Advanced SCO Training June 2018

Overview Basics Programs Responsibilities Miscellaneous and New Challenges Getting Assistance

A little history... (GI Bill) Provided 4 years of education or training Tuition, fees, books, supplies, and monthly stipend Guaranteed home, farm, or business loan Unemployment compensation Weekly payment for up to 52 weeks GI Bill term usually only used today for education programs President Franklin D. Roosevelt signing the Servicemen’s Readjustment Act of 1944

Education Programs Chapter 30 Chapter 1606 Chapter 1607 Chapter 35 Chapter 33 TOE Fry Scholarship

View from Above...How it works Veteran Services Application submitted from student VA Determines Eligibility and sends student COE You certify enrollment VA Makes payments

Chapter 33 Yellow Ribbon School must enter into agreement with VA Program to help pay some/all of unmet charges at IHLs School must enter into agreement with VA School can contribute up to half of unmet charges and VA matches amount Only available to 100% tier AD, Spouses of AD, & Fry Scholarship Not eligible (Aug 2022) All Yellow Ribbon Debt is considered student debt Works on Academic YR 08/01 – 07/31

Fry Scholarship Provides Post-9/11 GI Bill® benefits to the children and surviving spouses of service members who died in the line of duty while on active duty after September 10, 2001 Children of active duty members of the Armed Forces who died in the line of duty after September 10, 2001, are eligible for this benefit. A child may begin an approved program of education before the age of 18. Eligibility ends on the child’s 33rd birthday. A child’s marital status has no effect on eligibility. Surviving spouses of active duty members of the Armed Forces who died in the line of duty after September 10, 2001, are also eligible for this benefit. A surviving spouse can receive benefits for terms beginning on or after January 1, 2015. A surviving spouse’s eligibility generally ends 15 years after the Servicemember’s death. A spouse will lose eligibility to this benefit upon remarriage if this occurs during the 15 year period. More information about eligibility and rules http://www.benefits.va.gov/GIBILL/docs/factsheets/Fry_Scholarship.pdf

Chapter 31 (Vocational Rehabilitation & Employment) This program assists Veterans with service-connected disabilities to prepare for, find, and keep suitable jobs. The Vocational Rehab program is NOT A VA Educational Benefit Does count against the 48 months Educational Benefits Does use the same certification process as VA Education Pays the student a monthly stipend based on dependents or BAH rates Requires communication between the Case worker and the SCO Pays the school directly for tuition/books/supplies

Release of Records Exceptions to Student Consent for Release of Educational Records FERPA allows the institution the right to disclose student records or identifiable information without the student's consent under the following circumstances: To authorized representatives for audit of Federal or State supported programs. To university employees who are in the process of carrying out their specifically assigned educational or administrative responsibilities... Veteran's Administration officials §21.4209 Examination of records (Approval) Please allow your VR&E Caseworkers access to their veterans transcripts and grades; these are needed in the rehabilitation of the veteran. Feel free to contact me with any questions you may have.

Roles and Responsibilities SAA State Approving Agency ELR Education Liaison Representative You Schools Certifying Official

State Approving Agency Congress recognized that it was the responsibility of the State to determine the education of its citizens. It was decided that each state would establish a “State Approving Agency” and that the governor of each state would designate a state bureau or department within which the SAA would operate. The SAA would be supported through funding, under contract, from the Department of Veterans Affairs (VA). This originated as part of the compromise that facilitated the passage of the original World War II GI Bill and which has evolved into a truly cooperative federal-state effort that maintains states’ rights for education while monitoring and protecting a federally sponsored program administered under the terms and conditions of federal laws.

SAA Responsibilities SAAs engage in six core functions: program approval; compliance and oversight; technical assistance; outreach; liaison; and agency management and contract compliance.

What can be Approved Program of Education Is a combination of subjects or unit courses pursued at an educational institution. The combination generally is accepted as necessary to meet the requirements for a predetermined educational, professional or vocational objective. It may consist of subjects or courses which fulfill requirements for more than one objective, if all objectives pursued are generally recognized as being related to a single career field.

