State Approving Agency, VA and NCD Schools

FLORIDA ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS 2014-2015 Clock Hour Workshop State Approving Agency, VA and NCD Schools November 20, 2014 Sanibel Harbour Marriott Resort and Spa Fort Myers, Florida Betsy Wickham Bureau Chief Florida Dept. of Veterans Affairs State Approving Agency Katherine Snyder Program Specialist Florida Dept. of Veterans Affairs State Approving Agency Flight Chairperson, NASAA

Topics SAA and VA Functions 2014 Veteran-Related Florida Legislation Education, Training and Employment Resources Principles of Excellence Compliance Centralized complaint system Catalog Approval Process Compliance Surveys Guidance for most common issues 2

State Approving Agency and VA Functions 3

SAA Functions Primary SAA The SAA was established to ensure that veterans or eligible dependents can use the GI Bill in an educational program that meets certain minimum requirements for quality, relevance and stability The primary function of the Florida SAA is to review, evaluate and approve quality educational and training institutions and programs for veterans benefits Promotes and safeguards quality education and training programs for veterans Ensures greater educational opportunities to meet the needs of veterans Assists VA in preventing fraud, waste and abuse in the administration of the GI Bill Interprets and enforces state rules that directly impact the administration of the GI Bill 4

SAA Functions Differences Between the SAA and VA SAA Approves programs for VA educational benefits Answers questions regarding rules, policies and procedures Ensures compliance with established standards Assists VA in conducting compliance surveys (as of 10/01/2011) Is under contract with VA for all work conducted (VA reimburses the state for cost of all SAA salaries, fringe benefits, and travel costs with an allowance for administrative costs) VA U.S. Department of Veterans Affairs (VA) administers federal programs nationwide for veterans and is responsible for the payments Answers questions regarding payment and entitlement as well as rules, policies and procedures and provides training for the same Conducts compliance surveys Reviews approvals submitted by SAA and enters them into VA s central school data system, WEAMS 5

SAA and VA Collaborate in: SAA Functions Collaboration with VA Maintaining integrity of programs Training of School Certifying Officials (SCOs) Encouragement of greater use of VA benefits Helping schools better serve veterans and their dependents Promoting and enabling information exchange between school officials regarding best practices 6

SAA Contact Information Schools contact the SAA for: Approval questions Catalogs, addenda, programs, policies, procedures New facilities Training Changes in accreditation, ownership, address Students contact the SAA for: Outreach questions Explain the approval process and what may or may not be approved Follow up on complaints made by students against facilities Provide guidance as to where to go for assistance Note: Cannot provide assistance regarding payments of benefits 7

VA Florida Outreach Office Contact Information Schools contact the VA Florida Outreach Office for: Interpretation of VA rules, policies, procedures and regulations To initiate or make changes in EFT Changes in SCO Procedures to follow to handle special situations Note: Do not contact for debt questions Students: Students should not contact the Florida Outreach Office since their mission relates to compliance and approvals. For questions related to education claims, remaining benefits, payment issues, etc., students should contact VA via phone or web (see Slide 15) 8

SAA facilitates use of VA benefits, Florida veteran benefits and employment resources 9

2014 Veteran-Related Florida Legislation 10

Veteran-Related Florida Legislation Effective July 1, 2014 Florida GI Bill - HB 7015 Out-of-State Tuition Waivers to student veterans Veterans Preference in state employment Residency requirement for state Veteran Nursing Homes Expands Florida National Guard education program Creates nonprofit organization, Florida is for Veterans, Inc. Florida - HB 851; SB 1400 Purple Heart Tuition Waivers at Technical Education Centers Florida - HB 5001 Honorably Discharged Graduate Assistance Program (HDGAP) 11

Veteran-Related Florida Legislation Effective July 1, 2014 Item passed within HB 7015 Additional Details Out-of-State tuition waiver for veterans Active Duty and in-state tuition FS 1009.21 Creates the Congressman C.W. Bill Young Veteran Tuition Waiver Program waiving out-of-state fees for honorably discharged veterans who reside in Florida. The following persons shall be classified as residents for tuition purposes: Active duty members of the Armed Services of the U.S. residing or stationed in Florida, their spouses and dependent children and active drilling members of the Florida National Guard; Active duty members of the Armed Services and their spouses and dependents attending a College System institution or state university in Florida within 50 miles of the military establishment where they are stationed, also outside of Florida, if it is 12 within a county contiguous to Florida

Veteran-Related Florida Legislation Effective July 1, 2014 Item passed within HB 7015 Expands Veterans Preference in state employment (see current: FS 295.07, 295.08, 295.085) Additional Details In addition to current Veterans Preference in employment in Florida, Veterans Preference has been expanded to include: All honorably discharged veterans; Current members of the Florida National Guard and U.S. Armed Forces Reservists; The mother, father, legal guardian, or unremarried widow or widower of a member of the US Armed Forces who died in the line of duty under combat-related conditions; 13

