Compliance Survey Overview

Topics to cover Overview and purpose Obtaining Samples School Notification Prep work Entrance Interview Document Review Standards Reviewed Submission of Referrals Exit Interview Post Survey

Compliance Survey Objectives: Overview and Purpose Compliance Survey Objectives: Verify the accuracy of payments to educational beneficiaries. Assist School Officials in better understanding their responsibilities. Identify, through documentation review, deviations from responsibilities. Ensure proper action is taken to correct discrepancies. Administered to ensure that training establishments are in compliance with Federal law. Part of a spectrum of activities put in place to prevent violations. Purpose of all these activities is prevent, identify, and correct deficiencies.

Obtaining Samples Master List- Where to go and when/Total # of active students ARF Report- List of students certified in calendar year Reporting Fee- Payment sent to a facility for reporting enrollment Sample Size Calculator- Provides specific # of benefit type to review Spreadsheets you will need: CS Master List ARF Report/Sample Size CS Sample Size Calculator

Step 1: Review the CS Master List

Step 2: Determine # of Files to Review

Step 3: ARF Report/(STATE)Sample Size Number of Students by Chapter: Chapter 33- 225 Chapter 35- 78 Chapter 30- 10 Chapter 1607- 20 Chapter 1606- 30

Step 4: Enter Totals Into Calculator Number of Students by Chapter: Chapter 33- 225 Chapter 35- 78 Chapter 30- 10 Chapter 1607- 20 Chapter 1606- 30

School Notification Notify the school of the date and time. Provide adequate notice. Submit formal notification: Notification letter Compliance Survey Checklist List of student record(s) to be reviewed POE questionnaire, if applicable Encourage the school to correct any discrepancies prior to the visit. SAA’s- Inform your ELR about the visit.

Prep Work Access VA Systems to produce award history. LTS, BDN, TIMS, VA-Once Redact PII. Print a copy of the WEAMS Report. Print and review prior survey, if applicable. Complete a 22-1936 Compliance Survey Worksheet for each student.

Long Term Solutions (LTS) For Chapter 33 students only Prepare Work Product Summary (WPS) Reports WPS Report can be used in lieu of BDN Provides: Entitlement Award History Payments to the School Books and Supplies Enrollment History

Benefits Delivery Network (BDN) Provides information for all non-Chapter 33 students. M21- Record Status M22- Payment History M23- Claimant Transaction M24- School Transaction M01- Receivables

VA Online Certification of Enrollment (VA-ONCE) Print 22-1999 and 22- 1999b’s Only go back 3 years Watch for Facility Codes If school is not signed up for VA-Once, print copies from TIMS.

The Image Management System (TIMS) Provides scanned images of 22-1999 and 22- 1999b’s Review for: Denial of Benefit Letters Award Letters Communications between student/school/VA

Complete Compliance Survey Worksheets Prepare a separate worksheet for each student. Save copies electronically. Leave “Findings” section blank to complete during visit. Add remarks that may help later, such as effective dates of changes.

Web Enabled Approval Management System (WEAMS)

Entrance Interview Some questions to ask: Are you using VA-Once to certify enrollment? Are any VA students receiving scholarships or grants? Does the school charge any fees that are not mandatory? Have you submitted any changes since being notified of the survey? Has the school added/removed any Certifying Officials? No specific template, be yourself! Greet the SCO and explain the Compliance Survey process. Provide any updates to on reporting procedures. Quick review of a sample student record to verify contents.

Document Review Institutional Records for Review Types of and evidence of institutional advertising Updated 22-8794 Designation of Certifying Official form Current Catalog and student handbook Copy of current student enrollment agreement or contract if appropriate NCD programs as necessary – weekly scheduled hours of instruction VA Form 22-1919 Conflicting Interest Certification for private institutions as appropriate Non VA student record review to confirm charges same or similar to VA student enrollment

Document Review Institutional Records for Review Institutional monitoring systems Institutional tracking systems Total student enrollment count 85/15 compliance Power of Attorney disclaimer (prohibited) Method of instruction (on line, hybrid, blended, practical) Student has applied and been accepted Matriculated into approved program/objective Non-accredited Institutions – Restrictions on modality of instruction Pro-rata refund of unused tuition Timely refunds of unused tuition

