1. History and Role of the State Approving Agencies
Dr. Joseph Wescott II, Legislative Director, NASAA

2. History FDR signs GI Bill of Rights
Congress recognizes responsibility of States to determine education of their citizens
Late State Approving Agencies created;
1940’s overseen by Governor, but funded by the VA
Today A cooperative and successful combined federal-state program!

3. The Serviceman’s Readjustment Act of 1944, more popularly known as the G. I. Bill of Rights was introduced in Congress in January 1944, and President Franklin Roosevelt signed it into law on June 22, 1944.  The G. I. Bill provided books, tuition, and a monthly stipend for veterans who enrolled in colleges and universities.  Over 2 million veterans attended college on the G.I. Bill, and it is estimated that, in 1947, veterans accounted for 49% of college students.  Another 5 million veterans attended vocational schools or participated in on-the-job training opportunities funded through the G. I. Bill.  The unemployment pay included in the G.I. Bill was known as 52/20 Club, which provided a payment of $20 a week for up to 52 weeks while veterans looked for jobs following their discharge.  Another important provision of the G.I. Bill was low interest, zero down payment home loans for servicemen. This enabled millions of American families to move out of urban apartments and into suburban homes.

5. A view of the Quonset huts used for temporary classrooms during the boom in the student population after World War II. This photo was taken in February (Photograph courtesy of Special Collections, NCSU Libraries)

6. A New Federal State Partnership
Congress also recognized that it was the responsibility of the State to determine the education of its citizens. It was decided that each state would establish a “State Approving Agency” and that the governor of each state would designate a state bureau or department as the SAA for the state. The SAA would be supported through funding, under contract, from the Department of Veterans Affairs (VA). This evolved as a cooperative federal-state effort that maintained states’ rights while monitoring and protecting a federally sponsored program administered under the terms and conditions of federal laws.

7. Initially, the SAA’s role was to provide information on state approved programs to the VA. By the late 1940s and early 1950s, the SAAs were operating under specifically mandated federal standards, the Code of Federal Regulations, and providing approval and oversight activities. The SAAs became the primary source of assuring institutional accountability with specialized authorization exercising the state’s authority to approve, disapprove and monitor education and training programs for veterans and began to assist states and the VA with exposing fraudulent and criminal activity involving the payment of veterans’ benefits.

8. Congress, recognizing that education was a state responsibility, mandated that each State create an agency to approve the programs within their borders and to determine which programs were appropriate for veterans to enroll in, to utilize their VA educational benefits. The first State Approving Agencies (SAA) were formed for veterans after World War II. For example, the North Carolina State Approving Agency was established in Today it is an affiliate institution of the University of North Carolina General Administration.

9. In 1948, SAA representatives met to form an organization, the National Association of State Approving Agencies (NASAA). With the formation of NASAA, the SAAs began to create professional standards for themselves. The organization established a forum for the exchange of ideas, the promotion of high professional standards, policies and ethical practices among its members and representation on mutual interests of issues coming before the membership. It also worked to protect both the schools and the veterans from fraud, waste and abuse. The organization continues to work to develop and maintain uniform standards for all SAAs.

10. (3) to protect the GI Bill resources available for those programs.
Our Mission Statement
The National Association of State Approving Agencies works in cooperation with its partners:
to facilitate the efforts of the state approving agencies to promote and safeguard quality education and training programs for all Veterans and other eligible persons;
(2) to ensure greater education and training opportunities that meet the changing needs of Veterans; and
(3) to protect the GI Bill resources available for those programs.

11. And of course--THE VA-ELIGIBLE STUDENTS
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!

12. It Takes A Team! SAA & VA collaborate to assist vets
Interpret laws and regulations
Maintain integrity of programs
Train the SCOs
Encourage greater use of VA benefits
Help institutions better serve veterans! VA
VA Central Office (VACO)
Regional Processing Office (RPO)
Education Liaison Rep (ELR)
State Approving Agency (SAA)
School Certifying Official (SCO)

13. State Mission & Responsibility
NC SAA
State Mission & Responsibility
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:
Validating and approving educational courses and programs to be pursued by veterans and eligible persons
Overseeing educational institutions, and ensuring compliance with federal and state guidelines
Ensuring the interests and prerogatives of the State are preserved in both processes

14. Our Partnership with Institutions
SAA
Our Partnership with Institutions
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

15. SAA
The Approval
This is THE document that actually conveys State / VA 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

16. NC SAA The Re-Approval The Re-Approval…
Required Prior to 1) the ending date of the previously approved calendar and / or with 2) the publication of a new Catalog, school officials will apply for re-approval or revision of the current approval.
Must be mailed to the NC SAA office and all documents, except catalogs, must be submitted SINGLE-SIDED.

17. Important Special Interest Items
SAA
Important Special Interest Items
Prior Credit
Must be evaluated and recorded (by law…) prior to enrollment OR within 2-terms.
This means you must have official transcripts of all previous training on file.
Must have proof of prior credit evaluation in the student file.

18. Important Special Interest Items, cont.
SAA
Important Special Interest Items, cont.
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

19. Important Special Interest Items, cont.
SAA
Important Special Interest Items, cont.
Continuing Education Courses
Generally these courses are not approved.
All courses must lead to a vocational objective, i.e. a job.
Few exceptions: state licensed, state mandates, etc.