Veteran-Related Florida Legislation Effective July 1, 2014 Item passed within HB 7015 Residency requirement for state veteran nursing homes Florida National Guard Educational Dollars for Duty (EDD) Program Additional Details Removes one-year residency requirement for acceptance into one of the six state nursing homes in Florida Appropriates $1.53 million in recurring funds to the Department of Military Affairs to fund EDD tuition scholarships and book stipends for National Guard members and $250,000 in nonrecurring funds for information technology upgrades for EDD 14

Veteran-Related Florida Legislation Effective July 1, 2014 Item passed within HB 7015 Florida is for Veterans, Inc. Additional Details Creates a nonprofit corporation within FDVA to promote Florida as a veteranfriendly state. The corporation will encourage and assist retired and recently separated military personnel to keep or make Florida their permanent residence and help equip veterans for employment opportunities and promote veteran hiring 15

Veteran-Related Legislation Effective July 1, 2014 Item passed in HB 851; SB 1400 Purple Heart Tuition Waiver Purple Heart Waiver FS 1009.26 Additional Details Grant tuition waivers at State Technical Centers for recipients of the Purple Heart or other combat decorations superior in precedence Effective July 1, 2006; Provides a fee waiver to recipients of the Purple Heart or other combat decoration superior in precedence if the recipient enrolls in a Florida public community college or state university 16

State of Florida Veteran Benefits Honorably Discharged Graduate Assistance Program (HDGAP) House Bill 5001 signed into law June 2, 2014 Commencing Fall, 2014 Appropriated $1,000,000 for supplemental need-based aid to assist in the payment of supplemental living expenses during holiday and semester breaks. The annual maximum award - $50/day for up to 20 days during holidays and semester breaks. To be eligible a student must: be a Florida resident; be enrolled in a program of study (in term prior to break and next future term); be an active duty or honorably discharged member of the Armed Forces who served on or after September 11, 2011; complete an error-free FAFSA; have sufficient unmet need (award may not exceed need) 17

State of Florida Veteran Benefits Honorably Discharged Graduate Assistance Program (HDGAP) October 24, 2014 Letter from FLDOE to Financial Aid Directors November 15, 2014 Deadline for postsecondary institutions to submit allocation request Allocations to institutions first-come, first-served FLDOE Contact: Nanette.Smith@fldoe.org or 888-827-2004 18

Veteran Dependents State of Florida Veteran Benefits The Florida Department of Education Office of Student Financial Assistance www.floridastudentfinancialaid.org offers: Scholarships for Children and Spouses of Deceased or Disabled Veterans who entered the military from the state of Florida it essentially pays all tuition and fees Beneficiaries may also receive VA Chapter 35 benefit 19

State of Florida Veteran Benefits Veterans Access, Choice and Accountability Act of 2014 Stay tuned 20

Resources Florida Benefits Guide http://floridavets.org Florida benefits for active duty: http://myarmybenefits.us.army.mil/home/benefit_library/s tate Territory_Benefits/Florida.html#top Tracking Florida Bills: http://flsenate.gov/session/bills FDVA Contact: Bobby Carbonell, Florida Department of Veterans Affairs Legislative and Cabinet Affairs Director CarbonellR@FDVA.STATE.FL.US 21

Veteran Employment Resources 22

Veterans Veterans Job Training Assistance Employment Resource The Florida Department of Economic Opportunity provides job placement services for all veterans Upon leaving the military and/or graduating from school, veterans should register on the Employ Florida Marketplace website shown below https://www.employflorida.com Within two weeks of registration, veterans will be contacted by a LVER or DVOP (Local Veterans Employment Representative and Disabled Veterans Outreach Person) The goal is to assist each veteran to find employment within six months from date of registration 23

Principles of Excellence 24

Principles of Excellence Executive Order 13607 Executive Order 13607 Establishing Principles of Excellence for Educational Institutions Servicing Servicemembers, Veterans, Spouses and Other Family Members Signed by President Obama on April 27, 2012 SAA and VA began incorporating into compliance surveys as part of the review process beginning October 1, 2013 Program is entirely voluntary Not participating or not adhering if signed may lead to a school receiving bad publicity, but there are no civil or criminal penalties for not participating or for not adhering if signed As indicated in the www.benefits.va.gov/gibill website, educational institutions participating in the PoE program agree to certain guidelines 25

Principles of Excellence Participating Schools/Compliance Surveys SAA and VA must review certain items regarding PoE during a compliance survey visit Use of the GI Bill Comparison Tool to determine if a school participates in the PoE Comparison Tool/GI Bill Estimator website: http://department-of-veterans-affairs.github.io/gi-billcomparison-tool/ Allows veterans and family members to make informed decisions by: Researching approved educational institutions Calculating estimated GI Bill benefits 26

