IHL & NCD FLIGHT TRAINING WORKSHOP

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June 2, 2015 ♦ Thirty Ninth Annual FAVES School Conference ♦ TradeWinds Resort St. Pete Beach, Florida C r e a t e d b y R o n S c o g g i n s & K a t h e r i n e S n y d e r J a n u a r y 2 0 1 4 R e v i s e d J u n e & O c t o b e r 2 0 1 4 . a n d J u n e 2 0 1 5

IHL & NCD

FLIGHT TRAINING

WORKSHOP

Ron Scoggins

Lead Education Liaison Representative US Dept. of Veterans Affairs

VA Central Office Southern Region

Katherine Snyder

Program Specialist Florida Dept. of Veterans’ Affairs State Approving Agency Flight Chair, NASAA

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TOPICS

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Getting Started

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Contracted Vocational Flight School Approval

•

Contracts/MoUs/Agreements

•

Miscellaneous Policies and Requirements

•

General Requirements for All Flight Courses

•

Certifying the Enrollment of VA Students in Flight Programs

•

How the Various GI Bill

®

Programs Pay Benefits and to Whom

•

Compliance Surveys

•

Licensing and Certification

•

Vocabulary Unique to the Professional Aviation Vocation

•

Questions

•

NOTE: For the most current version of this PowerPoint, please

go to the FAVES Website at

:

http://www.flfaves.org/

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

Determining whether specific SAA approval is required for

degree programs with a component of flight/aviation :

YES

 If a school is not considered to have “deemed approved” programs  If a school with “deemed approved” programs utilizes services from a

vocational flight school, i.e., “under contract”

NO

 If a school with “deemed approved” programs utilizes its own flight line, instructors, TCOs, syllabuses, Part 141 approval, etc.



Credit hour certificate and non-degree programs of flight

training may not be approved under any circumstances

,

nor may students be certified by an IHL as a credit hour

non- degree student

 If the IHL is also approved as a vocational flight school, then they may certify those students as vocational flight students subject to the rules for vocational flight schools and subject to the Chapter 33 annual cap for vocational flight schools, currently $11,562.86

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Getting Started

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Applying for Approval



Utilize Appropriate SAA Application/Request for

Approval Form

 Use the SAA Catalog Submission and Program

Approval/Modification Form (or equivalent* for states other than Florida) to request approval of individual degree programs for

which the school has a contract, MoU, or other agreement for use of space, equipment and/or instructors, aka degree programs

“under contract.”

*Each state will have its own application/request for approval form.

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IHLs with Degree Programs “Under Contract ”

 If a school does not have its own flight line and must make

arrangements with a Part 141 pilot school to provide flight training, then the flight school contractor must be approved by the SAA with jurisdiction over pilot schools for veterans’ training, and the

contracted course section of the application applies and the following must be attached:

 Copy of contract/MoU/agreement

 Copy of pilot school’s Air Agency Certificate

 Copy of TCO and Syllabus for each course offered as part of the degree

 If, at any time, an IHL changes its contract from one flight provider to another, it needs to notify the SAA immediately so that (if all is in order) the approval of their flight degree programs may continue uninterrupted.

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IHLs with Degree Programs “Under Contract” (cont.)

 The IHL must inform the SAA with whom they have an

arrangement, MoU, or contract to conduct all or a portion of the flight training,

 Often times, the flight schools with whom the IHLs have an arrangement are posted on their websites

 Once the flight schools are identified, the SAA will ensure each has already been approved for veterans’ training

 This assumes that the IHL and flight schools under contract are within close proximity/commuting distance of each other and

within the same state, thus allowing students to physically attend in resident college classes and flight training simultaneously. If this is not the case, additional requirements apply.

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Additional requirements where the IHL and pilot school are

not within commuting distance of each other and/or are in

different states. The controlling CFRs are:

 21.4263(g) – Providing a flight course under contract between schools or entities

 21.4233(e) – Contracted courses in general

 21.4266 – Approval of branch campuses

 It should be noted from the start we are talking about college students pursuing college credit courses, albeit flight courses; thus, a contracted flight school cannot, under any

circumstances, certify the enrollment of college students – they are an NCD school and not a college

 Only the college can certify the enrollment of their students to VA for pursuit of their own college credit courses 8

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Additional requirements where the IHL and pilot school are not within commuting distance of each other and/or are in different states (cont.)

 A college approved for online training may certify online courses from their main campus for online courses regardless as to

where the student is located

 In resident training may only be certified to VA by the campus where the in resident training is physically being pursued

 Since the college students at the contracted flight school site are pursuing in resident flight training as college students pursuing college credit courses, and the pilot school cannot certify the enrollment of those college students, the IHL must establish a branch campus at the flight school to certify the enrollment of their college students at that site. ₉

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Additional requirements where the IHL and pilot school are

not within commuting distance of each other and/or are in

different states (cont.)

 This means that the IHL must request for and receive approval of that branch campus from the SAA with jurisdiction over that

physical location in order for the IHL to certify the enrollment of those college students. That branch campus must have:

 Administrative capability (including all records required of a branch)

 A certifying official

 Meet any other requirements specified by the SAA with jurisdiction over that site. That may include licensing requirements, health and safety rules, etc.

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Additional requirements where the IHL and pilot school are not within commuting distance of each other and/or are in different states (cont.)

Examples:

 IHL contracts with a flight school 200 miles away within the same state: The IHL must establish a branch campus at that pilot school and the pilot school, IHL branch campus, and

program at the main campus must be approved by that state’s SAA.

