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2017 NCACVA ALL SCHOOLS Ihl and ncd approvals dr. joseph w. Wescott ii, NC SAA, Executive Director (september 2017)

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Presentation on theme: "2017 NCACVA ALL SCHOOLS Ihl and ncd approvals dr. joseph w. Wescott ii, NC SAA, Executive Director (september 2017)"— Presentation transcript:

1 2017 NCACVA ALL SCHOOLS Ihl and ncd approvals dr. joseph w. Wescott ii, NC SAA, Executive Director (september 2017)

2 background “The student is eligible for the GI BILL®, so why does my school have to deal with the SAA?” GI Bill® benefits may be used only in programs that are approved as meeting certain legal requirements The SAA has legal responsibility to approve programs VA has approval authority under certain limited circumstances

3 background (cont.) “But my programs are deemed approved!”
Public and not-for-profit IHL degree programs are deemed approved, if…. (more on this later) Registered apprenticeships and flight programs are deemed approved, if…. For-profit IHL degree programs are not deemed approved Non-degree programs are not deemed approved Your policies and procedures are not deemed approved Bottom Line: Everyone must obtain an Approval. Form and procedures will vary from State to State.

4 AGENDA LEGAL FOUNDATION APPROVALS – Programs not Deemed Approved
GI Bill® History and the Players U.S. Code & Code of Federal Regulations APPROVALS – Programs not Deemed Approved School Actions – The Application State Approving Agency Actions – The Review and Approval APPROVALS – Institutions with Deemed Approved Programs RE-APPROVALS SAA OVERSIGHT Risk-Based Reviews, Compliance, Technical Assistance Suspensions, Disapprovals WHAT’S NEW OR ON THE HORIZON

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

6 VA Central Office (VACO) Regional Processing Office (RPO)
The Players 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)

7 And of course -- THE VA-ELIGIBLE STUDENTS
The Players (cont.) 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!

8 Legal Foundation (cont.)
Public Laws Congressional bills that become law (signed by the President or automatically after 10 days w/o President) U.S. Code Compilation and codification of the provisions of the Public Laws into federal statutes Title 38: Veterans Benefits Chapter 36: Administration of Educational Benefits Code of Federal Regulations Compilation of federal agency regulations implementing the federal statutes Title 38: Pensions, Bonuses, and Veterans’ Relief Part 21: Vocational Rehabilitation and Education

9 Legal Foundation (cont.)
38 U.S.Code §3671 Authorizes governor or state legislature to create or designate a department or agency as the “State approving agency” for purposes of the GI Bill chapters In North Carolina, the North Carolina State Approving Agency has been so designated NC SAA’s Mission: To ensure quality instruction, appropriate administration, and fair and equitable practices for every veteran (and eligible person) who enters a NC SAA-approved educational or apprenticeship/OJT program. We validate and approve educational and apprenticeship/OJT programs to be pursued by veterans and eligible persons We oversee North Carolina’s educational institutions & apprenticeship/ OJT employers, and ensure compliance with federal and state guidelines We ensure the interests and prerogatives of the State are preserved in both processes

10 legal foundation (cont.)
38 U.S.C. §3672 – the basic authority for all approvals “Such other…policies as the [SAA] may adopt.”

11 legal foundation (cont.)
38 U.S.C. §3672 – Deemed approved programs Deemed Approved Public/Not-for-Profit IHL Accredited Degree Programs FAA-approved Flight Training Registered Apprenticeships Secondary School Diploma Programs Government Licensure

12 legal foundation (cont.)
38 U.S.C. §3675 – Approval of Accredited Courses For approving accredited programs at for-profit IHLs And other accredited degree programs that do not meet deemed approved requirements And accredited NCD programs at public & not-for-profit IHLs Sets out school catalog & application requirements Sets out SAA approval requirements Incorporates 38 USC 3676(c)(16) : Implemented in 38 CFR “Such additional criteria as may be deemed necessary by the State approving agency….” Therefore, application and some approval requirements will vary from State to State