Principles of Excellence Comparison Tool 27

Principles of Excellence Compliance School agreed to: Provide students with a personalized form covering the total cost of an education program Provide educational plans for all military and veteran education beneficiaries End fraudulent and aggressive recruiting techniques and misrepresentations During compliance survey, SAA and VA check to see whether school: Provided a Financial Aid Shopping Sheet http://www2.ed.gov/policy/highered/guid/aidoffer/index.html Informed, or has policies to alert, students of the availability of federal financial aid prior to arranging other financing Used fraudulent and unduly aggressive recruiting 28

Principles of Excellence Compliance School agreed to: Accommodate servicemembers and reservists absent due to service requirements Designate a point of contact to provide academic and financial advice Ensure accreditation of all new programs prior to enrolling students During compliance survey, SAA and VA check to see whether school: Readmits servicemembers and reservists into programs if they are temporarily unable to attend class or have to suspend their studies due to service requirements and accommodations made for short absences resulting from service obligations Has a point of contact for academic and financial advising to assist servicemember and veteran students and their families Obtained the approval of its accrediting agency for new course offerings prior to enrolling students in such courses or programs 29

Principles of Excellence Compliance School agreed to: Align institutional refund policies with those under Title IV, which governs the administration of federal student financial aid programs Provide educational plans for all individuals using Federal military and veterans educational benefits that detail how they will fulfill all the requirements necessary to graduate and the expected timeline of completion During compliance survey, SAA and VA check to see whether school: Has a refund policy that is aligned with the refund of unearned student aid rules applicable to federal student aid provided through the Department of Education under Title IV Check to see if the school provides detailed educational plans outlining graduation requirements 30

Principles of Excellence Centralized Complaint System VA and DoD created a system for individuals currently using VA education benefits* to register complaints against educational institutions for fraudulent, deceptive and misleading practices Tracked to educational institution with responses provided to the complainant Initiative is part of implementation of E.O. 13607 and Public Law 112-249 Improving Transparency of Education Opportunities for Veterans Act of 2012 Launched on January 30, 2014 *For those individuals not using VA education benefits, complaints are to be filed with the appropriate agency 31

Principles of Excellence Centralized Complaint System How to Access/Submit VA GI Bill Feedback System (aka Complaint System) www.benefits.va.gov/gibill/feedback.asp Complaints accepted through a webform (Principles of Excellence Complaint Intake Questionnaire) and the Education Service National Call Center Complaints to VA Central Office Appropriate Agency (DoD, ED, Consumer Protection Bureau, DoJ, and the FTC) Complaints also filtered for possible distribution to VA ELR (Ron Scoggins in FL) if not handled by ELR, then distributed to State Approving Agency Some complaints will be routed directly to the school by VA Central Office. This procedure is still being worked out Complaint system may be utilized for PoE and non-poe schools alike 32

Principles of Excellence Impact of Risk-Based Analysis on Compliance Survey Schedules Based upon complaint system and compliance survey analyses, some schools will require a risk-based review VA Central Office (VACO) will do the analyses and determine which schools must be surveyed based upon the risk The schools identified will be added to the annual compliance survey schedule or, if already scheduled, their survey may be moved up on the schedule Factors considered under risk-based analysis include: Complaint(s) received Previous compliance survey data Management mandates Information received from other government agencies and regulators Law suits against the institution Facility self-reported violations 33

Catalog Approval Process 34

Submission of Catalogs & Addenda Catalogs and addenda must be submitted to the SAA Part of initial approval criteria Maintenance of approval for the training of veterans and other eligible persons 35

Submission of Catalogs & Addenda SAA frequently sends catalog reminder letters; however, timing is based upon expiration date assigned to last catalog approved Expiration date based upon academic calendar and/or other dates within catalog If another catalog or addendum is published prior to the expiration date, school must submit within 30 days of publication If not, risk suspension or withdrawal for lack of compliance 36

Submission of Catalogs & Addenda Submit catalog and any addenda to the State Approving Agency (SAA) within 30 days of publication CD is preferred medium Information contained in catalog, bulletin, student handbook, supplements and addenda must be certified as true and correct in content and policy as required by 38 CFR 21.4253 The following statement must accompany and reference any of the above mentioned items: I hereby certify all information contained in the [specify catalog and/or other items] is true and correct in content and policy ; dated and signed by official signatory of the school Cover letter Signed CD or label Inside front cover if hard copy 37

Catalog Review and Approval Multi-step Process Once SAA in receipt of catalog, it is logged in for processing SAA has 14 business days to determine if catalog and/or addenda are approved or denied Approval or denial letter sent to specific campus where schools have multiple campuses with separate catalogs Read letter carefully to ensure accuracy and understanding If questions, contact the SAA If new programs, do not certify in VA-ONCE until WEAMS (aka VA Form 22-1998) has been updated by VA (VA will mail a copy to school) Veterans Claims Examiners (VCEs) will deny benefits for a program they do not see in WEAMS Ensure VA-ONCE reflects program name exactly as it appears in WEAMS 38