 IHL contracts with a flight school one mile away, but in a

different state: The IHL must establish a branch campus at that pilot school and the pilot school and IHL branch campus must be approved by the SAA with jurisdiction over that site, and the

program at the main campus must be approved by the SAA with jurisdiction over the main campus.

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

Air Agency Certificate

 Issued by the Flight Standards District Office (FSDO)  Includes a Letter of Authorization

 Is valid for two (2) years

 Specifies all the courses that the school is authorized to offer under FAR Part 141

 Only courses listed on the Air Agency Certificate and Letter of Authorization may be considered for approval

 If a Pilot School wishes to obtain approval of a course not currently listed on these documents, they must first obtain

approval from their FSDO and obtain a new or revised Air Agency Certificate and Letter of Authorization

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

Training Course Outline (TCO)

 Description of purpose of course

 Specific aircraft and Flight Training Devices (FTDs – mockups of airplane cockpits with varying degrees of complexity) that may be used for the course by make and model

 Restrictions on use of FTD (limited hours and for which specific flight lessons may be used)

 Airports that may be used in training

 Name of Chief and Assistant Chief Flight Instructor

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Training Course Outline (TCO)

 The SCO needs to have this information because it directly impacts flight costs and provides information needed in order to better

monitor compliance with the contract

 Although the SCO may not be directly involved in monitoring and

enforcing the terms of the contract, the SCO must know the people who have that responsibility and establish a good working relationship with them to ensure enough information is made available to the SCO to allow that person to make timely and accurate reports to VA on flight students.

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Syllabus

 There is one (1) syllabus approved for each Part 141 course approved by the FSDO

 It is approved with and accompanies the TCO

 It is a lesson-by-lesson outline of how the course is to be pursued

 The Ground School section specifies, lesson-by-lesson, the knowledge to be learned and how long (in hours) each lesson should take

 Ground School is specifically designed to prepare students to take and pass the FAA written exam for the course

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Syllabus (cont.)

 Ground School is not to be confused with preflight briefings and post-flight critiques (pre/post) which are always associated with actual flight lessons

 Pre/post is rarely ever enumerated in Part 141 syllabuses and for minimum hours is usually listed “as needed.”

 For GI Bill® approval, pilot schools may request approval of pre/post hours totaling no more than 25% of the minimum flight hours in each course. This is also true for the flight courses the IHL for which the IHL contracts with the pilot school.

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

Syllabus (cont.)

 Each lesson specifies the knowledge to be learned, maneuvers to accomplish, procedures to follow for each flight lesson as well as how long each lesson should take

 Includes a time distribution chart that lists all lessons, how long each should take, and totals all hours – the hours listed in the syllabus are the maximum hours that may be approved for VA training

 The FSDO-stamped copy must be submitted for approval for VA training

 Although most syllabuses are written within the FAA minimum hours, a pilot school may write its own syllabus for hours that

exceed the FAA minimum requirements. Those hours then become the hours required for all students in that course, including VA

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Obtaining Approval



As required by Title 38 CFR 21.4263, flight school approval

criteria includes, but is not limited to:

 Meeting the two-year rule

 Being financially sound

 Maintain all records pertaining to the training they give for at least three years following each student’s last date of training

 Have and enforce reasonable standards of progress and attendance

 Have the capability to identify the last date of training

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Finding a Flight School



IHLs may check to see if a flight school is already approved

for veterans training:

 Go to WEAMS Public:

http://inquiry.vba.va.gov/weamspub/buildSearchInstitutionCriteria.do

 Enter Program Type as “Flight” using the drop-down menu

 Click on your state

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

Training Centers

 Training Programs – Part 142

Although it is rare for a Training Center to enter into a contract with an IHL, with several approved training centers in Florida it is possible such a contract could be entered into at some time in the near future

 Training Centers (TCs) are approved by the FAA under this provision of the FARs

 This part allows a TC to offer an entire course through the use of flight simulators

 Almost always for large aircraft which would be extremely expensive to fly for training purposes

 Examples include A320, B727, DC10, Lear Jet, Cessna Citation, Sikorsky S71, etc.

 All elements for approval are the same as for Part 141 Pilot Schools with the exception that all elements found in TCOs and Syllabuses are found in the one training center document

 Once again, the minimum training hours listed in the training center document are the maximum hours that may be approved for VA

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

Cash Tickets/Student Ledgers/Invoices

 These are the basic documents that record all payments made for pursuit of flight courses

 We require them to verify that costs certified to VA for reimbursement are accurate

As it relates to IHLs…

 These documents are key to the IHL to verify the accuracy of the amounts of which the flight school invoices the IHL and must contain the following elements:

 Name and identifying information of the student

 Exact approved name of the course being pursued

 Date of training

 Flight or ground school lesson number

 Duration of training in hours and tenths of hours

 Aircraft flown including make, model, and tail number

 Per hour charge

 Total charges

 Signature of instructor and student 23

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

Flight Course Training Records

 The official record of each flight and ground school lesson completed

 Required by the FAA to verify that training has been given

 Flight schools often use the Jeppesen supplied tri-fold (or similar) training record, electronic records such as Paperless 141, record

training in the syllabus on special lesson sheets, or devise their own record

 Like the FAA, we use them to verify that training and hours certified to VA have been given

As it relates to IHLs…

 This is likened to a college instructor’s records of students’ class work in academic courses and is just as important to the IHL as academic records. In fact, they are the basis for the grades assigned by the IHL for each course students pursue.

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

Flight Course Training Records (cont.)

