1. VETERANS BENEFITS ADMINISTRATION AVECO July 14 – 18, 2014 Centralized Certification

2. VETERANS BENEFITS ADMINISTRATION Overview Centralized Certification Procedures Purpose. This document provides formal instructions for implementing Centralized Certification of enrollment information. New Procedure. As permitted by 38 CFR 21.4266, educational institutions with multiple campuses may be eligible to submit enrollment certifications to VA from a centralized location. Although “centralized certification” is not required, it does provide a streamlined alternative for institutions with multiple campuses. 1

3. VETERANS BENEFITS ADMINISTRATION Common terms associated with centralized certification are defined below. Administrative capability – the ability to maintain all records and accounts that 38 CFR §21.4209 requires. Branch campus – a location of an educational institution that: (a) Is geographically apart from and operationally independent of the main campus; (b) Has its own faculty, administration, and supervisory organization; and (c) Offers courses in education programs leading to a degree, certificate, or other recognized educational credential. 2 Terminology

4. VETERANS BENEFITS ADMINISTRATION Terminology Combined Approval – a single approval of courses offered by the main campus and a branch/extension. “The State approving agency may combine the approval of courses offered at the main campus only if the extension and the campus it is dependent on are within the same state.” (38 CFR 21.4266(e)) Extension – a location of an educational institution that is geographically apart from and is operationally dependent on the main campus or a branch campus of the educational institution. Main Campus (or Parent Facility) – the location where the primary teaching facilities of an educational institution are located. If an institution only has one teaching location, that location is its main campus (when unclear, this is the location of the primary office of the Chief Executive Officer). 3

5. VETERANS BENEFITS ADMINISTRATION Terminology Minimum Period of Operation – the minimum amount of time that an educational institution (or branch or extension of such educational institution) must have been continuously operating and offering courses before a State approving agency may approve a course(s). Branches and extensions are subject to the minimum period of operation requirements as stated in 38 CFR 21.4251 regardless of whether the branch or extension receives a separate or combined approval. Point of contact (POC) – a designated educational institution employee at an extension or branch campus that does not have a school certifying official on location. The POC performs various functions similar to those of the certifying official but does not have the capability to certify enrollments through VA-Once. 4

6. VETERANS BENEFITS ADMINISTRATION Terminology School Certifying Official (SCO or CO) – a representative of an educational institution designated to provide VA with the reports and certifications that title 38, Code of Federal Regulations, requires. State Approving Agency (SAA) of jurisdiction – the SAA for the state where the residence course is being taught. The SAA with jurisdiction over the main campus will not have jurisdiction over an approved branch/extension unless that branch/extension is in the same state as the main campus. 5

7. VETERANS BENEFITS ADMINISTRATION CENTRALIZED CERTIFICATION - SCHOOL RESPONSIBILITIES An official located at the main campus must request approval of centralized certification with the ELR of jurisdiction. Once approved for centralized certification, a school certifying official must add a POC for each approved branch or extension as a "user" in VA-Once. POCs must have access to VA-Once in order to provide certification information to beneficiaries and SAA and VA representatives. However, POCs should not be approved to transmit, edit, or delete certifications in VA-Once. SCOs will also be required to add POCs for branches/extensions that previously had their own designated certifying officials. ELRs will revoke certifying official access for all individuals with access at those locations upon notification of approval for centralized certification. 6

8. VETERANS BENEFITS ADMINISTRATION The SCO must request and maintain a list of all programs, or courses, approved for VA training for each location for which he or she is responsible for certifying enrollments. The branch/extension POC must notify the main campus each time approval is amended, suspended, withdrawn, or reinstated at that location. SCOs must certify students using the facility code of the branch where administrative capability exists for the teaching location where the student is attending. The SCOs and POCs must make records available for compliance surveys and SAA site visits. 7

9. VETERANS BENEFITS ADMINISTRATION CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS A. General What institutions can be approved for centralized certification? Educational institutions that have approved branches or extensions located in more than one state may now centralize certification of enrollments if the institution only offers IHL or NCD training and certifies students via the VA Online Certification of Enrollment (VA-Once) Internet application. (Note: Centralized certification is not available for training establishments or institutions offering correspondence courses, flight training, apprenticeship/on-the-job training, licensing or certification tests, or national tests due to the current limitations of VA- Once.) 8

10. VETERANS BENEFITS ADMINISTRATION CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS 2. If an institution with campuses in more than one state agrees to participate in centralized certification, is each campus required to sign a separate MOU for VA- Once access? No, the only campus required to sign a memorandum of understanding (MOU) for VA-Once is the main campus. That campus will be responsible for ensuring that all the requirements in the MOU are met by each of its branch locations. Points of Contact at the branch campuses will only have access to VA-Once after the main campus has added them as a user. Any individuals at branch/extension locations who were previously designated as certifying officials will be removed from the system as a certifying official by the ELR of jurisdiction upon notification of centralized certification approval. As a result, the main campus will control who has access to VA-Once at all locations in accordance with the VA-Once MOU. 9

