes it easier for FPIs to maintain compliance.

In the context of Public Law 119-21, it is important to note that the 90/10 Rule is not the only higher education provision that may affect student veterans. Some of the Public Law 119-21 changes include

• expanding Pell Grant eligibility to include very short-term job training programs, which may improve college affordability for individuals pursuing technical or vocational education pathways
• implementing new accountability measures that tie both nonprofit institutions’ and FPIs’ Title IV eligibility to the median earnings of their graduates, which may affect some fields, such as traditionally low-paying jobs (e.g., education), more than others
• pausing implementation of the Biden administration’s Borrower Defense and Close School Discharge rule, which forgives federal student loans for students defrauded by institutions
• establishing new annual and lifetime borrowing limits for graduate students, which may affect individuals differently, depending on their desired field or career
• phasing out existing repayment plans and replacing them with two new plans (Public Law 119-21, 2025).

Although some changes, such as those related to graduate student borrowers and the two new repayment plans, may be less relevant to student veterans, given the benefits of the PGIB, Public Law 119-21 may affect how student veterans access college and how institutions support them. Policymakers and educational administrators and practitioners may wish to consider their implications in the context of student veterans’ educational and workforce pathways.

Student Veterans Report Poor Experiences and Weaker Outcomes at For-Profit Institutions

FPIs are options for student veterans seeking flexible educational and training programs that are tightly linked to opportunities in the workforce (Steele, 2012). FPIs can play a critical role for student veterans who have goals, needs, and challenges that may not be met and addressed by other types of institutions (e.g., a veteran who is a single parent, works full-time, and requires a streamlined program).⁠^[4] Longitudinal evidence from a sample of students earning bachelor’s degrees in 1993 (and tracked for a decade), 2000, and 2008 (the latter two groups tracked for one year after graduation) demonstrates that student veterans who earn bachelor’s degrees from FPIs did not experience employment or earning penalties relative to students who earned bachelor’s degrees from NPIs (Steele, Buryk, and McGovern, 2018).

However, recent descriptive and cross-sectional research shows that FPIs report less favorable student veteran and workforce outcomes compared with NPIs (Radford et al., 2024). For instance, veterans who used their PGIB benefits to enroll in a four-year degree at FPIs in 2018 were 15 percent less likely to complete their educational goals. Veterans who completed their bachelor’s degrees at FPI programs earned 13 to 15 percent less than their counterparts from public institutions and, furthermore, paid more at FPIs than NPIs. Similar negative earning trends also occurred for veterans pursuing nondegree programs (e.g., dental assistant) at FPIs. These observations suggest that FPIs may not be performing in a manner aligned with veteran expectations and VA standards, especially because program completion rates and postprogram earnings are key metrics in determining a program or institution’s return on investment (Delisle and Cohn, 2024).

Some FPIs have also engaged in illegal practices and behaviors that deceived veterans (Cottom, 2017; Veterans Education Success, 2025). Whistleblowers and former staff at FPIs have described the intense pressure to recruit veterans by using aggressive tactics that convince them to enroll; lying to them that their benefits would cover the costs of the program when, in fact, their type of GI Bill fully covers tuition only at public universities; and taking out loans on students’ behalf without their knowledge to cover that difference (Veterans Education Success, 2022). Former student veterans also reported that their institutions delivered subpar curriculum and instruction that left them unprepared for their intended vocations and exhausted their PGIB benefits (U.S. Attorney’s Office, Northern District of Texas, 2021). Some veterans also found it confusing that institutions engaging in malpractices were even approved by VA, the source for determining program eligibility for veterans.⁠^[5] These tactics can be especially effective when individual veterans may not be familiar with the U.S. higher education landscape or lack the experience to evaluate institutional and program quality.

Even though the 90/10 Rule aims to discourage waste by preventing poorly performing FPIs from receiving federal education assistance funds, the impact of the 90/10 Rule on student veterans is not yet clear. A 2019 study by Brookings demonstrated that the elimination of the 90/10 Rule would likely lead to increased “enrollment at lower-quality institutions and increase[d] defaults” (Lee and Looney, 2019, p. 2). Another study found that one year after violating the rule, FPIs were likely to increase tuition and fees, expand short-term program offerings that allows FPIs the flexibility to modify their 90/10 ratio for compliance, and have a higher likelihood of closure (Ward, 2019). Although both studies bring clarity to the extent to which the rule is achieving its purpose, the implications for student access and college choice remain an important area for future inquiry.