SAA Approval Letter What you will see Date of approval = date letter was generated Effective date of approval = date the catalog or addenda went into effect Unless school has requested extension for last catalog approved, if we see an effective date more than 30 days beyond the date of publication, school is not in compliance Appropriate section of law is checked Chapter 36, Title 38, USC, Section 3675 applies to accredited courses/programs Ensure any new programs are accredited prior to certifying any VA student 39

SAA Approval Letter What you will see Specific catalog, year, publication date and any addenda will be reflected as to what is being approved along with an approved through or expiration date Specific programs will be listed Noncollege degree (NCD) programs Diploma or certificate Programs not leading to a standard college degree must NOT be certified to VA if taught in whole or in part in an independent study, distance learning, online, blended or hybrid format 40

SAA Approval Letter What you will see Page number of where within the catalog the program information is located Appropriate type of hours will be specified New NCD programs will have a Class or Shop designation (an X will be marked in the appropriate column) This will be the determining factor as to what will be considered full-time for a program Page Clock Hrs. Class Shop NCD Program Name 57 750 X 41

Compliance Surveys 42

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 Ensure schools and training establishments, along with their approved courses and programs, are in compliance with all federal and state requirements for administering VA programs Give an opportunity to provide training Monitor and assure continued acceptability of approval for previously approved facilities 43

Compliance Surveys How are Schools Selected? VA will establish and maintain a schedule of compliance surveys and inform SAA of schools to visit Schedules will be prepared before the beginning of each fiscal year Certain number of schools assigned to the SAA by the ELR; VA retains the balance Visits conducted at schools with veterans enrolled during the federal fiscal year (October - September) 44

Compliance Surveys When are They Conducted? Each fiscal year, the following active (have VA students enrolled) facilities are to be surveyed: 100% of facilities with 300 or more VA students 100% of NCD, OJT, Apprenticeships and Flight Additional surveys as determined by VA Because of staffing limitations, it is not feasible for most VA offices and SAAs to survey all of those schools; therefore, some schools that have had few or no errors may receive a waiver of compliance visit for up to two (2) years This does not mean schools that fall into the categories of error rates on the next slide will receive an automatic waiver A certain percentage of the facilities must be surveyed regardless as to how many may qualify for a waiver 45

Compliance Surveys When are They Conducted? Percentage (cont.) At least 60% of schools with 300 or more VA students At least 60% of active NCD schools At least 50% of active Flight schools At least 25% of active OJTs and Apprenticeships Within those parameters, facilities with the following error rates may be considered for a waiver of compliance visit 10 or less records reviewed - 0 errors 15-20 records reviewed - 1 error 25-35 records reviewed -2 errors 40-45 records reviewed - 3 errors Still must meet certain percentage of schools to visit not all schools meeting above criteria may be eligible Error: For the purpose of waiver assessment an error is defined as a reporting 46 error that results in an under or over-payment.

Compliance Surveys Notification of Visit Email, phone call or fax to inform you of our visit Advance notice provided Two to four weeks Survey confirmation letter emailed or mailed Confirm date and time of appointment Provide SCO with names of student files required and items/types of records to be reviewed Schedule face-to-face interviews with students, if applicable 47

Compliance Surveys Choosing Files for the Survey Randomly selected Roughly 10% of your VA student population No fewer than 10 - unless fewer than 10 VA students have been enrolled since the previous survey At least one (1) non-va beneficiary file No more than 45 unless sample expanded (samples are expanded only to verify error rates where they are high and not obviously systemic) 48

Compliance Surveys Choosing Files for the Survey Allocated by currently enrolled within each chapter 49

Compliance Surveys Required Changes If you notice errors requiring corrective action prior to survey, OK to submit through VA-ONCE If errors are identified during visit, correction via: VA-ONCE with assistance of surveyor Referral to VA Muskogee Regional Processing Office 50

Compliance Surveys Records Required for Review Application for admission Enrollment agreement/contract with school Record of evaluation of prior credit/training VA Forms received (date-stamped) or submitted Unofficial transcripts/grade reports/progress records (your school) Program outlines/tracking sheets Attendance records Enforce attendance policy Registration information Student account ledger detailed Scholarships listing 51

Compliance Surveys Records Required for Review Class schedules Documentation showing LDAs Catalog Disciplinary documentation Records of probation submitted to VA Reporting of graduation/completion of program to VA VA only wants reports of graduations that occur while the student is receiving GI Bill benefits Advertising Documents verifying the school s status regarding the 85-15% ratio 52

Compliance Surveys Records Required for Review VA work-study records, if applicable VA tutorial assistance, including school s verification of the need for tutoring, qualifications of the tutor, and reasonableness of the charges Principles of excellence documents and discussion Yellow ribbon fund Yellow ribbon allowed at IHLs and may include NCD programs Not allowed at standalone NCD schools Reporting fee fund 53

