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WACRAO 2014
WISCONSIN
CERTIFYING OFFICIAL
WORKSHOP
JUNE 17-18, 2014
GREETINGS
Day 1 – All SCO’s
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Apprenticeship Program – Kathy Wellington
RPO Updates
Complaint System
Communications with VA
Communications with ELR & SAA
Student Responsibility
SCO Concerns
• Principles of Excellence
• SCO monitoring has increased substantially due to
increased enrollments and certification
requirements
• CH33 – 3rd party tuition payments
• Institutional debts from CH33 – DMC & TOP
RPO UPDATES
– RPO Updates/Legislative Updates
• RPO Education Outreach Section re-organization effective
June 1, 2014
• VA Central Office November 2013 policy on unearned
punitive F grades
• RPO automated Chapter 33 processing (LTS) Long Term
Solution
• Updated on DEEMED approved institutions
RPO UPDATES
• VA & SAA Compliance survey Updates
• VA Annual Reporting Fees for calendar year 2013
• Paperless enrollments – VAONCE
– WI IHL stats – 120/137
– WI NCD stats – 25/42
• Direct Deposit – tuition and fee payments
• VA has issued 29.8 billion dollars in Post 9/11 GI Bill benefit
payments to 985,000 individuals since program inception as of
September 2013.
RPO UPDATES
– RPO Updates/Legislative Updates
• VA Central Office advisory March 28, 2014 Program
withdrawn and benefits continue – Chapter 33
• VA Central Office advisory September 30, 3013 Certifying
Sales Taxes as Fees
• VA Central Office policy – CH33 Yellow Ribbon Program
IHL contribution – restricted or unrestricted institutional
scholarships
• Books considered as fees- If a school charges every student for
books required for their program and does NOT allow them to
purchase outside that office, they may be include it with tuition
and fee charges
RPO UPDATES
– RPO Updates/Legislative Updates
CH33 Parking Fees –this fee is not specifically excluded by
regulation therefore are included as a payable fee as long as all
students have to pay this fee to the institution.
VA Central Office advisory April 21, 2014 – CH33 Fees
involving lab costs – there are instances when a lab fee is
mandatory for all students in a particular course during a
particular enrollment period. This is an acceptable fee to certify.
However during enrollment periods when the lab fee is waived
lab fees are not certified. NOTE: A lab fee does not have to be
charged during every term of enrollment in order to be
considered mandatory.
RPO UPDATES
– RPO Updates/Legislative Updates
• New – May 16, 2014 from VA Central Office
• Effective immediately VA Education Call Center
representatives are prohibited from releasing documents (such
as Certificates of Eligibility, Award Letters, etc) to veterans
and beneficiaries, veterans service organizations, school
certifying officials, or other entities based on a telephonic
request.
• Written requests which include FAX, RNW, as well as regular
mail from authorized individuals may be honored.
RPO UPDATES
– RPO Updates/Legislative Updates
• New – May 16, 2014 from VA Central Office
• WHY?
• VA General Counsel has determined that telephonic requests
for documents from a claimant’s VA records are not sufficient
to meet requirements and are prohibited.
• PER:
– Clarification on Freedom of Information (FOIA)
and Privacy Act (PA) Requirements for Telephonic
Requests of Documents Related to VA Education
Benefits
RPO UPDATES
– The Post-9/11 Veterans Educational Assistance Improvements Act of
2010 (Public Law 111-377) amended section 3322 of title 38, United
States Code, by adding subsection (h) which bars duplication of eligibility
based on a single event or period of service. Because of this addition,
individuals cannot– Use the same period (beginning on or after August 1, 2011) of active duty
service to establish eligibility for the Post-9/11 GI Bill and chapter 30,
chapter 32, chapter 1606, or chapter 1607, or
– Establish eligibility under both the Fry Scholarship provision of the Post9/11 GI Bill and chapter 35 (DEA) based on a parent’s death (i.e. a single
event) in the line of duty on or after August 1, 2011.
GI Bill web site
• Provides information on VA education benefit
chapter eligibility and usage
• Identifies approved institutions on gi bill web site
• Provides State listing of institutions approved for
YRP
• Contains institutional address, name of SCO with
phone number and email
• Provides students with researching schools and
provides for on line complaint system
Education Benefit Chapters
• Montgomery GI Bill (MGIB) Chapter 30 – Veterans
• Montgomery GI Bill-Selective Reserves Chapter 1606 for Members of
Reserves or National Guard
• (REAP) Chapter 1607 – mobilized under DOD Title 10 (called to
active duty)
• Dependents Educational Assistance Program Chapter 35 (spouse,
children, surviving spouse
• (Public Law 110-181 – affecting Ch 1606/1607) enacted January 28,
2008
• Post-9/11 GI Bill (Chapter 33) – veterans & dependents TOE
• Fry Amendment – CH33 dependent benefit death of service member
• VRAP – awarded benefits under Chapter 30 – closed March 2014
Principles of Excellence
Executive Order 13607 signed by the President on April 27,
2012 established principles of excellence for Educational
Institutions serving service members, veterans, spouses, and
other family members
Objective: designed to strengthen oversight, enforcement,
and accountability within the Department of Veterans Affairs
education benefit programs and DOD TA programs.
