November 20, 2014 ♦
Sanibel Harbour Marriott Resor t and Spa
♦
For t Myers, Florida
FLORIDA ASSOCIATION OF
STUDENT FINANCIAL AID
ADMINISTRATORS
Betsy Wickham
Bureau Chief
Florida Dept. of Veterans’ Affairs State Approving Agency
Katherine Snyder
Program Specialist Florida Dept. of Veterans’ Affairs State Approving Agency Flight Chairperson, NASAA
2014-2015 Clock Hour Workshop
State Approving Agency, VA and
NCD Schools
SAA and VA Functions
2014 Veteran-Related Florida Legislation
Education, Training and Employment Resources
Principles of Excellence
Compliance
Centralized complaint system
Catalog Approval Process
Compliance Surveys
Guidance for most common issues
2
3
State Approving Agency
and VA Functions
SAA
The SAA was established to ensure that veterans or eligible
dependents can use the GI Bill in an educational program that meets certain minimum requirements for quality, relevance and stability
The primary function of the Florida SAA is to review, evaluate
and approve quality educational and training institutions and programs for veterans’ benefits
Promotes and safeguards quality education and training
programs for veterans
Ensures greater educational opportunities to meet the needs of
veterans
Assists VA in preventing fraud, waste and abuse in the
administration of the GI Bill
Interprets and enforces state rules that directly impact the
administration of the GI Bill
4
SAA Functions
SAA
Approves programs for VA educational benefits
Answers questions regarding rules, policies and procedures Ensures compliance with established standards
Assists VA in conducting compliance surveys (as of 10/01/2011) Is under contract with VA for all work conducted (VA reimburses
the state for cost of all SAA salaries, fringe benefits, and travel costs with an allowance for administrative costs)
VA
U.S. Department of Veterans Affairs (VA) administers federal
programs nationwide for veterans and is responsible for the payments
Answers questions regarding payment and entitlement as well as
rules, policies and procedures and provides training for the same
Conducts compliance surveys
Reviews approvals submitted by SAA and enters them into VA’s
central school data system, WEAMS
5
SAA Functions
SAA and VA Collaborate in:
Maintaining integrity of programs
Training of School Certifying Officials (SCOs)
Encouragement of greater use of VA benefits
Helping schools better serve veterans and their dependents
Promoting and enabling information exchange between
school officials regarding best practices
6
SAA Functions
Schools – contact the SAA for:
Approval questions
Catalogs, addenda, programs, policies, procedures New facilities
Training
Changes in accreditation, ownership, address
Students – contact the SAA for:
Outreach questions
Explain the approval process and what may or may not be
approved
Follow up on complaints made by students against facilities Provide guidance as to where to go for assistance
Note: Cannot provide assistance regarding payments of benefits 7
SAA
Schools – contact the VA Florida Outreach Office for:
Interpretation of VA rules, policies, procedures and
regulations
To initiate or make changes in EFT
Changes in SCO
Procedures to follow to handle special situations
Note: Do not contact for debt questions
Students:
Students should not contact the Florida Outreach Office
since their mission relates to compliance and approvals.
For questions related to education claims, remaining
benefits, payment issues, etc., students should contact VA
via phone or web (see Slide 15)
8
VA – Florida Outreach Office
9
SAA facilitates use of VA
benefits, Florida veteran benefits
and employment resources
10
2014
Veteran-Related
Florida Legislation
Florida GI Bill - HB 7015
Out-of-State Tuition Waivers to student veterans
Veterans’ Preference in state employment
Residency requirement for state Veteran Nursing Homes
Expands Florida National Guard education program
Creates nonprofit organization, Florida is for Veterans, Inc.
Florida - HB 851; SB 1400
Purple Heart Tuition Waivers at Technical Education Centers
Florida - HB 5001
Honorably Discharged Graduate Assistance Program (HDGAP)
11Veteran-Related Florida Legislation
Effective July 1, 2014
12
Veteran-Related Florida Legislation
Effective July 1, 2014
Item passed within HB 7015 Additional Details
Out-of-State tuition waiver for veterans Creates the ‘Congressman C.W. Bill Young Veteran Tuition Waiver Program’ waiving out-of-state fees for honorably discharged veterans who reside in Florida.
