IHLs with Aviation Training; Approval & Surveys

Transcription

1 IHLs with Aviation Training; Approval & Surveys June 2014

2 Today s Objective This presentation will include: VA approval of aviation degree programs How to certify aviation courses Tracking aviation courses Compliance Surveys 1

3 VA Education Benefits Approval Basics

4 SAA Approval Specific SAA approval may be needed for aviation degree programs Yes - If not considered a Deemed Approved school Yes - If Deemed Approved school is using services from a 3 rd party flight school(s) No - If Deemed Approved school is using school s own flight line, instructors, etc. 3

5 Approval Requirements All aviation degree programs must meet the following criteria to be eligible for VA benefits Part 141 Approval (FAA determination) Provide copy of current Air Agency Certificate Provide copies of TCO and syllabus for each course offered as part of the degree program Each Flight School must also be approved for VA benefits 4

6 VA Education Benefits The 3 rd Party Contract

7 Contract Requirements The contract or MOU must clearly identify the IHL 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 must be listed Minimum hours required in each course syllabus are the maximum allowed for VA students All training must be completed by end of term; exceptions must be defined and listed Other obligations and restrictions on the college and the flight school 6

8 Contract Requirements, cont. The contract or MOU must clearly identify the method of payment for instruction given; If students pay the flight school and are considered to be flight school students flight school certifies the enrollment of students as vocational flight students More commonly, students register for college flight course, pay the college and are considered to be students of the college. The college must directly pay the flight school for all students in order for the flight fees to be reportable to VA. IHL certifies the enrollment of students as college students 7

9 Contract Requirements, cont. If students pay the college and the college in turn pays the flight school, the rates of payment must be clearly delineated Flat rate one fee for flight training regardless of time taken or aircraft flown Pay per hour college pays flight school based on hours completed & the specific aircraft flown The least expensive aircraft must be utilized except where required by syllabus or the FAA Hours certified must not exceed hours approved on the FSDOstamped syllabus for each course at the flight school 8

10 Refund Policies Whether flat rate or pay by hour, refunds of unearned fees (i.e., flights/lessons not completed) must be made to student or VA as appropriate for the student s GI Bill 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 latter instance, the amount of refund is the amount on account less the cost of lessons completed 9

11 VA Education Benefits Course Particulars

12 Course Details 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 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.) 11

13 Course Details Course Sequencing School s approved catalog will have the degree program outlined 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 12

14 Training Course Outline Training Course Outline (TCO) Description of purpose of course Specific aircraft and Flight Training Devices (FTDs) 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 13

15 Course Syllabus Lesson-by-lesson outline of the course Each lesson detailed as to principles to be learned and maneuvers to be practiced Minimum hours required for each lesson (becomes maximum for VA) Includes each ground school lesson with time required for each Includes a time distribution chart that summarizes the length This document strictly controls for how many flight hours a veteran can be paid 14

16 Standards of Progress For the aviation, the standards are generally set by the flight school Most often, 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 The IHL and the flight school must have a system in place to notify IHL, in a timely manner, of failure to progress satisfactorily 15

17 Aircraft Utilization For VA purposes, aircraft also means FTD/simulators Only the aircraft listed in the TCO may be used for a 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 16

18 Good Stewardship Flight training is inherently expensive and schools can take measures to limit costs Agreements with flight schools can permit use of expensive aircraft only where required by the syllabus or FAA rules Example: ABC College offers an AS degree that includes training in helicopters. The Robinson R-22 & R-44 are authorized. The 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 from the IHL Such provisions may be required by the SAA as an other reasonable criteria requirement for approval 17

19 85-15% Ratio Do students have the option of going to flight school on their own and paying the flight school directly, then having their credits transfer back to the IHL? Is there more than one type of payment plan? VA (85%) portion of ratio includes VA students & any veteran students receiving a grant, waiver, discount, scholarship, etc., directly from the school in lieu of VA benefits, (aka supported students) Non-VA (15%) portion of ratio includes all other students officially registered in that degree program You must calculate the ratio before certifying a VA student in the program for the first time 18