Compliance Surveys Reporting Fees 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. VA strongly encourages that those funds be used for SCOs to attend VA and other VA-specific training conferences Change in reporting fee amount Public Law 113-175 September 26, 2014 $12 $9 $15 $13 (advance pay) Effective January 1, 2015 February 2015 payment will be impacted One year period sunset provision SEC. 406. RESTORATION OF PRIOR REPORTING FEE MULTIPLIERS. 54

Compliance Surveys General Areas of Review Guidance for Common Items Records & Accounts The school must provide the records and accounts of VA beneficiaries and other students for examination. 38 CFR 21.4209, 21.7307, 21.9770 Guidance Review checklist provided to you by SAA or VA (whoever is conducting the visit) Ensure applicable checklist items are included in student file or made available at the time of the visit If you have any questions at all regarding any of the items on the list please immediately contact the person who will be conducting the survey 55

Compliance Surveys General Areas of Review Guidance for Common Items Commencement of Courses Checking to see if VA beneficiaries commenced course on the date certified 38 CFR 21.4131, 21.4203, 21.5810, 21.5831, 21.7131, 21.7152, 21.7631, 21.7652, 21.9720 Guidance If school certifies enrollment prior to actual start date, must review to ensure student actually began on the date (s)he was certified to start Submit termination of enrollment to VA if never attended Amend start date if applicable 56

Compliance Surveys General Areas of Review Guidance for Common Items Correct Program Certified Checking to ensure VA beneficiaries are enrolled in and pursing the program as certified 38 CFR 21.3030, 21.5131, 21.7130, 21.7630, 21.9710 Guidance Review SAA approval letters Monitor WEAMS (22-1998) reports Not approved unless appears on WEAMS report Enter program in VA ONCE exactly as approved in WEAMS (must be manually entered by the school) Ensure certification of correct program Compare enrollment agreement, transcripts, registration records to what you certified 57

Guidance (cont.) Compliance Surveys General Areas of Review Guidance for Common Items Course/Program name certified must match what is listed in the WEAMS report (aka VA Form 22-1998) Incorrect wording may impact whether payment is made If WEAMS is correct, then update VA-ONCE If WEAMS is incorrect, then submit a request to have it updated with correct information Program name must match what has been approved by CIE or the school's accrediting agency 58

Compliance Surveys General Areas of Review Guidance for Common Items Previous Education & Training Checking to ensure the school maintains record of and has evaluated previous education and training of VA beneficiaries, has granted credit as appropriate, and has reported the grant to the beneficiaries Guidance Maintain documentation in file including all official transcripts from other institutions and the transfer credit review sheet (may be your school s official transcript) 38 CFR 21.4253, 21.4254, 21.4263 59

Compliance Surveys General Areas of Review Guidance for Common Items Previous Education and Training Guidance (cont.) Schools must ask students to list all previous education and training To include where they attended, when they attended and in what program(s) they were enrolled Do not ask the student if they want any credit transferred in irrelevant; mandatory Schools must evaluate that education and training Must obtain all official transcripts This includes all educational pursuit even where the student did not utilize GI Bill benefits 60

Compliance Surveys General Areas of Review Guidance for Common Items Previous Education and Training Guidance (cont.) In most instances, schools must receive all transcripts: Within two (2) semesters or the equivalent Within 12 weeks if program is at least six (6) months long Prior to the start of the course if less than six (6) months long If applicable, schools must grant credit and reduce training time proportionately Notify student and retain in student s records Schools must review credit for prior training based upon their approved standards and policies, then grant credit as those standards and policies dictate 61

Compliance Surveys General Areas of Review Guidance for Common Items Previous Education and Training Guidance (cont.) Certain special exceptions (must consult with and obtain prior written acknowledgment and permission from ELR): Student cannot obtain transcript from one school where it is confirmed that there is no way any credit will apply to the student s current program because they do not have any course work that would apply, e.g., student was at a four year college that has no fire fighting program and student is now at NCD in a fire fighter program Prior school is no longer in business and records are no longer available When schools close in Florida, they are required to deposit their records with the CIE. Such records may then be obtained from that agency 62

Compliance Surveys General Areas of Review Guidance for Common Items Previous Education and Training Guidance (cont.) Certain special exceptions (must consult with and obtain prior written acknowledgment and permission from ELR) (cont.): Current school has a recency of credit rule and has confirmed that the student s prior coursework was completed too long ago to accept under the current school s published standards 63

Compliance Surveys General Areas of Review Guidance for Common Items Records Checking to ensure the school maintains accurate, current and complete records of enrollment Guidance Maintain for at least three (3) years from each student s last date of attendance 38 CFR 21.4253, 21.4254 64

