Program Approvals: IHL and NCD Michael Jurkowski: Education Liaison Representative GI Bill 70 Years 1944-2014 June 2014 GI Bill is a registered trademark of the U.S. Department of Veterans Affairs (VA). More information about education benefits offered by VA is available at the official U.S. government Web site at http://www.benefits.va.gov/gibill.
Program Approval: General Information As a general rule, veterans and dependents receiving VA Education Benefits must be enrolled in an approved Program of Education or Training offered at an approved training facility or educational institution. Institutes of Higher Learning (IHL) and Non College Degree (NCD) facilities are classified as either Accredited and Non-Accredited for VA approval requirements. IHL is a school that offers degree programs. It may also offer non-degree certificate programs. NCD is a school that only offers non-degree certificate programs. Accredited IHLs are further broken down into Deemed Approved and Non-Deemed Approved. State Approving Agencies (SAA) along with VA are responsible for approving Programs of Education and facilities offering those programs in accordance with 38 U.S. Code, Chapter 36. 1
Program Of Education A Program Of Education: Is a combination of subjects or unit courses pursued at an educational institution. The combination generally is accepted as necessary to meet the requirements for a predetermined educational, professional or vocational objective. Except for chapter 35, it may consist of subjects or courses which fulfill requirements for more than one objective, if all objectives pursued are generally recognized as being related to a single career field. 2
Program Of Education A claimant's program must meet each of the following conditions: Meet the definition of a program of education. NOTE: VA will pay only for courses and subjects which are part of an approved program. Have an acceptable educational, professional, or vocational objective. Be approved for VA training and offered at an approved facility or institution. The claimant must not be already qualified for the objective of the program. Selection of an Objective A program of education must lead to one of three types of objectives: educational, professional, or vocational. 3
Objectives Defined Educational Objectives: An educational objective leads to the awarding of a diploma, degree, or certificate which reflects educational attainment as distinguished from a certificate or a license to practice a profession or trade. The objective will be the name of the highest degree, diploma, or certificate included in the program, such as a GED (General Educational Development) certificate, high school diploma, bachelor degree, master degree, or Ph.D. degree. Non-Degree Postdoctoral and Graduate Level Certificate Programs. A postdoctorallevel certificate from an accredited college or university may be accepted as an educational objective. NOTE: Undergraduate-level certificate programs lead to vocational objectives. 4
Objectives Defined Vocational Objectives: A vocational objective leads to an occupation ordinarily attained after completion of a business, technical, trade, or other vocational school course, or an apprenticeship or other on-the-job training program. A vocational objective must be a recognized employment objective. It should be of the type listed in the DOL (Department of Labor) Dictionary of Occupational Titles found in the DOL "O*NET" database, at the following Internet site:"www.doleta.gov/programs/onet". Examples of vocational objectives are barber, secretary, machinist, computer programmer, automobile mechanic, and practical nurse. With respect to non-degree certificate programs, an undergraduate level certificate from an accredited college or university may be accepted as leading to a vocational objective. 5
Objectives Defined Professional Objectives: A professional objective leads to an occupation after an individual completes an extended academic program of study. The program must be at the college level and be generally accepted as necessary to satisfy the educational requirements for licensing or certification to practice the identified profession. Typical examples of professional objectives are lawyer, physician (M.D.), teacher, physical therapist, medical technologist, and medical record librarian. A program leading to a professional objective may include courses also leading to an educational objective. In this situation, the student may specify either the educational objective or the professional objective on his or her application. Examples are B.S. (Bachelor of Science) degree in secondary education or high school teacher, and J.D. (Juris Doctor) degree or lawyer. 6