Established a centralized compliant system which became
active in March 2014 – within initial 3 weeks – 900
complaints
Principles of Excellence
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Educational institutions participating in the Principles of Excellence program
agree to the following guidelines:
-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.
-Accommodate Service members 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.
-Align institutional refund policies with those under Title IV, which governs
the administration of federal student financial aid programs.
Principles of Excellence –
Student Complaints
Types of Complaints:
Recruiting/Marketing Practices, Accreditation, Financial
issues (e.g. tuition/fee charges), student loans, postgraduation job opportunities, change in degree plan
requirements, quality of education, grade policy, release of
transcripts, transfer of credits, refund issues, and other.
GI Bill web link for submitting a complaint:
http://www.benefits.va.gov/GIBILL/Feedback.asp
OTHER: is a general category that may involve complaints
about VA approval or processing applications or enrollments
Principles of Excellence –
Student Complaints
Other types of complaints may involve:
- student questioning SCO certification based on
applying VA reporting requirements
- student questioning institutional refund of tuition
- student questioning amount of Title IV funding
- student questioning CH33 Rate of Pursuit BAH
based on term length and equivalent credits
- student questioning VA action on eligibility based
on their military service and/or DOD information
Principles of Excellence –
Student Complaints
VA student can submit complaint on GI Bill web site:
Process:
- VA Central Office Education Service reviews
complaints and forwards to school SCO or designee;
- School is requested to provide VA with a response
or if VA will refer to another government agency if
appropriate.
- VA will review the response and provide a response
to student complaint
- VA may also contact institution as appropriate
Role of the IHL
• When feedback is received for a school, VA will contact school on
behalf of the student and work toward a resolution
• –The School Certifying Official (SCO) on record will be contacted
• –Institutions will have an opportunity to appoint another representative
other than the SCO to handle complaints
• •Complaints should be handled within 60 days from submission
• •Complaints and their resolution(s) will be forwarded to the FTC
Consumer Sentinel Network
• –These complaints will be accessible by over 650 federal, state, and
local law enforcement agencies
SCO Communication with VA
• Right Now Web to St Louis RPO via email
• National Education Call Center at 1-888-442-4551
• SCO Hotline number at National Education Call
center at 1-855-225-1159
• ELR – 612-970-5456 or email at
[email protected]
VA Student Responsibility
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Promptly notify SCO of changes to enrollment
- Understand benefit programs
- Application process to VA
- Progress and pursuit
- Contacting VA – inquiries concerning benefit
eligibility and benefit payments
• - Understand cause and effect of enrollment
changes
Student Contacting VA
• Students can access GI Bill web site to contact VA
by email
• Students can call VA at National Education Call
center at 1-888-442-4551
• Students can access GI Bill web site for extensive
information pertaining to benefit programs,
searching for schools, comparison shop for
schools, and search FAQ’s
• E Benefits access
E-Benefits
• The eBenefits web portal is an online resource for tools and benefitsrelated information.
• The portal serves Wounded Warriors, Veterans, Service Members,
their families, and their caregivers.
• Two main services:
– A catalog of links to military and Veteran benefits on other sites
– A personalized workspace giving quick access to online tools that
enable you to apply for benefits, download your DD-214, see your
benefits status online, and more
E-Benefits Registration
• There are two levels of eBenefits registration, Basic and
Premium.
– Basic Registration (Level 1 access) enables you to view
general eBenefits information. This level of access does not allow
you to view information about yourself from VA and DoD
systems.
– Premium Registration (Level 2 access) provides you the
highest level of access to eBenefits. With Level 2 access, you will
have a secure, personalized eBenefits account that pulls
information from your DoD and VA records.
E-Benefits Registration
• Both levels require a DoD (DS) logon.
