What we have done since the VPP for Ed program was established is create district-owned iTunes accounts for each building/department specifically for these VPP purchases. We only install "district-purchased apps" on "district-owned devices" so we can police the licensing (not easily though *sigh* still waiting for an inexpensive mobile device management solution for that), but it at least guarantees continued district ownership of the licenses.
We thought about this and we have lawyers chewing on the language to confirm our assumptions on the matter, but it appears to be a in conflict with apple TOS to do this.
Excerpt from TOS
"You agree to provide accurate and complete information when you register with, and as you use, the iTunes Service ("iTunes Registration Data"), and you agree to update your iTunes Registration Data to keep it accurate and complete. You agree that Apple may store and use the iTunes Registration Data you provide for use in maintaining and billing fees to your Account."
The use of the word "you" in this portion of the TOS and the use of the words "your primary email" "your birth date" etc. in the appleid creation process seems to indicate that you are not actually able to create a generic accounts for abstract entities but that it must be for an actual individual.
It's been recommended by local sales reps that we do exactly what you are talking about, however no one will go on the record and say its ok to do it.