Active Duty and in-state tuition
FS 1009.21 The following persons shall be classified as residents for tuition purposes: Active duty members of the Armed Services of the U.S. residing or stationed in Florida, their
spouses and dependent children and active drilling members of the Florida National Guard; Active duty members of the Armed Services and their spouses and dependents attending a College System institution or state university in Florida within 50 miles of the military establishment where they are stationed, also outside of Florida, if it is within a county contiguous to Florida
13
Veteran-Related Florida Legislation
Effective July 1, 2014
Item passed within HB 7015 Additional Details
Expands Veterans’ Preference in state employment
(see current: FS 295.07, 295.08, 295.085)
In addition to current Veterans’ Preference in employment in Florida, Veterans’
Preference has been expanded to include: All honorably discharged veterans;
Current members of the Florida National Guard and U.S. Armed Forces Reservists; The mother, father, legal guardian, or unremarried widow or widower of a
member of the US Armed Forces who died in the line of duty under combat-related conditions;
14
Veteran-Related Florida Legislation
Effective July 1, 2014
Item passed within HB 7015 Additional Details
Residency requirement for state veteran
nursing homes Removes one-year residency requirement for acceptance into one of the six state nursing homes in Florida
Florida National Guard Educational Dollars
for Duty (EDD) Program Appropriates $1.53 million in recurring funds to the Department of Military Affairs to fund EDD tuition scholarships and book stipends for National Guard members and $250,000 in nonrecurring funds for
15
Veteran-Related Florida Legislation
Effective July 1, 2014
Item passed within HB 7015 Additional Details
Florida is for Veterans, Inc. Creates a nonprofit corporation within FDVA to promote Florida as a veteran-friendly state. The corporation will
encourage and assist retired and recently separated military personnel to keep or make Florida their permanent residence and help equip veterans for employment opportunities and promote veteran hiring
16
Veteran-Related Legislation
Effective July 1, 2014
Item passed in HB 851; SB 1400 Additional Details
Purple Heart Tuition Waiver Grant tuition waivers at State Technical Centers for recipients of the Purple Heart or other combat decorations superior in precedence
Purple Heart Waiver
FS 1009.26 Effective July 1, 2006; Provides a fee waiver to recipients of the Purple Heart or other combat decoration superior in
precedence if the recipient enrolls in a Florida public community college or state university
Honorably Discharged Graduate Assistance Program (HDGAP)
House Bill 5001 signed into law June 2, 2014
Commencing Fall, 2014 – Appropriated $1,000,000 for
supplemental need-based aid to assist in the payment of
supplemental living expenses during holiday and semester breaks. The annual maximum award - $50/day for up to 20 days during holidays and semester breaks. To be eligible a student must:
be a Florida resident;
be enrolled in a program of study (in term prior to break and
next future term);
be an active duty or honorably discharged member of
the Armed Forces who served on or after September 11, 2011;
complete an error-free FAFSA;
have sufficient unmet need (award may not exceed need) 17
State of Florida
Honorably Discharged Graduate Assistance Program
(HDGAP)
October 24, 2014
Letter from FLDOE to Financial Aid Directors
November 15, 2014
Deadline for postsecondary institutions to
submit allocation request
Allocations to institutions first-come, first-served
FLDOE Contact:
Nanette.Smith@fldoe.org
or 888-827-2004
18
State of Florida
Veteran Dependents
The Florida Department of Education Office of Student
Financial Assistance
www.floridastudentfinancialaid.org
offers:
Scholarships for Children and Spouses of Deceased or
Disabled Veterans who entered the military from the state of
Florida – it essentially pays all tuition and fees
Beneficiaries may also receive VA Chapter 35 benefit
19
State of Florida
Veterans Access, Choice and Accountability Act of 2014
Stay tuned…
20
State of Florida
Florida Benefits Guide
http://floridavets.org
Florida benefits for active duty:
http://myarmybenefits.us.army.mil/Home/Benefit_Library/S
tate__Territory_Benefits/Florida.html#top
Tracking Florida Bills:
http://flsenate.gov/Session/Bills
FDVA Contact: Bobby Carbonell, Florida Department of Veterans’ Affairs Legislative and Cabinet Affairs Director
CarbonellR@FDVA.STATE.FL.US
21
22
Veterans
The Florida Department of Economic Opportunity
provides job placement services for all veterans
Upon leaving the military and/or graduating from school,
veterans should register on the Employ Florida Marketplace
website shown below
https://www.employflorida.com
Within two weeks of registration, veterans will be contacted
by a LVER or DVOP (Local Veterans’ Employment
Representative and Disabled Veterans’ Outreach Person)
The goal is to assist each veteran to find employment within
six months from date of registration
23
Veterans’ Job Training Assistance
24
Executive Order 13607 “Establishing Principles of Excellence
for Educational Institutions Servicing Servicemembers,
Veterans, Spouses and Other Family Members”
Signed by President Obama on April 27, 2012
SAA and VA began incorporating into compliance surveys as part
of the review process beginning October 1, 2013
Program is entirely voluntary
Not participating or not adhering if signed may lead to a school
receiving bad publicity, but there are no civil or criminal penalties for not participating or for not adhering if signed
As indicated in the
www.benefits.va.gov/gibill
website,
educational institutions participating in the PoE program
agree to certain guidelines
25
Principles of Excellence
SAA and VA must review certain items regarding PoE during
a compliance survey visit
Use of the GI Bill Comparison Tool to determine if a school
participates in the PoE
Comparison Tool/GI Bill Estimator website:
