WACRAO 2014 WISCONSIN

CERTIFYING OFFICIALWORKSHOP

JUNE 17-18, 2014

GREETINGS

Day 1 – All SCO’s

– Apprenticeship Program – Kathy Wellington

– RPO Updates

– Complaint System

– Communications with VA

– Communications with ELR & SAA

– Student Responsibility

SCO Concerns

• Principles of Excellence• SCO monitoring has increased substantially due to

increased enrollments and certification requirements

• CH33 – 3rd party tuition payments• Institutional debts from CH33 – DMC & TOP

RPO UPDATES

– RPO Updates/Legislative Updates• RPO Education Outreach Section re-organization effective

June 1, 2014

• VA Central Office November 2013 policy on unearned punitive F grades

• RPO automated Chapter 33 processing (LTS) Long Term Solution

• Updated on DEEMED approved institutions

RPO UPDATES

• VA & SAA Compliance survey Updates

• VA Annual Reporting Fees for calendar year 2013

• Paperless enrollments – VAONCE– WI IHL stats – 120/137

– WI NCD stats – 25/42

• Direct Deposit – tuition and fee payments

• VA has issued 29.8 billion dollars in Post 9/11 GI Bill benefit payments to 985,000 individuals since program inception as of September 2013.

RPO UPDATES

– RPO Updates/Legislative Updates• VA Central Office advisory March 28, 2014 Program

withdrawn and benefits continue – Chapter 33

• VA Central Office advisory September 30, 3013 Certifying Sales Taxes as Fees

• VA Central Office policy – CH33 Yellow Ribbon Program IHL contribution – restricted or unrestricted institutional scholarships

• Books considered as fees- If a school charges every student for books required for their program and does NOT allow them to purchase outside that office, they may be include it with tuition and fee charges

RPO UPDATES

– RPO Updates/Legislative UpdatesCH33 Parking Fees –this fee is not specifically excluded by regulation therefore are included as a payable fee as long as all students have to pay this fee to the institution.

VA Central Office advisory April 21, 2014 – CH33 Fees involving lab costs – there are instances when a lab fee is mandatory for all students in a particular course during a particular enrollment period. This is an acceptable fee to certify. However during enrollment periods when the lab fee is waived lab fees are not certified. NOTE: A lab fee does not have to be charged during every term of enrollment in order to be considered mandatory.

RPO UPDATES

– RPO Updates/Legislative Updates• New – May 16, 2014 from VA Central Office

• Effective immediately VA Education Call Center representatives are prohibited from releasing documents (such as Certificates of Eligibility, Award Letters, etc) to veterans and beneficiaries, veterans service organizations, school certifying officials, or other entities based on a telephonic request.

• Written requests which include FAX, RNW, as well as regular mail from authorized individuals may be honored.

RPO UPDATES

– RPO Updates/Legislative Updates• New – May 16, 2014 from VA Central Office

• WHY?

• VA General Counsel has determined that telephonic requests for documents from a claimant’s VA records are not sufficient to meet requirements and are prohibited.

• PER:

– Clarification on Freedom of Information (FOIA) and Privacy Act (PA) Requirements for Telephonic Requests of Documents Related to VA Education Benefits

RPO UPDATES

– The Post-9/11 Veterans Educational Assistance Improvements Act of 2010 (Public Law 111-377) amended section 3322 of title 38, United States Code, by adding subsection (h) which bars duplication of eligibility based on a single event or period of service. Because of this addition, individuals cannot-

– Use the same period (beginning on or after August 1, 2011) of active duty service to establish eligibility for the Post-9/11 GI Bill and chapter 30, chapter 32, chapter 1606, or chapter 1607, or

– Establish eligibility under both the Fry Scholarship provision of the Post-9/11 GI Bill and chapter 35 (DEA) based on a parent’s death (i.e. a single event) in the line of duty on or after August 1, 2011.

GI Bill web site

• Provides information on VA education benefit chapter eligibility and usage

• Identifies approved institutions on gi bill web site• Provides State listing of institutions approved for

YRP• Contains institutional address, name of SCO with

phone number and email• Provides students with researching schools and

provides for on line complaint system

Education Benefit Chapters

• Montgomery GI Bill (MGIB) Chapter 30 – Veterans• Montgomery GI Bill-Selective Reserves Chapter 1606 for Members of

Reserves or National Guard• (REAP) Chapter 1607 – mobilized under DOD Title 10 (called to

active duty) • Dependents Educational Assistance Program Chapter 35 (spouse,

children, surviving spouse• (Public Law 110-181 – affecting Ch 1606/1607) enacted January 28,

2008• Post-9/11 GI Bill (Chapter 33) – veterans & dependents TOE• Fry Amendment – CH33 dependent benefit death of service member• VRAP – awarded benefits under Chapter 30 – closed March 2014

Principles of Excellence

Executive Order 13607 signed by the President on April 27, 2012 established principles of excellence for Educational Institutions serving service members, veterans, spouses, and other family members

Objective: designed to strengthen oversight, enforcement, and accountability within the Department of Veterans Affairs education benefit programs and DOD TA programs.