13 Legal Foundation (cont.)
38 U.S.C. §3676 – Approval of Non-Accredited Courses Covers all non-accredited non-college degree (NCD) programs Also, in North Carolina: for approving all stand-alone NCD programs Sets out school’s catalog & application requirements Sets out SAA’s approval requirements Includes subsection (c)(16): Implemented in 38 CFR “Such additional criteria as may be deemed necessary by the State approving agency….” Therefore, application and some approval requirements will vary from State to State

14 legal foundation (cont.)
38 U.S.C. §3678 – Notice of Approval Approvals must be in writing “…other fair and reasonable provisions….” Written notice provided to the institution, with a copy to the VA (ELR) VA’s copy includes a copy of the catalog or bulletin Implemented in 38 CFR

15 legal foundation (cont.)
38 U.S.C. §3679 – Disapproval of Courses Disapprovals must be in writing New authority: 18-month grace period on approvals of programs whose accreditors lose U.S. Dept of Education recognition Disapproval authority is implemented in 38 CFR

16 AGENDA LEGAL FOUNDATION APPROVALS – Programs not Deemed Approved
GI Bill® History and the Players U.S. Code & Code of Federal Regulations APPROVALS – Programs not Deemed Approved School Actions – The Application State Approving Agency Actions – The Review and Approval APPROVALS – Institutions with Deemed Approved Programs RE-APPROVALS SAA OVERSIGHT Risk-Based Reviews, Compliance, Technical Assistance Suspensions, Disapprovals WHAT’S NEW OR ON THE HORIZON

17 approvals – Ihl & NCD programs not deemed approved
School Actions – The Application Schools must complete an application (IHLs and NCDs) Statutes and implementing regulations require certain information to be submitted for approval Applications will vary from State to State Will contain instructions for completion: will specify acceptable format(s), authorized signature(s), delivery options; generally, if you follow the instructions, the process will go smoothly Will include State-specific forms/requirements as well as VA forms/requirements, including requests for: Administrative information: e.g., organization; enrollment agreement; student handbook; floor plans*; lease/deed*; insurance* Programs (curricula and credit/clock hours) to be approved Programs or courses offered through contracts Examples of advertising *initial approvals only

18 approvals – Ihl & NCD programs not deemed approved (cont.)
School Actions – Required Additional Submissions Certified copies of the most recent catalog or bulletin that include: (IHLs and NCDs) Catalog/bulletin identifying data, names of school, officials, faculty (NCDs) Graduation requirements (IHLs) SAP policies, including grading system, probationary period (if applicable) & dismissal (IHLs and NCDs) Conduct policies, including conditions for dismissal (IHLs and NCDs) Evidence that adequate attendance records are maintained (NCDs) Attendance standards, if in place and are enforced (IHLs)

19 approvals – Ihl & NCD programs not deemed approved (cont.)
Catalog/bulletin requirements, cont. Academic/term calendar (NCDs) Enrollment policy/requirements (NCDs) Attendance policies (absences, tardiness, unsatisfactory attendance) (NCDs) Tuition and fees (IHLs/NCDs) Refund policy (NCDs) Description of available space, facilities & equipment (NCDs) Course outline, including time/clock hours spent on subjects (NCDs) Policy re granting transfer credit for previous education and training (NCDs) NC SAA requires IHLs to provide most of this information, too, as “additional criteria”

20 approvals – Ihl & NCD programs not deemed approved (cont.)
School application also must show: Maintenance of adequate records of progress, grades, and enforcement of satisfactory standards (IHLs and NCDs) Maintenance of written record of previous education and training, & transfer credit granted (IHLs and NCDs) Official transcripts; proof of high school/equivalent/ability to benefit Quality, content, and length of programs, curricula, & instruction (IHLs and NCDs) Adequate space, equipment, instructional material, & instructors to provide training of good quality (IHLs and NCDs) Qualifications of directors, administrators, & instructors (IHLs and NCDs)

21 approvals – Ihl & NCD programs not deemed approved (cont.)
School application also must show (continued): Students are provided course outline, T&F charges, attendance & grading policies, rules of operation & conduct (NCDs) Students receive a certificate of completion (NCDs) School complies with local, city, county, state, federal regulations (e.g., fire and sanitation codes) (NCDs) School is financially sound and capable* (NCDs) School does not utilize erroneous or misleading advertising (NCDs) SAA may require IHLs to provide this information, too, as “additional criteria” *initial approvals only

