October 6, 2015 ♦ NAVPA 40th Annual Conference ♦ Nashville, TN 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 L a s t R e v i s e d S e p t e m b e r 1 4 , 2 0 1 5
IHL & NCD
FLIGHT TRAINING
WORKSHOP
Ron ScogginsLead Education Liaison Representative US Dept. of Veterans Affairs
VA Central Office Southern Region
Katherine Snyder
Program Consultant Florida Dept. of Veterans’ Affairs State Approving Agency Flight Chair, NASAA
2
TOPICS
•
Getting Started
•
Contracted Vocational Flight School Approval
•
Contracts/MoUs/Agreements
•
Miscellaneous Policies and Requirements
•
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
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., however, as indicated on Slide 25, the SAA must still review each program to ensure it meets the criteria to be considered “deemed approved”
Credit hour certificate and non -degree programs of flight
training may not be approved under any circumstances
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, effective 08/01/2015: $12,048.50 (up from $11,562.86)
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Getting Started
Requesting Approval
Utilize Appropriate SAA Application/Request for
Approval Form
Contact your SAA to obtain the appropriate form* to request approval (or modification or deletion) 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.
Getting Started
IHLs with Degree Programs “Under Contract ”
If a school does not have its own flight line and offer training in -house, the IHL must:
Make arrangements with a Part 141 pilot school to provide flight training
Ensure the flight school contractor is approved by the SAA with jurisdiction over pilot schools for veterans’ training
Submit a copy of the following to the SAA: Contract/MoU/Agreement
Pilot school’s Air Agency Certificate
FSDO-approved 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 must 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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Getting Started
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
SAA to ensure flight training providers are approved for veterans’ training
If IHL and flight schools under contract are not 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, additional requirements apply
Getting Started
IHLs with Degree Programs “Under Contract” (cont.)
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
Only the college can certify the enrollment of their students to VA for pursuit of their own college credit courses
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Getting Started
IHLs with Degree Programs “Under Contract” (cont.)
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
If branch campus approval is required by the SAA, it 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
9
Getting Started
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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Getting Started
Training Course Outline (TCO)
Each training course for which approval is requested must contain:
A description of each room used for ground training, including the room's size and the maximum number of students that may be
trained in the room at one time, unless the course is provided via an internet-based training medium;
A description of each type of audiovisual aid, projector, tape recorder, mockup, chart, aircraft component, and other special training aids used for ground training;
A description of each flight simulator or flight training device used for training;
Getting Started
TCO (cont.)
A listing of the airports at which training flights originate and a description of the facilities, including pilot briefing areas that are available for use by the school's students and personnel at each of those airports;
A description of the type of aircraft including any special equipment used for each phase of training;
The minimum qualifications and ratings for each instructor assigned to ground or flight training; and
A Training Course Syllabus
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Getting Started
TCO (cont.)
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.
Getting Started
Syllabus
There is one (1) syllabus approved for each Part 141 course approved by the FSDO
It is approved with and accompanies the TCO or is part of 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
14
Getting Started
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.
Getting Started
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
students 16
Getting Started
Obtaining Approval – Vocational Flight School
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
Understand… It is not a given that a flight school will be approved just because it has FAA Part 141 approval
17
Getting Started
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
Flight Schools
Seek approval through your SAA
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Getting Started
Finding a Flight School
Getting Started
Finding a Flight School
20
Getting Started
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 21
Getting Started
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.
22
Getting Started
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
23
Getting Started
Flight Training Devices (FTDs)
Must be specifically approved for each flight course in the Part 141 FSDO-stamped TCO
Training in FTDs is considered dual flight for VA purposes
Training in FTDs may only be paid for those lessons for which the TCO allows them to be utilized and only for the number of hours the TCO allows to substitute for actual dual flight lessons
Again, the minimum hours listed in the TCO are the maximum that may be approved and which schools can certify veterans for GI Bill® training
24
Getting Started
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.
If school has its own flight line and Part 141 approval, then
special approval of that degree program is not required;
however, the SAA must still review the program.
The AAC, TCO and Syllabus are required when you submit a catalog or addendum
This is necessary to ensure that your program meets the criteria to be “deemed approved” and to determine the hours of your program
With this information, the SAA can make the “deemed approved”
determination and establish the hours in your program. Should your school decide to add hours to the approved syllabus, you need to also
provide a copy of your syllabus with the additional hours. 25
Getting Started
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 its 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
26
Getting Started
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 27
Getting Started
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
If a fee is assessed for students needing additional hours of flight
training beyond the minimum required, the school cannot certify that fee to VA for reimbursement
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
28
Getting Started
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
Getting Started
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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Getting Started
New VA Policy Advisory
Requires schools to provide complete descriptions of flight lab
subjects which provide for breakdown of hours (dual, solo, ground, and pre/post) and flight fees (for dual, solo, ground, and pre/post hours)
The curriculum or syllabus conforms to the FAA Part 141 Flight Standards District Office (FSDO) approved hours for the individual pilot flight lab hours offered by the IHL
Complete description for each pilot rating (private pilot,
commercial, instrument, multi-engine, certified flight instructor, certified flight instructor-instrument) for airplane/fixed wing single engine land (SEL), airplane fixed wing multi -engine land (MEL), and the same for helicopter/rotorcraft listings
Getting Started
New VA Policy Advisory (cont.)
