1. End of Term Reporting
June 2018

2. Topics Non-Punitive End of Term Incomplete or "I" Grades
Graduation and End of Term or Course
Earned ‘F’ Grades, to report, or not to report?
Do you have an enforceable attendance policy?
Enforcing Standards of Academic Progress and VA reporting requirements
Repeat classes, can you report?
What about Pass/Fail courses?

3. Tools of the SCO trade
Basic information, and reporting requirements about these end of term topics are covered in the SCO Handbook. Information covered in this presentation can be found on page

4. Non-Punitive Grades Assigned at the End of Term
A non-punitive grade is a grade that does not count as earned credit, and is not considered in progress standards for graduation. An example of a non-punitive grade is a “W” or “NP”. VA does not pay for non-punitive grades. If a student completes the term and receives non-punitive grades, the non-punitive grades must be reported to VA, using the last date of the course as the LDA/EFF date. VA ONCE should automatically populate this field. If a course was certified as a remedial course, do not report if an end of term non-punitive grade was earned.
At the end of a course, you earn a grade, punitive, or non-punitive. At your school, and at the VA, a non-punitive grade is one that does not count as earned credit, and not calculated in the student’s GPA, or towards progress standards. VA does not pay for non-punitive grades.
A bit later in the presentation, we will cover repeat grades, and how NP grades should be treated in repeat course situations.

5. Reporting a Non-Punitive Grades Assigned at the End of Term REDUCTION
With the appropriate term selected in VA-ONCE, choose “Adjust”.
The reason “Student Completed Term But Non-Punitive Grades Assigned For One Or More Courses” should be selected, and the credit load adjusted appropriately.
If a student certified 12 credits receives a non-punitive grade for a 3 credit class, report the non-punitive grade as an adjustment from 12 to 9 credits hours.
If a change in credit is certified for Chapter 33 the corresponding change in tuition, fees, and Yellow Ribbon for the remaining credit must also be reported.
The LDA/EFF date should automatically populate to the last day of the term, but please ensure its accurate prior to submitting.

6. Reporting a Non-Punitive Grades Assigned at the End of Term TERMINATION
With the appropriate term selected in VA-ONCE, choose “Terminate”.
The reason “Other” should be selected if all credits being terminated are non- punitive.
The reason “Unsat Attendance, Progress, or Conduct may be the appropriate reason if punitive grades were also earned, and the student violated the SAP.
In the remarks, enter the number of credits which were non-punitive
The LDA/EFF date should automatically populate to the last day of the term, but please ensure its accurate prior to submitting.

7. How does VA treat a Non-Punitive End of Term grade?
Since non-punitive grades do not count towards academic progress, VA does not pay for these type of grades
When a non-punitive grade is reported, VA will ask for mitigating circumstances
VA will develop to the claimant upon processing the 1999b
If known to the SCO, this information can be provided in VA ONCE
If mitigating circumstances are not provided, or justifiable, VA will adjust the award to reduce those credits (and charges), effective on the first day of the term

8. Incomplete or "I" Grades by benefit chapter
Chapter 33: All incomplete grades must be reported for Chapter 33 per the rules in the forthcoming slides.
Chapters 30, 32, 35, 1606, and 1607: The reporting requirements are the same as Chapter 33 if training time is affected by reducing the credits. If the training time isn’t affected, an incomplete grade doesn’t need to be reported.
Example: A student takes 15 credit hours, completes 12 credit hours, and receives 3 credit hours incomplete. Training time isn’t affected because the incomplete doesn’t change the student’s full-time training time.

9. Incomplete or "I" Grades
There are 2 types of “I” (incomplete) grade policies:
Some institutions allow the assignment of an "I" grade on a provisional basis only. These institutions require a student to remove the "I" grade within a specified time (e.g., by the end of the term following the term for which the "I" grade was assigned).
If the student does not replace the "I" grade within the prescribed time period, a punitive failing grade will be assigned and recorded in the student's academic record. This does not have to be reported to the VA.
Results in VA paying for the punitive grade
Institutions that have and enforce such a policy, and prescribe a maximum time period for grade replacement of less than one year, are not required to report the assignment of an "I" grade as an NP grade.

