COMPLIANCE SURVEYS. Ron Marcinko: Supervisory Education Liaison Representative Ursula Bailey: Education Liaison Representative

Transcription

1 VETERANS BENEFITS ADMINISTRATION COMPLIANCE SURVEYS Ron Marcinko: Supervisory Education Liaison Representative Ursula Bailey: Education Liaison Representative JUNE 2014

2 TRAINING OVERVIEW & OBJECTIVES Objectives of Compliance Surveys Purpose & Authority Access to Institutional Records Educational Claims Processing Jurisdiction VA Fiscal Year Schedules of Compliance Survey PL (SAA & VA Conduct Compliance Surveys) Preparation, Scheduling, Conducting & Post Survey Survey Data Questions 1

3 VA Regional Processing Offices and Jurisdictions 2

4 NATIONWIDE DATA NATIONAWIDE: Institutions: 6626 active Institutions of Higher Learning 3136 active Non Degree Institutions Public 30% Pvt Profit 42% Pvt Non Profit 28% Enrollments Enrollment totals as of April 2013: CH30-81,102 CH31-37,829 CH32-12 CH33-562,375 72% CH35-57,169 CH ,453 CH1607-9,488 TOTAL - 784,428 Nationwide FY2012 expenditures for VA education payments - $ in excess of $11 billion dollars to over 800,000 recipients and in excess of 27B$ since

5 BUFFALO JURISDICTION The jurisdiction contains 12 States The Education Service Outreach Section has a total of 21 staff for which there are 1 CELO, 1 SELR, 13 ELR s, 5 full time Education Compliance Survey Specialists and 1 Program Specialist The section is responsible for oversight and maintaining the approval data base for all institutions and training establishments in the region needed for education claims at the RPO for the processing of applications and enrollment certifications to support approved facilities Conducts compliance surveys, EO investigations, and participates in numerous local and regional SCO workshops and other organizations Responsible for SAA contract administration for 13 contracts FY14 scheduled compliance surveys total 1115 (VA 482 and SAA 633 to conduct) includes Vocational Flight Schools, On the Job and Apprenticeship training establishments, and the balance of surveys are at IHL and NCD schools required to be done but only have resources to compete

6 TYPES OF SURVEYS VA compliance surveys are conducted at the following types of active facilities: Institutions with 300 plus VA certified VA beneficiaries Institutions of Higher Learning (less than 300) Non College Degree Institutions Vocational Flight Training Schools Training Establishments Apprenticeship (APPR) On-the-Job training (OJT) Federal and Nationally approved OJT and APPR facilities Existing requirements are annual surveys at institutions with All 300 or greater VA student enrollment All Non college degree are annual surveys All Training establishments are annual surveys Active Vocational Flight Schools 5

7 Who Conducts Compliance Surveys Effective October 1, 2011 per Public Law both VA and State Approving Agency (SAA) staff conduct compliance surveys. VA Education Service Outreach ELR s ECSS s All aspects of compliance surveys remain unchanged regardless of VA or SAA staff conducting the survey. 6

8 OBJECTIVES OF COMPLIANCE SURVEYS What are they and what is the purpose? Routine reviews of selected students records to verify that payments of GI Bill benefits were properly made to your VA students Assist School Officials in better understanding their responsibilities and the procedural requirements of VA Conducted in order to ensure schools and training establishments, along with their approved courses and programs, are in compliance To determine, on the basis of facts disclosed from document reviews & personal visits, whether there are deviations from the responsibilities & requirements by eligible individuals, schools or training establishments Scheduled to previously approved facilities to monitor and assure continued acceptability of approval To assure that proper action is promptly taken through appropriate channels for the correction of existing discrepancies 7

9 PURPOSE & AUTHORITY Compliance surveys are conducted in order to ensure that schools and training establishments, and their approved courses, are in compliance with all applicable provisions of the laws administered by VA. Authority: Title CFR M22-4 Policy Advisories 8

