Presentation on theme: "Education Service Outreach Section"— Presentation transcript:
1 Education Service Outreach Section Compliance SurveysEducation Service Outreach SectionAVECO ConferenceSt Louis, MO
2 Training Overview Objectives SCO turnover rate VA enrollment statisticsPurpose and AuthorityAccess to Institutional RecordsJurisdiction of Regional Processing OfficesSt Louis RPO survey dataVA Fiscal Year Schedules/Types of compliance surveysVA Education Benefit Chapters - SurveysPL (SAA & VA conduct surveys)Who conducts surveysPreparation, Scheduling, Conducting, & Post Survey
3 Objectives of Compliance Surveys Compliance surveys have five principal objectives:To verify the propriety of payments of educational benefits to eligible individuals under the provisions of the laws administered by VA;(2) To provide a reasonable basis for cooperating with SAAs;(3) To assist school or training officials and eligible individuals in better understanding their responsibilities and the procedural requirements of VA;(4) To determine, on the basis of facts disclosed from document reviews and personal visits, whether there are deviations from the responsibilities and requirements by eligible individuals, schools or training establishments; and(5) To assure that proper action is promptly taken through appropriate channels for the correction of existing discrepancies, or for the discontinuance of benefits in the event correction is not accomplished.
4 Training OverviewGenerally the turnover rate of designated VA School Certifying Officials is approximately 30% annually.New SCO training is a continuing requirementVA compliance surveys can be of assistance to a new SCO however compliance surveys are conducted by ELR, ECSS, and SAA ConsultantsELR is a valuable resource for trainingVAONCECertifying enrollment data to VARole of SAA and ECSS is generally not to provide in depth certification training
5 Enrollment Certification VA Form , Enrollment Certification states the SCO/Institution is certifying:Exercised reasonable diligence in meeting all applicable requirements for the following seven (7) criteria:
6 Enrollment Certification 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 VAThe 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.
7 Enrollment Certification The 85/15% enrollment ratio requirement has been satisfiedStudent certified is not an owner or officer of the school nor is the student certified as an official authorized to sign enrollment certificationsThe institution holds no power of attorney agreement authorizing the institution to negotiate VA educational assistance allowance checksNo course certified is a repetition of any course previously satisfactorily completed except as permitted by VA regulationsThe course or courses certified (added: excluding DEEMED approved institution degree programs) are approved by the State Approving Agency and are generally acceptable to meet requirements for the student’s objective
8 Benefit ChaptersVA education benefit chapters reviewed on compliance surveys are:Chapter 30 – MGIBChapter 32 – VEAPChapter 33 – Post-9/11 GI BillChapter 35 – Dependent Education AssistanceChapter 1606 – Selected ReservesChapter 1607 – REAP(VRAP administered under Chapter 30 – ended March 014 Fry Amendment administered under CH33CH33TOE and Yellow Ribbon ProgramExcluded: Chapter 31 Vocational Rehabilitation Benefit
9 ENROLLMENT ACTIVITY St Louis VA RPO Overview of institutional activity and enrollment activity based on calendar year 2013:3,138 – number of IHL and NCD schools active during calendar year 2013287,084 – number of VA beneficiaries who received VA education benefits during calendar year 2013Number of schools with 100 plus VA students – 561 (18%)Number of students in receipt of benefits at the 561 schools – 237,300 (83%)Number of schools with 1 – 10 VA students in receipt of benefits – 1,314 (42%)
10 Nationwide Data (April 2014) ENROLLMENT ACTIVITYNationwide Data (April 2014)Total of 6,663 IHL and 3,083 NCD schools active meaning VA students received benefitsIHL-public – 35%-private profit – 27%-pvt non profit - 38%NCD-public – 20%-private profit – 73%-private non profit – 7%
11 National Totals (April 2014) ENROLLMENT ACTIVITYNational Totals (April 2014)Chapter ,897Chapter ,479ChapterChapter , %Chapter ,023Chapter ,451ChapterTOTAL ,339* Excess of $29 billion in expenditures since 8/2009;Overall enrollment has increased approximately 200% since August 2009 and over 1 million received benefits in FY13.
12 Purpose and AuthorityCompliance surveys are conducted in order to ensure that schools and training establishments, and their approved courses, are in compliance with all applicable provisions of the laws administered by VA.Authority:Title 3838 CFRM22-4
13 Access to RecordsCFR – Title 38 provides VA & SAA access to any institutional records as condition of approvalVA and SAA exempt from FERPA concerning privacy of student recordsAccess to VA and non VA student academic and financial recordsAccess to review Institutional Advertising MaterialsPrinciples of ExcellenceStudent Interviews
14 Access to RecordsThe Buckley amendment (Public Law ) requires that institutions receiving Federal funds administered by the Department of Education must obtain the student's consent to release information from school records.It has been determined that school records relating to VA benefits fall into the "financial aid" category and are therefore exempt from the provisions of the Buckley amendment.Therefore, the VA (and SAA) shall have access to the records of VA beneficiaries as well as non-VA students without the written consent of the student in order to monitor the school's compliance with the law.