Educational An educational objective leads to the awarding of a diploma, degree, or certificate which reflects educational attainment as distinguished from a certificate or a license to practice a profession or trade. The objective will be the name of the highest degree, diploma, or certificate included in the program, such as a GED (General Educational Development) certificate, high school diploma, bachelor degree, master degree, or Ph.D. degree.

Vocational A vocational objective leads to an occupation ordinarily attained after completion of a business, technical, trade, or other vocational school course, or an apprenticeship or other on-the-job training program and which leads to entry level employment. Approval of continuing education and career enhancement programs is generally not allowed. A vocational objective must be a recognized employment objective. It should be of the type listed in the DOL (Department of Labor) Dictionary of Occupational Titles found in the DOL "O*NET" database Examples of vocational objectives are barber, secretary, machinist, computer programmer, automobile mechanic, and practical nurse. With respect to non-degree certificate programs, an undergraduate level certificate from an accredited college or university may be accepted as leading to a vocational objective.

Professional A professional objective leads to an occupation after an individual completes an extended academic program of study. The program must be at the college level and be generally accepted as necessary to satisfy the educational requirements for licensing or certification to practice the identified profession. Typical examples of professional objectives are lawyer, physician (M.D.), teacher, physical therapist, medical technologist, and medical record librarian. A program leading to a professional objective may include courses also leading to an educational objective. In this situation, the student may specify either the educational objective or the professional objective on his or her application. Examples are B.S. (Bachelor of Science) degree in secondary education or high school teacher, and J.D. (Juris Doctor) degree or lawyer.

Not Approvable Bartending Personal Development Avocational or Recreational Photography Music course Horseback riding Private Pilot Any music course, instrumental or vocal, public speaking course, or course in dancing, sports or athletics, such as horseback riding, swimming, fishing, skiing, golf, baseball, tennis, bowling, sports officiating, or other sport or athletic courses, except courses of applied music, physical education, or public speaking which are offered by institutions of higher learning for credit as an integral part of a program leading to an educational objective, or any other type of course which the Department of Veterans Affairs determines to be avocational or recreational.

What Does the SAA Need From You? Catalogs (Disc)...not website URLs • Calendars • Schedules • Enrollment agreements • Student handbooks • Addendums and changes Statement of True and Correct

Education Liaison Representative Receiving, reviewing, and taking appropriate actions on all approval notices submitted by SAAs and ensuring that VA only pays for programs that are approved in accordance with 38 U.S.C. Chapter 36. Updating the Web Automated Approval System (WEAMS) with program approval and other information about an approved facility. Disseminating approval information to all concerned elements within VA and approved schools. Acting as a liaison between the Regional Processing Offices and schools regarding issues of program approval. Training the SCO on their certification processes. Providing information to SCOs regarding the proper interpretation of all VA education rules, regulations, policies, and procedures. This includes giving presentations at education conferences and workshops. Conduct random liaison visits or as requested Conducts EO and Risk Based Compliance as needed

School Certifying Official (SCO)

Responsibilities for Reporting Keep VA informed of the enrollment status of Veterans and other eligible persons. Use basic forms to keep VA informed, such as: • Enrollment Certification (VA Form 22-1999) to report required enrollment information • Notice of Change in Student Status (VA Form 22-1999b) to report changes to enrollment information • Monitor the subjects pursued by a student to certify to VA only those subjects that apply to the student’s program • Monitor student’s grades to ensure s/he is making satisfactory progress; report when a Student was terminated due to unsatisfactory progress • Monitor student’s conduct and report when student is suspended or dismissed for unsatisfactory conduct

Responsibilities for SCO’s Retain file of VA papers submitted & records of academic progress, program pursuit, etc. Maintain records for at least three years following the student’s last date of attendance Ensure that records are kept in a safe place and that the privacy of VA students is protected Attend VA training opportunities