10. Incomplete or "I" Grades
Grading policy permits an "I" grade (incomplete) be replaced with a non-punitive (NP) grade, or which allows a NP "I" grade to remain in a student's record indefinitely. In such cases the school must report the incomplete grade as non-punitive at the time the grades are assigned.
If it is resolved into a punitive grade (passing or failing) within one year of the date it was originally assigned, the school should report the change to VA. Such reports should clearly indicate that the change in enrollment status being reported is the replacement of an "I" grade previously reported by adding a remark to the certification.
If at the end of the 1-year control period no report has been received from the institution to indicate that the "I" grade has been replaced, the VA will assume that the "I" grade has not been changed.
Results in VA taking adjudicative action, and treating the “I” grade as a non-punitive

11. Reporting an Incomplete Non-Punitive Grade
Same principles apply as if you were reporting a Non-Punitive End of Term grade (“Adjust or “Terminate”).
Enter a remark to indicate a non-punitive “I” (incomplete) grade was assigned
This prompts the VA to “diary” the claim for 1-year
If a punitive grade is later earned, you would adjust the credits back, and add a remark about replacing the “I” grade.
The LDA/EFF date should automatically populate to the last day of the term, but please ensure its accurate prior to submitting. The affects on a student’s VA benefits with an “I” grade, is the same as the NON-PUNITIVE.

12. Graduation
Reporting graduation of Chapter 33 recipients is required, but why?
Executive Order of April 27, 2012: Establishing Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members
Implementation of the Principles of Excellence ordered VA, DoD, and DoED to develop outcome measures allowing students to make comparisons across Federal educational programs, across institutions, and types of institutions
VA determined using VA-ONCE to gather this information satisfied the Executive Order’s request to rely on existing administrative data to minimize the reporting burden on institutions

13. Graduation or End of Term or Course Reporting
Schools are required to report graduation or program completion to VA using the VA-ONCE Terminate option
Student graduates from a degree program (AA, BA, MA) “Graduation” should be selected as the termination reason
Student completes a Non-College Degree program (technical diploma, certificate program) “End of Term or Course” should be selected as the termination reason
If a student has multiple enrollment certifications for the same term, the enrollment period with the LATEST end date should be used to report the information
Enrollments submitted to VA
01/13/ /15/2017 ← This is the latest course date and should be used to report graduation
01/13/ /10/2017
03/10/ /12/2017

14. Reporting Graduation or End of Term or Course
The LDA/EFF Date will be pre-populated to reflect the end date of the selected enrollment

15. Earned ‘F’ Grades: To report, or not to report?
When a Veteran or eligible person interrupts or terminates their training, changes their enrollment (voluntary or involuntary reductions or terminations), violates the established policies for attendance, conduct or progress, or for corrections to information previously certified in error, these changes must be reported to VA. What if they earn a punitive ‘F’ grade during this period?

16. Earned ‘F’ Grades: To report, or not to report?
Question: If a student completes a period of enrollment with a failing punitive grade (i.e. an F) assigned, does the school need to report the last date of attendance during that enrollment period? Answer: No. The last date of attendance during a period of enrollment does not need to be reported if a student completes the enrollment period with a punitive grade and does not violate the school’s standards of conduct, progress, or attendance during that term. Question: Are schools required to report any changes in attendance, or only those that violate the schools attendance policy? Answer: 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 without delay. 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.

17. Earned ‘F’ Grades: To report, or not to report?
Question:  But the SCO Handbook states, “If a student completes the term with all “F” and/or non-punitive grades, then determine and report the actual last date of attendance for each course and, if required, terminate the student for unsatisfactory progress.” (page 73) Doesn’t this say I have to report a last day of attendance if they earn ALL “F” grades?
Answer: Yes, IF you have an enforceable attendance policy. If you do not have an attendance policy, you will likely have to report them as unsatisfactory, earned on the last day of the course.
Question: Has this always been the rule?
Answer: No. The VA released an advisory November 15, 2013 to help clarify VA’s interpretation of 38 CFR and 38 CFR
Embedded Advisory dated November 15, 2013.

18. Example of an enforceable attendance policy
Faculty are required to keep accurate attendance records which are submitted to the student records. The College makes attendance records available to supporting agencies and prospective employers. Students must maintain regular attendance and be in satisfactory academic standing to remain eligible for financial aid. A. First Week Attendance: Students are expected to meet attendance requirements in their courses on or before the seventh (7th) day of the start of a term. Students who have not met the attendance requirement in at least one scheduled College course within seven days of the start of a term may be administratively withdrawn from the College. B. Course Attendance: If a student has not been in attendance in a course within 14 days of their last date of attendance in that course, he or she may be administratively withdrawn from the course. If the student has not been in attendance in any courses within 14 days of their last day of attendance, he or she may be administratively withdrawn from the College. Upon withdrawal, a student’s financial aid eligibility will be adjusted according to the Institution’s refund policy as described in the College Catalog and will be assigned grades according to the College Drop/Add Class Policy.

19. Example of attendance policy which is NOT enforceable
It is expected that every student will be present at all classes. Students are required to be present at the beginning of the semester/term and to remain until the work of the semester/term is completed (which includes final examinations). Note that any excused or unexcused absences may have a negative impact on a student's final grade in a course. Because courses are designed and conducted in diverse ways, faculty and instructors should inform students in writing at the beginning of each course if there are specific expectations for attendance and/or participation, including whether any component of the grade will be based on such attendance or participation. Students should be mindful of class attendance policies for each of their classes and make sure they completely understand the ramifications of missing classes (either excused or unexcused).