Compliance Surveys General Areas of Review Guidance for Common Items Accurate & Prompt Certifications Checking to ensure the school accurately and promptly reported enrollment, and tuition and fees 38 CFR 21.4203(e)(f)(g), 21.4204, 21.7156, 21.9735 Guidance Enrollment periods Start and end dates Tuition and fees Actual tuition charged Allowable fees Clock hours Scheduled per week Timely - within 30 days of the latter of the following: First day of class Student s request for certification 65

Compliance Surveys General Areas of Review Guidance for Common Items Clock Hour Measurement Are you reporting the correct hours? Certify the actual number of clock hours per week the student is scheduled to attend, not the minimum it takes to be full-time for VA purposes Certified hours will be compared with those listed on the enrollment agreement and actual class schedules No averaging unless it does not change training time or rate of pursuit (for full time/100% rate of pursuit students only) 66

Compliance Surveys General Areas of Review Guidance for Common Items Clock Hour Measurement Are you reporting the correct hours? (cont.) One clock hour = 60 minutes of instruction Classroom/Theory Allows for 10 minutes to change classes each hour, which can be included in the total hours of instruction (must deduct if not changing classes) Also allows for 10 minutes to change subjects even if students remain in the same classroom (e.g., finish talking about gasoline motors and switch to studying diesel motors) Shop Practice Allowance for 15 minute break in morning; another in the afternoon. Can be included in total hours of instruction. Shorter breaks allowed for part-time enrollment. 67

Compliance Surveys General Areas of Review Guidance for Common Items Clock Hour Measurement Are you reporting the correct hours? (cont.) All clock hours reported to VA must exclude any lunch or meal breaks The morning and afternoon breaks may not be combined for a half hour lunch Averaging only allowed if the clock hours do not change training time/rop for full-time only. Not allowed for less than full-time/100% ROP 68

Compliance Surveys General Areas of Review Guidance for Common Items Notification of Terminations/Interruptions Checking to ensure the school promptly notified VA when beneficiaries terminated or interrupted training Guidance Within 30 days of actual LDA prior to interruption of training, e.g., leave of absence 38 CFR 21.4203, 21.7156, 21.9735 69

Compliance Surveys General Areas of Review Guidance for Common Items Attendance Policy - Monitor All NCD programs measured on a clock hour basis must maintain attendance records for each class A student s schedule is not an attendance record and not sufficient for this purpose All instructor-led classes must have a roll book or other record maintained by the instructor to verify each student s attendance Often, a physical sign-in sheet is used for this purpose and is sufficient as long as the class instructor maintains constant control over it so that s/he actually observes the student signing in 70

Compliance Surveys General Areas of Review Guidance for Common Items Attendance Policy Acceptable Account for early departures, class cuts, tardies, etc., for any portion of a class period will be counted as absence. Students exceeding % total absences in a calendar month will be terminated from their VA benefits for unsatisfactory attendance. 71

Compliance Surveys General Areas of Review Guidance for Common Items Attendance Policy Acceptable (cont.) In order to show that the cause of unsatisfactory attendance has been removed, students must show good attendance (as defined) for one calendar month after being terminated for unsatisfactory attendance. After such time, the student may be recertified for VA education benefits, but only at the end of the satisfactory attendance period, i.e., no retroactive certifications. The student s attendance record will be retained in the veteran s file for SAA and USDVA audit purposes. 72

Compliance Surveys General Areas of Review Guidance for Common Items Leave of Absence How to Report If the begin and end dates of the leave of absence are known: Schools may submit an amendment to the original certification that reflects the revised end date of the enrollment period to align with the new projected graduation date after factoring in the leave of absence. Include a free text remark under Other stating the following: Student took a leave of absence from [enter dates]. Note: If the student does not return, submit a termination using the last date of attendance prior to leave. 73

Compliance Surveys General Areas of Review Guidance for Common Items Leave of Absence How to Report (cont.) If the end date of the leave of absence is not known: Schools are to submit a termination with the Reason for Termination Withdrawal or interruption (Non-college Degree Programs Not On A Term Basis and enter the last date of attendance. When the student resumes training, a new certification (22-1999) should be submitted to include a free text remark under Other stating the following: Student is resuming class after a leave of absence during [enter dates]. 74

Compliance Surveys General Areas of Review Guidance for Common Items Progress/Grades Checking to ensure that accurate, current and complete records of progress or grades maintained for VA beneficiaries 38 CFR 21.4253, 21.4254, 21.4262, 21.4263 Guidance Must include final grade for each class/module/subject, record of withdrawal from any subject to include the LDA, records of re enrollment, etc. 75

Compliance Surveys General Areas of Review Guidance for Common Items Satisfactory Progress Check to ensure the school promptly notified VA when beneficiaries did not progress satisfactorily according to the approved standards and practices of the school. 38 CFR 21.4203(d), 21.4277 Guidance This relates to standards of progress for academics as well as attendance. Monitor records frequently enough to be able to report unsatisfactory progress or attendance within 30 days of LDA of: Last date of attendance before the student was found to be unsatisfactory for progress; or Last date of attendance before the absence that caused the student to be unsatisfactory for attendance 76