Directions for Future Research and Policy

Future research is necessary to better understand the impacts of the 90/10 Rule. Even though the rule is meant to protect students from fraud and harm, the rule may have implications for institutional performance, access and college choice. Other rules, such as Gainful Employment, which holds primarily FPIs accountable for their graduates’ financial outcomes, may have similar and simultaneous impacts on FPIs, but the distinct effects of these different policy levers are unclear. The following are three possible directions for institutions and researchers to consider.

Understanding the Impact of the 90/10 Rule on For-Profit Institution Performance

Research is unclear on the impact the rule has on institutional performance. Future studies could assess the extent to which student and employment outcomes improved following changes in rules, particularly following the two-year provisional period or after the two years of Title IV ineligibility. Studies could also document students’ perceptions of program quality and career readiness in those periods to understand if these penalties matter to students.

Understanding the For-Profit Institutions That Violate the 90/10 Rule and the Students Who Attend Them

Opponents of the 90/10 Rule argue that it limits college access and choice, but the research is unclear about this matter, especially because more than 50 percent of Title IV institutions are broad access or open enrollment institutions (e.g., community colleges, technical schools) (National Center for Education Statistics, 2024b). Yet, little is known about the FPIs that violate the rule and the students who attend them. Future studies might explore what student veterans lose (e.g., the only program in their area of study in their region) when these institutions are no longer eligible to receive federal funds and help develop an understanding of the student veterans choosing to attend those schools. Findings could help inform how VA and other relevant stakeholders counsel veterans on navigating the college and program choice process.

Estimating the Distinct Effects of the 90/10 Rule

As mentioned previously, the 90/10 Rule is not the only regulation that impacts student veterans. Gainful Employment, further amplified by OBBBA’s latest accountability measures, ties student earnings to Title IV eligibility. Because FPIs are subject to both rules, researchers should leverage longitudinal data from the Integrated Postsecondary Education Data and National Student Loan Data systems to employ a study that disentangles each rule’s effects on student veterans’ enrollment, completion, employment outcomes, and debt loads. Findings may highlight the differential impacts of each rule and assess the extent to which they are adding value or redundant as related to student veteran educational and workforce outcomes.

Notes

1. Executive Order 14347, signed September 5, 2025, authorized the use of Department of War as a secondary name for the Department of Defense. This publication was written before that order was released and thus refers to the secretary and department by their current statutory names under Public Law 81-216, National Security Act Amendments of 1949. Return to content ⤴
2. Both MGIB-SR and MGIB-AD provide benefits to those whose service began or continued after July 1, 1985, and issue one direct monthly payment to cover such expenses as tuition, books, and supplies; however, for MGIB-SR benefits, the individual must remain with the Selective Service for benefits to continue. PGIB is the most extensive education benefit of the three programs and is for veterans who served on active duty after September 10, 2001. For a full detailed description of VA’s eligibility criteria, see the specific programs at VA, 2024. Return to content ⤴
3. The federal government did not start monitoring FPIs until the 1976–1977 school year. Return to content ⤴
4. See RAND Corporation (2024) for more details on the educational pathway challenges that student veterans who are single parents face. Return to content ⤴
5. To be eligible for payments of VA education benefits, education and training programs are required to go through their State Approving Agency (SSA). Approval requirements are similar for both accredited and nonaccredited institutions, including application submission, a catalog of institutional policies (e.g., graduation, tuition or fees), written records of review and appropriate credit for prior training, and additional criteria as requested by the SSA. Nonaccredited institutions may be asked to submit additional information, such as financial status and enrollment policies (VA, 2025). Return to content ⤴