22 approvals – Ihl & NCD programs not deemed approved (cont.)
School application also must show (continued): School does not exceed enrollment limitations SAA establishes (NCDs) School’s administrators, directors, owners, & instructors are of good reputation & character (NCDs) School provides a pro rata refund based on the length of the completed portion of the total course (NCDs) “Such additional criteria as may be deemed necessary” by the SAA / “Such other fair and reasonable provisions as considered necessary” by the SAA (IHLs and NCDs) This is the authority for SAA to require IHLs to provide the same types of information / documentation as required of NCD programs

23 NC SAA Initial Approval Application: IHL

24 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – The Review and Approval SAA will review the application for completeness All questions answered?? Appropriate signatures?? SAA will ensure that all required supplemental documentation is present, including If applicable, documentation that the school or organization has been in operation for at least two years* Copies of the most current accreditation letter, state licensure to operate, teach-out bond, if applicable Two certified true and correct copies of the catalog/bulletin VA Forms: – Designation of School Certifying Official (when necessary) – Conflicting Interests Certification (Proprietary Schools Only)* – Statement of Assurance of Compliance with Equal Opportunity Laws* *initial approvals only

25 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review What is the school’s period of operation? NCD programs offered by proprietary institutions (profit or not-for-profit) are subject to the two-year rule. May not be approved when: Offered at an institution that is not approved and has been operating for less than two years Offered at a branch or extension that has been operating for less than two years Exemption for schools with DoD contract & on military base Other actions that may trigger two-year waiting requirement: Change of ownership Unless faculty, student body, and courses remain “substantially the same” Change of address Unless move is within normal commuting distance of original location (i.e., no more than 55 miles) and substantially the same faculty, student body, and courses

26 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Is the school accredited? SAA will check U.S. Dept of Education’s website to determine whether accreditor is nationally recognized Also must determine whether the programs are accredited What is the school’s organization? Names & titles of owners or governing body / administrators Type of institution* Public, proprietary Sole proprietor, partnership, corporation Profit, not-for-profit Is the school financially sound?* Non-accredited institutions must provide documentary proof E.g., independent audit report; proof of insurance SAA may require accredited institutions to provide such proof *initial approvals only

27 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Are the school’s standards of progress adequate? (IHLs and NCDs) 38 CFR : The VA will discontinue benefit payments for students who fail to maintain satisfactory academic progress, attendance, or conduct Academic progress: Does the school’s policy set out: The grading system, including minimum grades considered satisfactory and acceptable evaluation periods? I.e., Will the school be able to determine in a timely manner the point when the student’s progress became unsatisfactory? Conditions for interruption for unsatisfactory grades or progress? The probationary period, if any? Conditions for re-entrance for those students dismissed for unsatisfactory progress? A policy regarding progress records kept by the school & given to the student? Conduct: Does the school’s policy set out: Description of conduct considered unacceptable? Conditions for interruption for unsatisfactory conduct? Conditions for re-entrance for those students dismissed for unsat conduct?

28 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Are the school’s standards of progress adequate? (cont.) Attendance: Non-accredited programs are required to have an attendance policy Does the policy address absences (e.g., total allowable), leaves of absence, class cuts, makeup work, tardiness, and interruptions (i.e., termination) for unsatisfactory attendance? Are there acceptable intervals at which attendance is evaluated? I.e., Will the school be able to determine in a timely manner the point when the student’s attendance becomes unsatisfactory? Accredited Institutions: Not required to have an attendance policy, but if you do, and if it is enforced, the attendance standards must be reviewed by the SAA for approval (If your institution does not have an attendance policy, you, nevertheless, must monitor VA student attendance in order to report LDA!)