Established a centralized compliant system which became active in March 2014 – within initial 3 weeks – 900 complaints

Principles of Excellence

• Educational institutions participating in the Principles of Excellence program agree to the following guidelines:

• -Provide students with a personalized form covering the total cost of an education program.

• -Provide educational plans for all military and Veteran education beneficiaries.

• -End fraudulent and aggressive recruiting techniques and misrepresentations.

• -Accommodate Service members and Reservists absent due to service requirements.

• -Designate a point of contact to provide academic and financial advice.

• -Ensure accreditation of all new programs prior to enrolling students.

• -Align institutional refund policies with those under Title IV, which governs the administration of federal student financial aid programs.

Principles of Excellence – Student Complaints

Types of Complaints:

Recruiting/Marketing Practices, Accreditation, Financial issues (e.g. tuition/fee charges), student loans, post-graduation job opportunities, change in degree plan requirements, quality of education, grade policy, release of transcripts, transfer of credits, refund issues, and other.

GI Bill web link for submitting a complaint:

http://www.benefits.va.gov/GIBILL/Feedback.asp

OTHER: is a general category that may involve complaints about VA approval or processing applications or enrollments

Principles of Excellence – Student Complaints

Other types of complaints may involve:

- student questioning SCO certification based on applying VA reporting requirements

- student questioning institutional refund of tuition

- student questioning amount of Title IV funding

- student questioning CH33 Rate of Pursuit BAH based on term length and equivalent credits

- student questioning VA action on eligibility based on their military service and/or DOD information

Principles of Excellence – Student Complaints

VA student can submit complaint on GI Bill web site:

Process:

- VA Central Office Education Service reviews complaints and forwards to school SCO or designee;

- School is requested to provide VA with a response or if VA will refer to another government agency if appropriate.

- VA will review the response and provide a response to student complaint

- VA may also contact institution as appropriate

Role of the IHL

• When feedback is received for a school, VA will contact school on behalf of the student and work toward a resolution

• –The School Certifying Official (SCO) on record will be contacted

• –Institutions will have an opportunity to appoint another representative other than the SCO to handle complaints

• •Complaints should be handled within 60 days from submission

• •Complaints and their resolution(s) will be forwarded to the FTC Consumer Sentinel Network

• –These complaints will be accessible by over 650 federal, state, and local law enforcement agencies

SCO Communication with VA

• Right Now Web to St Louis RPO via email• National Education Call Center at 1-888-442-4551• SCO Hotline number at National Education Call

center at 1-855-225-1159• ELR – 612-970-5456 or email at

john.johnson11@va.gov

VA Student Responsibility

• Promptly notify SCO of changes to enrollment• - Understand benefit programs• - Application process to VA• - Progress and pursuit• - Contacting VA – inquiries concerning benefit

eligibility and benefit payments• - Understand cause and effect of enrollment

changes

Student Contacting VA

• Students can access GI Bill web site to contact VA by email

• Students can call VA at National Education Call center at 1-888-442-4551

• Students can access GI Bill web site for extensive information pertaining to benefit programs, searching for schools, comparison shop for schools, and search FAQ’s

• E Benefits access

E-Benefits

• The eBenefits web portal is an online resource for tools and benefits-related information.

• The portal serves Wounded Warriors, Veterans, Service Members, their families, and their caregivers.

• Two main services:

– A catalog of links to military and Veteran benefits on other sites

– A personalized workspace giving quick access to online tools that enable you to apply for benefits, download your DD-214, see your benefits status online, and more

E-Benefits Registration

• There are two levels of eBenefits registration, Basic and

Premium.– Basic Registration (Level 1 access) enables you to view

general eBenefits information. This level of access does not allow you to view information about yourself from VA and DoD systems.

– Premium Registration (Level 2 access) provides you the highest level of access to eBenefits. With Level 2 access, you will have a secure, personalized eBenefits account that pulls information from your DoD and VA records.

E-Benefits Registration

• Both levels require a DoD (DS) logon.– With a DS logon, you can use a single user

name and password to access various websites, including many VA and DoD sites

– All DoD sponsors, veterans spouses, and other beneficiaries who are registered in the Defense Enrollment Eligibility Reporting System (DEERS) can obtain a DS logon

BREAK

Experienced SCO Overview2:15 – 3:15pm

• Recap of benefit chapters• Approval Criteria• Modality of instruction to certify• Standard Term & nonstandard term certification• Sunday – Saturday start date of term (mult-iterm)• Overpayments and TOP• In-depth case study examples – complex• VA compliance surveys

Importance of Certifying OfficialsImportance of Certifying Importance of Certifying

OfficialsOfficialsThe success of VA The success of VA

educational programs educational programs dependsdepends

largely on you. Your largely on you. Your work on behalf work on behalf

of your institution in of your institution in assistingassisting

VA students is critical in VA students is critical in thethe

processing and payment processing and payment ofof

veterans educational veterans educational benefits. benefits.