References

• Cellini, Stephanie Riegg, “For‐Profit Colleges in the United States: Insights from Two Decades of Research,” Brown University, Annenberg Institute, EdWorkingPaper No. 21-398, May 2021. As of October 20, 2025: https://edworkingpapers.com/sites/default/files/ai21-398.pdf
• Cottom, Tressie McMillan, Lower Ed: The Troubling Rise of For-Profit Colleges in the New Economy, New Press, 2017. As of October 22, 2025: https://thenewpress.org/books/lower-ed/?v=eb65bcceaa5f
• Delisle, Jason, and Jason Cohn, College Completion and Earnings, Urban Institute, Center on Education Data and Policy, January 2024. As of October 17, 2025: https://files.eric.ed.gov/fulltext/ED654108.pdf
• Geiger, Roger L., The History of American Higher Education: Learning and Culture from the Founding to World War II, Princeton University Press, 2016. As of October 20, 2025: https://press.princeton.edu/books/paperback/9780691173061/the-history-of-american-higher-education
• Hegji, Alexandra, The 90/10 Rule Under HEA Title IV: Background and Issues, Congressional Research Service, R46773, April 26, 2021. As of October 17, 2025: https://files.eric.ed.gov/fulltext/ED614219.pdf
• Kamarck, Kristy N., and Clayton M. Levy, Military Tuition Assistance Program: Background and Issues, Congressional Research Service, R47875, updated June 11, 2025. As of October 17, 2025: https://www.congress.gov/crs_external_products/R/PDF/R47875/R47875.4.pdf
• Kinser, Kevin, “From Main Street to Wall Street: The Transformation of For-Profit Education,” ASHE Higher Education Report, Vol. 31, No. 5, 2006. As of October 22, 2025: https://eric.ed.gov/?id=EJ791615
• Lee, Vivien, and Adam Looney, Understanding the 90/10 Rule: How Reliant Are Public, Private, and For-Profit Institutions on Federal Aid? Brookings Institution, Center on Regulation and Markets, January 2019. As of October 17, 2025: https://www.brookings.edu/wp-content/uploads/2019/01/ES_20190116_Looney-90-10.pdf
• National Center for Education Statistics, Table 317.10, Degree-Granting Postsecondary Institutions, by Control and Level of Institution: Selected Academic Years, 1949–50 Through 2022–23, Digest of Education Statistics, January 2024a.
• National Center for Education Statistics, “The Total Number of Higher Education Institutions Decreases by 2 Percent,” press release, August 21, 2024b.
• New America, “Regulatory and Legislative History of Short-Term Programs,” webpage, undated. As of October 17, 2025: https://www.newamerica.org/education-policy/reports/short-memories-lead-long-term-consequences-higher-education-policy/regulatory-and-legislative-history-of-short-term-programs/
• Public Law 89-329, Higher Education Act of 1965, November 8, 1965, as amended through Public Law 119-21, July 4, 2025. As of October 20, 2025: https://www.govinfo.gov/content/pkg/COMPS-765/pdf/COMPS-765.pdf
• Public Law 102-325, Higher Education Amendments of 1992, July 23, 1992. As of October 20, 2025: https://www.congress.gov/102/statute/STATUTE-106/STATUTE-106-Pg448.pdf
• Public Law 110-315, Higher Education Opportunity Act, August 14, 2008. As of October 20, 2025: https://www.congress.gov/110/statute/STATUTE-122/STATUTE-122-Pg3078.pdf
• Public Law 117-2, American Rescue Plan Act of 2021, March 11, 2021. As of October 20, 2025: https://www.congress.gov/117/plaws/publ2/PLAW-117publ2.pdf
• Public Law 119-21, An Act to Provide for Reconciliation Pursuant to Title II of H. Con. Res. 14 [previously known as the One Big Beautiful Bill Act], July 4, 2025. As of October 20, 2025: https://www.congress.gov/119/plaws/publ21/PLAW-119publ21.pdf
• Radford, Alexandria Walton, Paul Bailey, Amber Bloomfield, Naomi Rockefeller, Bruce H. Webster, Jr., and Hyo C. Park, Post-9/11 GI Bill Benefits: How Do Veterans’ Outcomes Differ Based on the Type of Education They Received? And How Are Veterans Who Have Not Used Their Education Benefits Faring? American Institutes for Research; U.S. Census Bureau; and U.S. Department of Veterans Affairs. National Center for Veterans Analysis and Statistics, July 2024. As of October 17, 2025: https://air.org/sites/default/files/2024-07/pgib-outcomes-by-use-enrollment-characteristics.pdf