– With a DS logon, you can use a single user
name and password to access various websites,
including many VA and DoD sites
– All DoD sponsors, veterans spouses, and other
beneficiaries who are registered in the Defense
Enrollment Eligibility Reporting System
(DEERS) can obtain a DS logon
BREAK
Experienced SCO Overview
2:15 – 3:15pm
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Recap of benefit chapters
Approval Criteria
Modality of instruction to certify
Standard Term & nonstandard term certification
Sunday – Saturday start date of term (mult-iterm)
Overpayments and TOP
In-depth case study examples – complex
VA compliance surveys
Importance of Certifying Officials
Education Benefit Chapters
• Montgomery GI Bill (MGIB) Chapter 30 – Veterans
• Montgomery GI Bill-Selective Reserves Chapter 1606 for Members of
Reserves or National Guard
• (REAP) Chapter 1607 – mobilized under DOD Title 10 (called to
active duty)
• Dependents Educational Assistance Program Chapter 35 (spouse,
children, surviving spouse
• (Public Law 110-181 – affecting Ch 1606/1607) enacted January 28,
2008
• Post-9/11 GI Bill (Chapter 33) – veterans & dependents TOE
• Fry Amendment – CH33 dependent benefit death of service member
• VRAP – awarded benefits under Chapter 30 – closed March 2014
VA Application Forms
• VA Form 22-1990 – All Chapters except Chapter 35 for original
claims
• VA Form 22-1990e – Chapter 33 Transfer of Entitlement
• VA Form 22-5490 – Chapter 35 original claims and Fry
• VA Form 22-1995 – All Chapters except Chapter 35 &
• VA Form 22-5495 – Chapter 35 subsequent claims
• *do we need 1995 & 5495 changing programs at same schools - NO
• ALL CAN BE COMPLETED AND SUBMITTED ON LINE AT GI
BILL WEB SITE VONAPP – (preferred method)
VA Access to Records
• CFR 21.4209 – 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
VA Interface with DOD
• VA can access DOD data base to obtain and
verify:
– Military service dates, type of discharge, contributions,
kickers, reserve/guard deployments under Title 10
– AGR32 military service
– Transferred benefits to spouse or dependents under
Chapter 33 by serviceperson
RPO Interface with
VA Regional Offices
• VA RPO must verify spouse and dependent
eligibility under Chapter 35 Dependent Education
Assistance program.
• RPO obtains confirmation from VA RO where
veteran claims folder is located to confirm spouse
and or dependents are properly listed and veteran
is rated for VA service connected disability rating
to qualify for Chapter 35 benefits.
Institutional Approval
(IHL & NCD)
• Accredited – institution’s accrediting agency recognized
by U.S. Department of Education (Public or Private)
• Non-Accredited – institution may have:
– Accrediting agency not recognized by US Dept of
Education
– SAA does not recognize accrediting agency
– or has no accrediting agency approval
– * May not be under State licensure by WI Education
Approval Board (EAB)
DEEMED approved facilities
• Public Law 111-377 enacted August 1, 2011
provided for Institutions of Higher Learning (IHL)
to be deemed approved for degree programs only
if:
• Institution accreditation recognized by US Dept of
Education
• Licensed by State as Institution of Higher Learning
• Did not change requirements for all NCD and private
profit IHL institutions
DEEMED approved facilities
• VA assumed approval authority for Deemed
approved institutions (public and private nonprofit Institutions of Higher Learning)
• Effective late 2013 VA transferred approval
authority back to SAA for institutional approval
and non college degree programs at Deemed
approved institutions – degree programs are
deemed approved
• SAA retained approval function for all other
institutions
Modality of Certifications –
CH33
– Resident – lecture, lab, or shop instruction
– On line – distance learning or independent study
– Blended/hybrid – combination resident and on line
instruction- differences undergrad and graduate level
– Remedial – subjects required as determined by
institution as deficiency (resident instruction only)
– Practical Training (internships, externships, etc)
NCD schools – must be resident instruction and no on line
instruction
Modality of Certifications
Non CH33
– There is no distinction by VA for non Chapter 33
education benefit award of benefits and treated as credit
value other than:
– Remedial – subjects required as determined by
institution as deficiency (resident instruction only)
– Practical Training (internships, externships, etc)
NCD schools – must be resident instruction and no on line
instruction
Resident or Distance
(Chapter 33)
– In-residence training for undergraduate students
consists of regularly scheduled standard class sessions
(at least once every two weeks). The total number of
hours of classroom instruction (based on 50 minutes of
instruction per hour) must equal, or be greater than, the
number of credit hours awarded for the course
multiplied by the number of weeks in the term.
– In-residence training for graduate students consists of
at least two regularly scheduled standard class sessions,
research (either on or off campus), or a combination of
both.