11. VETERANS BENEFITS ADMINISTRATION CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS If approval for a central location is withdrawn, can centralized certification be continued? No, if approval for the central location is withdrawn, the remaining locations will need to designate a new certifying official (using VA Form 22-8794) in order to submit enrollment certifications. However, another campus may request approval for centralized certification by contacting the ELR of jurisdiction and submitting an application package. If the central location's approval is later reinstated, a subsequent application for centralized certification must be submitted and approved before that institution can resume using the centralized certification option. 10

12. VETERANS BENEFITS ADMINISTRATION 4. Can an institution choose which branches/extensions participate in centralized certification? Yes, if an institution with several branches wants to centrally certify its enrollments, the institution is given the flexibility of deciding which branch locations will be included. It is not required that all school locations participate in centralized certification. 11 CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS

13. VETERANS BENEFITS ADMINISTRATION 5. Since institutions participating in centralized certification may have SCOs and POCs in more than one state, who will be responsible for training those personnel on VA-Once? The ELR with jurisdiction over the campus personnel needing assistance is responsible for providing training. 12 CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS

14. VETERANS BENEFITS ADMINISTRATION 6. How will VA verify that the designated certifying official is submitting the enrollment certifications? Each institution using VA-Once is required to sign a memorandum of understanding (MOU) prior to being granted access to the application. The MOU requires that institutions take reasonable precautions to safeguard against unauthorized access and to prevent improper disclosure of passwords. The MOU also requires the institution to promptly notify VA if an authorized certifying official no longer serves in that position. VA may review adherence to this policy during school site visits and make adjustments as necessary. 13 CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS

15. VETERANS BENEFITS ADMINISTRATION 7. How will customer inquiries be handled by POCs? POCs should have view only access to VA-Once in order to provide information to beneficiaries and SAA or VA representatives. POCs do not have the authority to certify or amend enrollment information and must report any changes in enrollment to a certifying official at the main campus. 14 CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS

16. VETERANS BENEFITS ADMINISTRATION 8. Will reporting fees be sent to approved branches/extensions or to the Main Campus? Schools are entitled to a reporting fee for each VA student enrolled during the preceding calendar year. Currently, reporting fees are calculated based on the number of students attending a specific facility code (as entered in the Benefits Delivery Network). Since centralized certification procedures require SCOs to certify students using the facility code of the branch with administrative authority over their location, the reporting fees will be continue to be forwarded to each branch that has active students. 15 CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS

17. VETERANS BENEFITS ADMINISTRATION 9. How and where will the records be kept for schools with centralized certification? Records will continue to be kept at each approved location in accordance with the requirements of 38 CFR 21.4209. Records at approved branches/extensions may be kept as originals, certified copies, or in an electronically formatted record keeping system. 16 Approval Requirements/ Procedures

18. VETERANS BENEFITS ADMINISTRATION 10. Will the SAAs in each State the school has a branch location be required to provide the certifying official at the main campus a copy of the approval for the branch in their State? No, the SAAs may provide the main campus with a copy of the approval but will not be required to do so. The main campus official should request and maintain approval information for each approved branch/extension in accordance with the agreed upon responsibilities of the institution (See notification and approval letters). In the event that the main campus is unable to obtain approval information from a branch/extension, the ELR with jurisdiction over the main campus will be responsible for obtaining and providing the information. (Con’t) 17 Approval Requirements/ Procedures

19. VETERANS BENEFITS ADMINISTRATION (10. Con’t) If an institution is frequently unable to obtain information for one or more of it's approved branches/extensions, the ELR may need to review centralized certification approval for that institution to determine if approval should be withdrawn or if a specific branch/extension should be removed from approval. 18 Approval Requirements/ Procedures

20. VETERANS BENEFITS ADMINISTRATION 11. Will the ELR in each state be required to provide the certifying official (located at the main campus) with a copy of reports available in WEAMS? ELRs may, at their discretion, provide requested reports to certifying officials 12. Who is responsible for entering the "associated" branches/extensions in VA- Once? The main campus ELR is responsible for notifying the ELRs with jurisdiction over the branches/extensions of the approval. The ELR with jurisdiction over each branch/extension is responsible for associating the branches/extensions in his or her jurisdiction in VA-Once. ELRs with jurisdiction over branches/extensions should revoke certifying official access for all individuals at those branches/extensions. POCs at branches/extensions should only be granted "view only" access. 19 Approval Requirements/ Procedures

21. VETERANS BENEFITS ADMINISTRATION 20 Sample Letter

22. VETERANS BENEFITS ADMINISTRATION 21 Sample Letter

23. VETERANS BENEFITS ADMINISTRATION 22 Sample Letter

24. VETERANS BENEFITS ADMINISTRATION 23 Sample Letter

25. VETERANS BENEFITS ADMINISTRATION Sample VA Form 22-0831 24

26. VETERANS BENEFITS ADMINISTRATION 25 Approval Sample Letter

27. VETERANS BENEFITS ADMINISTRATION 26 Questions