1. NCD Programs Jodie Balder Education Liaison Representative
Overview & Best Practices
NCACVA SCO CONFERENCE
March
2019
Jodie Balder Education Liaison Representative

2. TOPICS Weekly clock hours of attendance
Approved length and the NCD Validator
Standards of progress
Debts
Pro Rata Refund
Leave of Absences (LOA)
Extending students for school closures
Graduating students in VA Once
MISC

3. Weekly Clock Hour Attendance
CERTIFICATION
Report the student’s scheduled hours of attendance
Ensure that you are not certifying a length, based on the scheduled clock hours per week, that exceeds the program length as approved by the SAA
The total clock hours certified will be checked by claims processors and denied if certified over the approved
If the student misses classes you will NOT report the change to VA
Follow your school’s published attendance & progress policies, as approved by the SAA, and listed in your approval letter
You cannot extend the students certified period to VA if the student does not attend classes that were available

4. What is the NCD Validator
If the hours you have certified should
NOT exceed the SAA approved hours for the program
unless the school had closures
The validator is a calculator to help you determine what dates to certify in VA Once in order to ensure that you are not exceeding the SAA approved hours for a program.
You should complete the validator for each student you will certify to VA and place a copy in their file.
If you have a program that is certified via mods/terms you can save the validator to your computer and add each new mod/term. The Validator will keep a running total of the hours certified for you.

5. How does the Validator Work
Many schools say they have a one year contract with students and that is what they certify to VA. That often exceeds the SAA approved hours however.
Let’s look at an example for a student certified for one year. In the example I’ve
entered the SAA approved hours of 1500, year long program dates and the
number of weekly clock hours (35 in this example).
This student will reach the 1500 approved hours on 11/5/19 so that is the end date that should be certified in VA Once.
NOTE: If there is no date in the Approved Hours End Date your end date is good.

6. How does the Validator Work
For all programs it is a good idea to explain to students that you are limited to certifying the approved hours in order to maintain you’re VA approval. This often helps with questions they have if they have not finished the required hours by the end of the period you have certified to VA.
I have a power point that shows in detail how to enter info in the validator
TIP: For schools on terms/mods the Validator also provides you with the remaining hours approved as of the end of that term/mod. Sharing the validator with the student can help them see how many hours remaining that VA will pay so they can plan their schedule accordingly.

7. Questions 7

8. Terminating Students
TERMINATION
If the student is not meeting attendance and/or progress standards you will terminate the student’s certification
In VA once you will terminate for “unsatisfactory Progress, Conduct or Attendance”
Ensure the LDA matches the date on which the student stopping meeting attendance or progress standards per your SAA approval
Check your SAA approval for the requirements for certifying after a student has been terminated for Unsat.
Do not terminate a student for unsat, as above, if they simply withdraw or stop attending
If a student stops attending for any reason you will process a Pro Rata Refund based on the students completed hours vs required hours for the program
If the student takes a Leave of Absence you will report it to VA
Different procedures for CH33 than non33
An extension may be due if student does not finish on time

9. STANDARDS OF PROGRESS

10. STANDARDS OF PROGRESS ADDENDUM
NOTE: This ADDENDUM clarifies the requirements for enforcing minimum standards and terminating students for unsatisfactory progress or attendance. This addendum supplements the Catalog identified above and becomes a part of the approval.
Probationary Period: (Ref SATISFACTORY PROGRESS POLICY)
VA students will be evaluated a the end of each month. If a student failed to meet a standard (80% for attendance or 75% for academics/grade average) during that month, s/he will be placed on probation for the following month. At the end of the month of probation, if the student continued to fail to meet a standard (80% attendance or 75% academic/grade average), his/her enrollment will be terminated.
Summary: 1 month below standards: 1 month probation; then termination.
Re-entry Policy: (Ref SATISFACTORY PROGRESS POLICY, RE-ENTRY PROCEDURES)
Once a student is terminated the following actions will be accomplished for re-entry,
- Student must be terminated for a period of 60 days before reconsideration of re-entry,
- Student will submit a new application for admission,
- President/CEO/Dir will evaluate student’s written request and status; determine the student has sufficient ability and potential to warrant a 2nd entry,
- President/CEO/Dir will provide the student 1) letter of reentry 2)contract for re-entry specifying hours of pursuit,
- If the student has not obtained standards of progress at the end of two months, s/he will be terminated and will not receive future consideration for re-entry.