 Must contain the following elements:

 Name and identifying information of the student

 Exact approved name of the course being pursued

 Date of training for each lesson

 Aircraft flown for that lesson to include make, model and tail number

 Amount of time expended in completing that lesson

 May be compared to the FSDO-approved syllabus  The elements of the lesson completed

 A grade for that lesson

 Once again, is equivalent to an IHL instructor’s grade book or grade records  Instructor signature and comments

 Student signature

 Both instructor and student signatures may be electronic

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Ground School – what may and may not be approved

 Ground school must be actual face-to-face training with an instructor, either in a group classroom setting or one-on-one

 Ground school offered through online training cannot be approved for stand alone vocational flight schools

 Ground school may be offered through computer generated lessons, but only at the flight school with an instructor immediately available to answer questions and direct study with times recorded by the

instructor

 If a particular flight course includes online ground school that may not be approved, the flight portion of the syllabus may still be approved and paid if appropriate

 Exception: If an accredited IHL is FAA approved to offer ground school under Part 141 or 142, then all or part of the ground school may be approved for pursuit through an online mode of delivery as long as they are measured in credit hours and apply to a college degree. 26

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Flight Training Devices (FTDs)

 Must be specifically approved for each flight course in the Part 141 FSDO-stamped TCO for Pilot Schools and the Part 142 CMO - or

FSDO-stamped Flight Training Manual (general operations,

courseware, training curriculum, instructor/evaluator courses, etc.) for Training Centers

 Training in FTDs is considered dual flight for VA purposes

 Training in FTDs may only be paid for those lessons for which the TCO or Course Training Outline (CTO) allows them to be utilized and only for the number of hours the TCO allows to substitute for actual dual flight lessons or for the number of lessons in the CTO

 Again, the minimum hour listed in the CTO are the maximum that may be approved and which schools can certify veterans for GI Bill training

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Basic Student Requirements



Medical Certificates

 FAA requires student pilots must possess a medical certificate valid for third class privileges throughout their training in each course

 A medical certificate is valid for third class privileges through the end of the 36th_{month after the date of the medical exam}

 FAA and flight schools strictly monitor that for student pilots and all pilots; therefore, it is not an item we review at IHLs with flight

degrees, either under contract or at IHLs with their own flight line

 Note: Even though the FAA only requires a third class medical for

student and recreational pilots, to pay education benefits at vocational flight schools VA requires first and second class medical certificates as appropriate for the license or rating. We do not require first and

second class medicals for IHL flight students because their objective is a college degree and not a pilot ’s license or rating 28

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

Prior Training

 Flight schools must grant credit for all appropriate prior education and training without regard to the wishes of the veteran, just the same as with all IHLs

 The FAA 50% and 25% rules with regard to transfer of prior Part 141 training do apply for GI Bill benefits - FAR 141.77(b)

 Credit may be given for up to no more than 50% of the course requirements for training received at another Part 141 certified school

 Credit may be given for up to no more than 25% of the course requirements for training given under Part 61

 The request for prior training, evaluation of same, and proper application to the student’s current course must be documented

 All appropriate training transferred must be deducted from the student’s program with the hours of dual and solo flight, ground school shortened proportionately, and cost reduced appropriately

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

Standards of Progress

 Like any other school approved for GI Bill training, flight schools must have and enforce standards of progress

 The SAA has certain minimum standards which are included in their recommendation to VA for final approval

 Typical standards are tied to stage checks (e.g., failure to pass two stage checks will result in termination of the student’s VA

education benefits)

 Records must be maintained to reflect that the student was terminated and why

 Because those standards are specifically geared to flight training, IHLs should adhere to the flight school’s standards of progress

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

Refund Policies

 For their VA students, flight school refund policies must be pro rata

 Not a problem for ‘pay as you go’

 If student pays on account then drops, the refund must be for all funds still on account that have not been applied to appropriate training already given prior to the drop

 Records must be maintained to verify that the refund was given and for the correct amount

As it Relates to IHLs…

 Should an IHL choose to have this type of pro rata refund policy, refunds such as this are easy for IHLs to administer since all flight schools are required by the FAA to maintain detailed progress and attendance records. IHLs must follow their published and

approved refund policies, including any special refund policies

delineated in their contract with the flight school(s). 31

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These are schools that own/lease their own aircraft, hire

their own flight instructors and are approved by the FAA

under Part 141 with their own air agency certificate, and

their own TCOs and syllabuses, i.e., they are also a flight

school.



No separate SAA application/request for approval form

is necessary since the program would be “deemed

approved”

 If school has its own flight line and Part 141 approval, then special approval of that degree program is not required; however:

 We still need the AAC, TCO and Syllabus when you submit a catalog

 This is necessary to ensure that your program meets the criteria to be deemed approved and so that we know the maximum hours for your program

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These are schools that own/lease their own aircraft, hire their

own flight instructors and are approved by the FAA under Part

141 with their own air agency certificate, and their own TCOs

and syllabuses, i.e., they are also a flight school.



No separate SAA application/request for approval form is

necessary since the program would be “deemed approved”

 If school has its own flight line, but training is given under Part 61, then the school should provide their own syllabus that outlines the minimum hours of dual, solo, and ground school required to complete their flight courses. Such hours then become the maximum payable for VA.

