North Carolina State Approving Agency North Carolina State Approving Agency Dr. Joseph Wescott II, Executive Director, NC SAA

North Carolina State Approving Agency History 1944FDR signs GI Bill of Rights 1945Congress recognizes responsibility of States to determine education of their citizens Late State Approving Agencies created; 1940’soverseen by Governor, but funded by the VA TodayA cooperative and successful combined federal-state program!

North Carolina State Approving Agency NC SAA Staff  Joseph Wescott II, Executive Director  Program Specialists ○ Elizabeth Kelly ○ Jay Fitzgerald ○ Meghan-Joy Woodall ○ John Pritchett  Jenne Herbst, Program Assistant

North Carolina State Approving Agency The Players  The “Triad” ○ VA ○ SAA ○ Institution/SCO  Other players ○ ED ○ DoL ○ FAA ○ Accrediting agencies ○ State L&C agencies And of course--THE VA-ELIGIBLE STUDENTS Mutual trust, Mutual dependence! Mutual trust, Mutual dependence!

North Carolina State Approving Agency It Takes A Team!  SAA & VA collaborate to help you ○ Interpret laws and regulations ○ Maintain integrity of programs ○ Train the SCOs ○ Encourage greater use of VA benefits ○ Help your school better serve veterans! Education Liaison Rep (ELR) State Approving Agency (SAA) Regional Processing Office (RPO) VA Central Office (VACO) VA School Certifying Official (SCO)

North Carolina State Approving Agency NC SAA  To ensure quality instruction, appropriate administration, and fair and equitable practices for every veteran (and eligible person) who enters a NC SAA-approved educational program.  We do this by: o Validating and approving educational courses and programs to be pursued by veterans and eligible persons o Overseeing North Carolina’s educational institutions, and ensuring compliance with federal and state guidelines o Ensuring the interests and prerogatives of the State are preserved in both processes Mission & Responsibility

North Carolina State Approving Agency NC SAA Program Specialists’ Assignments*  All: Public and Private Universities, Community Colleges  Elizabeth Kelly: On-Military-Base, Truck, Beauty, Barber  Jay Fitzgerald: Religious Exempt Institutions & Nursing  Meghan-Joy Woodall: Trade, Business, Hospitals, Massage  Joseph Wescott: Flight, High Schools, L&C, new applications * Note: Some assignment overlap occurs based on workload

North Carolina State Approving Agency Approvals  Evaluate educational programs for approval  Provide written evaluations and approvals to VA and the schools Inspections and Compliance Survey Visits  Visit and inspect each new/active educational institution  Confirm compliance for approved courses and programs Technical Assistance  Respond to institutional and veteran requests for information and assistance  Provide written reports to DVA, as requested  Maintain records and files for the State of North Carolina Our Partnership with You NC SAA

North Carolina State Approving Agency NC SAA This is THE document that actually conveys State / DVA approval for educational programs to be considered for payment under the GI Bill®. Your Approval contains…  General information about your school  Programs and hours that are approved (or EXCLUDED…)  Calendars, tuition and fees  Unique programs or policies (Remedial / Branches, others…)  Requirements specific to your institution  Note last calendar date approved The Approval

 Remember: o Every approval is different! It is specific to your school or institution, and is based upon your catalog and applicable state and federal law. o You should read/review your approval annually, and comply daily. o Many of your questions are answered here. Keep it handy! The Approval, cont. NC SAA

 Foot Stomp: o Most approvals must be re-approved annually. o Submit re-approval application, including new catalog, calendar dates, T&F, etc., by date listed in last approval, or as soon thereafter as possible. o Contact your program specialist if re-application will be late. o Follow instructions included with application (guidelines & checklist) o Two copies of catalog/handbook/bulletin & certifications o Single-sided application documents o Accreditation and licensure information, as applicable The Approval, cont. NC SAA

 The Addendum… o A unique NC SAA Form that contains…  The General Information section from the Approval, AND  A specific change to the Approval o Corrects or changes some portion of an Approval o Examples:  Changes to the academic calendar date (after published)  Change of policy in Requirements section  Delete/add a program or change the hours approved for a program The Approval, cont. NC SAA

 The Addendum… o Addenda are mailed or ed to you, with instructions o Supersedes the original information in the Approval o Print a copy of the Addendum and add it to the Approval o Comply with the Addendum changes, as well as basic approval requirements The Approval, cont. NC SAA

North Carolina State Approving Agency Computer based remedial content may be certified if it meets the following conditions: o It is delivered in a classroom on campus (set time and place). o Attendance is taken. o An instructor is present at all times to facilitate and answer questions. o Coursework is organized in such a fashion that students are working on the same material during the class period. Remember: Remedial courses may not be certified if they are offered as independent study, distance learning, or hybrid course delivery. Remedial Training Also Note:

 Prior Credit  High School Transcripts  Continuing Education  Study Abroad  Contract Programs  Proprietary For-Profit Schools & Financial Incentives  The DVA Form Important Special Interest Items NC SAA

