Jodie Balder NCACVA School Certifying Officials Conference Measurement and Pay Issues Non college Degree (NCD) Programs Jodie Balder Education Liaison Representative US Dept. of Veterans Affairs MARCH 2017

Pre-Certification Schools must ask students to list all previous education and training Do not ask the student if they want any credit transferred in – transcripts are mandatory and the students have no choice in the matter You can see in VA Once if a student was previously certified to VA by another school - must request those transcripts even if the student didn’t list the training Schools must evaluate that education and training for Prior Credit Must obtain official transcripts Even for training for which the student did not utilize VA benefits Schools must grant credit, as applicable, and reduce training time proportionately Notify student and retain in student’s records

Credit for Prior Training Must be obtained! Schools should make every effort to obtain all transcripts: If transcripts have not been received by the time period specified in your SAA approval you will continue to certify the student if they have met your school’s matriculation requirements If the student has not met your school’s matriculation requirements you will not continue to certify the student IMPORTANT: Even if your school’s matriculation policy allows a student to remain enrolled without transcripts this does NOT remove the requirement, for GI Bill® purposes, that they be obtained QUESTION AFTER 1ST SECTION – WHERE DO YOU VERIFY YOUR SCHOOLS TIME LIMITS?

Transcripts What am I required to do? If you have not received official transcripts by the end of the period specified in your SAA approval letter you will not terminate the student’s award however: The law has not changed - obtaining official transcripts is still a requirement of your approval by the State Approving Agency (SAA). All that has changed is that the consequence has been moved from the student (i.e., termination) to the school (approval status of school). If it is found that you are routinely not obtaining official transcripts your SAA approval may be suspended or withdrawn. There is no specific guideline for the suspension or withdrawal of a school for failure to obtain transcripts. The SAA will look at schools on a case by case basis and use multiple factors to determine what action to take.

JOINT SERVICE & MILITARY TRANSCRIPTS If a school is required to obtain Joint Service Transcripts by DoD MOU or school policy then they are should be in the students’ files. If Joint Service Transcripts are not in the file, even if required by DoD or school policy , you will not be cited on a compliance survey Transcripts from military colleges and universities are treated like any other secondary school transcripts. This would include but is not limited to Community College of the Air Force, National Defense University, Army Command and General Staff College If these transcripts are not in the student’s file you will be cited on a compliance survey

Questions 21 #

Clock Hour Measurement Are you reporting the correct hours? VA pays clock hour programs based on an approved finite total number of clock hours: The approved total clock hour length of each program listed in your State Approving Agency (SAA) approval letter VA does not pay based on months, weeks and/or what the school may allow over and above state required hours You cannot certify for more than the SAA approved hours The only exception is if there is documented evidence that a student FAILED a portion of the training and is required to repeat that training Keep track of total hours completed

Clock Hour Measurement Are you reporting the correct hours? Certify the ‘scheduled’ number of clock hours per week (ie the number of clock hours they are contracted to attend each week) not the minimum required to be full-time Certifications should be submitted within 30 days after the start of class Do not report an average number of hours per week Certify the beginning and ending date of the entire program unless your official SAA approved school calendar shows official terms, mods, units or blocks of training You cannot certify arbitrary blocks of training if your official SAA approved calendar does not show those breakdowns Certified hours will be compared with those listed on the enrollment agreement and schedules on compliance surveys

Clock Hour Measurement Are you reporting the correct hours?

How to Determine What Length to Certify Are You Reporting the correct length? Based on the beginning date, ending date and number of clock hours per week, you should not certify a student for more than the approved number of total hours EXAMPLE: Cosmetology program approved by the SAA for 1500 total hours The student has contracted to attend 35 clock hours per week 1500/35 = 42.86 weeks This student will reach the 1500 approved in 43 weeks (43 x 35 = 1505 total hours) SAA and VA will not cite a school if the clock hours certified are in excess of the approved hours for a program by 10% or less. Claims examiners will now check the length upon receipt of a certification and contact the ELR for verification of payment or denial if the hours are in excess of the max You should use the NCD length worksheet Plug in the beginning and ending dates and clock hours The worksheet calculates the max ending date (including an additional 10%) If your ending date is too long, it adjusts it and provides a “New None Date.” You must subtract one day from the None Date on your cert

NCD CLOCK HOUR LENGTH CALCULATION WORKSHEET The worksheet shows that for a 1500 program @35 c lock hours per week, certifying for one year is 35 days too long (this figure includes the additional 10% allowed for approved absences), as it equates to a total of 1825 hours. The worksheet calculated the correct “New None Date” of 12/11/15. As a None Date is the 1st day not payable you would certify this student through 12/10/15. On 12/10/15, VA will have paid the student a total of 1650 hours (1500 + 10%).