 In the same situation a school could have it’s own fixed wing flight line and contract for rotorcraft. The fixed wing can be given under Part 61, but the rotorcraft must be given under Part 141

 Most of the payment procedures on the following slides also apply to schools with their own flight line

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

Must clearly identify the IHL offering the degrees and the

flight school providing the flight training



Each course for which training is being given must be

identified



Location where flight training is given



Clear identification as to method of payment for instruction

given

 Students pay the flight school and are considered to be flight school students – flight school certifies the enrollment of students as vocational flight students

 Students pay the college, register for college flight course, are considered to be students of the college, the college pays the flight school – IHL certifies the enrollment of students as college

students ₃₄

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

Where students pay the college and the college pays the

flight school, rates of payment

must be clearly delineated

 Flat rate – one fee for flight training regardless of time taken or aircraft flown

 Pay by hour – college pays flight school based upon hours completed and specific aircraft flown



Flight and ground hours upon which charges to VA are based

must not exceed hours approved on the FSDO-stamped

syllabus for each course at the flight school

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

List of limitations for training given - examples:

 Least expensive aircraft must be utilized except where required by the course syllabus or the FAA

 Minimum hours required in course syllabus are the maximum allowed for VA students

 All training must be completed by end of term, with exceptions defined and listed



Other obligations and restrictions on the college and the

flight school. Examples include, but are not limited to:

 Disposition of unused funds (refunds)

 Who will supervise which personnel

 Who is obligated to pay personnel salaries

 Where records are maintained and who maintains them

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

Things to avoid on MoUs that would not be approved by an

SAA:

 Arrangements to sub-contract any instruction to a non-approved school

 Provisions to conduct any part of the training under Part 61

 Provisions to allow for additional flight hours beyond the minimum requirements of the flight school’s syllabuses

 Any clauses that would allow the IHL to alter the flight school’s FSDO approved Part 141 courses in any way

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Missed and Make-up Flights

 Where flights cannot be conducted because of inclement weather, mechanical problems, illness, unavailability of instructors, etc., a policy for making up such missed flights, including time limits, must be delineated in the MoU, school catalog and any program material

 Because of concerns regarding keeping students current in training and skills, time limits for making up missed flights cannot be as liberal as with other courses for which an incomplete grade has been issued

 In no case may students fly and be certified to VA for more than the minimum hours required in the course syllabus

 It should be rare that students need to make up flights after the end of the enrollment period

 Frequent such occurrences would be a red flag

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Standards of Progress & Attendance

 For the flight courses, standards are set by the flight school and are specific for all subjects containing elements of flight training. This includes standards of attendance/frequency of scheduling and taking flight lessons to insure that flight skills are maintained.

 A suggested standard would require students schedule flights every week and at a frequency to insure they will complete all flights within the term. Failure to schedule any flights for two consecutive weeks will result in the student being dropped from the course as of the date of the last flight for failure to attend

 Flight school standards relate to individual lesson grades and

stage checks may contain a probationary period which is generally linked to the number of poor lessons grades and/or failed check rides

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

Standards of Progress & Attendance (cont.)

 IHL and flight school must have a system in place to notify IHL, in a timely manner, of failure to progress satisfactorily or failure to schedule/show up for flight lessons, e.g., did not schedule flights for two weeks

 Regardless of the fact that the flight school may have given late notice to the IHL of a change, the IHL is still held responsible for reporting all changes/terminations within 30 days

 Hence the importance of open and continuous lines of

communication between the flight school and the IHL and between appropriate elements of the IHL and the SCO

 Typical standards are tied to stage checks, e.g., failure to pass two stage checks will result in termination of the student’s VA

education benefits

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

Standards of Progress & Attendance (cont.)

 Records must be maintained to reflect that the student was

terminated and why, along with the date the IHL was notified of the unsatisfactory progress by the flight school

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

Refund Policies

 Whether flat rate or pay by hour, refunds of unearned fees, i.e., flights/lessons not completed, must be made to the student or VA as appropriate for the student’s GI Bill and in accordance with

your school’s approved refund policy and/or included in the MoU with the flight school

 It is a best practice for the refund policy to be spelled out in the MoU/Agreement

 Records must clearly indicate how the refund was calculated

 If pay by hour plan is implemented, then refunds are generally a moot point unless students pay on account

 In this instance, the amount of refund is the amount on account less the cost of lessons completed

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

Term Dates/Enrollment Periods

 IHLs use standard and accelerated term dates just the same as for non-flight students

 Flight courses are certified in appropriate credit hours just the same as any other non-flight students



Course Descriptions

 Flight courses should be described in the IHL’s catalog the same as any other course

 The course title/description should clearly indicate the flight objective (instrument rating, commercial pilot, certified flight instructor, etc .)

 Should include all required hours of flight, ground school and pre/post

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

Course Descriptions

 Notice that this Commercial Pilot Ground School course description does not make mention of the required hours.

 Hours are not required to be listed within the course description; however, if added, must match the FSDO-stamped syllabus.

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

Course Sequencing

 School’s approved catalog must have the degree program outlined

 As a best practice, the program outline should sequence course pursuit to reflect a healthy mix of flight and general

education/academic courses each term

 Students should not be allowed to take all flight courses up front, sometimes called front-loading

 Since FAA rules require a certain sequence of flight training, i.e., from one course to another, front-loading should not normally be a problem

 For instance, all students must take private pilot course first and absolutely cannot pursue any other flight courses concurrently. The credits awarded for that course are normally insufficient for award of the monthly housing allowance (MHA). Thus, Chapter 33 students must take additional academic courses in the program to receive the MHA. ₄₅

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General Requirements for

All Flight Courses

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

Aircraft Utilized

 For VA purposes, aircraft also means FTD/simulators

 Only the aircraft listed in the TCO for a course may be used for a that course

 The syllabus specifies when a specific type of aircraft must be used such as a complex aircraft (retractable landing gear), multi engine aircraft, etc.