Documentation published by the IHL in the catalog (or addendum) disclosing information in previous slide and if offered by/under contract or in-house
Contracted fixed base operator (FBO) must be an FAA Part 141 approved pilot school that has been issued an Air Agency
Certificate (AAC) and is also approved by the SAA as a standalone, vocational flight school
In-house flight training must also be approved by the FAA under Part 141 or conducted under Part 61. The minimum hours
approved will be the hours published in the school’s Part 141 syllabus or a specified number of hours that the school adds to that syllabus and publishes as the course requirements or, for Part 61 approval, the hours the IHL publishes as minimum
requirements for completion of the course.
32
Getting Started
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
Getting Started
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
34
Getting Started
Standards of Progress
IHLs
As stated in school catalog and approved by the SAA Individual flight lab courses
Example: Flight lab may have a minimum number of flight instructional hours for incomplete (I) grades or nonpassing
Vocational Flight Schools
Like any other school approved for GI Bill® training, flight schools must have and enforce standards of progress
The SAAs have certain minimum standards
Other 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 35
Getting Started
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 ensure that flight skills are maintained.
A suggested standard might require students schedule flights every week and at a frequency to ensure 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
36
Getting Started
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
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
37
Getting Started
Refund Policies
IHLs
IHLs must follow their published and approved refund policies, including any special refund policies delineated in their contract with the flight school(s).
Flight Schools
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
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.
38
Getting Started
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 .)
If all required hours of flight, ground school and pre/post are listed, they must match the FSDO-approved syllabus
Getting Started
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. 40
Getting Started
Aircraft Utilized
For VA purposes, aircraft also means FTD/simulators
Only the aircraft listed in the TCO for a course may be used for 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.
Getting Started
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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Getting Started
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. Congress is considering imposing a cap on contracted programs.
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
Getting Started
44
Certifying the Enrollment
of VA Students in
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
Certifying the Enrollment of VA
Students in IHL Flight Programs
85-15% Ratio (cont.)
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 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.
46
Certifying the Enrollment of VA
85-15% Ratio (cont.)
VA/Supported (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/Non-supported (15%) portion of ratio includes all other students officially registered in that degree program
47
Certifying the Enrollment of VA
85-15% Ratio (cont.)
Non-VA/Non-supported (15%) portion of ratio includes all other students officially registered in that degree program
Title 38 CFR 21.4201(e)(2) defines non-supported students as:
Students who are not veterans or reservists, and are not in receipt of institutional aid;
Students in receipt of any federal aid (other than Department of Veterans Affairs benefits);
Degree students receiving any assistance provided by an institution, if the institutional policy for determining the recipients of such aid is equal with respect to veterans and nonveterans alike.
48
Certifying the Enrollment of VA
85-15% Ratio (cont.)
Schools 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
Schools must report the ratio to the ELR within 30 days of the start of each standard term
If out of compliance for any program, school cannot enroll new students until ratio comes into compliance
Certifying the Enrollment of VA
Students in IHL Flight Programs
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.
50
Certifying the Enrollment of VA
Completing the Enrollment Certification (VA Form 22 -1999)
Enter the exact name of the program as found in WEAMS and yourcatalog
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
Certifying the Enrollment of VA
Students in IHL Flight Programs
Completing the Enrollment Certification (VA Form 22-1999)
Enter total charges – pay as you go 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 in the FAA-approved 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.
52
Certifying the Enrollment of VA
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 IHL for required equipment, etc.
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 examiner fee must not be certified to VA; however, may be reimbursed under LACAS (see subsequent slides)
May not be in student’s best interest due to entitlement hit
Certifying the Enrollment of VA
Students in IHL Flight Programs
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
54
Certifying the Enrollment of VA
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
Certifying the Enrollment of VA
Students in IHL Flight Programs
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. 56
Certifying the Enrollment of VA
Students in IHL Flight Programs
How the Various GI Bill
®
Programs Pay Benefits and to
Whom
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 rate on 09/14/2015, full-time monthly payment for three (3) years of credible active duty is $1,717.00
Chapter 1607 – Current rate on 09/14/2015, 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 58
How the Various GI Bill
®
Programs
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 on
09/14/2015, full-time monthly benefit is $367.00
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
How the Various GI Bill
®
Programs
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, on 09/14/2015,
full-time monthly benefit is $1,018.00
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
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How the Various GI Bill
®
Programs
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
How the Various GI Bill
®
Programs
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 Yearly cap (2015-2016) is $21,084.89
Cap for previous academic year was $20,235.02
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 $16,867.91 (80% of yearly cap))
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How the Various GI Bill
®
Programs
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
How the Various GI Bill
®
Programs
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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.