PLACE THIS CALCUATION SHEET IN ALL VA STUDENTS FILES ** HAVE STUDENTS INITIAL THE WORKSHEET ** It will be checked for and used on compliance surveys BRING WORKSHEET OUT DURING PROGRESS REVIEWS SO SEE WHERE STUDENT IS IN RELATION TO WHERE THEY NEED TO BE.

Independent Study/ Online Training Prohibited!! Courses/programs taught in whole or in part in an independent study, online, distance learning, hybrid or blended format are not approved at any NCD school This also means that study labs where the students come in when they want to during certain hours, cannot be approved All courses approved at NCD schools must strictly be offered in a traditional classroom, laboratory or shop setting (i.e., students physically in the same room at the same pre- scheduled time with a live instructor)

Training Time ~ non CH33 Chapters

Ch33 Rate of Pursuit Clock Hour Measurement Rate of Pursuit (ROP) – CH33. Calculated by dividing hours pursued by the number of hours considered to be full-time by the school. The resulting percentage is the student’s rate of pursuit (ROP).

Questions 21 #

Attendance & Progress Policies Why they are important The GI Bill® is intended to help someone make the transition from military to civilian life by preparing them to enter positions in the job market.

Attendance & Progress Policies Know them! One size does not fit all – the length of the course/program will be used by the SAA to determine how often you must monitor and enforce. Know and understand your SAA approved attendance and progress policies Often times, they are different than the policy for your Non VA students

Attendance & Progress Compliance Surveys Although changes to weekly attendance are not reported by the school and will not be cited on a compliance survey: The person conducting the compliance survey will be looking closely at your attendance and progress standards and each students’ fulfillment of both If discrepancies are found regarding certifying beyond the approved length or lack of termination for violation of attendance/progress standards the school will be cited Overpayments will be created on the school and/or student The schools VA approval can be suspended or withdrawn

Standards of Progress Monitor and Enforce! Ensure you are monitoring VA students’ progress Your catalog and/or SAA Approval will tell you at what points in a student’s training progress must be evaluated VA student’s enrollment must be terminated for not achieving satisfactory progress Law requires VA educational benefits be terminated when student fails to make satisfactory progress toward completion of training objective (Title 38, USC, Section 3675(b)(1)) Report termination for unsatisfactory progress through VA-ONCE If your policy allows for probation/warning there must be a clear, definite point in time when: A VA student will be placed on probation/warning (cannot be indefinite) Report probation/warning through RightNowWeb (RNW)

Standards of Progress When & How to Terminate in VA Once For unsatisfactory progress: SAA approval generally does not allow for certification of a student for more than two consecutive months while they are not meeting progress standards CHECK your individual SAA Approval for specifics for your school Terminate the cert and report the last day attended prior to violating the standards of progress policy (LDA/EFF box) Choose “unsatisfactory attendance, progress or conduct” from the drop down menu for reason

Attendance Policy Monitor it! Ensure you are monitoring VA students’ attendance Programs measured on a clock hours must maintain attendance records for each class A student’s schedule an attendance record and is not sufficient for this purpose Maintain detail in file: We must see a record of every day the student was scheduled; the number of hours per day the student was scheduled; and how many hours the student actually attended Excused absences and LOAs must be documented All instructor-led classes must have a roll book or other record maintained by the instructor to verify each student’s attendance Often, a physical sign-in sheet is used for this purpose and is sufficient as long as the class instructor maintains constant control over it and actually observes the student signing in