Roles of SAA and ELR The approval of programs/courses at schools is the responsibility of the State Approving Agencies (SAA). SAAs have jurisdiction over the schools operating within the borders of their respective states and must inspect schools to determine whether or not their programs meet the requirements of title 38 U.S.C. chapter 36. SAAs in states where extensions, branches, or additional facilities of out-of-state schools are operating may approve the programs at these extensions, branches, or additional facilities. SAAs will require any schools desiring approval to submit an application and provide evidence that they meet the legal requirements for approval. SAAs must notify the school and VA after determining whether or not a program meets the requirements for approval. SAAs are also responsible for notifying VA of each amendment, modification, or withdrawal of any approval. 7
Roles of SAA and ELR The Education Liaison Representative (ELR) is responsible for receiving, reviewing, and taking appropriate actions on all approval notices submitted by SAAs and ensuring that VA only pays for programs that are approved in accordance with 38 U.S.C. Chapter 36. ELRs are assigned to the ESUs (Education Services Units) at RO s (Regional Offices) and the Regional Processing Offices. They are under the jurisdiction of the CELO (Chief Education Liaison Officer) at the RPO (Regional Processing Office) of jurisdiction. ELRs are responsible for updating the Web Automated Approval System (WEAMS) with program approval and other information about an approved facility. ELRs are responsible for disseminating approval information to all concerned elements within VA and approved schools. ELRs are responsible for acting as a liaison between the Regional Processing Offices and schools regarding issues of program approval. 8
Approval Process Flowchart Student Requests Program / School Submits Enrollment School wishes to get program approved SAA may request additional information VCE checks WEAMS / ELR for program approval ELR may check with SAA School submits application and catalog to SAA Program is not approved Program is approved SAA submits approval to ELR ELR may request additional information VA notifies student and SAA of denial VA issues COE or payment ELR processes approval / updates WEAMS / Notifies School 9
Accredited Programs To be approved as Accredited, schools must meet one of the following criteria: (1) Programs must be accredited by nationally recognized accrediting agencies. A nationally recognized accrediting agency is one recognized as such by the Department of Education and listed in the "Nationally Recognized Accrediting Agencies, Criteria and Procedures for Listing by the US Secretary of Education and Current List. Note 1: Schools may be approved to offer both Accredited and Non-Accredited programs. Note 2: Holding candidate for accreditation status (or its equivalent) is not a basis for approval as Accredited. (2) The program is recognized by a State department of education as applicable to or required for the attainment of a high school diploma. (3) The program is offered by a public vocational school operating under the provisions of the Smith- Hughes Vocational Education Act. (4) The program is recognized by a State department of education for a teacher's certificate or a teacher's degree. (Requirements for approval of Accredited Programs are found in 38 U.S. Code 3675 - Approval of Accredited courses and 38 CFR 21.42543 Accredited courses.) 10
Non-Accredited Programs A school not meeting the requirements of an Accredited Institution, can be approved as a Non-Accredited facility provided they meet the legal requirements of a Non-Accredited School. Non-Accredited schools are schools that are not accredited or do not meet the legal requirements for being considered an Accredited school for VA purposes. Non-Accredited schools can be either IHL or NCD and be can either be public, private forprofit or private not-for-profit institutions. Non-Accredited programs and facilities will have different requirements for approval than Accredited programs and facilities. Non-Accredited programs will have limitations on the types of training that can be approved for VA Benefits (for example: Practical Training or Independent Study cannot be approved for Non-Accredited programs or schools). (Requirements for approval of Non-Accredited Programs are found in 38 U.S. Code 3676 - Approval of Non-Accredited courses and 38 CFR 21.4254 Non-Accredited courses.) 11
What Is Deemed Approved The following programs are deemed to be approved effective August 1, 2011, subject to sections 3675 (b)(1) and (b)(2), 3680A, 3684, and 3696 of Title 38, United States Code: Accredited standard college degree programs offered at an accredited public or accredited not-for-profit proprietary educational institution, that is accredited by an agency or association recognized for that purpose by the Secretary of Education. A flight training course approved by the Federal Aviation Administration that is offered by a certified pilot school that possesses a valid Federal Aviation Administration pilot school certificate. An apprenticeship program registered with the Office of Apprenticeship (OA) of the Employment Training Administration of the Department of Labor or a State apprenticeship agency recognized by the Office of Apprenticeship. A program leading to a secondary school diploma offered by a secondary school approved in the State in which it is operating. A licensure test offered by a Federal, State, or local government is deemed to be approved for purposes of this chapter. All schools and training facilities must first be approved by the SAA and VA before they can be Deemed Approved. 12