Certification Responsibilities Courses Approved by the SAA/VA Meets Students’ Learning Objectives Not a Repeat of Previously Passed Courses Promptly Report any Changes Noncredit R/D classes Required Meets 85/15 Rule

Certification Term Dates Standard Terms (Semesters-15 to 19 weeks, Quarters-10 to 13 weeks) Classes that begin and end in the same calendar week can be certified as the term start in end date Non Standard Terms -If a school offers training on a nonstandard term basis, or if there are nonstandard formats or sessions within standard terms, the beginning and ending dates of each term, session or course must be shown separately from the standard semester or quarter

Calendar Week Defined Prior to April 25, 2016, if a class began after the initial calendar week then the school would report the actual date those classes began. (Sunday-Saturday) If the standard term is after April 25, 2016 and a course begins within 7 calendar days then the school should certify the course using the first day of the term. If a standard term is taken concurrently with a nonstandard term, the two must still be certified separately. • If a student enrolls in a course and the actual first day that the student attends class is no later than the seventh calendar day of the term, then the beginning date of the certification will be the first day of the term, quarter, or semester in which the student is enrolled. • If a student enrolls in a course and the actual first day that the student attends class is after the seventh calendar day of the term, then the beginning date of the award will be the actual date of the first class scheduled for that particular course.

Modality If a course does not meet the definition of residence training it must be considered independent study. Courses offered in whole or part by independent study cannot be approved at non-accredited schools. On the enrollment certification, resident training should be identified as “res”. Independent study, on-line and hybrid courses should be identified as “dist”. Do not add these hours together in VA-ONCE. Resident or Distance The total number of hours of classroom instruction must equal, or be greater than, the number of credit hours awarded for the course multiplied by the number of weeks in the term. X 3 = 30 classroom hours to be resident training. Weeks X Credit hours ≤ to classroom instruction

Certification - Hours Schools with multiple consecutive sessions Do not lump hours together Certify each non-standard term separately Resident, Distant, Remedial, and clock hours are reported separately for all chapters Graduate Students number of hours considered fulltime by your school (for that term)

Certification Yellow Ribbon Report up to half of the unmet charges per your Yellow Ribbon agreement. Student must be at 100% level Public School: Difference between In-State Net Costs and Out-of-State Net Costs Private School: School Year 2017/2018 $22,805.34 School Year 2018/2019 $23,671.94

Certification Changes Adjustment To report an increase or decrease in credit hours. If tuition, fees, or Yellow Ribbon were reported, they must also be changed to correspond to the adjusted hours Amendment To change begin date, end date, tuition and fees, Yellow Ribbon, add a remark, and advance pay and accelerated pay requests on a certification already submitted Termination To report a complete withdrawal from an enrollment period, or to report graduation or program completion

Certification Changes Non-33s A change in dates, ROP-rate of pursuit, or reportable costs 33s Any change in dates, hours (number or type), or costs

Certification Changes Within 30 days (Of action) Reduction in Hours Report new costs as if student were enrolled in reduced hours from beginning of term VA will Prorate LDA/EFF Last date of Attendance Effective Date

Certification Miscellaneous Undeclared Major By Junior Year Matriculation By Third Term Guest Student Parent Letter on File Active Duty T/A (Now must certify fees for Chapter 30) Top Up

Certification Miscellaneous Unsatisfactory Progress, Conduct, or Attendance - LDA/EFF Probation - Right Now Web Graduation - Termination

Prohibited Payments Non-Punitive Grades (New Policy) Non-Attendance (Attendance policy) Audited Classes Repeat of Previously Passed Courses Classes outside program requirements Previously Qualified On-Line Remedial Leave of Absence

What to do if a student repeats a course Classes that are successfully completed may not be certified for again for VA purposes if they are repeated. However, if a student fails a class, or if a program requires a higher grade than the one achieved in a particular class for successful completion, that course class may be repeated and certified to VA again. Example 1, if a Nursing program requires a “B” or better in Biology, then that class may be repeated if a “B” or better was not earned. That requirement must be in the school catalog. Example 2. If a course is required for graduation, a student may repeat the course and be certified for it until it is successfully completed. No further information needs to be provided to VA regarding those courses. Example 3. If a student chooses to repeat a course that was successfully completed, just to improve their GPA, that course cannot be certified to VA.