10 ACCESS TO INSTITUTIONAL RECORDS Records and Accounts What gives us the authority to review all these records without the permission of each student? Title 38 United States Code, Section 3690(c) Notwithstanding any other provision of law, the records and accounts of educational institutions pertaining to eligible veterans or eligible persons.as well as the records of other students which the Secretary determines necessary to ascertain institutional compliance with the requirements of such chapters, shall be available for examination by duly authorized representatives of the Government. CFR Title 38 provides VA & SAA access to any institutional records as condition of approval VA and SAA exempt from FERPA concerning privacy of student records Access to VA and non VA student academic and financial records Access to review Institutional Advertising Materials 9

11 ACCESS TO INSTITUTIONAL RECORDS Records and Accounts 38 CFR The Buckley amendment (Public Law ) requires that institutions receiving Federal funds administered by the Department of Education must obtain the student's consent to release information from school records. It has been determined that school records relating to VA benefits fall into the "financial aid" category and are therefore exempt from the provisions of the Buckley amendment. Therefore, the VA (and SAA) shall have access to the records of VA beneficiaries as well as non-va students without the written consent of the student in order to monitor the school's compliance with the law. 10

12 COMPLIANCE SURVEY - PREPARATION How are schools selected? VA will establish and maintain a schedule of compliance surveys and inform SAA of which schools it has been assigned to visit Schedules will be prepared before the beginning of each fiscal year Certain number of schools assigned to the SAA; VA retains the balance Visits conducted at approved schools and facilities with veterans enrolled during the previous federal fiscal year (October - September) Several schools visited per week to reduce costs Same geographical location Majority of compliance surveys we conduct involve travel meaning a number of institutions may be scheduled for a given week (Monday Friday). We strive to not schedule at institution peak workload periods however this may not occur based on travel plans. May be more than one person conducting visit if at a large school 11

13 COMPLIANCE SURVEY - PREPARATION How are student files selected? Randomly chosen by the SAA or VA employee who will be conducting the visit (to identify any pattern of error) (no longer chosen by the school or training facility as they were with SAA supervisory visits) VA reports (RCS & COIN 289); TIMS or VA-Once used to obtain random sample RCS Records Control Schedule COIN Computer Output Identification Number The institutional records copied will be retained by VA and SAA to include in our compliance survey records PII data is safeguarded and necessary as internal quality reviews by VA are conducted to ensure all aspects of the compliance survey were accurately reviewed and completed. 12

14 COMPLIANCE SURVEY - PREPARATION How many files must be reviewed? Depending upon the size of your VA student population Sample Size is based on total VA Student awarded enrollment total - No fewer than 10 (unless you have less than 10 current enrolled VA students) ~~~Expanded ~ If review of the initial sample reveals overpayment errors in 30 percent or more of the cases, or discrepancies of any type in 50 percent or more of the cases reviewed, the survey will be expanded using a sample equal to the size of the initial sample. The survey specialist may exercise his/her discretion to expand any survey based on professional judgment and not to expand surveys in cases of repeated minor errors. VA Student Population Records to Review 0 to to to to to to to or more 45 13

15 COMPLIANCE SURVEY SURVEY NOTIFICATION OF APPOINTMENT FOR SURVEY How will we notify you? , phone call or fax to inform you of our visit Advance notice provided VA and/or SAA will call the primary SCO to schedule a date(s) and time for conducting the survey in addition to providing institution with names of students in the sample size to be reviewed. A letter or will be furnished the SCO of the student names and the institutional records to copy for our review. Survey Confirmation Letter ed or mailed Confirm date and time of appointment Provide school official with names of student files required and items/types of records to be reviewed Schedule face-to-face interviews with students, if applicable Hand out ~ sample notification letter 14

16 COMPLIANCE SURVEY Records & Accounts Needed What Records & Accounts are needed for the survey? Institutional Records Needed for Student Records: Copy of unofficial transcript Copy of Degree Audit Report (DAR) Copy of Student Account Ledger Copy of Student term registration schedules Identifying start date, end date Identifying modality of instruction Captures non-standard term dates by subjects Verification of prior credit evaluations Progress Standards (GPA) Obtaining LDA or last activity to confirm withdraw of subjects for student records 15

