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

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. NC SAA Staff Joseph Wescott II, Executive Director Program Specialists
Elizabeth Kelly
Jay Fitzgerald
Meghan-Joy Woodall
John Pritchett
Jenne Herbst, Program Assistant
NCSU Intern: Open

4. 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!

5. 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! VA
VA Central Office (VACO)
Regional Processing Office (RPO)
Education Liaison Rep (ELR)
State Approving Agency (SAA)
School Certifying Official (SCO)

6. Mission & Responsibility
NC SAA
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 North Carolina’s educational institutions, and ensuring compliance with federal and state guidelines
Ensuring the interests and prerogatives of the State are preserved in both processes

7. 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

8. Our Partnership with You
NC SAA
Our Partnership with You
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

9. NC 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

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

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

15. 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.

16. NC SAA The Re-Approval, cont.
For Title 38, United States Code, Section 3675 – Accredited Institutions of Higher Learning, package must include:
-Signed Application
-Two hard copies of your current catalog
-Signed Catalog Certification Addendum
-A copy of the last NC SAA Approval marked with colored ink.
-Enclose Calendars / Schedules that are not contained in the catalog
-Provide a copy of the last letter of Accreditation
-If you are licensed, provide a copy of the latest letter of licensure or report of licensure to the State.
-New VA Form if it does not have the name(s) of current Certifying Official(s)

17. NC SAA The Re-Approval, cont.
For Title 38, United States Code, Section 3676 – Non-Accredited Institutions, package must include:
-Signed Application
-Two hard copies of your current catalog
-Signed Catalog Certification Addendum
-A copy of the last NC SAA Approval marked with colored ink.
-Enclose Calendars / Schedules that are not contained in the publication
-Provide copies of the latest NC License / Licensure Letter
-Provide copy of up-to-date bond documentation,
-Complete Addenda required for your school, provide signatures and copies
-Complete I/A Information Forms for all new instructors and administrators.

18. Important Special Interest Items
NC SAA
Important Special Interest Items
Prior Credit
High School Transcripts
The DVA Form
Continuing Education

19. Important Special Interest Items, cont.
NC SAA
Important Special Interest Items, cont.
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.

20. Important Special Interest Items, cont.
NC 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

21. Important Special Interest Items, cont.
NC SAA
Important Special Interest Items, cont.
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”

22. Important Special Interest Items, cont.
NC SAA
Important Special Interest Items, cont.
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
Name, phone and fax number and address for each certifying official in the appropriate box.
The Approving Official must sign box 7.

23. 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.

24. Information / Policies
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.

25. 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.

27. NC 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.

28. NC 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

29. Compliance Survey Process
NC SAA
Compliance Survey Process
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).
Expanded audits:
≥ 30% Financial discrepancies
≥ 50% Discrepancies of any type

30. Record Keeping Requirements 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 (if applicable)
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

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

32. 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

33. 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

34. 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

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

36. 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.

37. 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.

38. 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

39. 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!

40. On the Horizon
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.

41. Hundreds of technical assistance phone calls and e-mails
NC SAA
Responsibilities include:
282 separate institutions of learning, plus 42 branch locations  
Our Service to You:
Conducted 77 Compliance Survey visits
Processed requests for new approval, resulting in 7 new institutions
Reviewed and completed 348 applications for program re-approval (new catalogs)
Evaluated and approved over 1,000 individual programs
Hundreds of technical assistance phone calls and s 
*As of October 1, 2015

42. Thank you! Any (more) questions?