20 VA Education Benefits Enrollment Reporting Concerns

21 Completing the Enter term dates - Should be the published dates Enter credit hours in the same manner as non-flight degree students Enter total charges based on flat rate or pay as you go Calculate minimum cost student will incur and certify that amount up front At end of course, calculate actual charges and submit an amended enrollment to VA 20

22 Enrollment Tracking Verify that each aircraft flown/ftd/simulator used is approved for the course the student is pursuing Verify that all rates charged are at or below the approved rate for each aircraft, simulator, ground school lesson, pre/post, etc. Verify that progress records/cash tickets are signed by both the student and instructor Verify that all invoices/cash tickets are for training flights that are logged into the student s flight progress record 21

23 Enrollment Tracking Verify that each aircraft flown/simulator used is approved for the course the student is pursuing Verify that hours of pre-flight briefings and post-flight critiques are associated with an actual flight lesson. A rare exception may be made if the flight was cancelled at the last minute due to inclement weather, equipment failure, unforeseen family emergency, etc. All such exceptions must be documented 22

24 Missed & Make-up Flights When flights cannot be conducted because of inclement weather, mechanical problems, illness, etc., policy for making up such missed flights must be specified Time limit for making up missed flights must be delineated; (i.e. standard school policy for incomplete grade) 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 23

25 Cancelled/Postponed Flight Training In rare instances, students may not complete all lessons within the term due to weather or mechanical problems, etc. The school must have a policy for these types of situations; Example: Student allowed up to 60 days after the end of term to complete the flight training or receive a failing grade If flight fees are pay as you go, the flight charges may then be submitted to VA 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 24

26 Dropped Flight Courses Always report last date of training The contract with the flight school must specify the arrangements for handling funds when students drop The contract should include a policy that provides payment only for flight training actually given Flat rate because flight training is very costly, a nonrefundable flight fee is not an option Best practice for refund calculate cost of training given through date of drop Deduct cost of training given; refund the remainder of the unearned fees (pro rata) 25

27 VA Education Benefits Compliance Surveys

28 Compliance Surveys All standard procedures apply, in addition to the following records specific to the aviation students: Each current course TCO and FSDO-stamped syllabus Flight school progress records Flight school student cash tickets/ledgers/invoices Current AAC (we will also review for revocation before the survey at the FAA Web site) 27

29 Survey Review IHL Documents: Registration documents, class schedules, transcripts, drop slips, withdrawal documentation, tuition payment ledgers, etc. Class schedules and detailed record of tuition and fees Records specific to flight training: Lesson-by-lesson progress records signed by the student and instructor, whether ground school or flight lessons Cash tickets/student ledgers/invoices specific to flight that list each flight tied to the specific flight lesson, aircraft utilized, time spent training in the aircraft, etc. 28

30 Records available at visit FAA website links: Pilot Schools - Training Centers - Pilot School will show up if AAC is still valid Pilot School will show up if AAC is still valid 29

31 Common Survey Findings Hours certified to VA do not match up with training records Dates certified to VA do not reflect actual beginning of training (first ground school or flight lesson) Rates certified are maximum approved instead of actual charges Aircraft/rates certified to VA are not approved Pre/post lumped into or interchanged with Ground School Documentation of training, billing, licenses, certificates, grades, etc. not maintained for three (3) years from last day of training 30

32 Common Survey Findings Student flying and being certified for more flight hours (and associated charges) than the course syllabus requires Notice of termination for unsatisfactory pursuit sent more than 30 days after the last flight or ground school class Administrative withdrawal date certified instead of last flight or ground school class Courses taken out of sequence, per in the school s catalog Refund after termination not prorated for lessons not taken 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 31

33 VA Education Benefits Available Resources

34 Contact Information For Students: Toll free: for Education Questions Toll free: for other VA questions Submit a Question via For School VA Certifying Officials (only): Local Education Liaison Representative (ELR) Certification, regulatory requirements, VAONCE assistance Hardship cases (i.e. certified student has no payment or communication from VA and has exhausted other contact resources) National Hotline for School Certifying Officials General questions on student eligibility, claim status, payment status Allow a passage of time before making an inquiry re: a 1999 Schools may establish account/make inquiry direct to the Buffalo RPO via Submit A Question. 33

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