17 COMPLIANCE SURVEY Guidance to SCO What Records & Accounts to review prior to certification? Records & Accounts to Review Prior to Certification/Compliance Survey: Ensure student has applied to be a student Prior credit evaluation completed or pending Degree program approved Student term registration schedule Confirm modality of instruction Confirm length of period to certify Confirm subjects apply to program DAR Degree Audit Record Student Account Ledger for charges 16

18 COMPLIANCE SURVEY ASSISTANCE Need assistance prior to visit? Contact the person who will be conducting the survey As you gather the files/documentation requested and if you notice changes are required, it is recommended and you are encouraged to make the changes prior to our visit If we find anything that affects payment during visit, we must submit/refer to the Buffalo Regional Processing Office for corrective action. In some cases we will request that the school submit the appropriate corrections in VAONCE. Sometimes takes 30 days or longer to process Throughout the year, be sure to maintain contact with SAA and VA as needed Assistance provided via , phone or in person 17

19 COMPLIANCE SURVEY ON-SITE What happens when we arrive? Entrance Interview Typically with certifying official Others included as school (Student Accounts, Financial Aid, Registrar, etc.) as the facility, SAA, or Compliance Survey Specialist sees fit 18

20 COMPLIANCE SURVEY ON-SITE - Review What is reviewed during the survey? The following standards are those used by SAA and VA when reviewing records related to the compliance surveys 19

21 COMPLIANCE SURVEY ON-SITE - Review Records and Accounts Are your records/files available? Records and accounts of VA beneficiaries and other students must be provided for examination (38 CFR , , ) Review checklist provided to you by SAA or VA (whoever is conducting the visit) Ensure all items are addressed Ask questions if unsure Must have records available at time of visit 20

22 COMPLIANCE SURVEY ON-SITE - Review Commencement of Courses Did the student begin when certified? Date certified must agree with start date (38 CFR , , , , , , , , ) IHL: First day of classes for the semester or quarter NCD: First day the student is actually physically in class Flight: Date of first flight or ground school lesson OJT/Apprenticeship: For OJT - first day on the job For registered apprenticeships - the date of indenture or the first day on the job, whichever is later 21

23 COMPLIANCE SURVEY On Site Review Program Certified Is the correct program certified? Program certified must be the same as what the VA beneficiary is enrolled in and pursuing (38 CFR , , , , ) Review transcript, registrar records, enrollment agreement If they do not agree, update records and/or certification Monitor WEAMS ( ) reports Ensure program certified is exactly as appears on WEAMS 22

24 COMPLIANCE SURVEY On Site Review Is There Prior Credit? Previous Education & Training Record and evaluation of all previous education and training must be maintained in files (38 CFR , , ) Must review and evaluate acceptance of prior credit after no more than two semesters (or equivalent). If additional information is received at a later date, the evaluation can be revised. 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 VA and the veteran so notified (mandatory not a suggestion!) 23

25 COMPLIANCE SURVEY On Site Review Previous Education & Training (cont.) Make available for review all transcripts from previous institutions Review VA Forms , , , for indication of any previous education & training Take note of previous institutions in VA Once Review school application or other documentation Record prior credit submitted and total granted 24

26 COMPLIANCE SURVEY On Site Review Records Are your records accurate, current and complete? Records of enrollment, correspondence lessons serviced, flight training hours or OJT/APP hours must be accurate, current and complete (38 CFR , ) IHL: Registration documents, class schedules, transcripts, drop slips, withdrawal documentation, tuition payment ledgers, etc. NCD: Attendance records, registration documents, class schedules, transcripts, drop slips, tuition payment ledger, etc. Flight: Follow the Student Checklist that is supposed to be maintained in your files OJT/APP: Records of hours worked and wages paid to include pay and leave records, and records of training given 25

27 COMPLIANCE SURVEY On Site Review Records (cont.) Class Schedules must: be provided for each term/semester/quarter; include begin and end dates of course(s), days per week course(s) are scheduled to meet, hours per day, and location each class is scheduled to meet; be sufficient for SAA or VA to verify whether any particular class meets the regulatory requirements to be considered resident or online; and be coded to differentiate between resident and online/independent study classes and campuses (and should also be made clear in the catalog, handbooks, etc.). 26

