1. Compliance Survey Overview

2. 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

3. 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.

4. 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

5. Step 1: Review the CS Master List

6. Step 2: Determine # of Files to Review

7. Step 3: ARF Report/(STATE)Sample Size
Number of Students by Chapter:
Chapter
Chapter
Chapter
Chapter
Chapter

8. Step 4: Enter Totals Into Calculator
Number of Students by Chapter:
Chapter
Chapter
Chapter
Chapter
Chapter

9. 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.

10. 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 Compliance Survey Worksheet for each student.

11. 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

12. 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

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

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

15. 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.

16. Web Enabled Approval Management System (WEAMS)

17. 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.

18. Document Review Institutional Records for Review
Types of and evidence of institutional advertising
Updated 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 Conflicting Interest Certification for private institutions as appropriate
Non VA student record review to confirm charges same or similar to VA student enrollment

19. 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

20. 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 § , , , , )
Review transcript, registrar records, enrollment agreement
Monitor WEAMS ( ) reports
Ensure program certified is exactly as appears on WEAMS
(38 CFR § , , )
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 , , , 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

21. 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

22. 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

23. 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.

24. Standards Reviewed Was this reported to VA?
-Terminations or interruptions in training must be promptly
reported to VA (38 CFR § , , )
*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

25. 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 )

26. Submission of Referrals
Complete a Compliance Survey Referral form.
Scan the document and to: ESUOUTREACH 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

27. 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 address.

28. Select the Student
Selecting the Student

29. Open the “Certs” Tab

30. Click on the “Certs” Dropdown & Select Modification

31. Enter Correction and Required Info

32. Add CS Remark and Submit

33. 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

34. 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 )
-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”

35. Questions?