29 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. What are the school’s advertising and enrollment practices? Cannot be “erroneous, deceptive, or misleading by actual statement, omission, or intimation” Proprietary schools must not provide any “commission, bonus, or other incentive payment based directly or indirectly on success in securing enrollments or financial aid to any persons or entities engaged in any student recruiting or admission activities, or in making decisions regarding the award of student financial assistance.” (P.L ; 38 USC 3696(d)) Are programs/courses provided under contract? If yes, the provider of the training, as well as the school, must receive approval from the SAA Flight schools also must obtain approval from FAA

30 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Does the application include branches or extensions? All locations in the State where approved programs will be taught must be listed in an approval “Main campus”: the location where the primary teaching facilities are located; usually houses the primary office of the school’s CEO Branch campus: geographically apart from and operationally independent of the main campus Extension: geographically apart from but operationally dependent on main campus (also referred to as “additional facilities”) Branch campuses with separate administrative capability may be separately approved (with or without separate facility code) “Administrative capability”: ability to maintain all records & accounts Assignment of a separate facility code will require on-site certifying official, unless ELR approves school for centralized certification For schools with multiple campuses/locations in a State, at least one of the locations in that State must have administrative capability

31 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Are the programs approvable? SAAs may not approve certain courses, e.g., Bartending and personality development programs Sales or sales management courses that do not provide specialized training within a specific vocational field Avocational and recreational programs Photography or entertainment programs (unless clearly part of a program leading to an educational objective; e.g., “B.A. in Photography” is approvable) Self-improvement programs Non-accredited medical or dental internships Independent study courses offered by non-accredited institution or NCD-only institution (new exception for certain accredited NCD CTE & vocational programs - more later)

32 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Does the school meet enrollment limitations? Is the number of students that the program can support restricted by the available facilities, equipment, or instructors? Limitations may be imposed by State law or regulation and included in the approval as “other reasonable criteria” E.g., Minimum student-teacher ratio, minimum classroom size After initial approval, limitations imposed by the VA’s rule may require the ELR to suspend the school’s approval: The number of students receiving VA educational benefits and/or financial support from the school cannot exceed 85% The ratio applies to individual programs Waiver/exemption possible under limited circumstances (e.g., programs on military bases pursuant to contract with DoD)

33 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Does the school’s catalog/bulletin contain the information required by law for approval? I.e., all the items previously discussed, e.g.: Certified as true and correct, with school name, volume, date of publication, term dates/calendar Enrollment/admissions policies Adequate space, facilities, equipment Qualifications of instructors; reputation, character, and qualifications of owners, directors and administrators Policies re SAP, attendance, conduct, transfer credit, T&F, refunds, grading, suspension & dismissal, progress records, graduation requirements Program details: curricula, credit/clock hours

34 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Does the school’s catalog/bulletin contain the information required by law for approval? (cont.) If required information is not in the catalog, the SAA will require the school to provide the information in a separate document The document may be one prepared by the school The document may be a form required by the SAA (approval addendum)

35 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. The SAA also will review the catalog for special topics that must be addressed specifically in the approval, e.g.: Cooperative Courses (38 CFR ) Catalog must show that the training in the business establishment will be in a “real and substantial sense and will supplement” the school’s training; & that the school will exercise supervision and control over the student’s activities at the business Independent Study (38 CFR ) Approvable if at an accredited IHL and leads to a standard college degree or certificate; catalog must describe the conditions and requirements New exception for certain accredited CTE and vocational programs (more later) Current VA policy: independent study includes distance learning & online courses Practical Training (38 CFR ) Medical and dental internships or specialty courses, nursing courses, professional training courses, and other off-campus practical training courses must meet certain additional requirements for approval Remedial/Deficiency Courses (38 CFR ) May not be taken through independent study (including distance learning)

36 approvals – Ihl & NCD programs not deemed approved (cont.)
SAA Actions – Detailed Review, cont. Initial Applications, only After reviewing the application, the SAA will conduct an on- site inspection of the school Purpose: To confirm the correctness of the information presented in the application If deficiencies are found, the school will be notified and given an opportunity to correct them A written inspection report will be prepared and provided to the school and to the VA (ELR) The report will accompany or precede the SAA’s notice of approval or notice of disapproval SAA provides written notice of approval (or disapproval)

37 Sample Notice of Approval
Dates, including effective date Catalog identifying data and list of addenda and supplements that are approved as part of the catalog Summary of items covered in the approval document Legal authority is cited Signed by authorized SAA official Detailed approval document is attached

38 Sample Notice of Approval (Detailed Approval Document) – cont.
Identifying data, effective date Approval of special topics List of approved degree programs or page ranges; or determination regarding deemed approved programs List of approved NCD programs or page ranges Approved remedial / deficiency courses