Evidence to Review when
Certifying Enrollments
– Student application & matriculation
– Acceptance into program
– Institutional evidence of transfer credits
• Prior institutions
• Military academic transcripts
• Other – perhaps life experience, CLEP etc
– Student account ledger – CH33 for T & F
– Student term registration data
– Existing transcript to verify no repeat subjects
Evidence to Review when
Certifying Enrollments
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Rounding out in last term prior to completion
Academic probation
Student placed on academic suspension
Subject substitution
Remedial subjects pursued on line rather than resident
instruction
– What evidence have you reviewed to substantiate need
for remedial instruction subjects
– Repeating subjects based on grade posted and
institutional standards
Non College Degree School
Certifying Enrollments
– Student application & enrollment agreement
– Start date is actual first date of scheduled instruction
– Weekly schedule based on Sunday – Saturday hours
• Varying weekly scheduled hours of instruction *
– Institutional evidence of prior training evaluation
– Student account ledger – CH33 to determine T&F
– Certify appropriate tuition and fees per term prorated
amount if charged full tuition and fees but school
organized on term basis
VA Enrollment Forms
• PAPER DOCUMENTS
• 22-1999 Enrollment Certification
• 22-1999b Change of Status
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VAONCE
NEW CERT – Multiple term CERT
AMEND
ADJUST
TERMINATE
Yellow Ribbon Program
VAONCE Student BIO page must display as benefit chapter
33Yellow to add YRP fields
- Annual cap for 2013-2014 is: $19,198.31
- Annual cap for 2014-2015 is: $20,235.02
- VA Academic Year for CH33 (8/1 – 7/31)
- Public IHL – restricted to in-state tuition and fees without
YRP for nonresident tuition based on YRP agreement
requirements
ELR Request
• Attempt to limit enrollment changes to VA
until after the drop/add period (normally last
5-7 days after term starts
• VA is receiving numerous enrollment
adjustments changing credits before terms
have even started
• Refrain from submitting these changes until
drop/add limited days is over – 25% of RPO
documents are in this category.
Certifying Terms
– Single term
– Multiple term
• Start date of subjects
– *nonstandard term impact on rate of pursuit
– Reporting tuition and fees CH33, active duty, & -1/2 to
RPO
– Resident v/s non resident tuition
– Public YRP – Private YRP
– Modality – resident, distance, remedial, blended/hybrid,
practical (internship)
Calendar Week Rule
– Certifying starting dates within term, quarter, and
semester:
• VA requires institutions to certify start dates as the official
calendar that is published by the institution for terms.
However when a start date of subjects begin after the calendar
week of the published term start date – the SCO must certify
those credits using the start date of the subject scheduled first
class session.
• This results in multiple term enrollment certification due to
different start dates.
Calendar Week Rule
– Example: Fall Semester published dates are 9/3/14 –
12/12/14
– Student registration schedule identifies total of 12 cr
– 9 credits have start date of subjects on 9/3 – 9/5
– 3 credits have start date of subject on 9/9/14
– Proper certification would show:
• 9/3/14 – 12/12/14
9 credits
• 9/9/14 – 12/12/14
3 credits
• * Basis is that first scheduled class session for 3 credits is not
within the same week of 9/3/14 (Sunday – Saturday)
Certifying Terms
– Non College Degree Institutions
• Organized on terms
• Not organized on terms
If not organized on term basis and based on weekly
scheduled clock hours certify weekly scheduled hours of
instruction
Identify the projected completion date as end date
RPO processing of enrollments
– Chapter 33 Post-9/11 GI Bill
• Certify 1 semester or quarter at a time
– Certify non-standard terms for up to length of a term, Qtr, or Sem
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Enrollment does not include T and F
Enrollment includes T and F
Later submission of T and F - AMEND
14 day T and F release time frame
– Multiple terms
– LTS – automated processing – CH33 only
– VAONCE – NEW CERT, NEW Multiple term CERT,
AMEND – use for submitting tuition and fees
RPO processing of enrollments
– All other benefit Chapters excluding CH33
• Enrollment reviewed and processed
– Enrollment may include multiple terms
• Award notification to student
– AMEND
– ADJUST
– TERMINATE
Notifications to school and
student
– Student award letters
– School pay listings with ACH payments
Two pay listings from VA (mailed to institutions)
- Non CH33 student payments
- CH33 tuition and fee payments
Overpayments - Institutions
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A debt is established on a school when:
• The student never attended any classes for which he/she was certified regardless of the
reason for non-attendance
• The student completely withdraws on or before the first day of the term.
• The school received payment for the wrong student
• The school received a duplicate payment
• The school submitted an amended enrollment certification and reported reduced tuition
and fee charges, reduced Yellow Ribbon amount, or reduced both. (Reductions based on
student’s action should be reported on a 1999B with the changes in the enrollment and
will result in a debt to the student.)
• The student died during the term, or before start of the term
• VA issued payment above the amount certified on the enrollment certification that was
used to process the payment (VA data entry error)
Overpayments - Students
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A debt is established on the student for tuition/fees/yellow ribbon when:
• The student withdrew after the first day of the term (FDOT)
• If the student completely withdrew on the FDOT, treat as if student never attended
• The student reduced hours whether the reduction occurred before or during the term
• If the student attended at least one day of any of the classes certified and a payment
has been issued, any debt created by the reduction/withdrawal should be charged to the
student
• The school submitted a change in enrollment (1999b) and reported a reduction in
tuition, fees, and/or Yellow Ribbon due to student action reducing or terminating
training.