Prior Credit/Prior Post-Secondary Transcripts  By law, must be evaluated and recorded  Statutes: 38 USC §3675(b)(2) and 38 USC §3676(c)(4)  Regulations: 38 CFR (c)(3) and 38 CFR (c)(4)  This means you must have transcripts of all previous training and proof of prior credit evaluation in the student file  “institution maintains a written record of the previous education and training of the eligible person or veteran that clearly indicates that appropriate credit has been given by the educational institution for previous education and training, with the training period shortened proportionately” (38 USC §3675)  NC requirement: transcripts must be official Important Special Interest Items, cont. NC SAA

Prior Credit  Military Transcripts:  Obtain them in accordance with your applicable school policy  If your institution has signed the DoD MOU, then you must obtain military transcripts, and they must be evaluated for possible transfer credit  If a student has attended degree programs through the military (e.g., Community College of the Air Force), then you must obtain official copies of those transcripts, regardless of your school policy, and evaluate for possible transfer credit Important Special Interest Items, cont. NC SAA

High School Transcripts: Are they required?  Depends on your school and on your Approval…  If HS transcripts document “part” of admission process, YES! ○ Schools that teach degree / IHL programs generally require HS transcripts for new (freshmen) admissions ○ Private and Proprietary schools are “generally” required to meet State standards  NCD / Diploma / Certificate programs generally require “proof of high school completion” OR “ability to benefit” Important Special Interest Items, cont. NC SAA

North Carolina State Approving Agency Continuing Education Courses  Generally these courses are not approved.  Few exceptions: state licensed, state mandates, etc. (e.g., BLET)  To be approved:  The course must lead to a vocational objective, i.e., a job.  In North Carolina: Course administration must meet requirements of 38 USC §3676 (approval of nonaccredited programs) Important Special Interest Items, cont.

North Carolina State Approving Agency NC SAA Important Special Interest Items, cont. Study Abroad  “Approval” versus “Certification”  Approval does not mean all associated tuition and fees can be certified  New “Requirements Specific” statement: “Study Abroad is approved when the program of the “host” school in the foreign country is approved. VA can pay the home school’s tuition, up to the resident maximum allowed; or up to the national resident maximum tuition and fees (when the student is required to pay the host school). VA can provide monthly housing allowances if the student is enrolled more than half time. VA cannot pay any fees specific to studying abroad unless the student is required to study abroad as a part of their program. But if the student is required to pay the host school directly the tuition and fees charged by the host school, no fees solely related to the study abroad are payable even if the course is required to be done abroad. Refer to the SCO handbook and VA guidance on the GI Bill website for Study Abroad fee details and limitations.”

North Carolina State Approving Agency Contract Programs  You must notify NC SAA of all programs/courses provided under contract by a third party (excluding adjuncts): o Both the contractor and host institution must be approved.  Questions of academic quality control, awarding of credit, certification and records management. Proprietary For-Profit Schools & Financial Incentives  New “Requirements Specific” statement: “The Institution hereby assures the NC SAA that it does not provide any commission, bonus, or other incentive payment based directly or indirectly on success in securing enrollments or financial aid to any persons or entities engaged in any student recruiting or admission activities or in making decisions regarding the award of student financial assistance. ” Important Special Interest Items, cont. NC SAA

North Carolina State Approving Agency VA Form “Designation of Certifying Officials”  When there are changes, submit a new form to DVA and a copy of same to NC SAA.  Be sure to include full contact information for each certifying official o Name, phone and fax number and address for each certifying official in the appropriate box. o The Approving Official must sign box 7. Important Special Interest Items, cont. NC SAA

North Carolina State Approving Agency NC SAA ○ NC SAA assists DVA with this responsibility ○ Former “Supervisory Visits” were more focused on SCO training and process improvement ○ Compliance Surveys are primarily an audit of federal entitlement program; focus shifted from academic programs to more emphasis on financial side Compliance Surveys

North Carolina State Approving Agency NC SAA  NC SAA schedules visits with the institution  NC SAA Program Specialist conducts on-site visit reviewing: ○ Process Management (prior credit evaluation, timeliness/accuracy of certifications, attendance, etc.) ○ Records Management (required documentation is present)  Visit reports maintained at NC SAA with copy sent to DVA  Inspection discrepancies (if any) require resolution with documentation of corrective action to NC SAA (approval issues) or referral to DVA (payment issues).  Auditor will request copies of discrepancy evidence (transcripts/ledgers)  Expanded audits:  ≥ 30% Financial discrepancies  ≥ 50% Discrepancies of any type Compliance Survey Process