39 Sample Notice of Approval – cont.
Listing of other special topics Listing of unapproved programs or policies Approval of academic calendar and T&F

40 Sample Notice of Approval – cont.
Listing of approved branches Listing of additional facilities with approved programs Listing of specific requirements with which the institution must comply, e.g., obtain & evaluate prior transcripts; distance learning restrictions; ROTC approval requirements; attendance and progress requirements; SAA “additional criteria”

41 AGENDA LEGAL FOUNDATION APPROVALS – Programs not Deemed Approved
GI Bill® History and the Players U.S. Code & Code of Federal Regulations APPROVALS – Programs not Deemed Approved School Actions – The Application State Approving Agency Actions – The Review and Approval APPROVALS – Institutions with Deemed Approved Programs RE-APPROVALS SAA OVERSIGHT Risk-Based Reviews, Compliance, Technical Assistance Suspensions, Disapprovals WHAT’S NEW OR ON THE HORIZON

42 approval - Ihls with deemed approved programs
As previously mentioned, per 38 USC §3672: An accredited degree program will be considered deemed approved for the GI Bill® if the SAA determines that it meets certain requirements (“subject to…”) 38 U.S.C. §3675 (b)(1) – maintain adequate progress records; enforce satisfactory standards of progress and conduct 38 U.S.C. §3675 (b)(2) – maintain written record of prior education & training that indicates appropriate credit is granted and training period shortened proportionately 38 U.S.C. §3680A – programs are approvable; 85/15 ratio is met; 2-year rule is met (NCDs at proprietary schools); contracted programs are properly approved 38 U.S.C. §3684 – reports to the VA are made “without delay” (SCO Handbook— make reports (e.g., certifications) within 30 days of event triggering the report) 38 U.S.C. §3696 – advertising, sales, and enrollment practices are not erroneous, deceptive or misleading; advertising issued over the preceding 12- months is available to VA and SAA for inspection; commissions, bonuses, etc., for recruiting or admissions personnel are not contingent on securing enrollments or financial aid for students

43 approval - Ihls with deemed approved programs (cont.)
SAA must determine whether accredited degree programs of public IHLs and not-for-profit IHLs meet the requirements for their programs to be considered “deemed approved” (38 USC §3672) To make the determination, the SAA will need something in writing from the institution: What is required will vary from State to State North Carolina requires a written application, along with two certified copies of the catalog/bulletin, and such additional documentation/information as will enable us to determine that your institution meets the minimum statutory requirements. Initial approvals will complete the “initial application” All others will complete a “re-approval application”

44 approval - Ihls with deemed approved programs (cont.)
Reminder: If you have NCD programs, they are not “deemed approved” The SAA must approve the NCDs you want to be eligible for the GI Bill®, and will need: For accredited NCD programs: The information/ documentation required by §3675, and such other fair and reasonable criteria as the SAA requires For non-accredited NCD programs (e.g., programs in the continuing education department): The information/ documentation required by §3676, and such other fair and reasonable criteria as the SAA requires A written notice of approval will be provided

45 AGENDA LEGAL FOUNDATION APPROVALS – Programs not Deemed Approved
GI Bill® History and the Players U.S. Code & Code of Federal Regulations APPROVALS – Programs not Deemed Approved School Actions – The Application State Approving Agency Actions – The Review and Approval APPROVALS – Institutions with Deemed Approved Programs RE-APPROVALS SAA OVERSIGHT Risk-Based Reviews, Compliance, Technical Assistance Suspensions, Disapprovals WHAT’S NEW OR ON THE HORIZON

46 Therefore: SAA reviews of later catalogs will be necessary
continued approval Periodic re-approval will be necessary for programs approved under §§3675 and 3676 Periodic re-determinations will be necessary for programs deemed approved under §3672 WHY? – Because school policies and/or procedures change periodically Initial approval is based on catalog/bulletin certified as “true and correct in content and policy” Most institutions issue/publish new catalogs or bulletins annually or biennially SAA cannot assume there have been no changes The calendar will have changed (NCDs) The T&F may have changed (IHLs and NCDs) New programs may have been added (IHLs and NCDs) Changes may have been made to the standards of academic progress (IHLs and NCDs) Accreditation or licensure changes; bond lapses Etc. Therefore: SAA reviews of later catalogs will be necessary