http://department-of-veterans-affairs.github.io/gi-bill-comparison-tool/
Allows veterans and family members to make informed decisions
by:
Researching approved educational institutions
Calculating estimated GI Bill benefits
26
Principles of Excellence
27
Principles of Excellence
28
Principles of Excellence
Compliance
School agreed to: During compliance survey, SAA and VA
check to see whether school:
Provide students with a personalized form covering the total cost of an education program
Provided a Financial Aid Shopping Sheet
http://www2.ed.gov/policy/highered/guid/aid-offer/index.html
Provide educational plans for all military and
veteran education beneficiaries Informed, or has policies to alert, students of the availability of federal financial aid prior to arranging other financing
End fraudulent and aggressive recruiting
29
Principles of Excellence
Compliance
School agreed to: During compliance survey, SAA and VA
check to see whether school:
Accommodate servicemembers and
reservists absent due to service requirements Readmits servicemembers and reservists into programs if they are temporarily unable to attend class or have to suspend their studies due to service requirements and
accommodations made for short absences resulting from service obligations
Designate a point of contact to provide
academic and financial advice Has a point of contact for academic and financial advising to assist servicemember and veteran students and their families Ensure accreditation of all new programs
prior to enrolling students Obtained the approval of its accrediting agency for new course offerings prior to enrolling students in such courses or programs
30
Principles of Excellence
Compliance
School agreed to: During compliance survey, SAA and VA
check to see whether school:
Align institutional refund policies with those under Title IV, which governs the
administration of federal student financial aid programs
Has a refund policy that is aligned with the refund of unearned student aid rules
applicable to federal student aid provided through the Department of Education under Title IV
Provide educational plans for all individuals using Federal military and veterans
educational benefits that detail how they will fulfill all the requirements necessary to
graduate and the expected timeline of completion
Check to see if the school provides detailed educational plans outlining graduation
VA and DoD created a system for individuals currently using
VA education benefits* to register complaints against
educational institutions for fraudulent, deceptive and
misleading practices
Tracked to educational institution with responses provided to the
complainant
Initiative is part of implementation of E.O. 13607 and Public Law
112-249 “Improving Transparency of Education Opportunities for Veterans Act of 2012”
Launched on January 30, 2014
*For those individuals not using VA education benefits, complaints are to be filed with the appropriate agency
31
Principles of Excellence
VA GI Bill Feedback System (aka Complaint System)
www.benefits.va.gov/gibill/feedback.asp
Complaints accepted through a webform (Principles of
Excellence Complaint Intake Questionnaire) and the Education
Service National Call Center
Complaints to VA Central Office → Appropriate Agency
(DoD, ED, Consumer Protection Bureau, DoJ, and the FTC)
Complaints also filtered for possible distribution to VA ELR
(Ron Scoggins in FL) → if not handled by ELR, then
distributed to State Approving Agency
Some complaints will be routed directly to the school by VA
Central Office. This procedure is still being worked out
Complaint system may be utilized for PoE
and
non-PoE
schools alike
32
Principles of Excellence
Based upon complaint system and compliance survey
analyses, some schools will require a risk-based review
VA Central Office (VACO) will do the analyses and determine
which schools must be surveyed based upon the risk
The schools identified will be added to the annual compliance
survey schedule or, if already scheduled, their survey may be moved up on the schedule
Factors considered under risk-based analysis include:
Complaint(s) received
Previous compliance survey data Management mandates
Information received from other government agencies and regulators Law suits against the institution
Facility self-reported violations
33
Principles of Excellence
34
Catalogs and addenda must be submitted to the SAA
Part of initial approval criteria
Maintenance of approval for the training of veterans and
other eligible persons
35
SAA frequently sends catalog reminder letters;
however, timing is based upon expiration date assigned
to last catalog approved
Expiration date based upon academic calendar and/or other
dates within catalog
If another catalog or addendum is published prior to the
expiration date, school must submit within 30 days of
publication
If not, risk suspension or withdrawal for lack of compliance
36
Submit catalog and any addenda to the State Approving
Agency (SAA) within 30 days of publication
CD is preferred medium
Information contained in catalog, bulletin, student
handbook, supplements and addenda must be certified as
true and correct in content and policy as required by
38 CFR
§
21.4253
The following statement must accompany and reference any of
the above mentioned items: “I hereby certify all information contained in the [specify catalog and/or other items] is true and correct in content and policy”; dated and signed by official signatory of the school
Cover letter
Signed CD or label
Inside front cover if hard copy
37
Once SAA in receipt of catalog, it is logged in for processing
SAA has 14 business days to determine if catalog and/or
addenda are approved or denied
Approval or denial letter sent to specific campus where
schools have multiple campuses with separate catalogs
Read letter carefully to ensure accuracy and understanding
If questions, contact the SAA
If new programs, do
not
certify in VA-ONCE until WEAMS
(aka VA Form 22-1998) has been updated by VA (VA will mail
a copy to school)