Compliance Surveys General Areas of Review Guidance for Common Items Standards of Progress Monitor and Enforce Know and understand your SAA approved Standards of Progress policy for VA students Must relate to graduation requirements For example, if a student must have a 2.0 cumulative GPA in order to graduate, a standard of progress that only requires a 1.5 CGPA to remain satisfactory would not be acceptable Ensure you are monitoring VA students progress 77

Compliance Surveys General Areas of Review Guidance for Common Items Standards of Progress Monitor and Enforce (cont.) There must be a clear, definite point in time when a: VA student will be placed on probation (cannot be indefinite usually no more than two terms, months, enrollment periods, etc.) Report probation through RightNowWeb VA student s enrollment will be terminated for not achieving satisfactory progress Law requires VA educational benefits be discontinued when student fails to make satisfactory progress toward completion of training objective (Title 38, USC, Section 3675(b)(1)) Report termination for unsatisfactory progress through VA- ONCE 78

Standards of Progress Monitor and Enforce (cont.) Academic Probation Promptly notify VA when a student is placed on probation Via Right Now Web (VA s Internet Inquiry System in the Ask a Question section of the GI Bill website) https://gibill.custhelp.com/app/utils/login_form/redirect/ask Notifications must include: Student s name in the text VA file number in the text Academic Probation in the subject line Supporting documentation to be maintained in VA student files only If multiple students Compliance Surveys General Areas of Review Guidance for Common Items 79

Compliance Surveys General Areas of Review Guidance for Common Items Standards of Progress Monitor and Enforce (cont.) Academic Probation (cont.) If multiple students are being reported, you may submit a single notification by using the spreadsheet (page 76 of the online SCO handbook or https://gibill.custhelp.com/app/answers/detail/a_id/1436/~/how-do-i-reportacademic-probation%3) https://gibill.custhelp.com/app/answers/detail/a_id/1436/kw/academic%20probation : Advise students of counseling services available to them under Chapter 36 http://www.benefits.va.gov/vocrehab/edu_voc_counseling.asp Students complete VA Form 28-8832 80

Standards of Progress Monitor and Enforce (cont.) Academic Suspension Compliance Surveys General Areas of Review Guidance for Common Items SCOs must promptly report to VA when a student is no longer meeting the standards of progress for your school In VA-ONCE, specify reason as Unsatisfactory Attendance, Conduct or Progress LDA/Effective date defaults to end date of term If the effective date is prior to the end of the enrollment period, you must manually enter the LDA before unsatisfactory progress is found 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 81

Compliance Surveys General Areas of Review Guidance for Common Items Standards of Progress Monitor and Enforce (cont.) Academic Suspension (cont.) Schools often have policies whereby students are allowed to petition/appeal the determination If such a policy exists and student successfully petitions and is granted readmission or continued financial aid: Do not terminate the student s enrollment if s/he is already certified for the subsequent term Maintain documentation in the file (similar to what you would for Title IV purposes) and that student successfully appealed and was granted readmission Specify all restrictions on the student s enrollment as well as all other additional requirements the student must meet in order to remain satisfactory for progress 82

Compliance Surveys General Areas of Review Guidance for Common Items Standards of Progress Monitor and Enforce (cont.) Academic Suspension (cont.) Student may be recertified/benefits may be resumed only after achieving satisfactory academic progress If student reenrolls in same educational institution and in same program; or School must document that the cause of the unsatisfactory progress (or attendance or conduct) has been removed Maintain documentation in file; the fact that the school has recertified the student s enrollment is evidence to the VCE that the school has found the cause of unsatisfactory progress has been removed/resolved 83

Compliance Surveys General Areas of Review Guidance for Common Items Reporting Changes Check to ensure VA was promptly notified of changes in clock hours and/or tuition and fees that would affect payment 38 CFR 21.4203, 21.7156(b), 21.9735 Guidance 30 day rule Have system in place to ensure that you are notified of those changes soon enough to report them within 30 days of the actual change 84

Compliance Surveys Additional Areas of Review Guidance for Common Items Independent Study Independent Study, Distance Learning, Online, Hybrid and Blended courses must be approved in order to certify them to VA 38 CFR 21.4267 Guidance NCD schools/clock hour programs/flight: Such courses may not be approved for any of the above formats under any circumstances Work with the Registrar (or other appropriate office) to monitor course formats Make other individuals aware of VA regulations 85

Independent Study For VA purposes, the term Independent Study is used interchangeably with Online, Distance Learning, Blended or Hybrid courses and programs Such training/mode of delivery cannot be approved for veterans training in any clock hour program under any circumstances Title 38 CFR 21.4267(f) 86

