Compliance Surveys July 2016

SCO Basic Responsibilities 1. This institution has exercised reasonable diligence in meeting all applicable requirements of Title 38, U.S. Code, and any failure by the institution to meet any requirements of the law will be reported promptly to VA; 2. The course or program certified are approved by the State Approving agency and are generally acceptable to meet requirements for the student's educational, professional, or vocational objective; 3. No course certified is a repetition of any course previously satisfactorily completed except as permitted by VA regulations; 4. This institution holds no power of attorney agreement authorizing the institution to negotiate VA educational assistance allowance checks;

SCO Basic Responsibilities FOR PRIVATELY OWNED SCHOOLS: The student certified is not an owner or officer of the school nor is the student certified as an official authorized to sign enrollment certifications; This 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. FOR ENROLLMENTS UNDER CHAPTERS 30, 32, 33, 1606, and 1607: All the 85-15 ratio requirements have been satisfied.

Purpose of Compliance Compliance surveys are conducted in order to ensure that schools and training establishments, and their approved courses, are in compliance with all applicable provisions of the laws administered by VA. Compliance surveys are, however, not the only means to this end. They should be regarded as part of a spectrum of VA activities which includes review of approval information and liaison with schools, training establishments, and SAAs. The purpose of all these activities is to prevent deficiencies and violations, as well as to identify and correct them when they are found. (M-22-4 1.01)

Authority Schools and training establishments must make records of progress and training, tuition and charges, and other records available upon request by a duly authorized representative of the Government. (38 U.S.C. 3690(c)) The records of both VA beneficiaries and non-VA students must be reviewed when comparing tuition charges, determining the 85-15 percent ratio, etc. The Buckley amendment (Public Law 93-380) requires that institutions receiving Federal funds administered by the Department of Education must obtain the student's consent to release information from school records. One exception to the law, however, is that information sought in connection with a student's application for receipt of financial aid is exempt. It has been determined that school records relating to VA benefits fall into the "financial aid" category and are therefore exempt from the provisions of the Buckley amendment. Therefore, the VA (and SAA) shall have access to the records of VA beneficiaries as well as non-VA students without the written consent of the student in order to monitor the school's compliance with the law.

Compliance Surveys Periodic review of school records by VA Verifies student is being certified correctly and payments to school and student are correct Mainly conducted by SAA and ECSS VA Form 22-1936A Records complete, certification of enrollments accurate. Records maintained for proper length of time. ____________________ _School certifying official___________________

Number of Students to be Surveyed

Compliance Survey 100% of facilities with 300 or more students 100% of non-college degree Granting facilities 100% of active OJT and non-registered apprenticeship facilities 100% of active Vocational Flight Schools An appropriate sample of Foreign Institutions as determined by the Assistant Director for Oversight and Outreach or designate (Remote surveys will be completed) Additional surveys as identified by CELOs or as directed by VACO

Compliance Trends Consolidating of terms Not reporting changes in schedules Fees Term Dates not matching school schedule Repeated or unrequired courses On Line Remedial

School Liability Facilities can be held financially liable for failure to adhere to VA policies and procedures.

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