Veterans Claims Examiners (VCEs) will deny benefits for a
program they do not see in WEAMS
Ensure VA-ONCE reflects program name exactly as it appears in
WEAMS
38
Catalog Review and Approval
Date of approval = date letter was generated
Effective date of approval = date the catalog or
addenda went into effect
Unless school has requested extension for last catalog
approved, if we see an effective date more than 30 days
beyond the date of publication, school is not in compliance
Appropriate section of law is checked
Chapter 36, Title 38, USC, Section 3675 applies to accredited
courses/programs
Ensure any new programs are accredited prior to certifying any
VA student
39
SAA Approval Letter
Specific catalog, year, publication date and any
addenda will be reflected as to what is being approved
along with an “approved through” or “expiration” date
Specific programs will be listed
Noncollege degree (NCD) programs
Diploma or certificate
Programs not leading to a standard college degree must NOT be
certified to VA if taught in whole or in part in an independent study, distance learning, online, blended or hybrid format
40
SAA Approval Letter
Page number of where within the catalog the program
information is located
Appropriate type of hours will be specified
New NCD programs will have a Class or Shop
designation (an “X” will be marked in the appropriate
column)
This will be the determining factor as to what will be
considered full-time for a program
Page Clock Hrs. Class Shop NCD Program Name 57 750 X
41
SAA Approval Letter
42
Routine reviews of selected students’ records to:
Verify that payments of GI Bill benefits were properly made
to your VA students
Ensure schools and training establishments, along with their
approved courses and programs, are in compliance with all
federal and state requirements for administering VA
programs
Give an opportunity to provide training
Monitor and assure continued acceptability of approval for
previously approved facilities
43
Compliance Surveys
VA will establish and maintain a schedule of compliance
surveys and inform SAA of schools to visit
Schedules will be prepared before the beginning of
each fiscal year
Certain number of schools assigned to the SAA
by the
ELR; VA retains the balance
Visits conducted at schools with veterans enrolled
during the federal fiscal year (October - September)
44
Compliance Surveys
Each fiscal year, the following active (have VA students
enrolled) facilities are to be surveyed:
100% of facilities with 300 or more VA students 100% of NCD, OJT, Apprenticeships and Flight Additional surveys as determined by VA
Because of staffing limitations, it is not feasible for most VA
offices and SAAs to survey all of those schools; therefore,
some schools that have had few or no errors may receive a
waiver of compliance visit for up to two (2) years
This does not mean schools that fall into the categories of error
rates on the next slide will receive an automatic waiver
A certain percentage of the facilities must be surveyed regardless
as to how many may qualify for a waiver…
45
Compliance Surveys
Percentage (cont.)
At least 60% of schools with 300 or more VA students
At least 60% of active NCD schools
At least 50% of active Flight schools
At least 25% of active OJTs and Apprenticeships
Within those parameters, facilities with the following error
rates may be
considered
for a waiver of compliance visit
10 or less records reviewed - 0 errors
15- 20 records reviewed - 1 error
25- 35 records reviewed -2 errors
40 - 45 records reviewed - 3 errors
Still must meet certain percentage of schools to visit – not all
schools meeting above criteria may be eligible
Error: For the purpose of waiver assessment an error is defined as a reporting error that results in an under or over-payment. 46
Compliance Surveys
Email, phone call or fax to inform you of our visit
Advance notice provided
Two to four weeks
Survey confirmation letter emailed or mailed
Confirm date and time of appointment
Provide SCO with names of student files required and
items/types of records to be reviewed
Schedule face-to-face interviews with students, if applicable
47
Compliance Surveys
Randomly selected
Roughly 10% of your VA student population
No fewer than 10 - unless fewer than 10 VA students have been
enrolled since the previous survey
At least one (1) non-VA beneficiary file
No more than 45 – unless sample expanded (samples are expanded
only to verify error rates where they are high and not obviously systemic)
48
Compliance Surveys
Allocated by currently enrolled within each chapter
49
Compliance Surveys
If you notice errors requiring corrective action prior to
survey, OK to submit through VA-ONCE
If errors are identified during visit, correction via:
VA-ONCE with assistance of surveyor
Referral to VA Muskogee Regional Processing Office
50
Compliance Surveys
Application for admission
Enrollment agreement/contract with school
Record of evaluation of prior credit/training
VA Forms – received (date-stamped) or submitted
Unofficial transcripts/grade reports/progress records
(your school)
Program outlines/tracking sheets
Attendance records
Enforce attendance policy
Registration information
Student account ledger – detailed
Scholarships listing
51
Compliance Surveys
Class schedules
Documentation showing LDAs
Catalog
Disciplinary documentation
Records of probation submitted to VA
Reporting of graduation/completion of program to VA
VA only wants reports of graduations that occur while the
student is receiving GI Bill benefits
Advertising
Documents verifying the school’s status regarding the
85-15% ratio
52
Compliance Surveys
VA work-study records, if applicable
VA tutorial assistance, including school’s verification of
the need for tutoring, qualifications of the tutor, and
reasonableness of the charges
Principles of excellence – documents and discussion
Yellow ribbon fund
Yellow ribbon allowed at IHLs and may include NCD programs
Not allowed at standalone NCD schools
Reporting fee fund…
53
Compliance Surveys
Are the reporting fees being appropriately
maintained/spent?