ADMISSIONS/REGISTRATION DOCUMENTATION A.Copy of student’s Application for Admission B. Copy of high school transcript for Entering Freshman and Transfer Students C. Copies of transcripts for all post secondary education with chosen Curriculum “Transfer Credit” clearly documented. D. Copy of student’s current Curriculum with: (1) All to- date credits and transfer credits clearly identified and, (2) If applicable, a prior credit re- assessment if student changes programs with new Curriculum record annotated accordingly. E.Copy of Remedial/Deficiency test scores (if applicable) F. Copies of Student Schedules with “non-Curriculum” course selections, i.e. not VA benefit eligible, clearly identified. G.Copies of completed Drop/Withdrawal forms H. Copies of Plan of Study course substitution approvals (if applicable) I.Copy of current academic transcript J.Copy of student ‘Attendance Records’ for clock-hour programs VA DOCUMENTATION a) (Optional) Copy of Application for VA Education Benefits (VA Form 1990) if available b) Copies of all Enrollment Certifications (VA Form ) to include Remedial/Deficiency CH (if applicable) identified separate from Curriculum CH c) Copies of all Changes in Student Status (VA Form 1999b); Amend, Adjust, Terminate d) Copies of Request for Change of Place of Training (VA Form 1995/5495) e) (Optional) Copies of DD-214s, Certificate of Eligibility and NOBEs as available f)Reporting fees usage Record Keeping Requirements

North Carolina State Approving Agency NC SAA  Summary of certain SAA-related changes to Post 9/11 GI Bill® provisions  P.L – Veterans Access, Choice, & Accountability Act of 2014 (The Choice Act) Changing Laws, Changing Roles

North Carolina State Approving Agency Post 9/11 GI Bill®  Became effective on August 1, 2009  A complex program! ○ Many levels of eligibility ○ Confusing concurrent eligibility ○ New benefits similar to original WW II GI Bill ○ Difficult to understand and administer  SAAs took on new “consultant/trainer” role

North Carolina State Approving Agency Summary of SAA- Related Changes  Public Law : Became effective October 1, 2011 o More programs now covered by Post 9/11 GI Bill® ○ More potential beneficiaries ○ A “Game-Changer” for SAAs  Changed State/Federal approval authorities o Accredited public & non-profit degree programs “deemed” approved without continuing State review o SAAs retained jurisdiction over for-profit schools, and Non-College Degree (NCD) programs at all schools o Approval AND disapproval authority given to U.S. Secretary of Veterans Affairs  SAAs acquired new role of assisting VA with Compliance Surveys Effective October 1, 2013, all requirements for approval of non-federal institutions go to NC SAA

North Carolina State Approving Agency Signed into law August 8, 2014 Primarily addresses veterans’ health matters Expands Fry Scholarship eligibility to spouses Effective January 1, 2015 Entitlement expires 15 years after service member’s death or the date the spouse remarries, whichever is earlier If also eligible for Chapter 35 (DEA), must make irrevocable election of one chapter Veterans Access, Choice, & Accountability Act of 2014 P.L

North Carolina State Approving Agency Choice Act, Section 702: Public IHLs and In-State Tuition Beginning July 1, 2015: Cannot approve programs for which “covered” students, regardless of residency, are charged T&F that are higher than the in-state rate “Covered individuals” are Ch 30 and Ch 33 vets discharged or released from active duty (≥ 90 days) less than 3 years before enrollment in the program, and Ch 33 Fry Scholarship beneficiaries and TOE recipients But: IHL may require covered individual to demonstrate intent to become resident Can require any type of proof of intent except “physical presence” Became NC Law § A on June 24, 2015 Veterans Access, Choice, & Accountability Act of 2014 P.L , cont.

North Carolina State Approving Agency NC General Statute A Waives 12-month residency requirement for in-state rate VA student is eligible for in-state rate if he/she applies for admission & enrolls w/in 3 years of discharge or release, qualifies for & uses Ch 30 or Ch 33 benefits, has a North Carolina abode*, and provides the IHL a letter of intent to establish residence in NC. Applies to Section 702 “covered individuals” and any other Ch 30 & Ch 33 recipients who meet the above requirements Eligibility continues after expiration of 3-year period so long as continuously enrolled (regularly scheduled breaks are OK) *“Abode” means the place where a person actually lives, whether temporarily or permanently Section 702,cont.

North Carolina State Approving Agency Pending Legislation HR 456 – Reducing Barriers for Veterans Education Act of 2015 o Would allow CH33 to be used for application fees at IHLs HR 476 – The GI Bill Education Quality Enhancement Act of 2015 o Clarification and codification of approval authority (“deemed approved)” o Capping tuition and fees for flight programs o Changing requirements for Compliance Surveys

North Carolina State Approving Agency NC SAA Responsibilities include:  282 separate institutions of learning, plus 45 branch locations Our Service to You:  Conducted 77 Compliance Survey visits  Processed requests for new approval, resulting in 10 new institutions  Reviewed and completed 338 applications for program re-approval (new catalogs)  Evaluated and approved over 1,000 individual programs Hundreds of technical assistance phone calls, meetings, and s  *Between October 1, 2014 and September 30, 2015

North Carolina State Approving Agency Thank you! Any (more) questions?