Remedial courses Remedial and deficiency courses are courses designed to correct deficiencies in Basic mathematics, English, and Reading at the elementary or secondary level. These courses can be certified as part of an approved program, but only for students for whom a verifiable need has been established. Keep test results and other documents in the student’s file that support the student’s need for remedial and deficiency courses.

Remedial courses Remedial and deficiency courses offered as independent study (online) cannot be approved and cannot be certified to VA. If a student fails to meet the objective of the remedial course they may continue to take the course until they have met the criteria to advance. If the student passes the remedial course and then fails the next level they can not repeat the remedial course in which they have already demonstrated proficiency.

What to do with a walk away Schools with an established attendance policy must monitor compliance with that policy, enforce the policy, and report terminations due to violations of the policy to VA. However, absences that do not violate the established attendance policy don’t need to be reported. Schools that don’t have an established attendance policy are not required to report changes in attendance.

How to Report Probations Schools that have an academic progress policy allowing for a period of academic probation prior to termination for Unsatisfactory Progress (Academic Suspension) should notify VA promptly when a student receiving VA education benefits is placed on academic probation. Notifications should be sent using VA’s “Ask a Question”. 10,000 foot view

How to Report Probations If multiple students are placed on academic probation (e.g., end of term, semester, quarter) schools may submit a single notification to VA by indicating that multiple students were placed on academic probation in the text and attaching an Academic Probation Spreadsheet listing each student. 10,000 foot view All notifications must include “Academic Probation” in the subject line. Use 000-00-0000 as Social Security Number

How to Report Suspensions Unsatisfactory Progress (Academic Suspension) must be reported to VA as a termination. Terminate the semester the student is suspended. If suspension follows the fall semester, for example, terminate fall semester. Choose “Unsatisfactory Attendance, Conduct, or Progress” as the reason. 10,000 foot view

How to Report Suspensions VA-ONCE will insert the end date of the term as the default “LDA/EFF Date”. You can change the default end of term date if it isn’t the correct date. 10,000 foot view

How to Report Suspensions If a student successfully petitions the dismissal, is readmitted, and is already certified the subsequent term, don’t terminate the student. Instead, annotate the student’s file that the student was dismissed and readmitted following a successful appeal. If enrollment status changed the subsequent term, be sure to adjust the credit for the term. When you submit the termination, a pop-up window will appear asking about subsequent terms if any are to be certified.

What to do with suspensions Student will receive a suspension letter:

Mitigating Circumstances Beginning November 15, 2015, VA requires students using the Post-9/11 GI Bill to provide mitigating circumstances when they withdraw from or drop a course after the drop/add period and receive a non-punitive grade. Acceptable mitigating circumstances must be provided in order to pay benefits for the period of attendance prior to the drop date. If they are not provided and accepted, any benefits paid from the beginning date of the term will be considered an overpayment, and a debt may be established. Mitigating circumstances are circumstances beyond the student's control that prevent the student from continuing in school or that cause the student to reduce credits.

Mitigating Circumstances Examples are: • An illness or death in the student’s immediate family. • An illness or injury afflicting the student during the enrollment period. • An unavoidable change in the student’s conditions of employment. • An unavoidable geographical transfer resulting from the student’s employment. • Immediate family or financial obligations beyond the control of the claimant that require him or her to suspend pursuit of the program of education to obtain employment. • Discontinuance of the course by the school. • Unanticipated active military service, including active duty for training. • Unanticipated difficulties with childcare arrangements the student has made for the period during which he or she is attending classes. VA- ONCE will display a Mitigating Circumstances box. The drop down arrow for the box will display the above list of mitigating circumstances. If the SCO knows the circumstance and it’s clearly one of the circumstances listed, then the SCO should select that circumstance and documentation of mitigating circumstances provided by the student should be retained within the student’s file.