28 COMPLIANCE SURVEY On Site Review Records (cont.) Detailed Records of Tuition and Fees Will be assessed for each student Chapter 33 students this will include all charges to the student s account, all payments/credits to the student s account from VA and all other sources including institutional, private, federal and other financial aid program Must be detailed enough to determine the source of all charges and credits/payments, including how charges were determined and payments were credited The term in which any charges/payments/credits occur should be clearly identified and linked to the appropriate dollar amount VA payments and refunds should be clearly labeled as such VA payments made to multiple campuses (with separate facility codes) should be distinguishable from the payments for your campus 27

29 COMPLIANCE SURVEY On Site Review Records (cont.) Attendance (programs approved in clock hours) Records must be maintained, monitored and policies enforced Records should be based on daily attendance (positive attendance as opposed to negative attendance records) Files must contain documentation of excused absences Once it is determined a student failed to meet attendance standards, you MUST terminate the student s enrollment certification. You may have an attendance policy that is more strict for the receipt of VA benefits than for other students. Monitor attendance to ensure compliance with reporting within 30 days 28

30 COMPLIANCE SURVEY On Site Review Accurate & Prompt Certifications Did you submit your certifications accurately and in a timely fashion? Enrollment, tuition and fees, lessons serviced, flight training hours or OJT/APP hours must be accurately and promptly submitted to VA (38 CFR (e)(f)(g), , , ) Accurate Certifications Ensure enrollments dates are correct utilize academic calendar, class schedules Ensure tuition and fees are properly allocated If unsure about fees to report, ask VA or SAA (See electronic bulletin dated January 28, 2013, regarding which fees may be included in net charges) 29

31 COMPLIANCE SURVEY On Site Review Accurate & Prompt Certifications (cont.) Timeliness All certifications must be submitted within 30 days of the latter of any of the following three (3) things: Start of the term End of drop/add Veteran s request for certification of benefits Consider having student submit request for certification If at a school where students frequently change schedules, consider certifying closer to or after drop/add, although changes made during this period must be reflected. If the certification is submitted within 30 days of the veteran s request, the request must be documented in writing through a veteran s request form, detailed telephone contact form, etc. 30

32 COMPLIANCE SURVEY On Site Review Terminated or Interrupted Training Was this reported to VA? Terminations or interruptions in training must be promptly reported to VA (38 CFR , , ) Have a system or mechanism (internal audit, report) in place to identify when students withdraw/terminate or interrupt training An automatic notice to the SCO through your computer system of any changes to a file marked VA, veteran, etc., is most helpful Last dates of attendance must be able to be identified during compliance survey visit and notification must be made to VA within 30 days of the student s last date of attendance Maintain drop and withdrawal slips in file 31

33 COMPLIANCE SURVEY On Site Review Progress and Grades Do you have adequate records of progress and grades? Accurate, current and complete records of progress or grades must be maintained for VA beneficiaries (38 CFR , , , ) Unofficial transcripts and/or progress (grade) reports should be monitored to ensure students are meeting satisfactory academic progress 32

34 COMPLIANCE SURVEY On Site Review Satisfactory Progress Did you promptly notify VA when satisfactory progress was not made? (38 CFR (d), ) Unofficial transcripts should be monitored to ensure students are meeting satisfactory academic progress Maintain documentation in files (e.g., letters of probationary status, suspension) SAP must be monitored and your approved policy enforced (i.e., students must be suspended/dismissed in strict adherence with your approved policy that policy may be more strict for the receipt of VA benefits than for other non-va students) Report probation to VA via RightNowWeb (mandatory as of August 1, 2011) 33

35 COMPLIANCE SURVEY On Site Review Charges 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 (38 CFR (d), , 38 U.S.C. 3690(a)) Monitor programs and charges for non-va students Some non-va files may be randomly selected for this purpose 34