Attendance Policy Adjusting & Terminating Clock hour programs are to be certified based on “scheduled” hours of attendance Adjustments based on weekly changes in attendance are no longer reported to If the student misses classes (due to their own fault), the school should apply its SAA approved attendance policy as appropriate: IMPORTANT: As VA is paying for these missed days, no extension to the end of the period certified is allowable If you extend their end date based on missed class days for which VA has already paid the student, you are in effect certifying the student for those hours twice These types of missed hours are why VA allows for a 10% overage above the approved length and should be adequate to cover an allowable amount of missed classes IMPORTANT: Not only are you not allowed to extend the student’s length of training certified to VA, you cannot bill VA for any additional T&F charged to a student who has not completed the required hours by the end of the contracted or certified period

Attendance Policy Adjusting & Terminating Schools are required to enforce their attendance policies and terminate the student accordingly if the student is not meeting published attendance standards as approved by the SAA and shown in your SAA approval letter: You cannot repeatedly put a student on LOAs so that they don’t appear to violate your approved attendance policies.  Terminations due to unsatisfactory attendance are submitted via VA Once and “Unsatisfactory Attendance, Progress or Conduct” should be chosen from the drop down menu in VA Once when terminating. Schools are required to terminate a student’s certification with VA within 30 days of the date on which the student stops attending a program The LDA/EFF date will be the last date attended whether they officially withdraw or just stop showing up for classes

Leave of Absence (LOA) LOAs must be treated differently for Non CH33 and CH33 students. If a student misses 14 or more consecutive class days (and the school was open and class was available) you have to: NON CH33: a. “Terminate” the cert effective the last date attended b. Do a brand new cert if/when the student returns. c. report the return date as the begin date and the modified completion date (if their ending date has been extended) as the end date for the cert d. You cannot extend the student for a longer period of time than the length of the LOA e. You cannot extend past the approved program length CH33: You have to “adjust” the cert I sent a power point that shows you how to submit a CH33 LOA Ask me for it if you do not have it and I will email it to you

When & How to Graduate a Student in VA Once You are not required to report graduation data but it is highly recommended, as this data is being used to provide GI Bill Outcome Measures for the GI Bill Comparison Tool that students use to choose a school For a completion/graduation date equal to the end date certified: EX: You certified the student from 1/15/15 – 12/11/15 & the student graduated on 12/11/15 Terminate the cert for ‘End of Term or Course’ effective 12/11/15 (LDA/EFF box) For a completion/graduation date prior to the end date certified: EX: You certified the student from 1/15/15 – 12/11/15 & the student graduated on 12/02/15 Terminate the cert for ‘End of Term or Course’ effective 12/2/15 (LDA/EFF box) For a completion/graduate date after the ending date certified: Only allowed with a documented failure or LOA reported to VA: EX: You certified the student from 1/15/15 – 12/11/15 & the student graduated on 1/15/16 Amend the ending date to reflect the correct extended end date (not to exceed approved length) May have been done during report of LOA Then terminate for “End of Term or Course’ effective last date attended (LDA/EFF box)

Last Dates of Attendance When Not to Graduate in VA Once You should not report graduation data at all for the following students: If the student didn’t complete his/her program until after the end date certified to VA Example: Student certified from 1/15/16 - 12/11/16 & on 12/11/16 they had not completed their required 1500 hours due to missing classes. They finally graduated on 05/23/17. If the student reached his/her delimiting date before graduating Example: Student was certified through 6/17/17 but reached his/her delimiting date on 3/15/16 (ie the date on which they are no longer eligible for VA benefits). If the student exhausted his/her entitlement prior to graduating Example: Student was certified through 6/17/16 but VA entitlement exhausted on 2/10/16.

Questions 21 #

Certifying Tuition Are you reporting the correct dollar amounts for Chapter 33? Non Ch33 students: You do not need to certify T&F unless they are on active duty or training at less than ½ time. CH33 students: Certify the net tuition and allowable fees NET Tuition is the amount of tuition remaining after deducting: Any school, local, state, private aid etc that can only be used toward T&F If it can be used towards other things such as books, room, board etc it does not have to be deducted Any Federal Funds, other than Title IV Financial Aid, such as: MYCAA ROTC Scholarship GETA Title IV Financial Aid (Pell Grants, Stafford Loans etc) do not need to be deducted Loans from any source do not need to be deducted