School

VA (ELR)

Students

Military Reserves

Other Schools

StateApproving

Agency (SAA)

CertifyingOfficial

Education Benefit Chapters

• Montgomery GI Bill (MGIB) Chapter 30 – Veterans• Montgomery GI Bill-Selective Reserves Chapter 1606 for Members of

Reserves or National Guard• (REAP) Chapter 1607 – mobilized under DOD Title 10 (called to

active duty) • Dependents Educational Assistance Program Chapter 35 (spouse,

children, surviving spouse• (Public Law 110-181 – affecting Ch 1606/1607) enacted January 28,

2008• Post-9/11 GI Bill (Chapter 33) – veterans & dependents TOE• Fry Amendment – CH33 dependent benefit death of service member• VRAP – awarded benefits under Chapter 30 – closed March 2014

VA Application Forms

• VA Form 22-1990 – All Chapters except Chapter 35 for original claims

• VA Form 22-1990e – Chapter 33 Transfer of Entitlement

• VA Form 22-5490 – Chapter 35 original claims and Fry

• VA Form 22-1995 – All Chapters except Chapter 35 &

• VA Form 22-5495 – Chapter 35 subsequent claims

• *do we need 1995 & 5495 changing programs at same schools - NO

• ALL CAN BE COMPLETED AND SUBMITTED ON LINE AT GI BILL WEB SITE VONAPP – (preferred method)

VA Access to Records

• CFR 21.4209 – Title 38 provides VA & SAA access to any institutional records as condition of approval

• VA and SAA exempt from FERPA concerning privacy of student records

• Access to VA and non VA student academic and financial records

VA Interface with DOD

• VA can access DOD data base to obtain and verify:– Military service dates, type of discharge, contributions,

kickers, reserve/guard deployments under Title 10– AGR32 military service– Transferred benefits to spouse or dependents under

Chapter 33 by serviceperson

RPO Interface with VA Regional Offices

• VA RPO must verify spouse and dependent eligibility under Chapter 35 Dependent Education Assistance program.

• RPO obtains confirmation from VA RO where veteran claims folder is located to confirm spouse and or dependents are properly listed and veteran is rated for VA service connected disability rating to qualify for Chapter 35 benefits.

Institutional Approval (IHL & NCD)

• Accredited – institution’s accrediting agency recognized by U.S. Department of Education (Public or Private)

• Non-Accredited – institution may have:

– Accrediting agency not recognized by US Dept of Education

– SAA does not recognize accrediting agency

– or has no accrediting agency approval

– * May not be under State licensure by WI Education Approval Board (EAB)

DEEMED approved facilities

• Public Law 111-377 enacted August 1, 2011 provided for Institutions of Higher Learning (IHL) to be deemed approved for degree programs only if:

• Institution accreditation recognized by US Dept of Education

• Licensed by State as Institution of Higher Learning

• Did not change requirements for all NCD and private profit IHL institutions

DEEMED approved facilities

• VA assumed approval authority for Deemed approved institutions (public and private non-profit Institutions of Higher Learning)

• Effective late 2013 VA transferred approval authority back to SAA for institutional approval and non college degree programs at Deemed approved institutions – degree programs are deemed approved

• SAA retained approval function for all other institutions

Modality of Certifications – CH33

– Resident – lecture, lab, or shop instruction

– On line – distance learning or independent study

– Blended/hybrid – combination resident and on line instruction- differences undergrad and graduate level

– Remedial – subjects required as determined by institution as deficiency (resident instruction only)

– Practical Training (internships, externships, etc)

NCD schools – must be resident instruction and no on line instruction

Modality of CertificationsNon CH33

– There is no distinction by VA for non Chapter 33 education benefit award of benefits and treated as credit value other than:

– Remedial – subjects required as determined by institution as deficiency (resident instruction only)

– Practical Training (internships, externships, etc)

NCD schools – must be resident instruction and no on line instruction

Resident or Distance(Chapter 33)

– 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, research (either on or off campus), or a combination of both.