11. What is the Pro Rata Refund
Nonaccredited schools must refund T&F on a pro rata basis when VA students withdraw or do not enroll after paying for courses,
in whole or part
The pro rata refund must, at a minimum, meet the following criteria:
School catalogs must have description of the refund policy. A simple statement that refunds are made on a pro rata basis is not sufficient.
The description must be clear enough for students to determine the amount of their refund
VA regulations allow a 10% deviation in the refund from an exact pro rata figure
VA regulations allow schools to retain up to $10.00 of any registration fee
Schools must make refunds promptly, i.e., within 40 days
Schools cannot not require VA students to request the refunds
If a school’s policy is more favorable to the student the school will use their policy
Schools may apply the pro rata refund policy to VA students only if they choose

12. How to Calculate a Pro Rata Refund
Calculate the number of clock hours the student completed
Divide the completed clock hours by the total approved clock hours
The resulting percentage is the amount the school can keep
Ex: A program is approved for 1500 total clock hours & costs $10,000
The student completed 1000 total clock hours
1000/1500 = or 67%
$10,000 x 67% = $6700
The school keeps $6700
The school refunds $3300 to the student
Any debt with VA is the student’s responsibility unless they never attended at all or attended only the 1st day and never returned

13. When Does a T&F Debt Belong to the School
Term Based
If the student never shows up at all (ie complete no show)
If student shows up only for the 1st day & never returns to school.
Dropping a class(s) but remaining in other classes causes a STUDENT debt regardless of when the drop occurs.
Non Term Based
If your program has one beginning & ending date and the student never shows up at all.
If the student only shows up for the 1st day & never returns to school.

14. QUESTIONS?

15. LOA Reporting
The Regional Processing office has requested that you not report an LOA until after the date the student has actually stopped attending.
So if you know ahead of time that a student is taking an LOA, please wait to report it in VA Once until after they have actually started the LOA.
I have a detailed power point that shows how to use the Validator and how to report the LOA in VA Once – let me know if you have not received that power point.

16. Entering an LOA for a CH 33 in VA Once
For CH33 you do not want to terminate the cert as it causes issues with T&F payments and debts in the VA system
Do an ADUST in VA Once
Enter the student’s last date of attendance prior to the LOA in the “LDA/EFF” date box
Remove any data in the “LD Accrued”
Delete the figure in the “clock” box & click anywhere on the screen.

17. Leave of Absence (LOA) CH 33
Once you click anywhere on the screen. You will get this pop up:
If the LOA will extend the student’s end date and you are fairly certain of the new end date enter the new end date in the “rev end dt” box that will become active NOTE: This info is not currently printing properly on the cert.
If the student’s ending date will not change or you’re not sure of the date leave the “rev end dt” box empty

18. Leave of Absence (LOA) CH 33
Reenter the scheduled clock hours in the “clock” box
Leave the T&F as initially certified
Choose “other” from the drop down box for adjustment reason
Enter the following remark: Student on LOA from xx/xx/xx to xx/xx/xx.
Also add: Ending date extended to xx/xx/xx (if applicable)

19. Leave of Absence (LOA) CH 33
If the student does not return as reported but still intends to return:
Amend the cert
Update the “rev end dt” box (if you entered a revised end date initially)
Update the remarks
If you are certain that the student will not return:
Terminate the certification
Provide the last date attended in the “LDA/EFF” date box
Provide the last date credit accrued in the “LD Accrued” box
Process a Pro Rata refund
Any debt with VA will be on the student
If the student is allowed to return after termination (AVOID this scenario when possible):
Contact me before recertifying as these will be handled on a case by case basis