47 continued approval (cont.)
Re-approvals (including deemed approved re-determinations) are accomplished IAW the US Code and CFR provisions previously discussed Applications for re-approval generally require less information / documentation than initial applications Process will vary from State to State

48 IHL Re-approval Application (NCD Re-approval Application is Longer)
NC SAA IHL Re-approval Application (NCD Re-approval Application is Longer)

49 AGENDA LEGAL FOUNDATION APPROVALS – Programs not Deemed Approved
GI Bill® History and the Players U.S. Code & Code of Federal Regulations APPROVALS – Programs not Deemed Approved School Actions – The Application State Approving Agency Actions – The Review and Approval APPROVALS – Institutions with Deemed Approved Programs RE-APPROVALS SAA OVERSIGHT Risk-Based Reviews, Compliance, Technical Assistance Suspensions, Disapprovals WHAT’S NEW OR ON THE HORIZON

50 saa oversight After approval, several methods used to help ensure continued compliance with approval standards Risk-based reviews 38 USC §3673(d): VA may utilize SAA for “conducting risk-based surveys and other such oversight purposes” as the VA, in consultation with the SAA, considers appropriate Parameters and procedures for risk-based surveys still being worked out Compliance surveys Fall within the “other such oversight” language of §3673(d) Compliance surveys cover some approval-related matters Technical assistance visits Conducted on an as-needed basis VA-requested visits Findings may affect the approval New catalog reviews and re-approval process Conducted periodically to ensure continued compliance with approval requirements

51 saa oversight (cont.) Methods available to address non-compliance:
Suspension and Disapproval Any approved program that fails to meet statutory requirements shall be immediately disapproved (i.e., withdrawal of approval) (38 USC §3679) Notice of disapproval will be in writing, sent to the school by certified or registered mail, with a return receipt SAA shall notify VA of each program disapproved SAA may suspend an approved program for new enrollments for up to 60 days (38 CFR ) If institution fails to correct the deficiencies within the 60 days, the SAA must “immediately disapprove” Notice to school is provided in writing by certified or registered mail; SAA also must notify the VA

52 Suspension and Disapproval, cont.
saa oversight (cont.) Suspension and Disapproval, cont. What if my school’s programs are deemed approved? Per contract between the VA and SAAs, the SAA will notify the VA of the suspension or withdrawal of the approval of deemed approved programs. And they WILL be suspended or withdrawn!

53 AGENDA LEGAL FOUNDATION APPROVALS – Programs not Deemed Approved
GI Bill® History and the Players U.S. Code & Code of Federal Regulations APPROVALS – Programs not Deemed Approved School Actions – The Application State Approving Agency Actions – The Review and Approval APPROVALS – Institutions with Deemed Approved Programs RE-APPROVALS SAA OVERSIGHT Risk-Based Reviews, Compliance, Technical Assistance Suspensions, Disapprovals WHAT’S NEW OR ON THE HORIZON

54 WHAT’S NEW OR ON THE HORIZON
P.L , Department of Veterans Affairs Expiring Authorities Act of 2016 Became law in September 2016 Contains several provisions; one pertaining to approvals: Section 415: A program that would be subject to disapproval solely because Dept of Education withdrew recognition of the accreditor may continue to be treated as approved for a period of 18 months from the date of withdrawal; VA Secretary must notify affected students (38 USC 3679) P.L , Jeff Miller and Richard Blumenthal Veterans Health Care and Benefits Improvement Act of 2016 Became law in December 2016 Contains several provisions; those pertaining to approvals: Section 408: Clarifies requirement for SAAs (or VA, when acting as an SAA) to determine whether public and not-for-profit IHL degree programs meet requirements for deemed approved status; expands §3675 to include all accredited programs not covered by §3672 (38 USC §§3672 & 3675)