Evidence to Review when Certifying Enrollments

– Student application & matriculation

– Acceptance into program

– Institutional evidence of transfer credits• Prior institutions

• Military academic transcripts

• Other – perhaps life experience, CLEP etc

– Student account ledger – CH33 for T & F

– Student term registration data

– Existing transcript to verify no repeat subjects

Evidence to Review when Certifying Enrollments

– Rounding out in last term prior to completion

– Academic probation

– Student placed on academic suspension

– Subject substitution

– Remedial subjects pursued on line rather than resident instruction

– What evidence have you reviewed to substantiate need for remedial instruction subjects

– Repeating subjects based on grade posted and institutional standards

Non College Degree School Certifying Enrollments

– Student application & enrollment agreement

– Start date is actual first date of scheduled instruction

– Weekly schedule based on Sunday – Saturday hours• Varying weekly scheduled hours of instruction *

– Institutional evidence of prior training evaluation

– Student account ledger – CH33 to determine T&F

– Certify appropriate tuition and fees per term prorated amount if charged full tuition and fees but school organized on term basis

VA Enrollment Forms

• PAPER DOCUMENTS

• 22-1999 Enrollment Certification

• 22-1999b Change of Status

• VAONCE

• NEW CERT – Multiple term CERT

• AMEND

• ADJUST

• TERMINATE

Yellow Ribbon Program

VAONCE Student BIO page must display as benefit chapter 33Yellow to add YRP fields

-Annual cap for 2013-2014 is: $19,198.31

-Annual cap for 2014-2015 is: $20,235.02

-VA Academic Year for CH33 (8/1 – 7/31)

-Public IHL – restricted to in-state tuition and fees without YRP for nonresident tuition based on YRP agreement requirements

ELR Request

• Attempt to limit enrollment changes to VA until after the drop/add period (normally last 5-7 days after term starts

• VA is receiving numerous enrollment adjustments changing credits before terms have even started

• Refrain from submitting these changes until drop/add limited days is over – 25% of RPO documents are in this category.

Certifying Terms

– Single term

– Multiple term• Start date of subjects

– *nonstandard term impact on rate of pursuit

– Reporting tuition and fees CH33, active duty, & -1/2 to RPO

– Resident v/s non resident tuition

– Public YRP – Private YRP

– Modality – resident, distance, remedial, blended/hybrid, practical (internship)

Calendar Week Rule

– Certifying starting dates within term, quarter, and semester:

• VA requires institutions to certify start dates as the official calendar that is published by the institution for terms. However when a start date of subjects begin after the calendar week of the published term start date – the SCO must certify those credits using the start date of the subject scheduled first class session.

• This results in multiple term enrollment certification due to different start dates.

Calendar Week Rule

– Example: Fall Semester published dates are 9/3/14 – 12/12/14

– Student registration schedule identifies total of 12 cr

– 9 credits have start date of subjects on 9/3 – 9/5

– 3 credits have start date of subject on 9/9/14

– Proper certification would show:• 9/3/14 – 12/12/149 credits

• 9/9/14 – 12/12/143 credits

• * Basis is that first scheduled class session for 3 credits is not within the same week of 9/3/14 (Sunday – Saturday)

Certifying Terms

– Non College Degree Institutions• Organized on terms

• Not organized on terms

If not organized on term basis and based on weekly scheduled clock hours certify weekly scheduled hours of instruction

Identify the projected completion date as end date

RPO processing of enrollments

– Chapter 33 Post-9/11 GI Bill• Certify 1 semester or quarter at a time

– Certify non-standard terms for up to length of a term, Qtr, or Sem

• Enrollment does not include T and F

• Enrollment includes T and F

• Later submission of T and F - AMEND

• 14 day T and F release time frame– Multiple terms

– LTS – automated processing – CH33 only

– VAONCE – NEW CERT, NEW Multiple term CERT,

AMEND – use for submitting tuition and fees

RPO processing of enrollments

– All other benefit Chapters excluding CH33• Enrollment reviewed and processed

– Enrollment may include multiple terms

• Award notification to student

– AMEND

– ADJUST

– TERMINATE

Notifications to school and student

– Student award letters

– School pay listings with ACH payments

Two pay listings from VA (mailed to institutions)

- Non CH33 student payments

- CH33 tuition and fee payments

Overpayments - Institutions

• A debt is established on a school when:

• • The student never attended any classes for which he/she was certified regardless of the reason for non-attendance

• • The student completely withdraws on or before the first day of the term.

• • The school received payment for the wrong student

• • The school received a duplicate payment

• • The school submitted an amended enrollment certification and reported reduced tuition and fee charges, reduced Yellow Ribbon amount, or reduced both. (Reductions based on student’s action should be reported on a 1999B with the changes in the enrollment and will result in a debt to the student.)

• • The student died during the term, or before start of the term

• • VA issued payment above the amount certified on the enrollment certification that was used to process the payment (VA data entry error)

Overpayments - Students

• A debt is established on the student for tuition/fees/yellow ribbon when:

• • The student withdrew after the first day of the term (FDOT)

• • If the student completely withdrew on the FDOT, treat as if student never attended

• • The student reduced hours whether the reduction occurred before or during the term

• • If the student attended at least one day of any of the classes certified and a payment has been issued, any debt created by the reduction/withdrawal should be charged to the student

• • The school submitted a change in enrollment (1999b) and reported a reduction in tuition, fees, and/or Yellow Ribbon due to student action reducing or terminating training.