• If a student drops a course and adds a course so that there is no net change in training
time, any change to tuition, fees, and/or Yellow Ribbon is a student debt
DMC and TOP
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2. Department of Veterans Affairs (VA) – Debt Management Center (DMC).
Receives overpayment amounts generated by RPO on school debts. Sends three Notices
of Indebtedness (NOIs) to schools regarding school debts. Takes action to clear debts or
forward inactivity to the Treasury Offset Program (TOP).
Notice 1: Sent three to five days after debt is established by RPO. Informs
school of debt amount and addresses the payment options.
Notice 2: Sent to school 30 days after first notice sent for past due accounts.
Informs school of impending actions if the debt is not addressed. Provides an additional
30 days for the school to clear the debt.
Notice 3: Sent to school 30 days after the second notice sent for all past due
accounts. Gives school a final warning and allows for another 60 days to pay debt.
Failure to clear debt after 60 days will result in debt amount being sent to the Treasury
Offset Program (TOP).
Treasury Offset Program
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3. US Department of the Treasury (DOT) – Financial Management
Services (FMS) – Debt Management Services (DMS) – Treasury Offset
Division (TOD) – Treasury Offset Program (TOP). Processes delinquent
payments to Federal Government Agencies. Provides payment vouchers to
schools. Takes action to clear debts by offsetting future Federal Government
designated funds to the school if the school fails to take action to the pay debt
and/or clear the debt through DMC.
**The Treasury Offset Program does not issue notices that funds are offset.
VA Debt Management Center
– Contact Information:
• 1-800-827-0648
• [email protected]
US Dept of Veterans Affairs
Debt Management Center
PO Box 11930
St Paul, MN 55111
Compliance Surveys
• Beginning on October 1, 2013 VA was authorized to waive
compliance surveys at those institutions that
• For the purpose of a waiver consideration, a compliance
survey conducted during the previous three (3) fiscal years,
and one fiscal year (1) for OJTs/Apprenticeships will be
reviewed. In the event that a facility was not surveyed
each of those fiscal years, a “demonstrated record of
compliance” can be determined if any records reviewed
included three previous years of training.
Compliance Surveys
• Since our last WACRAO SCO workshop we have
conducted a total of 92 compliance surveys in Wisconsin at
IHL – 38, NCD – 17, and OJT – 37
• Additionally I waived a total of 22 Wisconsin IHL and
NCD schools from survey requirements for FY14 based on
procedural requirements.
• The results of our findings (VA & SAA) has been positive
based on sample records reviewed when compared to
findings.
Compliance Surveys
• Examples of reporting errors noted:
– Incorrectly certifying tuition and fees
– Incorrectly reporting fees
– Occasional oversight – failing to report credit load reductions or
student withdrawing from school
– Not reporting non-standard terms that are within the academic
semesters
– Late reporting beyond 30 days from date student changed credit
load
– Not reporting students placed on academic probation or suspension
Complex Case Examples
• Non-Standard Terms
• Certifying concurrent enrollment
– Parent & Guest Institutions
• Amending tuition and fees – CH33
• Non resident tuition – public IHL
• Study Abroad tuition and fees - restrictions
• Blended or Hybrid – VA requirements
• Repeating F subjects – VA requirements
BREAK
–THANK YOU -
POST-9/11 GI BILL
July 18, 2014
• BREAKOUT SESSION 8:30 – 10:30AM
• SCO Resources (Instructions & Training)
Reporting tuition and fees – source documents
-Certification issues
-Common certification problems
Processing and VA releasing payments
-Notification to institutions and students
Institutional Overpayments
VA surveys – Q and A –
Contact Information
• John Johnson – Phone: 612-970-5456, FAX 612970-5458, email: [email protected]
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Mailing Address:
VA Regional Office
Education Service (272L)
1 Federal Drive
St Paul, MN 55111
VA Regional Processing Offices
and Jurisdictions
SCO RESOURCES
www.gibill.va.gov
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- National SCO Handbook
- VAONCE Training Guide
- On line SCO training modules
- SCO toll free help line
- Education Liaison Representative
- State Approving Agency
- Vocational Rehabilitation Case Managers
- State and local agency staff
- National Guard and Reserves Education Office
- Institution staff (Financial Aid, Registrar, Business Office, etc)
SCO Communicating with
VA & SAA
• Contacting ELR by phone or email concerning procedural
or certification issues and DEEMED approved approval
questions
• Contacting SAA offices pertaining to approval issues
• Right Now Web (RNW) secure email when
communicating with VA Regional Processing Office St
Louis
• Accessing the VA National SCO hot line
• Contacting VA Debt Management Center (DMC)
involving institutional overpayments
SCO Communicating VA
• Email to St Louis VA RPO by using Right Now Web
– Pertaining to student issues
– School questions tuition payments
– School requests audit of tuition payments for institutional debt