Certifying Tuition Are you reporting the correct dollar amounts for Chapter 33? For CH33 students certify only allowable fees can be certified Validity of Fees - Before a fee can be certified to VA it must meet the requirements stated below: Be listed in the school’s approved catalog as a fee; Be listed on the student invoice/payment ledger as a fee; Be listed in the enrollment agreement/contract between the student and school as a fee; and Be “mandatory” or otherwise “required” of all similarly circumstanced students

Certifying Tuition Are you reporting the correct dollar amounts for Chapter 33? Validity of Fees (cont.) A school charges a fee for a kit/book, but allows students to purchase items in that kit or that book on the open market This fee is not mandatory and cannot be certified to VA A school charges for a kit/book and will not allow any student, under any circumstances, to have fee waived if they purchase the items on the open market This kit/book can be certified as a fee to VA This policy must be clearly stated in your catalog/contract etc

Questions 21 #

Tuition & Entitlement Charges Chapter 33 Entitlement is charged differently at stand alone NCD schools than it is at IHLs THE RULE: If T&F are certified entitlement is charged based on T&F paid Academic cap = 12 months of entitlement One Day of Entitlement Used = Academic Year T&F Cap/360 days (30 day months) $21,970.46/360 = 1 day of entitlement for each $60.03 paid If no tuition and fees are certified, entitlement will be charged based on the rate of pursuit (ROP) Days of entitlement charged = Payable ROP (not rounded) multiplied by the Payable Days divided by 30 Student enrolled for 4 months at FT uses 4 months of entitlement

Certifying Tuition ~ Not on a terms Chapter 33 Example: First student enrolled FT 8/10/15 – 3/10/16 with T&F of $3,000. Student is enrolled at 100% ROP/FT for about 7 months, VA will charge the student about 1 ½ months of entitlement $21,970.46/360 = 1 day of entitlement for each $60.03 paid $3000/$60.03 = 49.97 or approximately 50 days entitlement Second student enrolled 8/10/15 – 3/10/16 with T&F $22,000 Student is enrolled at 100% ROP/FT for about 7 months, VA will charge the student about 12 months of entitlement T&F are higher than the cap of $21,970.46 Cap of $21,970 .46 is paid so 12 months entitlement charged STUDY THIS!!!

Tuition & Entitlement ~ Not on Terms Chapter 33 If a school does not charge all tuition up front Tuition certified to VA should be submitted in the same increments as which it is billed to the students Important because if school bills in increments but certifies all charges to VA up front, then the student drops, VA will charge the student with a large debt for tuition and fees that have not actually yet been charged Once the student is billed, amend the certification to increase the T&F certified THINK ON THIS ONE!!!

Certifying Tuition ~ Not on terms Chapter 33 Example: Program runs 1/15/15 – 12/14/15 $15,000 total net T&F School bills the students $5000 at the each of the 1st 3 quarters INITIAL CERT: School will certify 1/15/15 – 12/14/15 and $5000 T&F School will amend the cert when student is billed on 4/15/15: Amend the cert and report $10,000 T&F LDA/EFF date = 1/15/15 VA will send the school $5,000 T&F (or % due if student is less than 100% eligible) School will amend the cert when the student is billed on 7/15/15: Amend the cert and report $15,000 T&F

Tuition & Entitlement Charges Chapter 33 Entitlement is charged differently at stand alone NCD schools than it is at IHLs AGAIN, THE RULE: If T&F are certified entitlement is charged based on T&F paid Academic cap = 12 months of entitlement One Day of Entitlement Used = Academic Year T&F Cap/360 days (30 day months) $21,970.46/360 = 1 day of entitlement for each $60.03 paid If no T&F are certified, entitlement will be charged based on the rate of pursuit (ROP) Days of entitlement charged = Payable ROP (not rounded) multiplied by the Payable Days divided by 30 Student enrolled for 4 months at FT uses 4 months of entitlement

Certifying Tuition ~ Schools on a term Basis Chapter 33 If a school charges all tuition up front: T&F certified should be prorated between enrollment periods Important because of the way entitlement is charged: If one term/mod lists all T&F for an entire program, entitlement is charged based on T&F certified If subsequent terms/mods are certified with no T&F, entitlement will be charged based on the rate of pursuit for those terms/mods -Results in VA student’s entitlement getting hit twice Prorating tuition between the enrollment periods also allows VA to calculate the correct amount of a payment/overpayment if there is a change in the enrollment ASK HOW MANY SCHOOLS ON TERMS/MODS ETC AND HOW MANY HAVE ONE ENROLLMENT PERIOD?