Mitigating Circumstances The school may act as an agent for the student. Schools are required to submit a description of the mitigating circumstances when reporting the reduction or termination. If the school reports the reason for the reduction or withdrawal, the VCE should consider it as the claimant’s statement. If additional corroborative documentation is needed to substantiate the reason for the withdrawal or reduction, the VCE will develop directly to the claimant.

6-Credit Hour Exclusion VA automatically grants mitigating circumstances for up to 6 credits the first time a student reduces or terminates and mitigating circumstances must be considered. This automatic grant is called the 6-Credit Hour Exclusion. The exclusion is a one-time grant made the first time mitigating circumstances must be considered for the student. Up to 6 credits can be excluded if the student has been awarded benefits for the credit. The 6-Credit Hour Exclusion cannot be granted if the student completes the term and receives non-punitive grades. If the student withdraws from 3 credits, the exclusion will be granted for 3 credits and the student’s one time exclusion is used. If the student withdraws from 12 credits, the exclusion will be granted for 6 credits, the student’s one time exclusion is used, and the student must provide mitigating circumstances for the other 6 credits.

Records and Student Files Certifying official must maintain copies of all certifications and changes in enrollment for a minimum of 3 years after last day of attendance. Hard copy or electronic format is ok. All documents subject to review by SAA or VA to include Chapter 31 caseworkers.

85/15 38 U.S.C 3680A(d) 38 CFR 21.4201 Prohibits paying benefits to students enrolled in a course when more than 85% of the students enrolled in the course are having all or part of their tuition, fees, or other charges paid to or for them by the school or VA

Reporting-Statement of Assurance List each program approved for VA education benefits with currently enrolled VA Students. All concentrations (may also be identified by school as emphasis; specializations; etc.) must be listed and computed separately. If “Undeclared” is listed, those students counted within that program may have only taken general education coursework. Any undeclared student who has taken courses associated with a specific major’s curriculum must be calculated within that program, even if student has not officially declared that major.

Reporting-Request for 35% Wavier When 35 percent or less of a school’s total enrollment receive VA benefits, the school and each branch with separate administrative capability may certify to that effect and receive a waiver of periodic reporting of the percentage of VA students enrolled in each program. The school must count all students receiving VA benefits on the VA side of the ratio. The certification is required only once. The waiver will remain in effect unless the school’s percentage of VA students rises above 35 percent.

Annual Reporting Fee The Annual Reporting Fee, authorized by U.S.C. §3684(c), is paid in lieu of any other compensation or reimbursement for reports or certifications that the school is required to submit to VA by law or regulation. The payment is intended to support the work of your institution’s office of Veterans Affairs and the Certifying Official. Public Law (PL) 111-377 requires that the ARF payment be used solely for the processing of enrollment certifications and changes to enrollment certifications, or for supporting programs for Veterans at your school.

Compliance Survey A compliance survey is periodically conducted for the following reasons: To ensure that VA payments to veterans ,eligible dependents enrolled in the training programs, and facilities are based upon proper and correct enrollment information furnished by the facility. (Is what you told us what the student did and costs.) Assist school officials and students in understanding the requirements of the law in order to prevent deficiencies. The information and data reviewed during the surveys includes, but is not limited to; prior credit evaluations, written agreements between the student and the facility, copies of the application, enrollment certifications, and copies of the progress reports. The tuition and fee information is also reviewed to ensure VA recipients are not charged increased rates. Advertising materials are reviewed to ensure no erroneous, misleading, or deceptive information is conveyed to the students. 85/15 calculations for violations….etc.