Compliance Surveys Common Errors (in no particular order) Not reporting changes or terminations Not reporting net charges correctly Late reporting of enrollment changes to VA Failure to request, evaluate and grant credit/hours for prior education and training Certifying incorrect program name or type of training Not reporting unsatisfactory progress or probation Lack of institutional records to support certifications to VA (attendance records, payment ledgers, etc.) Certifying programs not approved by SAA or VA 87

Compliance Surveys Exit Interview Conducted with SCO and others as school and auditor sees fit Recognize School Official s Efforts Discuss every Discrepancy & Provide Site Visit Reports Assist with Corrective Action & Provide Training 88

Compliance Surveys After We Leave Letter to school (sent to highest administrator with copy to certifying official) Identifies student records reviewed Details any findings Specifies corrective actions (if any) required by the school or job training establishment SAA and VA are audited, too Random sample of compliance survey files are reviewed each quarter for quality assurance 89

Compliance Surveys Questions? 90

Resources/Contact Information GI Bill website: http://www.benefits.va.gov/gibill/ (for schools and veterans) Education Call Center: 1.888.442.4551 (veterans and dependents) Muskogee, OK 7:00 a.m. 7:00 p.m. (CST), Monday through Friday SCO Hotline: for SCO use ONLY contact SAA or ELR for number SCO Handbook (Updated September 30, 2014)) http://www.benefits.va.gov/gibill/docs/job_aids/sco_handbook.pdf VA-ONCE Quick Reference Guide (Version 7, August 2014) http://www.benefits.va.gov/gibill/docs/vaonce/vaonce_sco_powerpoint_v7.pdf VA-ONCE Guide for Flight Schools http://www.benefits.va.gov/gibill/docs/vaonce/va-once_flight_training.pdf Online School Official Training http://www.benefits.va.gov/gibill/resources/education_resources/school_certifying_officials/online_sco_trainin g.asp 91

Resources/Contact Information Right Now Web (VA s Internet Inquiry System in the Ask a Question section of the GI Bill website): https://gibill.custhelp.com/app/utils/login_form/redirect/ask (for schools and veterans) Status of individual unusual/complex cases Individual cases that have been pending for a longer than usual time Hardship cases Written response VA Debt Management Center: Email address: dmc.ops@va.gov Phone number: 800.827.0648 Florida Association of Veteran Education Specialists: www.flfaves.org Scholarships for Children and Spouses of Deceased or Disabled Veterans: www.floridastudentfinancialaid.org 92

SAA Contact Information Betsy Wickham, Bureau Chief (727) 319-7401 wickhamb@fdva.state.fl.us Cora Stagner, Office Manager (727) 319-7402 stagnerc@fdva.state.fl.us Florida Department of Veterans' Affairs State Approving Agency for Veterans' Education and Training Mailing Address: P.O. Box 31003 St. Petersburg, FL 33731 Physical Address: 9500 Bay Pines Boulevard, Room 214 Bay Pines, FL 33744 93

SAA Program Specialist Contact Information AREA I To be determined AREA II - Katherine Snyder (941) 979-2525 snyderk@fdva.state.fl.us AREA III - Kelli Colborne (352) 422-5736 colbornek@fdva.state.fl.us AREA IV - Madeline Mendez (954) 540-6542 mendezm@fdva.state.fl.us AREA V - Dale Towery (954) 540-6157 toweryd@fdva.state.fl.us 94

SAA Area Distribution 95

VA Contact Information For school officials and contact representatives only Ron Scoggins Lead Education Liaison Representative ron.scoggins@va.gov John Martin Education Clerk john.martin1@va.gov MAILING ADDRESS: PHYSICAL ADDRESS: VA Regional Office Attn: Education Outreach (272A) PO Box 1437 St. Petersburg, FL 33731 VA Regional Office Attn: Education Services (272A) 9500 Bay Pines Boulevard St. Petersburg, FL 33708 96

VA Contact Information For school officials and contact representatives only Wayne Feazell donald.feazell@va.gov Cynthia Kujawski cynthia.kujawski@va.gov Chuck Peterman chuck.peterman@va.gov Rick Robertson rick.robertson@va.gov 97

VA Contact Information GI Bill website: http://www.benefits.va.gov/gibill/ (for schools and veterans) Education Call Center: 1.888.442.4551 (veterans and dependents) Muskogee, OK 7:00 a.m. 7:00 p.m. (CST), Monday through Friday SCO Hotline: for SCO use ONLY contact SAA or ELR for number Right Now Web (VA s Internet Inquiry System in the Ask a Question section of the GI Bill website): https://gibill.custhelp.com/app/utils/login_form/redirect/ask (for schools and veterans) Status of individual unusual/complex cases Individual cases that have been pending for a longer than usual time Hardship cases Written response 98

Contact Information VA Debt Management Center: Email address: dmc.ops@va.gov Phone number: 800.827.0648 Florida Association of Veteran Education Specialists: www.flfaves.org Scholarships for Children and Spouses of Deceased or Disabled Veterans: www.floridastudentfinancialaid.org 99