North Carolina State Approving Agency Dr. Joseph Wescott II, Executive Director, NC SAA

History FDR signs GI Bill of Rights Congress recognizes responsibility of States to determine education of their citizens Late State Approving Agencies created; 1940’s overseen by Governor, but funded by the VA Today A cooperative and successful combined federal-state program!

NC SAA Staff Joseph Wescott II, Executive Director Program Specialists Elizabeth Kelly Jay Fitzgerald Meghan-Joy Woodall John Pritchett Jenne Herbst, Program Assistant NCSU Intern: Open

And of course--THE VA-ELIGIBLE STUDENTS The Players The “Triad” VA SAA Institution/SCO Other players ED DoL FAA Accrediting agencies State L&C agencies And of course--THE VA-ELIGIBLE STUDENTS Mutual trust, Mutual dependence!

It Takes A Team! SAA & VA collaborate to help you Interpret laws and regulations Maintain integrity of programs Train the SCOs Encourage greater use of VA benefits Help your school better serve veterans! VA VA Central Office (VACO) Regional Processing Office (RPO) Education Liaison Rep (ELR) State Approving Agency (SAA) School Certifying Official (SCO)

Mission & Responsibility NC SAA Mission & Responsibility To ensure quality instruction, appropriate administration, and fair and equitable practices for every veteran (and eligible person) who enters a NC SAA-approved educational program. We do this by: Validating and approving educational courses and programs to be pursued by veterans and eligible persons Overseeing North Carolina’s educational institutions, and ensuring compliance with federal and state guidelines Ensuring the interests and prerogatives of the State are preserved in both processes

NC SAA Program Specialists’ Assignments* All: Public and Private Universities, Community Colleges Elizabeth Kelly: On-Military-Base, Truck, Beauty, Barber Jay Fitzgerald: Religious Exempt Institutions & Nursing Meghan-Joy Woodall: Trade, Business, Hospitals, Massage Joseph Wescott: Flight, High Schools, L&C, new applications * Note: Some assignment overlap occurs based on workload

Our Partnership with You NC SAA Our Partnership with You Approvals Evaluate educational programs for approval Provide written evaluations and approvals to VA and the schools   Inspections and Compliance Survey Visits Visit and inspect each new/active educational institution Confirm compliance for approved courses and programs   Technical Assistance Respond to institutional and veteran requests for information and assistance Provide written reports to DVA, as requested Maintain records and files for the State of North Carolina

NC SAA The Approval This is THE document that actually conveys State / VA approval for educational programs to be considered for payment under the GI Bill®. Your Approval contains… General information about your school Programs and hours that are approved (or EXCLUDED…) Calendars, tuition and fees Unique programs or policies (Remedial / Branches, others…) Requirements specific to your institution

NC SAA The Approval, cont. Remember: Every approval is different! It is specific to your school or institution, and is based upon your catalog and applicable state and federal law. You should read/review your approval annually, and comply daily. Many of your questions are answered here. Keep it handy!

NC SAA The Approval, cont. The Addendum… A unique NC SAA Form that contains… The General Information section from the Approval, AND A specific change to the Approval Corrects or changes some portion of an Approval Examples: Changes to the academic calendar date (after published) Change of policy in Requirements section Delete a program or change the hours approved for a program

NC SAA The Re-Approval The Re-Approval… Required Prior to 1) the ending date of the previously approved calendar and / or with 2) the publication of a new Catalog, school officials will apply for re-approval or revision of the current approval. Must be mailed to the NC SAA office and all documents, except catalogs, must be submitted SINGLE-SIDED.

NC SAA The Re-Approval, cont. For Title 38, United States Code, Section 3675 – Accredited Institutions of Higher Learning, package must include: -Signed Application -Two hard copies of your current catalog -Signed Catalog Certification Addendum -A copy of the last NC SAA Approval marked with colored ink. -Enclose Calendars / Schedules that are not contained in the catalog -Provide a copy of the last letter of Accreditation -If you are licensed, provide a copy of the latest letter of licensure or report of licensure to the State. -New VA Form 22-8794 if it does not have the name(s) of current Certifying Official(s)

NC SAA The Re-Approval, cont. For Title 38, United States Code, Section 3676 – Non-Accredited Institutions, package must include: -Signed Application -Two hard copies of your current catalog -Signed Catalog Certification Addendum -A copy of the last NC SAA Approval marked with colored ink. -Enclose Calendars / Schedules that are not contained in the publication -Provide copies of the latest NC License / Licensure Letter -Provide copy of up-to-date bond documentation, -Complete Addenda required for your school, provide signatures and copies -Complete I/A Information Forms for all new instructors and administrators.