Effective August 1, 2011, VA requires all reporting fees to
be used exclusively in support of school efforts to certify
the enrollment of their VA students. VA strongly
encourages that those funds be used for SCOs to attend VA
and other VA-specific training conferences
Change in reporting fee amount
Public Law 113-175 – September 26, 2014
$12 → $9
$15 → $13 (advance pay)
Effective January 1, 2015
February 2015 payment will be impacted One year period – sunset provision
SEC. 406. RESTORATION OF PRIOR REPORTING FEE MULTIPLIERS.
54
Compliance Surveys
55
Compliance Surveys
General Areas of Review
Guidance for Common Items
Records & Accounts
Guidance
• The school must provide the records
and accounts of VA beneficiaries and other students for examination.
• 38 CFR 21.4209, 21.7307, 21.9770
• Review checklist provided to you by
SAA or VA (whoever is conducting the visit)
• Ensure applicable checklist items are
included in student file or made available at the time of the visit
• If you have any questions at all
regarding any of the items on the list please immediately contact the
person who will be conducting the survey
56
Compliance Surveys
General Areas of Review
Guidance for Common Items
Commencement of Courses
Guidance
• Checking to see if VA beneficiaries
commenced course on the date certified
• 38 CFR 21.4131, 21.4203, 21.5810,
21.5831, 21.7131, 21.7152, 21.7631, 21.7652, 21.9720
• If school certifies enrollment prior to
actual start date, must review to ensure student actually began on the date (s)he was certified to start
• Submit termination of
enrollment to VA if never attended
57
Compliance Surveys
General Areas of Review
Guidance for Common Items
Correct Program Certified
Guidance
• Checking to ensure VA beneficiaries
are enrolled in and pursing the program as certified
• 38 CFR 21.3030, 21.5131, 21.7130,
21.7630, 21.9710
• Review SAA approval letters
• Monitor WEAMS (22-1998) reports • Not approved unless appears on
WEAMS report
• Enter program in VA ONCE exactly as
approved in WEAMS (must be manually entered by the school)
• Ensure certification of correct
program
• Compare enrollment
agreement, transcripts,
registration records to what you certified
Guidance (cont.)
Course/Program name certified must match what is
listed in the WEAMS report (aka VA Form 22-1998)
Incorrect wording may impact whether payment is made
If WEAMS is correct, then update VA-ONCE
If WEAMS is incorrect, then submit a request to have it
updated with correct information
Program name must match what has been approved by
CIE or the school's accrediting agency
58
Compliance Surveys
General Areas of Review
59
Compliance Surveys
General Areas of Review
Guidance for Common Items
Previous Education & Training
Guidance
• Checking to ensure the school
maintains record of and has
evaluated previous education and training of VA beneficiaries, has granted credit as appropriate, and has reported the grant to the
beneficiaries
• 38 CFR 21.4253, 21.4254, 21.4263
• Maintain documentation in file
including all official transcripts from other institutions and the transfer credit review sheet (may be your school’s official transcript)
Previous Education and Training Guidance (cont.)
Schools must ask students to list all previous education
and training
To include where they attended, when they attended and in
what program(s) they were enrolled
Do not ask the student if they want any credit transferred in
– irrelevant; mandatory
Schools must evaluate that education and training
Must obtain all official transcripts
This includes all educational pursuit even where the student did
not utilize GI Bill benefits
60
Compliance Surveys
General Areas of Review
Previous Education and Training Guidance (cont.)
In most instances, schools must receive all transcripts:
Within two (2) semesters or the equivalent
Within 12 weeks if program is at least six (6) months long
Prior to the start of the course if less than six (6) months
long
If applicable, schools must grant credit and reduce
training time proportionately
Notify student and retain in student’s records
Schools must review credit for prior training based
upon their approved standards and policies, then grant
credit as those standards and policies dictate
61Compliance Surveys
General Areas of Review
Previous Education and Training Guidance (cont.)
Certain special exceptions (
must
consult with and
obtain prior written acknowledgment and permission
from ELR):
Student cannot obtain transcript from one school where it is
confirmed that there is no way any credit will apply to the
student’s current program because they do not have any course work that would apply, e.g., student was at a four year college that has no fire fighting program and student is now at NCD in a fire fighter program
Prior school is no longer in business and records are no longer
available
When schools close in Florida, they are required to deposit their records with the CIE. Such records may then be obtained from that agency
62
Compliance Surveys
General Areas of Review
Previous Education and Training Guidance (cont.)
Certain special exceptions (
must
consult with and
obtain prior written acknowledgment and permission
from ELR) – (cont.):
Current school has a recency of credit rule and has confirmed that
the student’s prior coursework was completed too long ago to accept under the current school’s published standards
63
Compliance Surveys
General Areas of Review
64
Compliance Surveys
General Areas of Review
Guidance for Common Items
Records
Guidance
• Checking to ensure the school
maintains accurate, current and complete records of enrollment
• 38 CFR 21.4253, 21.4254
• Maintain for at least three (3) years
from each student’s last date of attendance
65
Compliance Surveys
General Areas of Review
Guidance for Common Items
Accurate & Prompt Certifications
Guidance
• Checking to ensure the school
accurately and promptly reported enrollment, and tuition and fees
• 38 CFR 21.4203(e)(f)(g), 21.4204,
21.7156, 21.9735
• Enrollment periods
• Start and end dates • Tuition and fees
• Actual tuition charged • Allowable fees
• Clock hours
• Scheduled per week
• Timely - within 30 days of the latter
of the following:
• First day of class
• Student’s request for
Clock Hour Measurement – Are you reporting the
correct hours?