20. Information / Policies
SAA
5/15/2009
ATTENDANCE, STANDARDS OF PROGRESS, RECORD KEEPING AND STUDENT CONDUCT POLICIES
CFR TITLE 38:
Reference Paragraph
POLICY
APPROVAL APPLICATION -
Information / Policies
(b5)
Attendance
Provide school policy and regulations relative to:
Leave
Absences
Class cuts
Make-up work
Tardiness
Conditions for interruption/termination for unsatisfactory attendance
Conditions for re-entrance for students dismissed for unsatisfactory attendance
(b6)
Standards of Progress/Grading
Grading system
Conditions for interruption/termination (minimum grades) for unsatisfactory grades or progress
Description of Probationary Period, if any
Conditions for re-entrance for students dismissed for unsatisfactory progress
Describe progress records kept by the school and furnished to the student
(b7)
Student Conduct
Provide Conditions for dismissal for unsatisfactory conduct
(c4)
Records of Previous Education and Training
Provide record of previous education and training with appropriate credit for previous education.

21. SAA Continuing Education Courses We approve programs not courses.
Approval package is worked through the school certifying official. They must give initial approval.
State licensed programs such as BLET, CNA, etc. are possible candidates for approval.
We usually will require an addendum be signed.

22. SAA Additional Items of Interest Contract Courses:
Both the contractor and host institution must be approved.
Questions of academic quality control, awarding of credit, certification and records management.
Additional Facilities:
Also must be approved.

23. SAA Compliance Surveys NC SAA assists DVA with this responsibility
Former “Supervisory Visits” were more focused on SCO training and process improvement
Compliance Survey primarily an audit of federal entitlement program; focus shifted from academic programs to more emphasis on finances

24. Compliance Survey Process
SAA
Compliance Survey Process
SAA schedules visits with the institution
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 SAA with copy sent to DVA
Inspection discrepancies (if any) require resolution with documentation of corrective action to SAA (approval issues) or referral to DVA (payment issues).
Expanded audits:
≥ 30% Financial discrepancies
≥ 50% Discrepancies of any type

25. Changing Laws, Changing Roles
SAA
Changing Laws, Changing Roles
The Post 9/11 GI Bill
Public Law
Public Law
Principles of Excellence (Executive Order 13607)
Public Law

26. 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

27. Public Law 111-377 Became effective October 1, 2011 Many positives
More programs now covered by Post 9/11 GI Bill
More potential beneficiaries
A “Game-Changer” for SAAs
Changed State/Federal approval authorities
SAAs acquired new role of assisting VA with Compliance Surveys

28. Changed States’ authority to approve programs
Public Law , cont.
Changed States’ authority to approve programs
Accredited, public & non-profit existing degree programs “deemed” approved without continuing State review
New degree programs at public and non-profit private institutions must be reviewed
Approval AND disapproval authority given to U.S. Secretary of Veterans Affairs
Schools with deemed approved programs provided approval/change notifications to ELR with courtesy copy of catalog/forms to NC SAA
SAAs retained jurisdiction over for-profit schools, and Non- College Degree (NCD) programs at all schools

29. BUT…
Big Change 2013
Effective October 1, 2013, VA no longer accepts modification form--all requirements for approval go to SAAs.
All NC institutions must submit an approval package to the NC SAA.
All approval related concerns and questions must come to the NC SAA.

30. Improving Transparency of Education Opportunities for Veterans
Public Law
Improving Transparency of Education Opportunities for Veterans
Public Law , signed on January 10, 2013, mandates, among other things...
A centralized mechanism for tracking/publishing feedback from students and SAA regarding quality of instruction, recruiting practices, and post-graduation employment placement of institutions of higher education.
SAA’s will share with accrediting agencies or associations information regarding the SAA’s evaluation of an IHL.

31. New This Year VA & NASAA Initiatives
National VA Online Feedback (Complaint) System
A centralized online reporting system; launched in Jan 2014
Report violations of the Principles of Excellence (E.O )
Report negative experiences with educational institutions
Identify and address unfair, deceptive, misleading practices
Ensure high quality academic and student support services
VA Online Comparison Tool
Launched in February 2014
Easier to calculate Post-9/11 GI Bill benefits and learn more about VA’s approved colleges, universities and other education and training programs across the country.

32. H.R. 3230 – Veterans Access, Choice, & Accountability Act of 2014
Also This Year…
H.R – Veterans Access, Choice, & Accountability Act of 2014
Signed into law August 8, 2014, as Public Law
Primarily addresses veterans’ health matters
Expands Fry Scholarship eligibility to spouses
Effective January 1, 2015
Entitlement expires 15 years after servicemember’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

33. Veterans Access, Choice, & Accountability Act of 2014
P.L , cont.
Veterans Access, Choice, & Accountability Act of 2014
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”
THIS IS NOW STATE LAW!

34. Pending Legislation
HR 3016 passed the House of Representatives February 8, This bill will:
Clarify and codify approval authority with SAAs
Cap contracted flight programs at the prevailing private school tuition and fee cap
Restructure the way compliance surveys are performed. Schools/training establishments with > 20 veteran students enrolled survey biannually. Method and manner determined with SAA.

35. Pending Legislation S. 2921 Veterans First Act
A bill to amend title 38, United States Code, to improve the accountability of employees of the Department of Veterans Affairs, to improve health care and benefits for veterans, and for other purposes.
Includes HR 3016 language, except Flight provisions.
Section (RESTORATION OF ENTITLEMENT TO POST-9/11 EDUCATIONAL ASSISTANCE FOR VETERANS AFFECTED BY CLOSURES OF EDUCATIONAL INSTITUTIONS.)

36. VA Expiring Authorities Act
HR 5985
VA Expiring Authorities Act

37. Thank you! Any (more) questions?