The Approval Process For Deemed Approved Schools Accredited public and not-for-profit institutions will no longer have to report new standard college degree programs or changes to those standard college degree programs. Schools must continue to maintain all appropriate records. Institutions and facilities must meet or be compliant with sections 3675 (b)(1) and (b)(2), 3680A, 3684, and 3696 of Title 38, United States Code to be considered Deemed Approved. Continuing Ed, Workforce Development and/or Professional Development courses are NOT deemed approved. Courses offered under contract with a third party are not Deemed Approved and must be approved like any other program is that is not Deemed Approved. Additions/changes to non-degree certificate and diploma programs must be approved by SAA and VA before benefits can be paid. Changes to accreditation status; ownership status; school policies; school address and any changes to approval criteria must be reported to SAA and VA. 13
Non-Deemed Approved Non Deemed-Approved Facilities No change from the existing process Requests for approvals or changes must be submitted to SAA for approval SAA approves programs notifies school and ELR of approval ELR then accepts approvals for VA SAA also approves all new facilities, including new Public and Non Profit Private Deemed Approved schools 14
IHL & NCD Approval Process Non-Accredited School Non-College Degree (NCD) School Private For-Profit IHL Accredited Public or Not-For-Profit IHL Requires Approval of all Programs by SAA and VA Certificate Program Degree Program Deemed Approved 15
COURSES PRECLUDED FROM PAYMENT OF VA EDUCATIONAL BENEFITS UNDER ALL CIRCUMSTANCES VA Education Benefits are not payable for all types of courses or all types of programs even at schools that are deemed approved. Payment of VA Education Benefits will always be prohibited for the courses indicated below: Bartending and Personality Development. Any bartending or personality development courses. Radio: Any course(s) given by radio. Private Pilot's Training. Vocational flight training for a private pilot's certificate. However, flight training at the private pilot's level may be pursued under all chapters at an IHL (Institution of Higher Learning) for credit toward a standard college degree (flight training provided under contract must be approved by the SAA). Self-Improvement Courses. Self-improvement courses such as reading, speaking, woodworking, basic seamanship, or English as a second language, which may or may not lead to a certificate in general studies. Although a certificate is awarded upon completion of a required number of courses or subjects, it does not meet the legal requirements of an educational, professional, or vocational objective. 16
COURSES PRECLUDED FROM PAYMENT OF VA EDUCATIONAL BENEFITS UNDER ALL CIRCUMSTANCES Audited Courses. Because no credit toward attainment of an educational objective can be earned for such a course, it cannot be a part of the student's approved program. Schools must not include audited courses on enrollment certifications and must report when a previously certified course changes to an audited course. Unapproved Courses. Courses that are not approvable at a particular school, such as Independent Study at a Non-Accredited school should not be certified. Course Not Part of Program. Any course which is not part of the student s approved program of education except for refresher, remedial, and deficiency courses required to pursue a program of education. (There are some exceptions to this such as the Rounding Out provision in a student s final term). Refresher, remedial and deficiency courses are only payable if offered In-Residence. Erroneous, Deceptive, Misleading Advertising. Any course offered by an institution which utilizes advertising, sales, or employment practices of any type which are erroneous, deceptive, or misleading either by actual statement, omission, or intimation is not payable. 17
COURSES PRECLUDED FROM PAYMENT OF VA EDUCATIONAL BENEFITS UNDER ALL CIRCUMSTANCES Avocational Courses Any course which is avocational or recreational in character, or for which the advertising contains significant avocational or recreational themes. (1) The following courses are presumed to be avocational or recreational in character and require evidence establishing that the course will be of bona fide use in the pursuit of the business or occupation: (a) Any photography or entertainment course; or (b) Any music course, instrument or vocal, public speaking course, or course in dancing, sports, or athletics, such as horseback riding, swimming, fishing, skiing, golf, baseball, tennis, bowling, sports officiating, or other sport or athletic courses, except courses of applied music, physical education, or public speaking which are offered by IHLs for credit as an integral part of a program leading to an educational objective; or 18