Certify the actual number of clock hours per week the
student is
scheduled
to attend, not the minimum it
takes to be full-time for VA purposes
Certified hours will be compared with those listed on the
enrollment agreement and actual class schedules
No averaging unless it does not change training time or rate
of pursuit (for full time/100% rate of pursuit students only)
66
Compliance Surveys
General Areas of Review
Clock Hour Measurement – Are you reporting the
correct hours? (cont.)
One clock hour = 60 minutes of instruction
Classroom/Theory
Allows for 10 minutes to change classes each hour, which
can be included in the total hours of instruction (must
deduct if not changing classes)
Also allows for 10 minutes to change subjects even if
students remain in the same classroom (e.g., finish talking
about gasoline motors and switch to studying diesel motors)
Shop Practice
Allowance for 15 minute break in morning; another in the
afternoon. Can be included in total hours of instruction.
Shorter breaks allowed for part-time enrollment.
67
Compliance Surveys
General Areas of Review
Clock Hour Measurement – Are you reporting the
correct hours? (cont.)
All clock hours reported to VA must exclude any lunch
or meal breaks
The morning and afternoon breaks may not be combined for
a half hour lunch
Averaging only allowed if the clock hours do not change
training time/ROP for full-time only.
Not allowed for less than full-time/100% ROP
68
Compliance Surveys
General Areas of Review
69
Compliance Surveys
General Areas of Review
Guidance for Common Items
Notification of
Terminations/Interruptions
Guidance
• Checking to ensure the school
promptly notified VA when beneficiaries terminated or interrupted training
• 38 CFR 21.4203, 21.7156, 21.9735
• Within 30 days of actual LDA prior to
interruption of training, e.g., leave of absence
Attendance Policy - Monitor
All NCD programs measured on a clock hour basis must
maintain attendance records for each class
A student’s schedule is not an attendance record and
not sufficient for this purpose
All instructor-led classes must have a roll book or other
record maintained by the instructor to verify each
student’s attendance
Often, a physical sign-in sheet is used for this purpose and is
sufficient as long as the class instructor maintains constant
control over it so that s/he actually observes the student
signing in
70
Compliance Surveys
General Areas of Review
Attendance Policy – Acceptable
Account for ea
rly departures, class cuts, tardies,
etc., for any portion of a class period will be
counted as _____ absence.
Students exceeding ______% total absences in a
calendar month will be terminated from their VA
benefits for unsatisfactory attendance.
71
Compliance Surveys
General Areas of Review
Attendance Policy – Acceptable (cont.)
In order to show that the cause of unsatisfactory
attendance has been removed, students must show
good attendance (as defined) for one calendar month
after being terminated for unsatisfactory attendance.
After such time, the student may be recertified for VA
education benefits, but only at the end of the
satisfactory attendance period, i.e., no retroactive
certifications.
The student’s attendance record will be retained in the
veteran’s file for SAA and USDVA audit purposes.
72
Compliance Surveys
General Areas of Review
Leave of Absence – How to Report
If the
begin and end
dates of the leave of absence
are
known:
Schools may submit an
amendment
to the original
certification that reflects the revised end date of the
enrollment period to align with the “new” projected
graduation date after factoring in the leave of absence.
Include a free text remark under “Other” stating the
following: “Student took a leave of absence from [enter
dates].”
Note:
If the student does
not
return
, submit a termination
using the last date of attendance prior to leave.
73
Compliance Surveys
General Areas of Review
Leave of Absence – How to Report (cont.)
If the end date of the leave of absence
is not
known:
Schools
are to submit a termination with the Reason for
Termination “Withdrawal or interruption (Non-college
Degree Programs Not On A Term Basis” and enter the last
date of attendance.
When the student resumes training, a new certification
(22-1999) should be submitted to include a free text remark
under “Other” stating the following: “Student is resuming
class after a leave of absence during [enter dates].”
74
Compliance Surveys
General Areas of Review
75
Compliance Surveys
General Areas of Review
Guidance for Common Items
Progress/Grades
Guidance
• Checking to ensure that accurate,
current and complete records of
progress or grades maintained for VA beneficiaries
• 38 CFR 21.4253, 21.4254, 21.4262,
21.4263
• Must include final grade for each
class/module/subject, record of withdrawal from any subject to include the LDA, records of re enrollment, etc.
76
Compliance Surveys
General Areas of Review
Guidance for Common Items
Satisfactory Progress
Guidance
• Check to ensure the school promptly
notified VA when beneficiaries did not progress satisfactorily according to the approved standards and
practices of the school.
• 38 CFR 21.4203(d), 21.4277
• This relates to standards of progress
for academics as well as attendance.