20. Standards of Academic Progress (SAP)
All schools must maintain progress records (academic transcript, for example) that clearly illustrate students’ progress towards the completion of their program. School officials are responsible for enforcing their established standards of progress.
Both accredited and non-accredited schools are required by law to have and to enforce standards of progress and conduct in order for their programs to be approved for VA benefits.
When a student has failed to maintain prescribed standards of progress, VA must be informed promptly so that benefit payments can be discontinued in accordance with the law.

21. SAP Failure: Placed on Academic Probation
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”. Notifications should include the student’s name and file number in the text. 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.
You may develop your own spreadsheet for reporting. This is an example of the required information when reporting multiple students.
All notifications must include “Academic Probation” in the subject line.

22. SAP Failure: Placed on Academic Probation
Students should be advised of any counseling services available to them at the school in order to resolve academic or other problems and to establish a meaningful plan for successful completion of their education or training.
Schools and training establishments are asked to remind students of the counseling services (page 78 of the SCO Handbook) and tutorial assistance benefits (page 89 of the SCO Handbook) available through VA.
Schools that provide a period of academic probation for an indefinite period of time may not continue to certify a Veteran or eligible person, if they remains in a probationary status.

23. SAP Failure: Placed on Academic Probation
The student will receive a letter from VA when they are reported to be on Academic Probation:

24. SAP Failure: Placed on Academic Suspension
The law requires that educational assistance benefits to Veterans and other eligible persons be discontinued when the student ceases to make satisfactory progress toward completion of his or her training objective. 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.

25. SAP Failure: Placed on Academic Suspension
VA-ONCE will insert the end date of the term as the default “LDA/EFF Date”. You can change the date if the student was deemed unsatisfactory prior to the term completing. The VA assumes the student earned punitive grades when “Unsat…” is reported.

26. SAP Failure: Placed on Academic Suspension
When submitting the UNSAT termination, and subsequent terms have been certified, it will prompt you to answer a pop-up. Please read if CAREFULLY! VA ONCE tries to trick you!
If the following terms remain as previously certified, click “OK”. To automatically terminate the terms that begin on or after the termination date, click “Cancel”. … If you’re not reading closely, you may think the opposite result of clicking OK or Cancel…please be diligent in clicking OK/Cancel.
If prior to you reporting the student was UNSAT, 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.

27. SAP Failure: Placed on Academic Suspension
The student will receive a suspension letter:

28. How do you restart benefits if the student is readmitted?
After VA has discontinued education benefits because of a student’s unsatisfactory status, education benefits may be resumed under the following conditions:
If the student again attends the same school and in the same program of education or training, resume payments without further development of the student's attendance, progress, or conduct and suitability of his or her program.  The school's certification of the student's enrollment is sufficient for resuming benefits. If an institution readmits a student after being found unsatisfactory, it is presumed the school has established there is a reasonable likelihood the student will be able to maintain satisfactory status in the future.
If the student enrolls or plans to enroll in a different school or a different program, VA must find that the cause of the unsatisfactory attendance, progress, or conduct has been removed and that the program of education or training to be pursued is suitable to the student's aptitudes, interests, and abilities.  The student must request that benefits be resumed preferably by submitting VA Form (VA Form 22‑5495 if chapter 35 student).

29. If a student has to repeat a class, can we report?
Courses that are successfully completed may not be certified 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 class may be repeated and certified to VA again.
There is no limit to the number of attempts which may be certified, if the repeat is justified. There is no requirement to report if a previously assigned punitive grade was changed to a non-punitive grade when a course is repeated.
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. If a “D” is acceptable to fulfill the graduation requirement, the course may not be recertified.

30. What about pass/fail courses, can we certify?
Courses which satisfy requirements outlined by the curriculum guide or graduation evaluation can be certified for VA purposes, regardless of the Pass/Fail, or Satisfactory/Unsatisfactory grading structure.
Example: A student must satisfy the physical fitness elective of their liberal arts college in order to earn a bachelor’s degree. The student chooses to enroll in a 1-credit Basketball course, which is graded as Satisfactory or Unsatisfactory.
This course may be certified. The student may earn an either a satisfactory, or unsatisfactory grade from the instructor.
As long as the student did not violate a school policy to earn the unsatisfactory grade (like attendance, conduct, or progress), there is nothing to report to the VA.

31. Overview of what we learned
Non-Punitive End of Term
Incomplete or "I" Grades
Graduation and End of Term or Course
Earned ‘F’ Grades, to report, or not to report?
Do you have an enforceable attendance policy?
Enforcing Standards of Academic Progress and VA reporting requirements
Repeat classes, can you report?
What about Pass/Fail courses?

32. Questions