 Aircraft used by the flight school must be approved by the FAA in the TCO

 Substitutions may be allowed, but only in very limited

circumstances such as temporary unavailability of aircraft for overhauls, aircraft sold and replacement not in place yet, etc.

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

Aircraft Utilized (cont.)

 Anyone who is monitoring the student’s training flights needs to know this to ensure that students are using the appropriate aircraft and only the aircraft actually necessary for the lesson

 For example, you would want to ensure that a student is not flying an expensive multi-engine aircraft where only a single engine

aircraft is required

 This is also something we will check during compliance surveys

 We will review flight training records you make available from the flight school

 We will compare those records to the TCO and syllabus for that course (that you again will make available to us) for the appropriateness of aircraft utilized

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

Good Stewardship

 Flight training is inherently expensive

 Congress has been focusing attention on the Post -9/11 GI Bill, especially how much more the cost per student is than its

predecessors. IHL flight training has come under close scrutiny as a particularly expensive component of that GI Bill. If IHL flight costs appear to be unduly expensive, caps on IHL flight training may well be considered and imposed by Congress

 Schools can take measures to limit costs

 Agreements with flight schools can limit the use of expensive aircraft only where absolutely required by the syllabus or FAA rules

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

Good Stewardship (cont.)

 Example: Veteran State College (VSC) offers an AS degree that includes training in rotorcraft (helicopters)

 The Robinson R-22 and R-44 are authorized

 VSC’s agreement with the flight school is to use only the much less expensive R-22

 The agreement allows the use of the much more expensive R -44 only where FAA weight limits require its use and only with prior

permission by VSC

 Such provisions may be a requirement for approval by the SAA

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General Flight

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Certifying the Enrollment

of VA Students in

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

85-15% Ratio

 First, determine if the degree program has more than one “track”

 Tracks, as referenced here, should not be confused with majors, minors, concentrations and such

 Tracks are not necessarily different curriculums, but rather are different arrangements to pay for courses

 Rather than pursuing their flight training at the IHL or as the IHL’s students at the IHL’s contracted flight school, do students have the option of going to a flight school on their own and paying the flight

school directly, then having their credits transfer back to the IHL ? Each of these is considered to be a separate track

 Is there more than one type of payment plan ? If so, then each payment plan is considered to be a separate track

 Calculate ratio separately for each “track”, major, concentration, etc., if any

 Example: A “Rotorcraft ” option would require a separate ratio calculation

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

85-15% Ratio (Cont.)

 Also determine whether or not the program has different majors, minors, concentrations, tracks, etc., and calculate the ratio

separately for each such subdivision of the degree

 Such differences are usually manifested as different courses

 Example: An AS, Professional Pilot degree could have Rotorcraft and a Fixed Wing concentrations/majors. The required courses are different for each such concentration/major and, thus, the ratio is calculated separately for each.

 Example: A BS in Aeronautical Science may include additional options such as Rotorcraft Option, Certified Flight Instructor – Multi-Engine

Option, and Airline Transport Pilot Option. The ratio must be calculated separately for each of those options.

 All ratio calculations are in full -time equivalents (FTEs)

 Example: two half-time students equal one FTE, two three quarter time students equal 1.5 FTE, etc.

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Certifying the Enrollment of VA

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

85-15% Ratio (cont.)

 VA (85%) portion of ratio includes VA students and any students

receiving a grant, waiver, discount, scholarship, etc., directly from the school and which has rules that have the effect of excluding VA

students (regardless of whether or not they are receiving GI Bill benefits) from receiving that school assistance, aka ‘supported’ students

 Example: The contracted flight school requires all of its instructors to

obtain the college degree for which they are contracted to help teach. The flight school pays those instructors to pursue the academic courses

required in the degree because all of the instructors already posses the licenses and ratings required for that degree. Those students count in the 85% portion of the ratio

 Non-VA (15%) portion of ratio includes all other students officially registered in that degree program

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Certifying the Enrollment of VA

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

85-15% Ratio (cont.)

 You must calculate the ratio before certifying a VA student in the program for the first time

 If a VA student’s enrollment causes that program to be out of balance for the ratio, that student may not be certified for VA education

benefits

 Unless 35% waiver has been granted, schools must report the ratio to the your ELR each standard term and for the summer

 The fact that a school has the 35% waiver of reporting requirements does not relieve them of the obligation to ensure they still meet the ratio in each program

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Certifying the Enrollment of VA

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

Why an 85-15% Ratio?

 Requiring that at least 15% of the students in a program are willing to shell out their own hard-earned money for that program allows the free market to determine that:

 The course is of sufficient quality to attract students who are spending their own money

 The course is of good value and not overpriced

 This helps keep prices lower, otherwise the school cannot attract sufficient non-VA/supported students to stay in balance with the ratio

 The ratio was promulgated by Congress after the original World War II GI Bill to maintain the integrity of the GI Bill. It is still valid and works well.

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

Completing the Enrollment Certification (VA Form 22 -1999)

 Enter the exact name of the program as found in WEAMS and your catalog

 Enter term dates (these should be in most cases the same as for all other students)

 Enter credit hours just the same as non-flight degree students

 Enter total charges – flat rate

 Public schools enter only the in-state rate

 Private schools enter the actual total charges (there should be no state differential)

 Enter actual charges – if Chapter 33 student is eligible at less than the 100% level, VA’s claims examiners will assume what you certify is the actual total in-state charges and pay the appropriate reduced rate

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

Completing the Enrollment Certification (VA Form 22-1999)

 Enter total charges – pay as you go (suggested procedure)

 Public and private schools same as previous slide with respect to in-state and out-of-state

 Calculate the minimum cost that the student will incur and certify that amount up front

 At end of course, calculate actual charges and submit an amended enrollment to VA

 In no case may additional flight or ground hours be certified for payment beyond the hours approved in the Part 141 syllabus

 Date submitted must be no later than 30 days after the first day of the term, end of drop/add, or date veteran requested the school to certify (documented), whichever is later

 Time limit is for certifying credit hours pursued. School may take longer to

certify tuition and fees or amended tuition and fees.