• Contacting Education Liaison Representative
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VAONCE questions
VA regulations, manual or policy questions
Approval data base issues that are not approval criteria
Updating certifying officials
Changes to Designated Certifying
Officials
- VA Form 22-8794 – Designation of VA Certifying
Official form is critically important when changes
occur for:
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VA approval data base to identify SCO
VAONCE web site authorization
ELR email distribution listings
National Education Call center to identify school official as
designated certifying official
- SCO submitting emails to RPO on student cases
- Privacy Act Issues
Certification Differences for non
Chapter 33
• Do not need to report tuition and fees unless less
than one half time training or student on active
duty
• Do not need to separately report resident, on line,
blended/hybrid
• Do not need to provide minimum credit full time
for graduate students. (only report level of
training – full time, ¾, ½ etc) as determined by
institutional academic requirements
Source Documents –
Tuition & Fees
- DO NOT
- – access institutional term schedule of standard
tuition and fees in course offerings
- – accept verbal or email confirmation from Business
Office
- – accept verification of 3rd party tuition from student
- – verify only based on Financial Aid Package of
cost of attendance
Source Documents –
Tuition & Fees
- Best Practice:
- Print a copy of the student registration schedule for each term
to certify
- Print a copy of the Business Office student account ledger for
each term to certify
- Identify sources listed for 3rd party or internal scholarships
- Confirm any military national guard or reserve TA
- Monitor during the term to obtain other sources of funding
received by your college –
- Timely report amended tuition and fees to VA
Tuition and Fees to report to VA
for Chapter 33
• Tuition – net charges
• Fees – those costs charged to similarly
circumstanced non VA students.
• The fees must be charged by the institution to
student.
• NO – SCO cannot report fees when student is
purchasing items on their own from vendor or
book store etc.
Public Non Resident Tuition
• The Yellow Ribbon Program is available
when a public school charges a Chapter 33
student non resident tuition.
– The YRP agreement is for up to the difference
of the in-State tuition and non resident amount
charged.
– VA YRP can not exceed the institutional
contribution nor 50% of the difference
Tuition & Fees
- TUITION: Identify if your institution offers –
- Student discounts on tuition
- Student waivers on tuition
- Internal institutional scholarships
- RESTRICTED OR UNRESTRICTED
- FEES: Confirm the fees charged are approved
to certify to VA. “Fees are those charges that
are charged to all similarly circumstanced
students”.
POST-9/11 GI BILL
Tuition & Fees (excluding Title IV):
1. Access student registration data
2. Determine when to certify to VA
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Prior to start of term
After registration closes
Identify credits to certify and charges for same
Determine net charges of tuition
Verify fees by VA requirements
Other 3rd party sources
POST-9/11 GI BILL
Recommend certifying term dates & credits without
tuition and fees
AMEND certification in VAONCE to later submit tuition
& fees to VA
1. Key to certify term dates and credits – for award of
book stipend and BAH (monthly housing allowance)
awarded to student
2. Certify net charges of T&F when registration closes
3. May result in credit adjustments when submitting
T&F if student adjusts credits
ENROLLMENT
CERTIFICATIONS
Standard terms combined with multiple non-standard term
dates
Only non-standard terms
Concurrent enrollment terms (parent & guest)
- Modulated terms based on individual unit subject
pursuit (sequentially versus concurrently)
- NCD schools not operating on term basis – tuition and
fees charged lump sum at start of program
- NCD schools operating on term basis – tuition and fees
charged lump sum at start of program
Basic SCO Responsibilities
• Inform VA of the enrollment status of veterans
and other eligible persons.
• Maintain adequate documentation at the
institution to support certifications.
• Certify enrollments & changes timely to VA.
• Inform SAA of new programs, changes in
programs, institutional changes, etc.
• Apprise supervisors of any internal problems
which may affect service to VA students.
Enrollment Certification
Institutional Compliance
- 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.
Enrollment Certification
Institutional Compliance
- The 85/15% enrollment ratio requirement has been
satisfied
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-
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
CFR 21.4203
Reports—requirements
Each educational institution, veteran and
eligible person shall report without delay the
following information:
Enrollment,
Change in the hours of credit or attendance,
Change in pursuit,
 Interruption and termination of attendance
of each veteran or eligible person enrolled in
an approved course.
38 CFR 21.4203
Keep VA Informed of Each
Student’s Enrollment Status
• Monitor unit subjects pursued to certify to VA
only those subjects which apply to the student’s
program.