36 COMPLIANCE SURVEY On Site Review Percentage of Enrollment Are you monitoring enrollment numbers? Verification of the 85 percent enrollment limitation must be performed Schools must provide documents verifying that the provisions of the % ratio have been met for each approved course (generally, a statement of total school/campus enrollment v. VA student enrollment) (38 CFR ) Monitor enrollment Waiver of reporting requirements for schools with fewer than 35% VA students Flight: The ratio includes only Part 141 students 35

37 COMPLIANCE SURVEY On Site Review Timely Changes Did you submit changes to VA in a timely fashion? Changes in clock or credit hours, tuition or fees must be promptly reported to VA (within 30 days) This includes reporting a Last Date of Attendance for students who received a punitive grade of F when they did not complete the course (i.e., unearned or walkaway F did not take the final exam) (38 CFR , (b), ) Consider having your IT office set up a veteran indicator/attribute in your system with automatic prompts sent to you for any changes to enrollment in an indicated file Use VA work-study students to help monitor for changes 36

38 COMPLIANCE SURVEY On Site Review Information furnished to students Did you provide the student with all appropriate copies? A copy of the course outline, schedule of tuition and fees and other charges, as well as regulations pertaining to attendance, grading policy and conduct of rules of operation must be furnished to students (38 CFR (c)) Create an acknowledgment form listing all items Have the student initial next to each item indicating s/he has received the above, then sign and date * Unless part of the approval criteria for an accredited course 37

39 COMPLIANCE SURVEY On Site Review Enrollment Limitation Are you within the limits? Enrollments must be within the limitation established by the State Approving Agency (38 CFR (c)) Enrollment limitations (typically based on number of students per instructor or classroom space), if applicable, will be specified on the WEAMS report * Unless part of the approval criteria for an accredited course 38

40 COMPLIANCE SURVEY On Site Review Refund Policy Do you have and enforce a Pro Rata refund policy? Refund policies must meet the requirements of VA regulations (38 CFR (c), , ) For non-accredited schools, the refund policy must be pro rata or more advantageous to VA students than pro rata Must be pro rata to the very end Example: Student drops out after completing 75% of the course; the school must refund 25% of the tuition to the student An accredited school could have a nonaccredited program to which the pro rata refund rule would apply 39

41 COMPLIANCE SURVEY On Site Review Déjà Vu? Repeat Discrepancies We will review to ensure you corrected and did not repeat any discrepancy found during the prior survey other than an occasional clerical error (38 CFR (d)) Implement procedures or mechanisms after a survey to ensure you do not repeat any discrepancies 40

42 COMPLIANCE SURVEY On Site Review Advertising Is your advertising in compliance with the law? Past 12 months of advertising is reviewed to ensure advertising, sales or enrollment practices are not erroneous, deceptive or misleading by actual statement, omission, or intimation. (38 CFR (h)(1) and (c)(10)) Review your website, publications, television and radio spots, etc., to ensure your advertising is not false or misleading; no promises of placement 41

43 COMPLIANCE SURVEY On Site Review Power of Attorney Does your school hold any power of attorney over any veterans education payments/checks? Reviewed to ensure the school has neither a direct nor indirect power of attorney over any VA education payments to the student. This is strictly prohibited by law and could be cause for a school s instant withdrawal of approval to train VA students (38 CFR , ) Ensure that if veterans checks come to your school address, you immediately hand them over to the student with no strings attached none whatsoever An indirect power of attorney (prohibited) is where, for example, VA checks are deposited into a joint student/school bank account to which the school has access to the funds therein 42

44 COMPLIANCE SURVEY On Site Review Independent Study Are your programs approved for independent study? (38 CFR ) Independent Study, Distance Learning, Online, Hybrid and Blended Courses must be approved in order to certify them At non-accredited NCD schools, clock hour program courses may not be approved for any online study under any circumstances Remedial courses (IHL & NCD) If offered online or as independent study, remedial courses cannot be certified under any circumstances 43

45 COMPLIANCE SURVEY On Site Review Independent Study (cont.) Work with the registrar (or other appropriate office) to monitor course formats Make other individuals aware of VA regulations To be considered in-resident training a course must have at least one class session (50 minutes) scheduled per week per credit hour. 44