15 VA Regional Processing Offices and Jurisdictions
16 St Louis RPO The jurisdiction of the RPO contains 18 States- The Education Service Outreach Section currently has a total of 27 staff for which there are 18 ELR’s and 6 full time Education Compliance Survey Specialists (ECSS)This section is responsible for oversight and maintaining the approval data base for all institutions and training establishments in the region – needed for RPO claims processing of applications and enrollment certifications to support approved facilitiesState Approving Agency Consultants are responsible for institutional approval and also conduct compliance surveys for VAAlso VA conducts compliance surveys, EO investigations, and participates in numerous local and regional SCO workshops and other organizationsResponsible for SAA contract administration for 19 contracts
17 St Louis RPOThere also are 19 State Approving Agencies (55 SAA staff) for the 18 States responsible for approval of institutions and training establishments – ELR is Contracting Officer Technical Representative for oversight of performance and reimbursement of expenses.FY13 scheduled compliance surveys total 1,657 includes 17 Vocational Flight Schools, 607 On the Job and Apprenticeship training establishments, and the balance of surveys are at 1,033 IHL and NCD schools.
18 Types of SurveysVA compliance surveys are conducted at the following types of active facilities as of October 1, 2013 (FY14)Institutions with 300 plus VA certified VA beneficiaries – 60%Institutions of Higher Learning – (less than 300) – as requiredNon College Degree Institutions – 60%Vocational Flight Training Schools – 50%Training Establishments – 25%Apprenticeship (APPR)On-the-Job training (OJT)Federal and Nationally approved OJT and APPR facilities – excluded in FY14Director, Education Service, may act for the Secretary and may waive compliance surveys at institutions with a demonstrated record of compliance. St Louis CELO did request ELR staff to review and submit waiver requests for schools that had met demonstrated record of compliance – meaning no compliance survey at these institutions in FY14.
19 Who Conducts Compliance Surveys Effective October 1, 2011 per Public Law both VA and State Approving Agency (SAA) staff conduct compliance surveys.Noted facts that:- sample student size decreased effective 10/1/13 for schools with higher VA student enrollment- institutional source documents may not be required to be retained by VA or SAA following on site compliance surveys- Increased efforts to conduct remote surveys in FY14
20 SurveysEach survey conducted by VA consists of a random sample of VA student records for those who have been certified and awarded benefits at that institution.Sample size is based on total VA student awarded enrollment total. NOTE: We review minimum of 10 VA student records unless there are fewer than 10 students enrolled (excluding Chapter 31)Purpose of the sample size is to validate and confirm institutional certifications and practices – to ensure accurate and timely reporting to VA by the designated SCO.
21 The Compliance Survey Survey Preparation Scheduling survey appointments with InstitutionsConduct SurveyInstitutional Records providedEntrance BriefingReview of RecordsOther aspects of compliance survey – non VA student record, advertising, 8794 up to date, VA work study, current catalog & student handbookAcademic term dates (calendar), total enrollmentStudent Interviews – private profit institutionsExit BriefingPost Survey RequirementsDiscrepancy referrals (approval & payment)Compliance survey acknowledgement letter
22 Training Overview Institutional Records for Sample Student Records: Copy of unofficial transcriptCopy of Degree Audit Report (DAR)Copy of Student Account LedgerVerification of prior credit evaluationsCopy of Student term registration schedulesIdentifying start date, end dateIdentifying modality of instructionCaptures non-standard term dates by subjectsProgress Standards (GPA)Obtaining LDA or last activity to confirm withdraw of subjects for student records
23 Guidance to SCO Records to review prior to certification Ensure student has applied and accepted as a studentPrior credit evaluation completed or pendingDegree program approvedStudent term registration scheduleConfirm modality of instructionConfirm length of period to certifyConfirm subjects apply to programDAR – Degree Audit RecordStudent Account Ledger for charges – net charges
24 Training Overview Institutional Records for- Types of and evidence of institutional advertisingUpdated Designation of Certifying Official formCurrent Catalog and student handbookCopy of current student enrollment agreement or contract if appropriateNCD programs as necessary – weekly scheduled hours of instructionVA Form Conflicting Interest Certification for private institutions as appropriateNon VA student record review to confirm charges same or similar to VA student enrollment
25 Training Overview Institutional Records for- VA work study student records as appropriateInstitutional monitoring systemsInstitutional tracking systemsTotal student enrollment count85/15 compliancePower of Attorney disclaimerMethod of instruction (on line, hybrid, blended, practical)Student has applied and been acceptedMatriculated into approved program/objectiveNon-accredited Institutions –Restrictions on modality of instructionPro-rata refund of unused tuitionTimely refunds of unused tuitionVerification of enrollment limitation