• Monitor student’s grades to insure (s)he is
making satisfactory progress and report
unsatisfactory progress.
• Must monitor student’s conduct and report
when student is suspended/dismissed for
unsatisfactory conduct.
• Monitor monthly to ensure timely reporting of
reductions, terminations or increases in
training.
POST-9/11 GI BILL
Yellow Ribbon Program certifications:
- VAONCE BIO should identify as VA benefit chapter
as CH33 Yellow
- PRIVATE
- Submit 0 charges in YRP column until term when
annual cap will be exhausted
- PUBLIC
- Restricted to difference of resident to non resident
tuition net charges – certify each term when YRP exists
VA PROCESSING – CH33
• Long Term Solution (LTS) VA computer program
exported October 2012 at VA Regional Processing
Offices to automate enrollment processing to
reduce processing time
– Results demonstrate over 50% automated
enrollment processing provided:
• VAONCE enrollment clears edits
• Tuition/fee payments released no earlier than
14 days prior to each term start date
Award Authorizations
• Student will be sent an award letter by VA for each
enrollment term processed.
– Non Chapter 33 will be computer generated letter
– Chapter 33 will be program release letter to provide:
•
•
•
•
•
•
•
SCO enrollment information for each term
Charges for tuition and fees
Resident or on line pursuit
BAH rate for each term
Books and Supply stipend payment
Kicker payment information
Remaining entitlement and delimiting date
• NOTE: CH33 Tuition and fee payments are released for each term not more
than 14 calendar days from the term start dates.
Case Studies
Enrollments
– Refer to Handout for case scenarios involving
certifications:
• Enrollment Certifications
– Start & end dates of term(s)
– Reporting credits
- Resident, practical, remedial, distance, blended/hybrid
– Reporting tuition & fees
» Net Charges, 3rd party tuition payments, institutional
waivers, discounts, internal scholarships, military TA
Case Studies
– Refer to Handout for case scenarios involving
certifications:
• Enrollment Certification Changes
– When to use AMEND
– When to use ADJUST
– When to use TERMINATE
Compliance Survey Findings
• Overall the findings have been very good.
Common errors involve:
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Not reporting changes or terminations
Not reporting net charges correctly
Not reporting non-standard terms
Not reporting unearned F grades – (procedural change)
Not reporting distance learning correctly
Late reporting of enrollment changes to VA
Failure to monitor prior credit evaluations
THANK YOU!
• QUESTIONS & ANSWERS
Day 2 12:30 – 2pm
VAONCE DEMO Session
– What is SCO certifying when submitting enrollments to
VA? – How to add student in VAONCE
– How to add or change information on BIO page
– How to prepare enrollment certifications
• Standard terms
• Nonstandard terms
• AMEND – ADJUST – TERMINATE
– CASE STUDIES
VAONCE Information
The purpose of the following exercises involve VAONCE
demo site are presented as instructional and informational
-
Institutional computer operating systems
Adding, deleting, inactivating students
BIO Page
Enrollments
- New single cert, new multiple term cert
- AMEND – ADJUST - TERMINATE
VAONCE Information
Entering information for:
Term dates
Approved Program Names
- BIO page
-
entering name of program – reference undeclared
entering correct VA file number
entering CH35 payee number
email of students for internal use
VAONCE Information
- How to report unsatisfactory academic progress
- How to certify student after successful appeal of
academic suspension. Documentation required by SCO
- How to report unearned F grade when institution takes
attendance of all students for each subject
- NO – how to report academic probation to VA
VAONCE Information
Scenarios will involve basic certification case studies to
more complex certifications
Accessing proper enrollment lines in VAONCE when
making changes
Is VAONCE user friendly?
management tools to access in VAONCE
Cleaning out old records in VAONCE
What exactly happens when I make a student inactive or
delete them in VAONCE?
VAONCE Information
THANK YOU!
CH33 YRP Breakout Session
• Training for this breakout session will include
discussion on:
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–
–
- Yellow Ribbon Program MOA
- YRP FAQ
- YRP – VAONCE how to?
- Public – Private Institutions of Higher Learning YRP
• Public
• Private
– Case studies
CH33 YRP Breakout Session
• Confirm institution is YRP MOA approved
• Confirm CH33 student is at 100% level
• Confirm this is not a spouse of active duty service
person or active duty service person
• CONFIRM NET CHARGES
• Private – certify YRP when cap exhausted
• Public – certify each term as needed for non
resident tuition charges in excess of in state costs
CH33 YRP Breakout Session
• Yellow Ribbon Program under Chapter 33 is
limited to Institutions of Higher Learning –
excludes all other types of schools
• Open to Public and Private IHL’s – public YRP
based on non-resident tuition charged
• Annual action – are now posted for 2014-15 YRP
schools on gi bill web site
• Review web site for WI YRP Institutions
CH33 YRP Breakout Session
• VA Central Office, Education Service,
Washington, DC processes and maintains
oversight on the Yellow Ribbon Program.