Standards Reviewed -Records and accounts of VA beneficiaries and other students must be provided for examination -Did the student begin when certified? -Date certified must agree with start date -Is the correct program certified? Program certified must be the same as what the VA beneficiary is enrolled in and pursuing -Is There Prior Credit? Record and evaluation of all previous education and training must be maintained in files -Records of enrollment, correspondence lessons serviced, flight training hours or OJT/APP hours must be accurate, current and complete GUIDANCE Review checklist provided to you by SAA or VA (whoever is conducting the visit) Ensure all items are addressed Ask questions if unsure Must have records available at time of visit (38 CFR §21.3030, 21.5131, 21.7130, 21.7630, 21.9710) Review transcript, registrar records, enrollment agreement Monitor WEAMS (22-1998) reports Ensure program certified is exactly as appears on WEAMS (38 CFR §21.4253, 21.4254, 21.4263) Must review and evaluate acceptance of prior credit after no more than two semesters (or equivalent). If additional information is received at a later date, the evaluation can be revised. The school must maintain a written record that clearly indicates that appropriate previous education and training has been evaluated and granted, with training time shortened and tuition reduced proportionately, and the VA and the veteran so notified (mandatory – not a suggestion!) Review all transcripts from previous institutions Review VA Forms 22-1990, 22-5490, 22-1995, 22-5495 for indication of any previous education & training Take note of previous institutions in VA Once Review school application or other documentation Record prior credit submitted and total granted

Standards Reviewed Detailed Records of Tuition and Fees -Must be assessed for each student Chapter 33 students – this will include all charges to the student’s account, all payments/credits to the student’s account from VA and all other sources including institutional, private, federal and other financial aid program -Must be detailed enough to determine the source of all charges and credits/payments, including how charges were determined and payments were credited -The term in which any charges/payments/credits occur should be clearly identified and linked to the appropriate dollar amount -VA payments and refunds should be clearly labeled as such

Standards Reviewed Attendance (programs approved in clock hours) -Records must be maintained, monitored and policies enforced -Records should be based on daily attendance (positive attendance as opposed to negative attendance records) -Once it is determined a student failed to meet attendance standards, the SCO MUST terminate the student’s enrollment certification. -Monitor attendance to ensure compliance with reporting within 30 days

Standards Reviewed Timeliness -All certifications must be submitted within 30 days of the latter of any of the following three (3) things: Start of the term End of drop/add Veteran’s request for certification of benefits *If at a school where students frequently change schedules, consider advising the SCO to certify closer to or after drop/add, although changes made during this period must be reflected. *If the certification is submitted within 30 days of the veteran’s request, the request must be documented in writing through a veteran’s request form.

Standards Reviewed Was this reported to VA? -Terminations or interruptions in training must be promptly reported to VA (38 CFR §21.4203, 21.7156, 21.9735) *Encourage the SCO to develop a system or mechanism (internal audit, report) in place to identify when students withdraw/terminate or interrupt training *Last dates of attendance must be identified during compliance survey visits and notification must be made to VA within 30 days of the student’s last date of attendance *Maintain drop and withdrawal slips in file

Standards Reviewed Have adequate records of progress and grades been provided? -Accurate, current and complete records of progress or grades must be maintained for VA beneficiaries *Unofficial transcripts and/or progress (grade) reports should be monitored to ensure students are meeting satisfactory academic progress -Did the SCO promptly notify VA when satisfactory progress was not made? *Unofficial transcripts should be monitored to ensure students are meeting satisfactory academic progress *Documentation in files (e.g., letters of probationary status, suspension) *SAP must be monitored and the school’s approved policy enforced (i.e., students must be suspended/dismissed in strict adherence with your approved policy )

Submission of Referrals Complete a Compliance Survey Referral form. Scan the document and email to: ESUOUTREACH email for your region. To be used in the following instances: School not using or locked out of VA-Once Potential school liability If enrollment was terminated Expanded survey

Steps for submitting referrals through VA-Once Send it through VA-Once Have the SCO initiate an adjustment, amendment, or termination, per usual. Modify remarks- Add Standard Remark “Upon completion of award send overpayment or underpayment amounts to…” Enter your email address.

Select the Student Selecting the Student

Open the “Certs” Tab

Click on the “Certs” Dropdown & Select Modification

Enter Correction and Required Info

Add CS Remark and Submit

Exit Interview Before We Leave -Exit interview conducted with Certifying Official and others as school or auditor sees fit. -Describe your findings and recommended corrective action -Tell them what they are doing well -Identify systematic deficiencies -Offer technical Assistance -Explain that they will not receive a copy of the report, but they will receive a letter from you

Post Survey -Letter to school (sent to highest administrator with copy to certifying official) -Identify student records reviewed by Chapter -Detail any discrepancies/findings -Specify corrective actions (if any) required by the school or facility Schools and facilities are not the only ones audited… -A random sample of compliance survey files are reviewed each quarter for quality assurance -SAA prepares a narrative describing our survey findings -Opening paragraph identifies CS overview (who, what, when…) -Detail discrepancies, evaluation and corrective action (ref. 22-1934) -Debt prevention steps taken by the school -Summary (“The school has systems in place to effectively monitor…) -Recommendations- “As a result of our findings regarding compliance, the SAA recommends corrective action and a follow-up survey next year”

Questions?