• • If a student drops a course and adds a course so that there is no net change in training time, any change to tuition, fees, and/or Yellow Ribbon is a student debt

DMC and TOP

• 2. Department of Veterans Affairs (VA) – Debt Management Center (DMC). Receives overpayment amounts generated by RPO on school debts. Sends three Notices of Indebtedness (NOIs) to schools regarding school debts. Takes action to clear debts or forward inactivity to the Treasury Offset Program (TOP).

• Notice 1: Sent three to five days after debt is established by RPO. Informs school of debt amount and addresses the payment options.

• Notice 2: Sent to school 30 days after first notice sent for past due accounts. Informs school of impending actions if the debt is not addressed. Provides an additional 30 days for the school to clear the debt.

• Notice 3: Sent to school 30 days after the second notice sent for all past due accounts. Gives school a final warning and allows for another 60 days to pay debt. Failure to clear debt after 60 days will result in debt amount being sent to the Treasury Offset Program (TOP).

Treasury Offset Program

• 3. US Department of the Treasury (DOT) – Financial Management Services (FMS) – Debt Management Services (DMS) – Treasury Offset Division (TOD) – Treasury Offset Program (TOP). Processes delinquent payments to Federal Government Agencies. Provides payment vouchers to schools. Takes action to clear debts by offsetting future Federal Government designated funds to the school if the school fails to take action to the pay debt and/or clear the debt through DMC.

•  

• **The Treasury Offset Program does not issue notices that funds are offset.

•  

VA Debt Management Center

– Contact Information:• 1-800-827-0648

• Dmcedu.vbaspl@va.gov

US Dept of Veterans Affairs

Debt Management Center

PO Box 11930

St Paul, MN 55111

Compliance Surveys

• Beginning on October 1, 2013 VA was authorized to waive compliance surveys at those institutions that

• For the purpose of a waiver consideration, a compliance survey conducted during the previous three (3) fiscal years, and one fiscal year (1) for OJTs/Apprenticeships will be reviewed. In the event that a facility was not surveyed each of those fiscal years, a “demonstrated record of compliance” can be determined if any records reviewed included three previous years of training.

Compliance Surveys

• Since our last WACRAO SCO workshop we have conducted a total of 92 compliance surveys in Wisconsin at IHL – 38, NCD – 17, and OJT – 37

• Additionally I waived a total of 22 Wisconsin IHL and NCD schools from survey requirements for FY14 based on procedural requirements.

• The results of our findings (VA & SAA) has been positive based on sample records reviewed when compared to findings.

Compliance Surveys

• Examples of reporting errors noted:– Incorrectly certifying tuition and fees

– Incorrectly reporting fees

– Occasional oversight – failing to report credit load reductions or student withdrawing from school

– Not reporting non-standard terms that are within the academic semesters

– Late reporting beyond 30 days from date student changed credit load

– Not reporting students placed on academic probation or

suspension

Complex Case Examples

• Non-Standard Terms

• Certifying concurrent enrollment

– Parent & Guest Institutions

• Amending tuition and fees – CH33

• Non resident tuition – public IHL

• Study Abroad tuition and fees - restrictions

• Blended or Hybrid – VA requirements

• Repeating F subjects – VA requirements

BREAK

–THANK YOU -

POST-9/11 GI BILLJuly 18, 2014

• BREAKOUT SESSION 8:30 – 10:30AM• SCO Resources (Instructions & Training)

Reporting tuition and fees – source documents

-Certification issues

-Common certification problems

Processing and VA releasing payments

-Notification to institutions and students

Institutional Overpayments

VA surveys – Q and A –

Contact Information• John Johnson – Phone: 612-970-5456, FAX 612-

970-5458, email: john.johnson11@va.gov

• Mailing Address:• VA Regional Office• Education Service (272L)• 1 Federal Drive• St Paul, MN 55111

VA Regional Processing Offices and Jurisdictions

Importance of Certifying Importance of Certifying OfficialsOfficials

The success of VA The success of VA

educational programs educational programs dependsdepends

largely on you. Your largely on you. Your work on behalf work on behalf

of your institution in of your institution in assistingassisting

VA students is critical in VA students is critical in thethe

processing and payment processing and payment ofof

veterans educational veterans educational benefits. benefits.

School

VA (ELR)

Students

Military Reserves

Other Schools

StateApproving

Agency (SAA)

CertifyingOfficial

SCO RESOURCESwww.gibill.va.gov

• - National SCO Handbook

• - VAONCE Training Guide

• - On line SCO training modules

• - SCO toll free help line

• - Education Liaison Representative

• - State Approving Agency

• - Vocational Rehabilitation Case Managers

• - State and local agency staff

• - National Guard and Reserves Education Office

• - Institution staff (Financial Aid, Registrar, Business Office, etc)

SCO Communicating with VA & SAA

• Contacting ELR by phone or email concerning procedural or certification issues and DEEMED approved approval questions

• Contacting SAA offices pertaining to approval issues

• Right Now Web (RNW) secure email when communicating with VA Regional Processing Office St Louis