• GI Bill web site will list those institutions
approved and participating in YRP
• Currently there are 81 Wisconsin institutions
(Public & Private) of higher learning participating
in YRP for 2014-2015 VA Academic Year.
CH33 YRP Breakout Session
• Follow terms of YRP agreement
– - Create a list of YRP students
– - If limited create waiting list
– - Confirm business office aware of YRP students and
amounts
– - Private --Certify YRP when $20,235.02 cap is
exhausted within VA academic year (8/1/14 – 7/31/15)
* Increase effective 8/1/14 from $19,198.31
– - Public --Certify YRP when student charged non
resident tuition per term. Report resident amounts and
enter YRP contribution
CH33 YRP Breakout Session
• Tuition – net charges
• Fees – those costs charged to similarly
circumstanced non VA students.
• The fees must be charged by the institution
to student.
• NO – SCO cannot report fees when student
is purchasing items on their own from
vendor or book store etc.
Public Non Resident Tuition
• The Yellow Ribbon Program is available
when a public school charges a Chapter 33
student non resident tuition.
– The YRP agreement is for up to the difference
of the in-State tuition and non resident amount
charged.
– VA YRP can not exceed the institutional
contribution nor 50% of the difference
Private
• VA Academic year (8/1 – 7/31) $19,198.31 for
year ending 7/31/2014
• Maximum for tuition and fees increases on 8/1/14
ti $20,235.02 for year ending 7/31/15
• Do not certify YRP contributions until the term
begins that will exhaust annual maximum during
the VA academic year
• Set VAONCE BIO for CH33 YRP and enter zero
in enrollment YRP field until above applies.
Ch 33: Tuition & Fees
Established Tuition Charges• This includes any scholarship(s), or other Federal,
State, institutional or employer-based aid or assistance
(other than loans and any funds provided under section
401(b) of the Higher Education Act of 1965 (Title IV))
that is provided to the institution and is specifically
designated for the sole purpose of defraying tuition and
fees.
• The actual tuition charge that similarly circumstanced
non-veterans enrolled the program of education are
required to pay.
Chapter 33YRP: Student credit load reductions
•
Guidance when IHL reports CH33 YRP student withdraws due to
reduced credit hours:
– When schools report the withdrawal, they also report the T&F and YR
that would be associated with the reduced hours
– The VA will do its proration and collect any overpayments due
– The School will refund IAW its own policies
• School should have a written policy in place that describes
implications of withdrawals on YR and provide it to students
– Just like T&F, the YR amounts are not based on reality but rather the
amount needed to calculate the proration
Ch 33: Tuition & Fees
Reporting Tuition and Fees
• For each term, report actual net cost for tuition and fees to VA:
• Tuition and Fees for 12 credits (full-time) =$12,000.00
School Veteran Tuition Waiver
= ($1,000.00)
Private Tuition Scholarship
= ($1,000.00)
Your State Vets’ Tuition Assistance
= ($2,000.00)
Net Tuition and Fees
= $8,000.00
Report $8,000.00 to VA as the T&Fs for this this term. If the student
received any Title IV funds, (Pell Grant) or assistance not specifically
designated for the payment of tuition and fees – No need to deduct
from the amount reported to VA.
Ch 33: Net Payer Defined
SUMMARY OF PROVISION:
The actual net cost for tuition and fees assessed by the
institution after the application of—
(a) any waiver of, or reduction in, tuition and fees; and
(b) any scholarship, or other Federal, State, institutional,
or employer-based aid or assistance (other than federal
loans and Pell grants) that is “provided directly to the
institution and specifically designated for the sole
purpose of defraying tuition and fees”
Use “Amend” When
• Reported an incorrect “Begin” or “End”
term date
• Need to add a VBA Standard Remark
• Correct tuition & fee amount
• Correct Yellow Ribbon amount
Note: Debt will be placed against the institution when
overpayment of CH33 benefits results from an
incorrect tuition & fee or YR amount certified to VA.
Termination Reasons
•
•
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•
•
End of Term or Course
Graduation
Unsatisfactory Attendance, Conduct, or Progress
Withdrew Before Beginning of Term
Withdrawal or Interruption (Non College Degree
Programs Not on a Term Basis)
Withdrawal After Drop Period-Non-punitive Grades
Assigned
Withdrawal After Drop Period-Punitive Grades
Assigned
Withdrawal During Drop Period
Preregistered But Never Attended
Other (Explain in Remarks)
Case Studies
• Refer to the handout for several case studies that are
examples of Yellow Ribbon Program Certifications