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Completing the Enrollment Certification (VA Form 22 -1999)

 FEES – Only required fees may be certified to VA for reimbursement. This means that each student is required, without exception, to pay a fee to the school for required equipment, books, etc.

 Example: The school has a flight kit fee listed in the catalog. It includes all books, supplies, headset, etc., needed in the pilot training program. Even if a student has the same make and model of all equipment in the kit, the school requires each student to purchase the kit. This fee may be certified to VA.

 Example: If a student already has the same make and model headset, the school will give the student credit for the headset and (s)he does not have to purchase it from the school. This fee may not be certified to VA.

 Flight checks – Neither the cost for rental of the aircraft nor the flight examiner fee may be certified to VA. The flight examiner fee may be reimbursed under LACAS (see slides 89 -94).

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

What to Do When a Student Drops/Withdraws from a

Flight Course

 Always report last date of training with a 1999b

 Punitive and non-punitive grade policies apply

 Generally speaking, the school’s refund policy prevails

 As we discussed earlier, such policies must be delineated in the MoU, school catalog, and program materials, and may actually be the

refund policy of the flight school and/or be different from the IHL’s general refund policy.

 The contract/MoU/agreement with the flight school must specify the financial arrangements for handling funds when students

drop/withdraw

 The contract/MoU/agreement should always include a policy that provides payment only for flight training actually given

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

What to Do When a Student Drops/Withdraws from a

Flight Course (cont.)

 Flat rate – because flight training is very costly, a non -refundable flight fee is not a best practice and is not recommended

 Best practice for refund – calculate cost of training given through date of drop/withdrawal

 Deduct cost of training given and refund the remainder of the unearned fees (pro rata)

 Pay as you go – generally, a refund of fees is not a factor since payment is only made for actual training given

 It students pay on account, then the procedure above regarding flat rate fees should be followed to refund unearned fees

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Certifying the Enrollment of VA

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

Cancelled or Postponed Flight Training

 In rare instances, students may not be able to complete all flight training/lessons within the term due to inclement weather,

mechanical problems, scheduling problems, etc .

 The school must have a policy in place for these types of situations

 Schools may utilize their standard incomplete grade policy; however, for the sake of helping the student to maintain flight proficiency, it is a best practice to require less time to make up missed flights than is allowed for other incomplete grades

 Example: The student is allowed up to 30 days after the end of the term to complete the flight training or be assigned a failing grade

 If flight fees are ‘pay as you go’, the flight charges may then be submitted to VA for reimbursement as an amended certification

 In no case may flight hours beyond the minimum approved be charged to VA

 In no case may a penalty fee be charged to VA

 For example: A college charges students an additional flight fee of $500 if they required

training beyond the hours in he approved syllabus. This fee may not be charged to reimbursed by VA.

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Certifying the Enrollment of VA

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63

How the Various GI Bill Programs

Pay Benefits and to Whom

(64)

All payments are made based upon the enrollment certifications submitted by the school (VA Form 22 -1999) and, in some cases, based upon monthly verifications of pursuit by the student

 Chapters 30 & 1607

 Benefits payments are paid to the student based on length of credible service

 For less than the full service required students are eligible at a percentage of the full-time rate

 Chapter 30 – Current full-time monthly payment for three (3) years of credible active duty is $1,717.00

 Chapter 1607 – Current full-time monthly payment for two (2) plus years of credible active duty is $1,373.60

 Payment for training to the school is between the student and the school

 Entitlement is charged at the rate of one (1) month for each full -time month paid

 Students must verify enrollment each month to receive benefits 64

How the Various GI Bill

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

Chapter 1606

 Monthly payments to the student

 There is no level of benefit payment for chapter 1606 – all payments are at the 100% eligibility level – current full-time monthly benefit is $367.00

 Entitlement is charged at the rate of one (1) month for each full-time month paid

 Students must verify enrollment each month to receive benefits

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

Chapter 35

 Monthly payments to the student

 There is no level of benefit payment for chapter 35 – all payments are at the 100% eligibility level – current full-time monthly

benefit is $1,018.00

 Entitlement is charged at the rate of one (1) month for each full-time month paid

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

Chapter 33

 Benefits payments are paid based on length of credible service

 For less than the full service required, students are eligible at a percentage of the full-time rate

 Payments are separate for:

 Housing allowance

 Books and supplies

 Tuition and fees

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How the Various GI Bill

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

Chapter 33 (cont.)

 Reimburse each school for up to 100% of all approved charges

 All payments subject to the student’s level of eligibility

 For public IHLs, payment is for all allowed costs of in -state tuition and fees with no yearly limit

 For private IHLs, payment is for all allowed costs of tuition and fees up to an academic year cap

 Academic year is August 1 through July 31

 Current yearly cap (2014-15) is $20,235.02

 Cap for previous academic year was $19,198.31

 Both the monthly amount paid and yearly cap are subject to the student’s level of

eligibility (e.g., student eligible at the 80% level will have payments made to the school at the rate of 80% of the actual charges certified and the yearly cap is $16,188.02 (80% of yearly cap))

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

If They Have a Choice, Which GI Bill Should They Use ?