Certifying Tuition ~ Schools on a term Basis Chapter 33 EXAMPLE: Multiple Periods of Enrollment Student enrolled FT and all T&F for the year are charged up front: Sept 15th – Dec 14th 30 clock hours $3,000 reported to VA Jan 15th – May 14th 30 clock hours No T&F reported May 15th – Sept 14th 30 clock hours No T&F reported First Term Charge: Approx. 1 ½ months of entitlement Based on total T&F of $3,000 ($3,000 divided by $60.03 = 49.97 days used) Second & Third Terms: 4 months for a total of 8 months entitlement As there are no T&Fs paid for the other 2 terms VA charges entitlement based on Rate of Pursuit (1 month for each month enrolled)  TOTAL ENTITLEMENT USED: 9 ½ months of entitlement 1 ½ months for the first term + 8 months for terms 2 and 3

Certifying Tuition ~ Schools on a term Basis Chapter 33 Same student enrolled FT for the following periods and charges: Aug 15th – Dec 14th 30 clock hours $1,000 T&F certified Jan 15th – May 14th 30 clock hours $1,000 T&F certified May 15th – Aug 14th 30 clock hours $1,000 T&F certified TOTAL ENTITLEMENT USED: 1 ½ months $1,000/ $60.03 = 16.65 days of entitlement each term 16.65 x 3 TERMS = 49.95 total days or approx 1 ½ months Student charged approx. 8 months LESS entitlement

Questions 21 #

Quiz Time! 21 #

Certifying T&F Scenario #1 – A student is pursuing a certificate program which costs $20,000 and the program is broken into 5-week terms. The school is actually billing the student $20,000 on the first term. Question #1: Should the school report $20,000 on the first term, or divide the total cost of the program by the total number of terms and report the amount from the calculation on each term certified?

Certifying Modular Programs Answer #1: The School should not report $20,000 on the first term for the entire program. The school should break-up the tuition and fees and apply them to each term proportionately. Why? The student will be charged entitlement twice. First on the T&F and then on ROP.

Extended Term Dates Scenario #2 – A student is pursuing a 1500 hour program over 53 weeks. The student does not complete the required 1500 contact hours by the end of the 53 week period due to his/her inability to commit to full time attendance. Question #2: Should the school extend the end date for the term certified to the VA to compensate for the extra time needed to complete the required contact hours?

Extending Term Dates Answer #2: The School should not report a change in end date for the program as the student has already been paid for the approved number of hours in the program. We will pay a student to be in the classroom for the approved program hours and no more. If the student had an LOA reported to VA, you can extend the student for the length of the LOA up to the approved number of hours. We will still pay a student to be in the classroom only for the approved program hours and no more.

Reportable Fees Scenario #3 – ABC Beauty College requires that all students purchase a supplies kit for their certificate program. This kit includes two textbooks that ABC College writes and can only be purchased at the school. Question #3: Can the SCO certify the supply kit as fees even though it contains textbooks?

Reportable Fees Answer #3: Yes the SCO can certify that supply kit as fees if ALL students are required to purchase that kit and the textbooks can not be purchased ANYWHERE else. In addition, the supply kit fee must be specifically labeled as a fee in the catalog, enrollment agreement, and student payment ledger

School Resources Education, Training & Information GI Bill website: http://www.benefits.va.gov/gibill/ (for schools and veterans) Education Call Center: 1.888.442.4551 (veterans and dependents) SCO Hotline: For SCO use ONLY VA Debt Management Center: Phone number: 800.827.0648 Email address: dmc.ops@va.gov Right Now Web~RNW (VA’s Internet Inquiry System in the “Ask a Question” section of the GI Bill website): https://gibill.custhelp.com/app/utils/login_form/redirect/ask (for schools and veterans) Status of individual unusual/complex cases Individual cases that have been pending for a longer than usual time Hardship cases Written response