• Accessing the VA National SCO hot line

• Contacting VA Debt Management Center (DMC) involving institutional overpayments

SCO Communicating VA

• Email to St Louis VA RPO by using Right Now Web – Pertaining to student issues

– School questions tuition payments

– School requests audit of tuition payments for institutional debt

• Contacting Education Liaison Representative– VAONCE questions

– VA regulations, manual or policy questions

– Approval data base issues that are not approval criteria

– Updating certifying officials

Changes to Designated Certifying Officials

- VA Form 22-8794 – Designation of VA Certifying Official form is critically important when changes occur for:

- VA approval data base to identify SCO

- VAONCE web site authorization

- ELR email distribution listings

- National Education Call center to identify school official as designated certifying official

- SCO submitting emails to RPO on student cases

- Privacy Act Issues

Certification Differences for non Chapter 33

• Do not need to report tuition and fees unless less than one half time training or student on active duty

• Do not need to separately report resident, on line, blended/hybrid

• Do not need to provide minimum credit full time for graduate students. (only report level of training – full time, ¾, ½ etc) as determined by institutional academic requirements

Source Documents – Tuition & Fees

- DO NOT - – access institutional term schedule of standard

tuition and fees in course offerings

- – accept verbal or email confirmation from Business Office

- – accept verification of 3rd party tuition from student

- – verify only based on Financial Aid Package of cost of attendance

Source Documents – Tuition & Fees

- Best Practice:- Print a copy of the student registration schedule for each term

to certify

- Print a copy of the Business Office student account ledger for each term to certify

- Identify sources listed for 3rd party or internal scholarships

- Confirm any military national guard or reserve TA

- Monitor during the term to obtain other sources of funding received by your college –

- Timely report amended tuition and fees to VA

Tuition and Fees to report to VA for Chapter 33

• Tuition – net charges• Fees – those costs charged to similarly

circumstanced non VA students.• The fees must be charged by the institution to

student.• NO – SCO cannot report fees when student is

purchasing items on their own from vendor or book store etc.

Public Non Resident Tuition

• The Yellow Ribbon Program is available when a public school charges a Chapter 33 student non resident tuition.– The YRP agreement is for up to the difference

of the in-State tuition and non resident amount charged.

– VA YRP can not exceed the institutional contribution nor 50% of the difference

Tuition & Fees

- TUITION: Identify if your institution offers –- Student discounts on tuition

- Student waivers on tuition

- Internal institutional scholarships- RESTRICTED OR UNRESTRICTED

- FEES: Confirm the fees charged are approved to certify to VA. “Fees are those charges that are charged to all similarly circumstanced students”.

POST-9/11 GI BILL

Tuition & Fees (excluding Title IV):

1.Access student registration data

2.Determine when to certify to VA1. Prior to start of term

2. After registration closes

-Identify credits to certify and charges for same

-Determine net charges of tuition

-Verify fees by VA requirements

-Other 3rd party sources

POST-9/11 GI BILL

Recommend certifying term dates & credits without tuition and fees

AMEND certification in VAONCE to later submit tuition & fees to VA

1.Key to certify term dates and credits – for award of book stipend and BAH (monthly housing allowance) awarded to student

2.Certify net charges of T&F when registration closes

3.May result in credit adjustments when submitting T&F if student adjusts credits

ENROLLMENT CERTIFICATIONS

Standard terms combined with multiple non-standard term dates

Only non-standard terms

Concurrent enrollment terms (parent & guest)

-Modulated terms based on individual unit subject pursuit (sequentially versus concurrently)

-NCD schools not operating on term basis – tuition and fees charged lump sum at start of program

-NCD schools operating on term basis – tuition and fees charged lump sum at start of program

Basic SCO Responsibilities

• Inform VA of the enrollment status of veterans and other eligible persons.

• Maintain adequate documentation at the institution to support certifications.

• Certify enrollments & changes timely to VA.• Inform SAA of new programs, changes in

programs, institutional changes, etc.• Apprise supervisors of any internal problems

which may affect service to VA students.

Enrollment CertificationInstitutional Compliance

- The institution has exercised diligence in meeting all applicable requirements of Title 38 USC and any failure by the institution to meet any requirements of the law will be reported promptly to VA

- The institution agrees to report promptly to VA any enrollment change and any change due to unsatisfactory progress, conduct or attendance. Promptly means within 30 days of the enrollment change. Except for students receiving benefits under Chapter 33, the institution need not report an enrollment change for a student who was in full-time attendance before the change and in fulltime after the enrollment change.