26 Compliance Survey Findings Overall the findings have been very good. Common errors involve:Not reporting changes or terminations (occasional instances or for all students)Not reporting net charges correctly or YRP contributions incorrectNot reporting unearned F grades – discontinued per VACO policy Nov 2013Not reporting distance learning correctlyLate reporting of enrollments or enrollment changes to VAFailure of institution to evaluate or monitor prior credit evaluationsCertifying credits that do not apply to program requirementsCertifying remedial subjects when offered on lineIncorrectly reporting LDA – last day of attendance on withdrawingCertifying incorrect program name or type of trainingNot reporting unsatisfactory progress or probationLack of institutional records to support certifications to VACertifying programs not approved by VA or SAA
27 Surveys - Scheduling-Majority of compliance surveys we conduct involve travel meaning a number of institutions may be scheduled for a given week (Monday – Friday). We strive to not schedule at institution peak workload periods however this may not always occur based on travel plans.-VA and SAA will call the primary SCO to schedule a date(s) and time for conducting the survey in addition to providing institution with names of students in the sample size to be reviewed.-A letter or will be furnished the SCO of the student names and the institutional records to copy for our review.-The institutional records copied will be retained by VA and SAA to include in our compliance survey records – PII data is safeguarded and necessary as internal quality reviews by VA are conducted to ensure all aspects of the compliance survey were accurately reviewed and completed. (procedures changed for FY14)PII data can be shredded following a reasonable period from date of closed survey (normally within 90 days)
28 Conducting SurveyThe onsite compliance survey may involve 1 or more individuals based on the size of the sample VA student records to review.We will schedule an entrance briefing with the primary SCO and other institutional staff to describe and explain purpose of our visit and to confirm the requested records were provided for our review.The second step is to review the student records and compare to VA Form and VA Form b submissions to validate accurate and timely reporting to VA.Questions and confirmation of additional data will be made to the SCO during the on site compliance survey to validate last date of attendance, withdraw dates, or any other action requiring justification or clarification.The last step on the on site survey will be the exit briefing. The purpose of the exit briefing is to provide institution with survey results based on the findings with emphasis to identify the root cause of the exceptions.
29 Post Survey ActionsVA and SAA will prepare narrative reports for the survey findings.Findings of reporting discrepancies will involve referrals to the RPO for award actionsFindings of no reporting discrepancies however late reporting is noted and evaluatedFindings of approval criteria is referred to the SAA at all institution is for appropriate review, investigation, and necessary corrective actionOur internal reports capture primary causes or root causes for non compliance discrepancies found.Training of SCO’s is often required due to an estimate of a 30% annual turnover of designated certifying officials.A letter is sent to the institution to acknowledge the compliance survey that conveys the results of our visit. (Normally discrepancy issues are noted during our exit briefing)
30 Post Survey ActionsEvidence of non compliance may involve overpayments to both institutions and students noted on compliance surveys.Again summary on types of reporting discrepancies but not all inclusive are provided on the next slide.Overall the results of our compliance surveys have been good.Noted is additional action can be taken by expanding the number of student records to review based on a finding of 30% or greater reporting discrepancies. Also a total reporting error of 50% or greater may develop into a 100% review of VA student records.
31 Compliance Survey Findings Overall the findings have been very good. Common errors involve:Not reporting changes or terminationsNot reporting net charges correctlyNot reporting unearned F grades – change as of Nov 2013) excluded for those IHL’s that do not have required taking of attendance for all studentsNot reporting distance learning correctlyLate reporting of enrollment and enrollment changes to VAFailure to monitor prior credit evaluationsCertifying credits that do not apply to program requirementsCertifying remedial subjects when offered on lineIncorrectly reporting LDA – last day of attendance on withdrawingCertifying incorrect program name or type of trainingNot reporting unsatisfactory progress or probationLack of institutional records to support certifications to VACertifying programs not approved by VA or SAA
32 SummaryVA does maintain a tracking system on a fiscal year basis for all compliance surveys conducted as well as:- Name of institution and type- Date of compliance survey- Individual who conducted the survey- number of VA student records reviewed- number of VA students records with discrepanciesThis information is reported to VA Central Office, Washington, DC on a periodic basis to confirm institutional compliance.