55 WHAT’S NEW OR ON THE HORIZON (cont.)
P.L , cont. Section 409: Unless waived by VA Secretary, accredited and non- accredited programs designed to prepare students for licensure or certification must meet State instructional curriculum licensure/certification requirements (38 USC §§3675 & 3676) Also, programs designed to prepare individuals for employment pursuant to State board or agency standards in occupations that require approval, licensure or certification must meet the board or agency standards Law licensure programs must be accredited by ED-recognized accreditor These licensure/certification programs must be disapproved unless the institution publicly discloses, in a manner the VA Secretary considers to be prominent, any conditions or additional requirements required to obtain the license/certification Section 410: SAA must consult with VA on additional criteria (38 USC §§3675 & 3676)

56 WHAT’S NEW OR ON THE HORIZON (cont.)
P.L , Harry W. Colmery Veterans Educational Assistance Act of 2017 (aka, “The Forever GI Bill”) Became law August 16, 2017 Contains several provisions; those pertaining to approvals: Sec. 109: On a case-by-case basis, for students who continue to be enrolled in a disapproved program, VA may treat the program as approved if the disapproval was i) the result of a law enacted after the date the student enrolled in the program, or ii) the result of, after the student enrolled in the program, the VA prescribed or modified regulations or policies affecting the disapproval, and iii) continued pursuit of the course is in the student’s best interest Sec. 302: Authorizes approval of accredited Perkins Act post-secondary area career and technical education (CTE) certificate programs and accredited Higher Education Act post-secondary vocational certificate programs offered by independent study if the programs meet requirements of employers in the State or local area, provide a recognized credential, and meet applicable licensure or certification requirements of the State

57 WHAT’S NEW OR ON THE HORIZON (cont.)
P.L (cont.) Sec. 305: Authorizes VA to disapprove the programs of covered educational institutions that do not ensure their SCO meets training requirements developed by the VA in consultation with the SAAs “Covered” institution is an “educational institution that has enrolled 20 or more individuals” using the GI Bill (eff. Aug 1, 2018) Sec. 310: Authorizes SAAs to conduct risk-based surveys, in addition to other oversight (such as compliance surveys), as the VA Secretary, in consultation with the SAAs, considers appropriate On the Horizon…

58 What to Know About the New GIBill securing one of our greatest national assets for generations to come Student veterans are among the most successful students in higher education today. Based on research from Student Veterans of America, the National Veteran Education Success Tracker (NVEST), it’s clear that the investment our country is making in the education of veterans has an incredible impact on veterans, their families, and the country. The bill’s passage represents a new era for education for veterans—one where we no longer consider the GI Bill as a “cost of war”, but more powerfully, a right of service. Among the many provisions, the bill achieves the following improvements and expansions of the GI Bill: Ends 15-year limit on GI Bill usage, allowing all veterans who who exited service in 2013 or after go to school anytime; Provides GI Bill eligibility for reservists mobilized under selected reserve orders for preplanned missions in support of the combatant commands or in response to a major disaster or emergency (12304b, 12301h, 12301g); Provides GI Bill eligibility for reservists undergoing medical care; Provides full GI Bill benefits for Purple Heart recipients regardless of length of service; Extends Yellow Ribbon Program benefits to Fry scholarship recipients; Restores used GI Bill benefits to students who experience permanent school closures while enrolled; Increases GI Bill payments by $2,300 per year for veterans with less than 12 months of active service; Creates pilot program for high-technology and computer programming courses; Expands education benefits for veterans pursuing science, technology, engineering and math (STEM) degrees; Increases amount of fees paid to schools for certification of student veteran enrollments; Improves GI Bill information technology system to fully automate claims; Increases monthly amount of educational assistance for survivors and dependents of disabled veterans; Increases funding for state-approving agencies to conduct oversight of schools; and Allows GI Bill use for distance courses in technical and career education institutions.

59 WORKING FOR YOU! Your NC SAA Staff:
Joseph Wescott II, Executive Director Flight, High Schools, L&C, new applications Program Specialists* Elizabeth Kelly On-Military-Base, Truck, Beauty, Barber Jay Fitzgerald Religious Exempt Institutions & Nursing Meghan-Joy Woodall Trade, Business, Hospitals, Massage Jenne Herbst, Program Assistant Eva Nehring, Executive Assistant; Apprenticeship & OJT Liaison *All: Public and Private Universities, Community Colleges, Apprenticeships & OJT

60 Thank You! Any (more) Questions?
ihl and ncd approvals Thank You! Any (more) Questions?


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