 If they are eligible for more than one GI Bill and/or have an

opportunity to change from one to another, veterans should go to the website below and use the Comparison Tool/Payment Rates to determine which GI Bill would most advantageous for her/his

situation. Alternately, veterans may call the nationwide toll free education number also listed below:

 http://www.benefits.va.gov/gibill/comparison_tool.asp

 VA Toll Free Number: 1-888-442-4551

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

Entrance interview

 With SCO and others as school or auditor sees fit



Review of advertising to ensure compliance with the

law

 Past 12 months of advertising (website, publications, television and radio spots, etc.) to ensure not false or misleading; no promises of placement



Review of 85-15% ratio

 Based upon the total enrollment for the term as opposed to training for the prior 30 days as with flight schools

 Remember the ratio must be calculated separately for each track, major, minor, concentration, option, etc. (See slides 48 & 49)

 We will check a random sampling of non-VA files to ensure those

students are paying for their program out of their own funds 71

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

Records must be available at time of visit

 Review pre-survey checklist provided to you by the SAA or VA

 Ensure all items are addressed

 Hard copy or electronic records

 Ask questions before visit if unsure



IHL Documents

 Registration documents - application, enrollment agreement

 Class schedules

 Transcripts

 Drop slips; withdrawal documentation

 Tuition payment ledgers; detailed record of tuition and fees

 Yellow ribbon documentation

 Reporting fee fund documentation

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

Records specific to flight



For schools that contract their flight training or have their

own flight line, offer training under Part 141, and charge pay

as you go:

 Copy of contract/MoU/agreement with the flight school (N/A for schools that have their own flight line)

 Each current course TCO and FSDO-stamped syllabus  Flight school progress records

 Signed by instructor and student

 Flight school student cash tickets/ledgers/invoices

 Current AAC (we will also review for revocation before the survey at the FAA Website)

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

Records Specific to Flight (cont.)



For schools that contract their flight training or have their

own flight line, offer training under Part 141 and charge a

flat rate:

 Copy of the MOU/contract with the flight school (N/A for schools with their own flight line)

 Flight school’s/IHL’s Part 141 air agency certificate  TCO and syllabus for each flight course

 Ground school and flight records detailing the flight/ground training given with total hours given for each type of flight (dual/solo) as well as ground school

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

Records Specific to Flight (cont.)



For schools that have their own flight line and offer flight

training under Part 61

 Ledger/cash tickets/invoices detailing the flight training given – must include:

 Dates and duration of flights

 License/rating requirement covered including a grade/evaluation of that flight

 Hourly charge for that flight

 Total charge for that flight

 Aircraft utilized by make, model, horsepower, and tail/ID number

 Ground school records showing hourly charges and what particular portion of the written exam was covered

 School syllabus for each course that details what is to occur

during each lesson and how long each lesson should take. Should include a time distribution chart that shows total flight hours in

each program 75

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

Records must be available at time of visit (cont.)

 FAA website links:

Pilot Schools - http://av-info.faa.gov/PilotSchool.asp

Training Centers - http://av-info.faa.gov/TrainingCenter.asp

Pilot School will show up if AAC is still valid

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

Commencement of courses

 First day of classes for the semester, quarter or part of term



Program certified

 Must be same as what VA beneficiary is enrolled in and pursuing

 Review transcripts, registrar records, application, etc.

 If they do not agree, update records and/or certification

 Monitor WEAMS (22-1998) reports

 Ensure program certified is exactly as it appears on WEAMS

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

Previous education and training

 The school must maintain a written record that clearly indicates that appropriate previous education and training has been

evaluated and granted, with training time shortened and tuition reduced proportionately, and the veteran so notified

 For flight courses, the FAA places certain restrictions on how much credit may be granted, even when considering training completed at another college or Part 141 flight school

 Part 141 Pilot Schools may transfer credit that composes no more than

 50% of the hours in the school’s syllabus for training completed under Part 141 at

another certificated flight school

 25% of the hours in the school’s syllabus for training completed under Part 61

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

Previous education and training (cont.)

 This varies from college transfer policies that generally allow credit for all work successfully completed at certain other colleges

 The pilot school will process the prior credit under Part 141 rules, but the IHL needs to be aware of these rules and ensure that the flight school follows them and grants credit as appropriate

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

Certifications must be accurate and prompt

 Ensure enrollment dates are correct

 Ensure tuition and fees are properly reported dependent upon whether the school charges flight pay as you go or flat rate

 For pay as you go schools may certify up front the minimum charges they know all flight students will incur then certify the actual charges (if more than the minimum charges) at the end of the term as an

amended certification

 Utilize degree program/audit sheets to ensure courses certified apply to program requirements not already satisfactorily completed

 Review fees charged to ensure they are truly required of all students with no exceptions allowed under any circumstances

NOTE: This is why it is extremely important that the SCO have open communication with her/his own school’s finance/bursars office and registrar, and the appropriate officials at the flight school who can provide the training and billing records the SCO needs to properly certify enrollments to VA

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

Certifications must be accurate and prompt (cont.)