GI Bill ® Trademark The trademark symbol ‘‘®’’ should be placed at the upper right corner of the trademarked phrase in the most prominent place at first usage; such as the title of a brochure, form, or the very top of a Web page and the following trademark attribution notice must be prominently visible: ‘‘GI Bill® is a registered trademark of the U.S. Department of Veterans Affairs (VA). Authorized third-parties may use the registered trademark ‘‘GI Bill’’ in print, electronic, radio, digital, or other media as established by the terms of use. Key Strokes Alt 0174 ®

GI Bill ® Trademark Rules 1.The GI Bill trademark is not to be incorporated or included in company or product names, trademarks, logos or internet domain names. 2.The term ‘‘GI Bill®’’ is to be used solely to promote official VA benefit programs and services and must include the proper trademark symbol. 3.Use of the trademark attribution notice, indicating that the mark and all associated services belong to VA, is required and shall be taken as evidence that use of the mark is in good faith. 4.No entity shall use the GI Bill trademark in any manner that directly or indirectly implies a relationship, affiliation, or association with VA that does not exist. 5.Disparagement or misrepresentations of VA services through use of the mark, or by the use of confusingly similar wording, are strictly prohibited.

GI Bill Web Page http://www.gibill.va.gov/ SCO HB ELR Webinar Yellow Ribbon RNW Updates and Announcements

WEAMS Public http://inquiry.vba.va.gov/weamspub/buildSearchInstitutionCriteria.do Facility Information SCO MHA Rate Approved Programs both IHL and NCD

Current Stuff Post-9/11 GI Bill Rate Increase for August 2017 As you may know, the maximum amounts for tuition and fees under the Post-9/11 GI Bill change every academic year. For academic year 2017-2018, the maximum annual reimbursement for those attending a private or foreign school increased from $21,970.46 to $22,805.34. Additionally, the monthly housing allowance for those taking online training exclusively (no classroom instruction) increased to $840.50 per month. These increases are effective August 1, 2017 - July 31, 2018. Remember: while BAH rates for DoD personnel are effective in January, GI Bill beneficiaries will not see the change in MHA until Sept (for terms that started on or after Aug 1).

Current Stuff Army Reservists and GI Bill Eligibility Update The Department of the Army recently announced that they are now counting Active Duty Training (ADT), Active Duty Special Work (ADSW), and Active Duty Operational Support-Reserve Component (ADOS-RC) performed under section 12301(d) of title 10, United States Code, after September 10, 2001 as qualifying service for the Post-9/11 GI Bill. As a result, certain individuals may gain eligibility for Post-9/11 GI Bill benefits, be eligible to receive additional benefits as a result of a higher eligibility level (%), or establish eligibility for Transfer of Education Benefits (TEB). Those impacted will not need to reapply with VA for benefits. Corrections to service should be automatically transferred to VA and reviewed when beneficiary enrollments and/or applications are submitted for processing.

VONAPP "VONAPP“ our online education benefit application is officially retired. VONAPP was a fillable online VA form. We now have a user interface that guides you through the application process, much like tax preparation software does.

Harry W. Colmery Educational Assistance Act Harry W. Colmery Educational Assistance Act of 2017, aka the Forever GI Bill The Forever GI Bill focuses on enhancing the Post-9/11 GI Bill for service members, Veterans, and dependents. The Forever GI Bill (FGIB) ranges from technical fixes to new innovative programs to expanding benefits. Since the passing of the Harry W. Colmery Educational Assistance Act of 2017, otherwise known as the Forever GI Bill, Department of Veterans Affairs (VA) has taken action to successfully implement each of its 34 provisions. Actions taken vary from provision to provision.

Harry W. Colmery Educational Assistance Act Implementation of the Forever GI Bill is segmented into three implementation periods: Date of Enactment (13 provisions); (date signed into law) Effective January – August 2018 (18 provisions); and Effective October 2018 and Beyond (3 provisions).

Update SCO Handbook Revision Release of the Revised School Certifying Official (SCO) Handbook (01/16/2018) Education Service is pleased to announce the release of the updated School Certifying Official Handbook. The Handbook has been revised to include additional information and updates suggested by School Certifying Officials through their Education Liaison Representatives. A list of revisions can be found on page 8 of the handbook, which can be accessed and/or printed from the School Training and Information Resources page of the GI Bill website.

SCO Handbook Revisions 2018

Questions?