Enrollment CertificationInstitutional Compliance

- The 85/15% enrollment ratio requirement has been satisfied

- Student certified is not an owner or officer of the school nor is the student certified as an official authorized to sign enrollment certifications

- The institution holds no power of attorney agreement authorizing the institution to negotiate VA educational assistance allowance checks

- No course certified is a repetition of any course previously satisfactorily completed except as permitted by VA regulations

- The course or courses certified are approved by the State Approving Agency and are generally acceptable to meet requirements for the student’s objective

CFR 21.4203Reports—requirements

Each educational institution, veteran and eligible person shall report without delay the following information:

Enrollment, Change in the hours of credit or attendance, Change in pursuit, Interruption and termination of attendance

of each veteran or eligible person enrolled in an approved course.

38 CFR 21.4203

Keep VA Informed of Each Student’s Enrollment Status

• Monitor unit subjects pursued to certify to VA only those subjects which apply to the student’s program.

• Monitor student’s grades to insure (s)he is making satisfactory progress and report unsatisfactory progress.

• Must monitor student’s conduct and report when student is suspended/dismissed for unsatisfactory conduct.

• Monitor monthly to ensure timely reporting of reductions, terminations or increases in training.

POST-9/11 GI BILL

Yellow Ribbon Program certifications:

-VAONCE BIO should identify as VA benefit chapter as CH33 Yellow

-PRIVATE

-Submit 0 charges in YRP column until term when annual cap will be exhausted

-PUBLIC

-Restricted to difference of resident to non resident tuition net charges – certify each term when YRP exists

VA PROCESSING – CH33

• Long Term Solution (LTS) VA computer program exported October 2012 at VA Regional Processing Offices to automate enrollment processing to reduce processing time– Results demonstrate over 50% automated

enrollment processing provided:• VAONCE enrollment clears edits• Tuition/fee payments released no earlier than

14 days prior to each term start date

Award Authorizations

• Student will be sent an award letter by VA for each enrollment term processed. – Non Chapter 33 will be computer generated letter– Chapter 33 will be program release letter to provide:

• SCO enrollment information for each term• Charges for tuition and fees• Resident or on line pursuit• BAH rate for each term• Books and Supply stipend payment• Kicker payment information• Remaining entitlement and delimiting date

• NOTE: CH33 Tuition and fee payments are released for each term not more than 14 calendar days from the term start dates.

Case StudiesEnrollments

– Refer to Handout for case scenarios involving certifications:

• Enrollment Certifications– Start & end dates of term(s)

– Reporting credits

- Resident, practical, remedial, distance, blended/hybrid

– Reporting tuition & fees

»Net Charges, 3rd party tuition payments, institutional waivers, discounts, internal scholarships, military TA

Case Studies

– Refer to Handout for case scenarios involving certifications:

• Enrollment Certification Changes– When to use AMEND

– When to use ADJUST

– When to use TERMINATE

Compliance Survey Findings

• Overall the findings have been very good. Common errors involve:– Not reporting changes or terminations

– Not reporting net charges correctly

– Not reporting non-standard terms

– Not reporting unearned F grades – (procedural change)

– Not reporting distance learning correctly

– Late reporting of enrollment changes to VA

– Failure to monitor prior credit evaluations

THANK YOU!

• QUESTIONS & ANSWERS

Day 2 12:30 – 2pm VAONCE DEMO Session

– What is SCO certifying when submitting enrollments to VA? -

– How to add student in VAONCE

– How to add or change information on BIO page

– How to prepare enrollment certifications• Standard terms

• Nonstandard terms

• AMEND – ADJUST – TERMINATE

– CASE STUDIES

VAONCE Information

The purpose of the following exercises involve VAONCE demo site are presented as instructional and informational

-Institutional computer operating systems

-Adding, deleting, inactivating students

-BIO Page

-Enrollments- New single cert, new multiple term cert

- AMEND – ADJUST - TERMINATE

VAONCE Information

Entering information for:

Term dates

Approved Program Names

-BIO page- entering name of program – reference undeclared- entering correct VA file number- entering CH35 payee number- email of students for internal use

VAONCE Information

- How to report unsatisfactory academic progress

- How to certify student after successful appeal of academic suspension. Documentation required by SCO

- How to report unearned F grade when institution takes attendance of all students for each subject

- NO – how to report academic probation to VA

VAONCE Information

Scenarios will involve basic certification case studies to more complex certifications

Accessing proper enrollment lines in VAONCE when making changes

Is VAONCE user friendly?

management tools to access in VAONCE

Cleaning out old records in VAONCE

What exactly happens when I make a student inactive or delete them in VAONCE?

VAONCE Information

THANK YOU!

CH33 YRP Breakout Session

• Training for this breakout session will include discussion on:– - Yellow Ribbon Program MOA

– - YRP FAQ

– - YRP – VAONCE how to?