Important Special Interest Items NC SAA Important Special Interest Items Prior Credit High School Transcripts The DVA Form 22-8794 Continuing Education

Important Special Interest Items, cont. NC SAA Important Special Interest Items, cont. Prior Credit Must be evaluated and recorded (by law…) prior to enrollment OR within 2-terms. This means you must have official transcripts of all previous training on file. Must have proof of prior credit evaluation in the student file.

Important Special Interest Items, cont. NC SAA Important Special Interest Items, cont. Prior Credit Military Transcripts: Obtain them in accordance with your applicable school policy If your institution has signed the DoD MOU, then you must obtain military transcripts, and they must be evaluated for possible transfer credit If a student has attended degree programs through the military (e.g., Community College of the Air Force), then you must obtain official copies of those transcripts, regardless of your school policy, and evaluate for possible transfer credit

Important Special Interest Items, cont. NC SAA Important Special Interest Items, cont. High School Transcripts: Are they required? Depends on your school and on your Approval… If HS transcripts document “part” of admission process, YES! Schools that teach degree / IHL programs generally require HS transcripts for new (freshmen) admissions Private and Proprietary schools are “generally” required to meet State standards NCD / Diploma / Certificate programs generally require “proof of high school completion” OR “ability to benefit”

Important Special Interest Items, cont. NC SAA Important Special Interest Items, cont. VA Form 22-8794 “Designation of Certifying Officials” When there are changes, submit a new form to DVA and a copy of same to NC SAA. Be sure to include full contact information for each certifying official Name, phone and fax number and e-mail address for each certifying official in the appropriate box. The Approving Official must sign box 7.

Important Special Interest Items, cont. Continuing Education Courses Generally these courses are not approved. All courses must lead to a vocational objective, i.e. a job. Few exceptions: state licensed, state mandates, etc.

Information / Policies 5/15/2009 ATTENDANCE, STANDARDS OF PROGRESS, RECORD KEEPING AND STUDENT CONDUCT POLICIES CFR TITLE 38: Reference Paragraph POLICY APPROVAL APPLICATION - Information / Policies 21. 4254 (b5) Attendance Provide school policy and regulations relative to: Leave Absences Class cuts Make-up work Tardiness Conditions for interruption/termination for unsatisfactory attendance Conditions for re-entrance for students dismissed for unsatisfactory attendance 21.4254 (b6) Standards of Progress/Grading Grading system Conditions for interruption/termination (minimum grades) for unsatisfactory grades or progress Description of Probationary Period, if any Conditions for re-entrance for students dismissed for unsatisfactory progress Describe progress records kept by the school and furnished to the student 21.4254 (b7) Student Conduct Provide Conditions for dismissal for unsatisfactory conduct 21.4254 (c4) Records of Previous Education and Training Provide record of previous education and training with appropriate credit for previous education.

Continuing Education Courses We approve programs not courses. Approval package is worked through the school certifying official. They must give initial approval. State licensed programs such as BLET, CNA, etc. are possible candidates for approval. We usually will require an addendum be signed.

NC SAA Additional Items of Interest Contract Courses: Both the contractor and host institution must be approved. Questions of academic quality control, awarding of credit, certification and records management. Additional Facilities: Also must be approved.

NC SAA Compliance Surveys NC SAA assists DVA with this responsibility Former “Supervisory Visits” were more focused on SCO training and process improvement Compliance Survey primarily an audit of federal entitlement program; focus shifted from academic programs to more emphasis on finances

Compliance Survey Process NC SAA Compliance Survey Process NC SAA schedules visits with the institution NC SAA Program Specialist conducts on-site visit reviewing: Process Management (prior credit evaluation, timeliness/accuracy of certifications, attendance, etc.) Records Management (required documentation is present) Visit reports maintained at NC SAA with copy sent to DVA Inspection discrepancies (if any) require resolution with documentation of corrective action to NC SAA (approval issues) or referral to DVA (payment issues). Expanded audits: ≥ 30% Financial discrepancies ≥ 50% Discrepancies of any type

Record Keeping Requirements ADMISSIONS/REGISTRATION DOCUMENTATION A. Copy of student’s Application for Admission B. Copy of high school transcript for Entering Freshman and Transfer Students C. Copies of transcripts for all post secondary education with chosen Curriculum “Transfer Credit” clearly documented. D. Copy of student’s current Curriculum with: (1) All to-date credits and transfer credits clearly identified and, (2) If applicable, a prior credit re-assessment if student changes programs with new Curriculum record annotated accordingly. E. Copy of Remedial/Deficiency test scores (if applicable) F. Copies of Student Schedules with “non-Curriculum” course selections, i.e. not VA benefit eligible, clearly identified. G. Copies of completed Drop/Withdrawal forms H. Copies of Plan of Study course substitution approvals (if applicable) I. Copy of current academic transcript J. Copy of student ‘Attendance Records’ for clock-hour programs (if applicable) VA DOCUMENTATION a) (Optional) Copy of Application for VA Education Benefits (VA Form 1990) if available b) Copies of all Enrollment Certifications (VA Form 22-1999) to include Remedial/Deficiency CH (if applicable) identified separate from Curriculum CH c) Copies of all Changes in Student Status (VA Form 1999b); Amend, Adjust, Terminate d) Copies of Request for Change of Place of Training (VA Form 1995/5495) e) (Optional) Copies of DD-214s, Certificate of Eligibility and NOBEs as available f) Reporting fees usage