 Ensure that prior credit has been obtained, evaluated and granted as appropriate. It would not be unusual for a student applicant to have already obtained some flight licenses and ratings for which credit must be granted toward the degree program

 An IHL cannot, under any circumstances, require a student to pursue a license

or rating at that IHL or contract flight school if the student already possesses that license or rating from the FAA

 All certifications must be submitted within 30 days of the latter of any of the following three (3) events:

 Start of term  End of drop/add

 VA student’s request for certification of benefits

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

Terminated or Interrupted Training

 Must be promptly reported

 During our visit we must be able to identify the last dates of training. Notification must be made to VA within 30 days of student’s last date of attendance

 Maintain drop/withdrawal slips in file or make electronic record available

 The last date of training should be easy to obtain for flight courses because flight training requires accurate records of dates of training given

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

Grades of I and F

 An I grade is issued for flight courses only if the student has not completed all the lessons because of inclement weather,

mechanical problems, instructor unavailability, illness, etc., not because (s)he failed lessons. With I grades, VA can pay the

student to complete only the required hours of lesson remaining

to be completed in the course.

 An F grade is issued if the student did complete all the lessons, but was unsuccessful in and did not pass some of the lessons .

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

Incomplete Grades

 Ensure that the student does not re-enroll in same course unless an unsatisfactory grade is assigned

 Ensure that the time for completing the course is not exceeded

 If the student did not complete all flights during the term, we can pay for the student to complete the remaining approved hours in the course, but no more

 Student can take additional flight hours beyond that approved in the syllabus, but only at own expense

 VA payments can only be made for costs associated with the required hours in each flight syllabus

84

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

Failing Grades

 Where a student has actually earned an F in a flight course

because that student failed some of the lessons, the student may retake that course and be certified for VA benefits for retaking that course

 Because FAA rules do not require student pilots to retake lessons successfully completed, but only retake lessons that were failed, an IHL flight student is only required to take those lessons (s)he failed

 In practical terms, the flight contractor or flight department must evaluate which lessons were failed and when the student registers for that flight course again, they will only require that student to repeat the failed lessons

 The flight fees certified to VA should reflect only those costs associated with retaking the failed flight lessons

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

Satisfactory Progress

 Monitor unofficial transcripts

 Monitor progress records from flight school

 Ensure you have a good line of communication with the flight school or the element within your own school that would have access to those documents

 Maintain documentation in files

 Standards of Progress must be monitored and policy enforced



Report probation to VA via

‘Right Now Web’ (VA’s Internet Inquiry System in the “Ask a Question” section of the

benefits.va.gov/gibill website)

https://gibill.custhelp.com/app/utils/login_form/redirect/ask

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Standards of Progress

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

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Standards of Progress (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, 4th edition, 09/30/14 or

https://gibill.custhelp.com/app/answers/detail/a_id/1436/kw/acade mic%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 88

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Standards of Progress (cont.)



Academic Suspension

 SCOs must promptly report to VA when a student is no longer meeting the standards of progress for your school

 Terminate effective at the end of the last term during which the student is entitled to payment

 In VA-ONCE, specify reason as “Unsatisfactory Attendance, Conduct or Progress”

 Ensure the end date of the term is correct

 LDA/Effective date defaults to end date of term

 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. Be sure to thoroughly

document such appeals and positive results in the student’s file. 89

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

How do tuition and fees compare to other students’

charges?

 Tuition and fees charged to VA beneficiaries must be the same or less than charges to other similarly circumstanced students

 Some non-VA/non-supported student files are randomly selected for this purpose

 Authority: Title 38 USC, Section 3690(c)

 Schools found charging veterans more than similarly

circumstanced non-VA/supported students are subject to having their approval immediately withdrawn

38 CFR 21.4210(d)(4)(i)

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

Once the compliance survey visit is complete

 Exit interview will be conducted

 With SCO or others as school or auditor sees fit

 Site visit report – addresses findings and any corrective action that may be necessary

 If corrective payment action is required (i.e., changes that affect

payment of benefits), referrals will be submitted to the VA Muskogee Regional Processing Office for action OR we may work with the school to assist them in correcting via VA-ONCE

 A letter is sent to the school (to the highest administrator, with copy to the SCO)

 Identify student records reviewed

 Detail any discrepancies/findings

 Specify corrective action (if any) required by the school

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

Findings/Common Errors (in no particular order)

 Student flying and being certified for more flight hours (and associated charges) than the course syllabus requires

 Notice of termination for unsatisfactory pursuit sent to VA more than 30 days after the last flight or ground school class

 Administrative withdrawal date certified instead of last flight or ground school class

 Flight course taken out of sequence as listed in the school’s catalog

 Refund of fees after termination is not prorated for the flight lessons not taken (pay as you go/pay on account)

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

Findings/Common Errors (continued)

 85-15% ratio does not include supported students in the 85% portion of the ratio

 VA students charged more than non-VA students for the same course

 The IHL has not sought prior approval of its contractual

arrangement and it is found that the flight school is not approved for GI Bill® training

 Invalid fees charged to VA for reimbursement

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94

Licensing and Certification

(LACAS)

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

Following is the link that will take you to the information

regarding Licensing and Certification (LACAS). It gives

complete instruction on how a veteran may seek

reimbursement for LACAS exams not covered under GI Bill

benefits:

http://www.benefits.va.gov/gibill/licensing_certification.asp



Pamphlet:

http://www.benefits.va.gov/gibill/docs/pamphlets/lc_brochure.pdf



Individuals may also go to the following link to search for

approved exams and to find the appropriate address for

submission (name and address of organization issuing

license is required when submitting to VA for

reimbursement):

http://inquiry.vba.va.gov/weamspub/buildSearchLCCriteria.do 95

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

Items eligible for reimbursement under LACAS:

 FAA examiner’s fee for the check ride



IHLs – Items

not necessary

to request through LACAS

 Rental of the aircraft for the check ride (because IHL and not vocational)

 Submit on 22-1999 for Chapter 33



Entitlement

 Student is charged one (1) month of entitlement for every test VA pays

 May not always be in the student’s best interest

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References

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