• RAND Corporation, “Meeting the Changing Needs of Veterans: Insights from Student Veterans Who Are Single Parents,” RAND Corporation, RB-A1363-2, 2024. As of October 20, 2025: https://www.rand.org/pubs/research_briefs/RBA1363-2.html
• Rosenbaum, James E., Regina Deil-Amen, and Ann E. Person, After Admission: From College Access to College Success, Russell Sage Foundation, 2007.
• Salemme, Christopher J., “Unpatriotic Profit: How For-Profit Colleges Target Veterans and What the Government Must Do to Stop Them,” Brigham Young University, Journal of Public Law, Vol. 32, No. 1, 2017. As of October 20, 2025: https://heinonline.org/HOL/Page?handle=hein.journals/byujpl32&div=7&g_sent=1&casa_token=&collection=journals
• Steele, Jennifer L., Military Veterans’ Experiences in For-Profit Higher Education, RAND Corporation, CT-376, 2012. As of October 17, 2025: https://www.rand.org/pubs/testimonies/CT376.html
• Steele, Jennifer L., Peter Buryk, and Geoffrey McGovern, “Student Veterans’ Outcomes by Higher Education Sector: Evidence from Three Cohorts of the Baccalaureate and Beyond,” Research in Higher Education, Vol. 59, January 2018. As of October 20, 2025: https://link.springer.com/article/10.1007/s11162-017-9491-x
• Thelin, John R, A History of American Higher Education, 3rd ed., Johns Hopkins University Press, 2019. As of October 20, 2025: https://press.jhu.edu/books/title/12165/history-american-higher-education
• Tierney, William G., and Guilbert C. Hentschke, New Players, Different Game: Understanding the Rise of For-Profit Colleges and Universities, Johns Hopkins University Press, 2007.
• U.S. Attorney’s Office, Northern District of Texas, “For-Profit Trade School Sentenced to Nearly 20 Years for Defrauding VA, Student Veterans,” press release, September 22, 2021. As of October 17, 2025: https://www.justice.gov/usao-ndtx/pr/profit-trade-school-sentenced-nearly-20-years-defrauding-va-student-veterans
• U.S. Department of Education, 90/10 Public Hearing, October 26, 2021. As of October 20, 2025: https://www.ed.gov/sites/ed/files/policy/highered/reg/hearulemaking/2021/9010hearoct26.pdf
• U.S. Department of Education, “List of Federal Education Assistance for Proprietary Institutions of Higher Education to Include as Federal Revenue,” Federal Register, Vol. 87, No. 244, December 21, 2022. As of October 20, 2025: https://www.federalregister.gov/documents/2022/12/21/2022-27732/list-of-federal-education-assistance-for-proprietary-institutions-of-higher-education-to-include-as
• U.S. Department of Education, “90/10 Rule Failures,” webpage, June 3, 2025a. As of October 20, 2025: https://collegecost.ed.gov/ninety-ten
• U.S. Department of Education, “Clarification of Revenue Under Title IV,” Federal Register, Vol. 90, No. 127, July 7, 2025b. As of October 20, 2025: https://public-inspection.federalregister.gov/2025-12554.pdf
• U.S. Department of Veterans Affairs, Education, undated. As of October 20, 2025: https://www.benefits.va.gov/REPORTS/abr/docs/2024-education.pdf
• U.S. Department of Veterans Affairs, “About GI Bill Benefits,” webpage, last updated November 29, 2024. As of October 20, 2025: https://www.va.gov/education/about-gi-bill-benefits/
• U.S. Department of Veterans Affairs, “Education and Training,” webpage, last updated June 4, 2025. As of October 20, 2025: https://benefits.va.gov/gibill/School_Program_Approval.asp
• VA—See U.S. Department of Veterans Affairs.
• Veterans Education Success, Veterans with Student Loans They Never Authorized or Wanted, March 2022. As of October 20, 2025: https://vetsedsuccess.org/veterans-with-student-loans-they-never-authorized-or-wanted/
• Veterans Education Success, Lessons for Title IV from an Analysis of GI Bill Outcomes, May 2025. As of October 17, 2025: https://vetsedsuccess.org/lessons-for-title-iv-from-an-analysis-of-gi-bill-outcomes/
• Ward, James D., “Intended and Unintended Consequences of For-Profit College Regulation: Examining the 90/10 Rule,” Journal of Student Financial Aid, Vol. 48, No. 3, July 2019. As of October 20, 2025: https://ir.library.louisville.edu/cgi/viewcontent.cgi?article=1649&context=jsfa

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