We will check a random sampling of non-VA files to ensure those students are paying for their program out of their own funds
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)
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 contract/MOU/agreement 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 69
Records must be available at time of visit (cont.)
FAA website link:
Pilot Schools - http://av-info.faa.gov/PilotSchool.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
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
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
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
IHLs must follow their published grading policies
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.
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
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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
Standards of 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
Promptly 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 (cont.)
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.
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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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Findings/Common (and Not-so-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)
Findings/Common (and Not-so-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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Licensing and Certification
(LACAS)
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 86
Licensing and Certification
Items eligible for reimbursement under LACAS:
FAA examiner’s fee for the check ride
Entitlement
Student is charged one (1) month of entitlement for every test VA pays
May not always be in the student’s best interest
Licensing and Certification
Enter “Commercial Pilot ” for example as in the following screen as well as “Both” in the LAC Category type, and do a search by country (USA), then click Submit:
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Licensing and Certification
Licensing and Certification
Once there, click on Commercial Pilot to get the next screen:
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Licensing and Certification
Click on Institutional Profile and that will give the institution name and address for submission:
Licensing and Certification
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Vocabulary
Unique to the
Professional Aviation
Vocation
Air Agency Certificate:
The Air Agency Certificate is issued
by the FAA to flight schools authorizing them to offer
courses of instruction leading to pilot’s licenses and ratings.
Air Agency Certificates list the specific flight programs
approved by the FAA for the school to which the certificate
is issued. Certificate validity dates vary, but are always
indicated on the certificates. A Letter of Authorization must
accompany an Air Agency Certificate.
Chief Flight Instructor
: The Chief Flight Instructor is the
person in charge of all flight training at a flight school.
Chief Flight Instructor qualifications are contained in the
Federal Aviation Regulation (FAR), 14 CFR Part 141.35. The
FAR requires each school to designate a Chief Flight
Instructor.
Federal Aviation Administration (FAA):
The federal
government organization primarily responsible for the
advancement, safety and regulation of civil aviation.
The FAA establishes regulations and policies prevailing
over flight, including flight training, flight schools, and
certificates issued, and it oversees the development of
air traffic safety and control.
Federal Aviation Regulations (FARs):
The FARs are a
compilation of FAA regulations governing all aspects of
flight training, air carrier operations, medical
requirements for pilots, aviation safety, aircraft
maintenance training, airfield and airspace operations
within the US, its territories and their respective
boundaries.
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Fixed Base Operator (FBO):
A commercial business
granted the right by an airport to operate on the
airport and provide aeronautical services such as
fueling, hangaring, tie-down and parking, aircraft
rental, aircraft maintenance, flight instruction, etc.
When referring to Part 141 pilot schools this term is
applied to the primary location listed on the air agency
certificate and satellite operations under that same air
agency certificate located at other air fields
Fixed Wing:
An aircraft is describes as “fixed wing ” when it
derives the majority of its lift from a stationary or variable
geometry wing, as opposed to a helicopter, which derives
its lift from rotors (rotary wing). Fixed wing aircraft may be
powered by engines attached or built into its fuselage or
wings.
Flight Engineer Courses:
The flight engineer course is a
separate program with skills and requirements described in
14 CFR Part 63, Subpart B. Although the FAA has only one
flight engineer certificate, it also approves courses leading
to endorsements to the certificate for the aircraft on which
the engineer is qualified to serve. The SAA must approve a
flight engineer program offered by a school and the
additional add-on training endorsements. A VA student may
receive benefits for the endorsements.
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Flight Programs:
Flight training programs are formal
courses leading to FAA certifications or ratings to
operate aircraft. (NOTE: Pursuit of a private pilot’s
license, except as part of a degree program, is not
approvable for veteran students). All flight training
must be received from an authorized instructor.
Commercial Pilot
: The course of instruction leading to
licensing as a commercial pilot, authorized to operate
aircraft for hire. This is the initial program approvable for VA
training.
Instrument Rating
: A course of instruction leading to
certification to operate an aircraft in instrument
meteorological conditions (IMC); during periods of low
visibility.
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Flight Programs (cont.):
Certified Flight Instructor (CFI):
Course of instruction
leading to certification as a flight instructor, authorized to
conduct ground or flight training I accordance with the
privileges and limitations listed on the holder’s flight
instructor certificate.
Additional Flight Instructor Qualifications:
Certified Flight Instructor-Instrument (CFI-I): A course of instruction qualifying the CFI to provide ground and flight
instruction in all phases of flight planning, flight, and air traffic control procedures when operating in instrument
meteorological conditions.
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Flight Programs (cont.):
Additional Flight Instructor Qualifications (cont.):
Certified Flight Instructor Single Engine Land (CFI -ASEL – as opposed to seaplane) and Certified Flight Instructor -Multi Engine Land (CFI-AMEL): A course of instruction qualifying the CFI to provide ground and flight instruction in single -engine aircraft (ASEL) or multi-engine aircraft (AMEL), respectively.
Other: specific qualifications for unique aircraft or unique capabilities, such as aerobatic instructor qualifications are addressed in the FARs.