• Monitor records frequently enough
to be able to report unsatisfactory progress or attendance within 30 days of LDA of:
• Last date of attendance before
the student was found to be unsatisfactory for progress; or
• Last date of attendance before
the absence that caused the student to be unsatisfactory for attendance
Standards of Progress – Monitor and Enforce
Know and understand your SAA approved Standards of
Progress policy for VA students
Must relate to graduation requirements
For example, if a student must have a 2.0 cumulative GPA in
order to graduate, a standard of progress that only requires a 1.5 CGPA to remain satisfactory would not be acceptable
Ensure you are monitoring VA students’ progress
77
Compliance Surveys
General Areas of Review
Standards of Progress – Monitor and Enforce (cont.)
There must be a clear, definite point in time when a:
VA student will be placed on probation (cannot be indefinite
– usually no more than two terms, months, enrollment
periods, etc.)
Report probation through RightNowWeb
VA student’s enrollment will be terminated for not achieving
satisfactory progress
Law requires VA educational benefits be discontinued when
student fails to make satisfactory progress toward completion of training objective (Title 38, USC, Section 3675(b)(1))
Report termination for unsatisfactory progress through
VA-ONCE
78
Compliance Surveys
General Areas of Review
Standards of Progress – Monitor and Enforce (cont.)
Academic Probation
Promptly notify VA when a student is placed on probation
Via ‘Right Now Web’ (VA’s Internet Inquiry System in the “Ask a
Question” section of the GI Bill website)
https://gibill.custhelp.com/app/utils/login_form/redirect/ask
Notifications must include:
Student’s name in the text
VA file number in the text
“Academic Probation” in the subject line
Supporting documentation to be maintained in VA student files only If multiple students…
79
Compliance Surveys
General Areas of Review
Standards of Progress – Monitor and Enforce (cont.)
Academic Probation
(cont.)
If multiple students are being reported, you may submit a single
notification by using the spreadsheet (page 76 of the online SCO handbook or https://gibill.custhelp.com/app/answers/detail/a_id/1436/~/how-do-i-report-academic-probation%3)
https://gibill.custhelp.com/app/answers/detail/a_id/1436/kw/academic%20probation :
Advise students of counseling services available to them under
Chapter 36
http://www.benefits.va.gov/vocrehab/edu_voc_counseling.asp
Students complete VA Form 28-8832 80
Compliance Surveys
General Areas of Review
Standards of Progress – Monitor and Enforce (cont.)
Academic Suspension
SCOs must promptly report to VA when a student is no longer
meeting the standards of progress for your school
In VA-ONCE, specify reason as “Unsatisfactory Attendance, Conduct or
Progress”
LDA/Effective date defaults to end date of term
If the effective date is prior to the end of the enrollment period, you
must manually enter the LDA before unsatisfactory progress is found
If the student is not returning, you must still terminate
If the student is academically suspended and submits
documentation to appeal and the suspension status is overturned, you do not terminate the certification
81
Compliance Surveys
General Areas of Review
Standards of Progress – Monitor and Enforce (cont.)
Academic Suspension (cont.)
Schools often have policies whereby students are allowed
to petition/appeal the determination
If such a policy exists and student successfully petitions and is
granted readmission or continued financial aid:
Do not terminate the student’s enrollment if s/he is already certified for the subsequent term
Maintain documentation in the file (similar to what you would for Title IV purposes) and that student successfully appealed and was granted readmission
Specify all restrictions on the student’s enrollment as well as all other additional requirements the student must meet in order to remain satisfactory for progress
82
Compliance Surveys
General Areas of Review
Standards of Progress – Monitor and Enforce (cont.)
Academic Suspension (cont.)
Student may be recertified/benefits may be resumed only
after achieving satisfactory academic progress
If student reenrolls in same educational institution and in same
program; or
School must document that the cause of the unsatisfactory
progress (or attendance or conduct) has been removed
Maintain documentation in file; the fact that the school has recertified the student’s enrollment is evidence to the VCE that the school has found the cause of unsatisfactory progress has been removed/resolved
83
Compliance Surveys
General Areas of Review
84
Compliance Surveys
General Areas of Review
Guidance for Common Items
Reporting Changes
Guidance
• Check to ensure VA was promptly
notified of changes in clock hours and/or tuition and fees that would affect payment
• 38 CFR 21.4203, 21.7156(b), 21.9735
• 30 day rule
• Have system in place to ensure that
you are notified of those changes soon enough to report them within 30 days of the actual change
85
Compliance Surveys
Additional Areas of Review
Guidance for Common Items
Independent Study
Guidance
• Independent Study, Distance
Learning, Online, Hybrid and Blended courses must be approved in order to certify them to VA
• 38 CFR 21.4267
• NCD schools/clock hour
programs/flight: Such courses may not be approved for any of the
above formats under any circumstances
• Work with the Registrar (or other
appropriate office) to monitor course formats
• Make other individuals aware of VA
For VA purposes,
the term
Independent Study
is used
interchangeably with Online, Distance Learning,
Blended or Hybrid courses and programs
Such training/mode of delivery cannot be approved for
veterans’ training in any clock hour program under any
circumstances – Title 38 CFR 21.4267(f)
86
Not reporting changes or terminations
Not reporting net charges correctly
Late reporting of enrollment changes to VA
Failure to request, evaluate and grant credit/hours for
prior education and training
Certifying incorrect program name or type of training
Not reporting unsatisfactory progress or probation
Lack of institutional records to support certifications to
VA (attendance records, payment ledgers, etc.)