– - Public – Private Institutions of Higher Learning YRP• Public

• Private

– Case studies

CH33 YRP Breakout Session

• Confirm institution is YRP MOA approved• Confirm CH33 student is at 100% level• Confirm this is not a spouse of active duty service

person or active duty service person• CONFIRM NET CHARGES• Private – certify YRP when cap exhausted• Public – certify each term as needed for non

resident tuition charges in excess of in state costs

CH33 YRP Breakout Session

• Yellow Ribbon Program under Chapter 33 is limited to Institutions of Higher Learning – excludes all other types of schools

• Open to Public and Private IHL’s – public YRP based on non-resident tuition charged

• Annual action – are now posted for 2014-15 YRP schools on gi bill web site

• Review web site for WI YRP Institutions

CH33 YRP Breakout Session

• VA Central Office, Education Service, Washington, DC processes and maintains oversight on the Yellow Ribbon Program.

• GI Bill web site will list those institutions approved and participating in YRP

• Currently there are 81 Wisconsin institutions (Public & Private) of higher learning participating in YRP for 2014-2015 VA Academic Year.

CH33 YRP Breakout Session

• Follow terms of YRP agreement – - Create a list of YRP students– - If limited create waiting list– - Confirm business office aware of YRP students and

amounts– - Private --Certify YRP when $20,235.02 cap is

exhausted within VA academic year (8/1/14 – 7/31/15) * Increase effective 8/1/14 from $19,198.31

– - Public --Certify YRP when student charged non resident tuition per term. Report resident amounts and enter YRP contribution

CH33 YRP Breakout Session

• Tuition – net charges• Fees – those costs charged to similarly

circumstanced non VA students.• The fees must be charged by the institution

to student.• NO – SCO cannot report fees when student

is purchasing items on their own from vendor or book store etc.

Public Non Resident Tuition

• The Yellow Ribbon Program is available when a public school charges a Chapter 33 student non resident tuition.– The YRP agreement is for up to the difference

of the in-State tuition and non resident amount charged.

– VA YRP can not exceed the institutional contribution nor 50% of the difference

Private

• VA Academic year (8/1 – 7/31) $19,198.31 for year ending 7/31/2014

• Maximum for tuition and fees increases on 8/1/14 ti $20,235.02 for year ending 7/31/15

• Do not certify YRP contributions until the term begins that will exhaust annual maximum during the VA academic year

• Set VAONCE BIO for CH33 YRP and enter zero in enrollment YRP field until above applies.

Ch 33: Tuition & Fees

Established Tuition Charges-• This includes any scholarship(s), or other Federal,

State, institutional or employer-based aid or assistance (other than loans and any funds provided under section 401(b) of the Higher Education Act of 1965 (Title IV)) that is provided to the institution and is specifically designated for the sole purpose of defraying tuition and fees.

• The actual tuition charge that similarly circumstanced non-veterans enrolled the program of education are required to pay.

Chapter 33YRP: Student credit load reductions

• Guidance when IHL reports CH33 YRP student withdraws due to reduced credit hours:

– When schools report the withdrawal, they also report the T&F and YR that would be associated with the reduced hours

– The VA will do its proration and collect any overpayments due

– The School will refund IAW its own policies

• School should have a written policy in place that describes implications of withdrawals on YR and provide it to students

– Just like T&F, the YR amounts are not based on reality but rather the amount needed to calculate the proration

Ch 33: Tuition & Fees

Reporting Tuition and Fees

• For each term, report actual net cost for tuition and fees to VA:

• Tuition and Fees for 12 credits (full-time) =$12,000.00School Veteran Tuition Waiver =

($1,000.00)Private Tuition Scholarship = ($1,000.00)Your State Vets’ Tuition Assistance =

($2,000.00)Net Tuition and Fees =

$8,000.00

Report $8,000.00 to VA as the T&Fs for this this term. If the student received any Title IV funds, (Pell Grant) or assistance not specifically designated for the payment of tuition and fees – No need to deduct from the amount reported to VA.

Ch 33: Net Payer DefinedSUMMARY OF PROVISION:

The actual net cost for tuition and fees assessed by the institution after the application of—(a) any waiver of, or reduction in, tuition and fees; and(b) any scholarship, or other Federal, State, institutional, or employer-based aid or assistance (other than federal loans and Pell grants) that is “provided directly to the institution and specifically designated for the sole purpose of defraying tuition and fees”

Use “Amend” WhenUse “Amend” When• Reported an incorrect “Begin” or “End”

term date

• Need to add a VBA Standard Remark

• Correct tuition & fee amount

• Correct Yellow Ribbon amount

Note: Debt will be placed against the institution when overpayment of CH33 benefits results from an incorrect tuition & fee or YR amount certified to VA.

Termination ReasonsTermination Reasons• End of Term or Course• Graduation• Unsatisfactory Attendance, Conduct, or Progress• Withdrew Before Beginning of Term• Withdrawal or Interruption (Non College Degree

Programs Not on a Term Basis)• Withdrawal After Drop Period-Non-punitive Grades

Assigned• Withdrawal After Drop Period-Punitive Grades

Assigned• Withdrawal During Drop Period• Preregistered But Never Attended• Other (Explain in Remarks)

Case StudiesCase Studies• Refer to the handout for several case studies that are

examples of Yellow Ribbon Program Certifications