Approval Criteria – Part II Your Instructors for this presentation… were both child models… Part II will cover: Contract Learning Branch Campuses Resident and Distance Education Independent Study Practical Training

Contract Learning A college/university may offer a course, as part of a program of education, in which some or all of the instruction is provided by another educational institution or entity (this is referred to as a third party contract).  This may be approvable under the following circumstances: Such school or entity actually providing the training must obtain approval of the course from the State approving agency in the State having jurisdiction of that school or entity. The primary school must submit to the SAA a copy of the contract/agreement between the two entities and any other documents deemed appropriate by the SAA to determine if the program of education meets approval criteria.  If the course is a course of flight training, the school or entity actually providing the training must also obtain approval of the course from the Federal Aviation Administration. Authority: 38 USCS § 3680A(f)(1-2); and 38 C.F.R. §21.4233 (e)

Branch Campuses Administrative Capability: Defined as the ability of an institution or branch to maintain all records and accounts that 38 C.F.R. § 21.4209 requires.  Main Campus: The location where the primary teaching facilities of an educational institution are located.  Branch Campus: A location of an education institution that is geographically apart and operationally independent from the main campus. It has its own faculty, administration, and supervisory organization and offers programs leading to a degree, certificate, or other recognized education credential. Extension (Teaching Site): A location of an education institution that is geographically apart but operationally dependent upon the main campus or a branch campus of the institution.

Branch Campuses - continued State approving agency jurisdiction: 38 U.S.C. 3672; 38 C.F.R 21.4266 (b)(1-3) The state approving agency for the State where a residence course is being taught has jurisdiction over approval of that course for VA Education benefit purposes. The fact that the location where the educational institution is offering the course is temporary will not serve to change jurisdictional authority. The fact that the main campus of the educational institution may be located in another State from that in which the course is being taught does not serve to change SAA jurisdictional authority. An SAA in the state where a branch/extension campus is located can approve programs offered at that campus so long as (1) each location where the course or program is offered has administrative capability and (2) each location has a certifying official on site. 38 CFR § 21.4266(b)(2) There are some exceptions to these two requirements which are delineated in 38 CFR § 21.4266(f).

Resident and Distance Education The Department of Veterans Affairs definition of “in residence” courses for certification purposes:  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 per term, research (either on or off campus), or a combination of both. Approved practical training or cooperative training are considered resident training. Student teaching is also considered resident training.

Resident and Distance Education – continued Live instructor-facilitated training delivered online, in which a student is located in an on- campus classroom, where attendance is monitored and a site staff member is present, would be considered resident training. Any courses (hybrid or blended) that consist of some interaction using communications technology and some weeks of standard class sessions, but do not meet the requirements to be classified as in-residence training, are currently considered independent study/distance education. Independent Study and Distance Education may not necessarily be considered as the same thing; i.e., some resident courses can be considered independent study; distance education or online courses may not be considered as independent study. The VA has drafted proposed changes to the regulations regarding independent study/distance education to help clarify grey areas in the definitions and guidelines.

Independent Study/Distance Education 38 C.F.R. § 21.4267(b) defines a course to be entirely independent study when: It consists of a program of study that provides for interaction between the student and the regularly employed faculty of the institution. The interaction may be personally or through use of technology. It is offered without any regularly scheduled, conventional classroom or laboratory sessions. The VA views independent study to include distance education/online classes. A course taken by independent study must lead to a standard college degree or a certificate that reflects educational attainment at an accredited IHL. The recent “Forever GI Bill” passage included the addition of area career and technical education schools (limited in scope) and postsecondary vocational schools (also limited scope). 38 U.S.C. §3680A(a)(4) Remedial and deficiency courses offered by independent study cannot be approved. The catalog description for independent study should include the methods of communication that will be established between the faculty and the student, and timelines for completion. It must be clear that the course or program offered under independent study is the same as the course offered on -campus. Grading, credit values, course assignments, and graduation requirements should all be the same no matter what the mode of delivery.

Practical Training Practical training, such as internship, residency, practicum, externship, etc. provides a student with the opportunity to apply theories learned in the classroom to a workplace environment. 38 C.F.R. § 21.4265 (f) defines practical training as resident instruction if all of the following conditions are met. The course is: Accredited by a nationally recognized accrediting agency or offered by a school that is regionally accredited; Part of an approved curriculum of the school; Directly supervised by the school; Measured in the same units as other courses; Required for graduation; and

Practical Training - continued Has a planned program of activities described in the school’s SAA approved catalog and which is institutional in nature and includes: A description of the courses and provision for an assigned instructor; A statement that the school, not the job establishment, controls the program of activities; A requirement for class attendance at least a weekly basis; A statement that appropriate assignments are required for completion; A grading system similar to the system used for other resident subjects ; A schedule of time required for the training that demonstrates the student will spend at last as much time in preparation and training as normally required by the school for its other resident courses.

Practical Training - continued Medical/Dental internships and residencies may be approved only when accredited by the following accrediting agencies: 38 C.F.R. § 21.4265(a) The Accreditation Council for Graduate Medical Education (ACGME), or where the ACGME has delegated accrediting authority, to the appropriate Residency Review Committee; The American Osteopathic Association; and The Commission on Dental Accreditation of the American Dental Association. Residency programs must lead to certification by an appropriate Specialty or Subspecialty Board, the American Osteopathic Association, or the American Dental Association. A residency in podiatric medicine must be approved by the Council on Podiatry Education of the American Podiatry Association.

Practical Training - continued Nursing programs: 38 C.F.R. § 21.4265(b) Must be accredited by a nationally recognized accrediting agency or meet the requirements of the licensing body of the State in which the school is located. The hospital or fieldwork phase of a nursing course must require that the practical training be a prerequisite to completion of the program; the student must remain enrolled in the school during the period, and the training must be under the direction and supervision of the school. With the exception of a nurse's aide course approved pursuant to §21.4253(a)(5), non-accredited nursing courses which do not meet the licensing requirements of the State where the course is offered cannot be approved.

Practical Training - continued Medical and dental specialty courses: 38 C.F.R. § 21.4265(c) Required clinical training included in a school course given in an affiliated hospital, clinic, laboratory, or medical center, as a part of a medical or dental specialty course whether accredited or non-accredited must ensure: The student remains enrolled in the course during the clinical period; The clinical training is an integral part of the training and a prerequisite to successful completion of the course; Is under the direction and supervision of the school; The course includes substantial technical or professional training and does not consist of training preliminarily directed to clerical, administrative, secretarial, or receptionist duties. Clinical training included in a school course given in a physician's office or a dentist's office, also called externship, will be recognized as part of the institutional training if the course is accredited by a nationally recognized accrediting agency and meets the other requirements of § 21.4265 (c)(1). If the course is not so accredited, the practical or on-the-job training or experience in a physician's office may not be included unless the program is approved as a cooperative course.

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