Certifying programs not approved by SAA or VA
87
Compliance Surveys
Conducted with SCO and others as school and auditor
sees fit
88Compliance Surveys
Exit Interview Recognize School Official’s Efforts Assist with Corrective Action & Provide Training Discuss every Discrepancy &Provide Site Visit Reports
Letter to school (sent to highest administrator with copy
to certifying official)
Identifies student records reviewed
Details any findings
Specifies corrective actions (if any) required by the school
or job training establishment
SAA and VA are audited, too
Random sample of compliance survey files are reviewed
each quarter for quality assurance
89
Compliance Surveys
Questions?
90
GI Bill website: http://www.benefits.va.gov/gibill/(for schools and veterans) Education Call Center: 1.888.442.4551 (veterans and dependents)
Muskogee, OK
7:00 a.m. – 7:00 p.m. (CST), Monday through Friday
SCO Hotline: for SCO use ONLY – contact SAA or ELR for number SCO Handbook (Updated September 30, 2014))
http://www.benefits.va.gov/GIBILL/docs/job_aids/SCO_Handbook.pdf
VA-ONCE Quick Reference Guide (Version 7, August 2014)
http://www.benefits.va.gov/GIBILL/docs/vaonce/VAONCE_SCO_PowerPoint_v7.pdf
VA-ONCE Guide for Flight Schools
http://www.benefits.va.gov/gibill/docs/vaonce/va-once_flight_training.pdf
Online School Official Training
http://www.benefits.va.gov/gibill/resources/education_resources/school_certifying_officials/online_sco_trainin g.asp
91
Right Now Web (VA’s Internet Inquiry System in the “Ask a Question” section of the GI Bill website): https://gibill.custhelp.com/app/utils/login_form/redirect/ask
(for schools and veterans)
Status of individual unusual/complex cases
Individual cases that have been pending for a longer than usual time
Hardship cases
Written response
VA Debt Management Center:
Email address: dmc.ops@va.gov Phone number: 800.827.0648
Florida Association of Veteran Education Specialists: www.flfaves.org
Scholarships for Children and Spouses of Deceased or Disabled Veterans:
www.floridastudentfinancialaid.org
92
Betsy Wickham, Bureau Chief
(727) 319-7401
wickhamb@fdva.state.fl.us
Cora Stagner, Office Manager
(727) 319-7402
stagnerc@fdva.state.fl.us
Florida Department of Veterans' Affairs
State Approving Agency for Veterans' Education and Training Mailing Address:
P.O. Box 31003
St. Petersburg, FL 33731
Physical Address:
9500 Bay Pines Boulevard, Room 214
Bay Pines, FL 33744 93
SAA
AREA I – To be determined
AREA II - Katherine Snyder (941) 979-2525
snyderk@fdva.state.fl.us
AREA III - Kelli Colborne (352) 422-5736
colbornek@fdva.state.fl.us
AREA IV - Madeline Mendez (954) 540-6542
mendezm@fdva.state.fl.us
AREA V - Dale Towery (954) 540-6157
toweryd@fdva.state.fl.us
94
SAA
95
SAA
Ron Scoggins – Lead Education Liaison Representative
ron.scoggins@va.gov
John Martin – Education Clerk
john.martin1@va.gov
MAILING ADDRESS: VA Regional Office
Attn: Education Outreach (272A) PO Box 1437
St. Petersburg, FL 33731 PHYSICAL ADDRESS: VA Regional Office
Attn: Education Services (272A) 9500 Bay Pines Boulevard
St. Petersburg, FL 33708
96
VA Contact Information
Wayne Feazell
donald.feazell@va.gov
Cynthia Kujawski
cynthia.kujawski@va.gov
Chuck Peterman
chuck.peterman@va.gov
Rick Robertson
rick.robertson@va.gov
97VA Contact Information
GI Bill website: http://www.benefits.va.gov/gibill/ (for schools and veterans)
Education Call Center: 1.888.442.4551 (veterans and dependents)
Muskogee, OK
7:00 a.m. – 7:00 p.m. (CST), Monday through Friday
SCO Hotline: for SCO use ONLY – contact SAA or ELR for number
Right Now Web (VA’s Internet Inquiry System in the “Ask a Question” section of the GI Bill website): https://gibill.custhelp.com/app/utils/login_form/redirect/ask
(for schools and veterans)
Status of individual unusual/complex cases
Individual cases that have been pending for a longer than usual time
Hardship cases
Written response
98
VA Debt Management Center:
Email address: dmc.ops@va.gov Phone number: 800.827.0648
Florida Association of Veteran Education Specialists: www.flfaves.org
Scholarships for Children and Spouses of Deceased or Disabled Veterans:
www.floridastudentfinancialaid.org
99