46 COMPLIANCE SURVEY On Site Review Practical Training Is Practical Training approved? (38 CFR ) Monitor the SAA Catalog Approval Letters (if applicable) and WEAMS reports If Practical Training is not listed or is not approved on WEAMS, the programs are not approved for practical training Practical training generally consist of internships, externships, practicums, clinicals, residencies, etc. All such courses must be controlled by the school and not the training entity 45

47 COMPLIANCE SURVEY On Site Review Cooperative Courses Do you have approved cooperative courses? (38 CFR , , ) Cooperative courses may alternate classroom and practical training in an industry The classroom portion must compose at least 50% of the approved course Classroom and on-job training may alternate each day, week, month or term Keep detailed records of where all training takes place 46

48 COMPLIANCE SURVEY On Site Review Tutorial Assistance Do you participate in Tutorial Assistance? Tutors must be qualified by the school The school must determine that tutorial sessions are necessary, and that the cost is appropriate (38 CFR , ) Records of approved tutors and their qualifications must be maintained The justification for the need for tutoring must be documented such as test results, papers submitted, instructor recommendations, etc. Close relatives (siblings, parents, children, etc.) may not tutor each other under this program May only be utilized for post secondary courses VA Form t is used to claim expenses for tutoring 47

49 COMPLIANCE SURVEY On Site Review VA Form Conflicting Interests Certification for Proprietary Schools Is your institution a proprietary (for-profit) school? Neither VA nor SAA personnel may own any interest in or work for your school Owners, officers and certifying officials may not use their own GI Bill benefits to attend their school (38 CFR , (c), , , , ) Know who your students and employees are 48

50 COMPLIANCE SURVEY On Site Review Contractual Arrangements Has the school entered into a contractual arrangement with another entity to provide courses? Schools contracted to provide whole courses must be approved for veterans training as well (38 CFR (e)) Be sure the entity with whom you contract is approved for VA training 49

51 COMPLIANCE SURVEY On Site Review Advance Pay Is your school approved for Advance Pay? A school must agree to keep advance pay checks in a safe place and give them to the students, without strings attached, upon registration (38 CFR , ) Have a standard procedure in place to handle those checks Advance pay checks can help cover initial expenses at school; but, on the other hand, the student will not receive any further funds for almost two months and must budget accordingly 50

52 COMPLIANCE SURVEY On Site Review Nonduplication of benefits Has the school taken precautions to ensure that veterans are not using more than one federal program at the same time? Veterans may not use the Government Employees Training Act or active duty tuition assistance for the same course for which the student is receiving GI Bill benefits (38 CFR , , , , , , ) Work closely with your financial aid or bursar s office to ensure you know the sources of each student s tuition and fee payments 51

53 COMPLIANCE SURVEY On Site Review Yellow Ribbon Program Does the school participate in the Yellow Ribbon Program? We will review all financial records related to the school s waiver of their YR portion of tuition and fees and the exact source for the funding of that waiver For documentation, we will need to see the ledger records and other documents that verify the source funding of the waivers and whether there is a specific fund from which the waivers are derived Where private for-profit and non-profit schools are involved, we will need to see the same records at the IRS would request to see to verify funding sources and audit trails (38 CFR ) 52

54 COMPLIANCE SURVEY On Site Review Yellow Ribbon Program (cont.) Know how your school verifies its funding source Publicize the school s policies regarding YRP to incoming students Ensure students are informed of the programs provisions and how it works at your school Ensure the school s record keeping system is sufficient to verify that you are meeting your contractual requirements under YRP Understand what type of system the school uses to record requests to participate in YRP and document the observation of first come, first served rule Keep a list of students applying for YR that shows when they applied 53

55 COMPLIANCE SURVEY VA Form , Enrollment Certification states the SCO/Institution is certifying: Exercised reasonable diligence in meeting all applicable requirements - The institution has exercised diligence in meeting all applicable requirements of Title 38 USC and any failure by the institution to meet any requirements of the law will be reported promptly to VA - The institution agrees to report promptly to VA any enrollment change and any change due to unsatisfactory progress, conduct or attendance. Promptly means within 30 days of the enrollment change. Except for students receiving benefits under Chapter 33, the institution need not report an enrollment change for a student who was in full-time attendance before the change and in fulltime after the enrollment change. 54