COURSES PRECLUDED FROM PAYMENT OF VA EDUCATIONAL BENEFITS UNDER ALL CIRCUMSTANCES Courses Offered Under Contract By A Non-Approved Facility VA may not approve the enrollment of a veteran, servicemember, reservist, or eligible person in a course as a part of a program of education offered by any educational institution if the educational institution or entity providing the course under contract has not obtained a separate approval for the course from the appropriate State Approving Agency or from the Department of Veterans Affairs. 19
ADDITIONAL RESTRICTIONS ON PROGRAM/COURSE APPROVALS Non-Accredited Nurses Training. Non-accredited nurses training is not payable except for certain nurses aid training. Branch Locations. Courses offered at branch locations which are not included as part of the parent facility's approval or do not have their own separate approval are not payable. 85-15% Ratio. Courses /Programs which do not meet the 85-15% ratio requirement are not payable. Title 38 U.S.C. 3680A(d) and 38 CFR 21.4201 prohibit paying VA benefits to students enrolling in a course when more than 85 percent of the students enrolled in that course are having all or part of their tuition, fees, or other charges paid to or for them by the school or VA. The 85-15 percent ratio requirement does not apply to Chapters 31 or 35 certifications (however, students receiving Chapter 31 or 35 benefits must be counted as VA students when computing the ratio). Practical Training at Non-Accredited Schools. Practical Training courses (Internship or Externship) must be accredited by a nationally recognized accrediting agency. Candidate status is not sufficient. [If the courses are not accredited, the schools offering the courses must be accredited by one of the regional accrediting associations.] Independent Study (Distance Learning) at Certain Schools. 38 USC 3680A(a)(4) prohibits the approval of enrollment in any independent study program except for accredited courses leading to a standard college degree or certificate offered by an Institution of Higher Learning (IHL). 20
Independent Study vs In-Residence vs Hybrid Undergraduate Resident Training Must have regularly scheduled classes & meet at least once every 2 weeks Total hrs of instruction (based on 50 minutes per hour) must >/= the # of credits awarded multiplied by the number of weeks in a term 3cr over 16 week = 48 total hours in class* 3cr over 5 week = 15 total hours in class* *And must meet at least once every 2 weeks In class does not mean the student is in class working independently at his or her own pace with a teacher in the room to answer questions. Graduate Resident Training Consists of 2 regularly scheduled standard classes per term, research (on or off campus), or a combination of both. Independent Study, Online, Distance Ed These are all treated the same by VA Interaction between the student and the instructor (who is physically separated from the student) through the use of communications technology instead of regularly scheduled, conventional classroom or laboratory sessions. Communications technology includes (but is not limited to): Open Circuit TV Computer technology Wireless communication devices Any course, including hybrid or blended "that does not meet the requirements for Resident Training is considered Independent Study. 21
Program Approvals: School Responsibilities Schools should notify the SAA of any changes to their approved programs (except for Deemed Approved programs). Schools should only certify courses that are part of a student s approved Program of Education (some exceptions apply for rounding out terms and non-matriculated students). Courses that are offered under contract should not be certified unless the contracted facility has obtained a separate approval by the SAA and VA to offer those courses. Schools should make sure courses that are not approved for VA Education Benefits are not certified (such as Independent Study or Practical Training at a Non-Accredited school). Schools are responsible for ensuring that the 85/15 Rule has been met prior to submitting an Enrollment Certification. Schools are responsible for updating the approved or Deemed Approved Standard Programs listing in VA-ONCE. 22
VA-ONCE OBJECTIVE AND COURSE CODES OBJECTIVE CODES For IHL Schools & programs only Denotes the degree (i.e. bachelors) If your degree is not listed, use N.E.C. code IHL School/program must have both an objective and course code Added on your standard programs page Make sure your Bio screen reflects the correct type of training (IHL vs NCD) & the program name you enter matches your SAA approval or catalog. COURSE CODES For both IHL & NCD schools & programs Denotes the program (i.e. accounting) If your program is not listed, use the closest N.E.C code NCD school/program will have only a course code. VA Once will populate the Objective code field with the same code as you choose for the course code. Added on your standard programs page The VA Once Flip Book power point on the GI Bill website has been updated with instructions for course/objective codes. See slides 29-41. 23
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