Changing Laws, Changing Roles NC SAA Changing Laws, Changing Roles The Post 9/11 GI Bill Public Law 111-377 Public Law 112-249 Principles of Excellence (Executive Order 13607) Public Law 113-146

Post 9/11 GI Bill Became effective on August 1, 2009 A complex program! Many levels of eligibility Confusing concurrent eligibility New benefits similar to original WW II GI Bill Difficult to understand and administer SAAs took on new “consultant/trainer” role

Public Law 111-377 Became effective October 1, 2011 Many positives More programs now covered by Post 9/11 GI Bill More potential beneficiaries A “Game-Changer” for SAAs Changed State/Federal approval authorities SAAs acquired new role of assisting VA with Compliance Surveys

Changed States’ authority to approve programs Public Law 111-377, cont. Changed States’ authority to approve programs Accredited, public & non-profit existing degree programs “deemed” approved without continuing State review New degree programs at public and non-profit private institutions must be reviewed Approval AND disapproval authority given to U.S. Secretary of Veterans Affairs Schools with deemed approved programs provided approval/change notifications to ELR with courtesy copy of catalog/forms to NC SAA SAAs retained jurisdiction over for-profit schools, and Non- College Degree (NCD) programs at all schools

BUT… Big Change 2013 Effective October 1, 2013, VA no longer accepts modification form--all requirements for approval go to NC SAA. All NC institutions must submit an approval package to the NC SAA. All approval related concerns and questions must come to the NC SAA.

Improving Transparency of Education Opportunities for Veterans Public Law 112-249 Improving Transparency of Education Opportunities for Veterans Public Law 112-249, signed on January 10, 2013, mandates, among other things... A centralized mechanism for tracking/publishing feedback from students and SAA regarding quality of instruction, recruiting practices, and post-graduation employment placement of institutions of higher education. SAA’s will share with accrediting agencies or associations information regarding the SAA’s evaluation of an IHL.

New This Year VA & NASAA Initiatives National VA Online Feedback (Complaint) System A centralized online reporting system; launched in Jan 2014 Report violations of the Principles of Excellence (E.O. 13607) Report negative experiences with educational institutions Identify and address unfair, deceptive, misleading practices Ensure high quality academic and student support services VA Online Comparison Tool Launched in February 2014 Easier to calculate Post-9/11 GI Bill benefits and learn more about VA’s approved colleges, universities and other education and training programs across the country.

H.R. 3230 – Veterans Access, Choice, & Accountability Act of 2014 Also This Year… H.R. 3230 – Veterans Access, Choice, & Accountability Act of 2014 Signed into law August 8, 2014, as Public Law 113-146 Primarily addresses veterans’ health matters Expands Fry Scholarship eligibility to spouses Effective January 1, 2015 Entitlement expires 15 years after servicemember’s death or the date the spouse remarries, whichever is earlier If also eligible for Chapter 35 (DEA), must make irrevocable election of one chapter

Veterans Access, Choice, & Accountability Act of 2014 P.L. 113-146, cont. Veterans Access, Choice, & Accountability Act of 2014 Public IHLs and In-State Tuition Beginning July 1, 2015: Cannot approve programs for which “covered” students, regardless of residency, are charged T&F that are higher than the in-state rate “Covered individuals” are Ch 30 and Ch 33 vets discharged or released from active duty (≥ 90 days) less than 3 years before enrollment in the program, and Ch 33 Fry Scholarship beneficiaries and TOE recipients But: IHL may require covered individual to demonstrate intent to become resident Can require any type of proof of intent except “physical presence” THIS IS NOW STATE LAW!

On the Horizon HR 3016 passed the House of Representatives February 8, 2016. This bill will: Clarify and codify approval authority with SAAs Cap contracted flight programs at the prevailing private school tuition and fee cap Restructure the way compliance surveys are performed. Schools/training establishments with > 20 veteran students enrolled survey biannually. Method and manner determined with SAA.

Hundreds of technical assistance phone calls and e-mails NC SAA Responsibilities include: 282 separate institutions of learning, plus 42 branch locations   Our Service to You: Conducted 77 Compliance Survey visits Processed requests for new approval, resulting in 7 new institutions Reviewed and completed 348 applications for program re-approval (new catalogs) Evaluated and approved over 1,000 individual programs Hundreds of technical assistance phone calls and e-mails  *As of October 1, 2015

Thank you! Any (more) questions?