56 COMPLIANCE SURVEY - The 85/15% enrollment ratio requirement has been satisfied - Student certified is not an owner or officer of the school nor is the student certified as an official authorized to sign enrollment certifications - The institution holds no power of attorney agreement authorizing the institution to negotiate VA educational assistance allowance checks - No course certified is a repetition of any course previously satisfactorily completed except as permitted by VA regulations - The course or courses certified are approved by the State Approving Agency and are generally acceptable to meet requirements for the student s objective 55

57 COMPLIANCE SURVEY ~ Common Findings Overall the findings have been very good. Common errors involve: Not reporting changes or terminations Not reporting net charges correctly Not reporting unearned F grades Not reporting distance learning correctly Late reporting of enrollment changes to VA Failure to monitor prior credit evaluations Certifying credits that do not apply to program requirements Certifying remedial subjects when offered on line Incorrectly reporting LDA last day of attendance on withdrawing Certifying incorrect program name or type of training Not reporting unsatisfactory progress or probation Lack of institutional records to support certifications to VA Certifying programs not approved by VA or SAA 56

58 COMPLIANCE SURVEY ~ Common Findings Miscellaneous Proper Certifications Under Correct Facility Code Are the certifications being generated by the Certifying Official at the school/campus at which the student is attending? A School Certifying Official at one campus cannot certify the enrollment of students at another campus unless the school has centralized certification (one facility code for all or SCO must be designated at each FC code) Be sure that your SCOs are only certifying the enrollment for students attending the campus where the SCO is physically located 57

59 COMPLIANCE SURVEY ~ Common Findings Miscellaneous Are the reporting fees being appropriately maintained/spent? Effective August 1, 2011, VA requires all reporting fees to be used exclusively in support of school efforts to certify the enrollment of their VA students. This restriction allows those funds to also be used for school certifying officials to attend VA and other VA specific training conferences Ensure your fiscal/accounting/business office department is aware of how the funds must be spent and documents their use accordingly Maintain open communication 58

60 COMPLIANCE SURVEY ~ Common Findings Miscellaneous Do you utilize VA Work-Study students? If available, at least one VA Work-Study student will be interviewed Ensure the VA Work-Study file is complete and available during our compliance survey visit Work-Study students may only be utilized to facilitate VA related work They may not work at your school in offices not associated with the administration of GI Bill programs 59

61 COMPLIANCE SURVEY ~ Post Survey Actions What happens when the survey is complete? Before We Leave Exit interview conducted With Certifying Official and others as school or auditor sees fit After We Leave Compliance Survey site visit report Referrals submitted to Buffalo Regional Processing Office Occurs only if findings affect payment 60

62 COMPLIANCE SURVEY ~ Post Survey Actions What happens when the survey is complete? After We Leave (cont.) Letter to school (sent to highest administrator with copy to certifying official) Identify student records reviewed Detail any discrepancies/findings Specify corrective actions (if any) required by the school or facility Schools and facilities are not the only ones audited A random sample of compliance survey files are reviewed each quarter for quality assurance 61

63 COMPLIANCE SURVEY ~ Post Survey Actions What happens when the survey is complete? VA and SAA will prepare narrative reports for the survey findings. Findings of reporting discrepancies will involve referrals to the RPO for award actions Findings of no reporting discrepancies however late reporting is noted and evaluated Findings of approval criteria is referred to the SAA or ELR when institution is DEEMED approved for corrective action Our internal reports capture primary causes or root causes for non compliance discrepancies found. Training of SCO s is often required due to an estimate of a 30% annual turnover of designated certifying officials. A letter is sent to the institution to acknowledge the compliance survey that conveys the results of our visit. (Normally discrepancy issues are noted during our exit briefing) 62

64 COMPLIANCE SURVEY Questions?