20. Leave of Absence (LOA) NON CH 33
If a student takes a Leave of absence you have to report the LOA to VA.
For a NON CH33 you will:
Terminate the cert effective the last date attended in the “LDA/EFF” box in VA Once
Choose “Withdrawal or Interruption (NonCollege Degree Programs) from Reason Box
You do not need to add a remark about the LOA
Enter the date through which they accrued credit in the “LD Accrued” box
This is the date where they will pick up once they return to training
If they will pick up right where they left off you will enter the same date as in the “LDA/EFF” date box
If your school is organized on Mods etc., you will enter the begin date of the mod from where the student will pick back up.
If the student returns complete the Validator (entering both enrollment periods) to make sure your second enrollment end date does not exceed the approved
Do a brand new cert in VA Once
Enter the date they returned to class in the “Begin” date box
Enter the date they will complete training in the “End” date box

21. Entering an LOA for a NON CH 33 in VA Once
For a NON Ch33 you will Terminate the cert eff the date the student last attended prior to the LOA. So in this example the student’s LDA was 12/23/13. Remember to use the correct LD Accrued Date.
Always choose W/d or interruption Non College degree for

22. How to Use the Validator After an LOA
If a student returns from a documented and approved LOA that was reported to VA you may be able to extend the certification but still not past the Approved Hours End Date
In the example below the student attended 1/10/18 to 6/10/18 & then began a month long LOA on 6/11/18 LDA 6/10/18), she returned on 7/10/18 & was certified through a 1/9/18 end date.
As you can see this cert was denied as it exceeds the 1500 approved hours.
This student will reach the 1500 approved hours on 12/4/18 so that is as far as you can extend for the LOA and is your new end date for VA Once.

23. QUESTIONS?

24. Extensions Beyond the Approved Hours End Date
There are only two reasons that allow you to extend the end date certified past the Approved Hours End Date:
(1) If your school had closures for holidays and/or weather.
You can extend by the number of days the school was closed
(2) If the student has a documented failure and the school’s SAA approved policy is to require the student to retake the failed training.
For a documented failure you will need to add a remark to the cert when certifying repeated training providing the number of failed hours (credit or clock) to be repeated and amended ending date if applicable.
You will want to closely monitor students progress based on your SAA approved standards of progress and terminate the student if standards are not met.
NOTE: If you extend past the Approved Hours and it is not justified by one of these two reasons corrective action will be required and debts will be created if that file is chosen for a compliance survey.

25. Using the Validator for Closure Extensions
If the school had closures such as for snow days or holidays you can extend past the Approved Hours End Date
Allowed Hours End Date (boxed in red). This is the date on which the student will reach the approved hours plus 10%, based on the enrollment dates & hours you have entered.
You will only reference this box if the student hasn’t completed training by the Approved Hours End date and the school had closures.
You CANNOT use this date if the student missed classes but the school was open. The student was already paid by VA for the days they missed.
If the school had closures you can extend a student’s ending date past the Approved Hours End date ONLY by the same number of days the school was closed.

26. Using the Validator for Extensions
If the school had closures such as for snow days or holidays you can extend past the Approved Hours End Date
EXAMPLE: student originally certified 4/25/17 to 2/18/18 at 35 hours per week for the total 1500 required hours.
-On 2/18/18 student had not completed their 1500 hours.
-School was closed for Christmas and New Year’s from 12/24/17-1/2/18 (10 days).
-School amended the ending date to 3/29/18 and the claim was denied.
The school can extend by the number of days the school was closed. So the latest ending date you can extend to is 2/28/18 (10 days past the Approved Hours End Date).
You will amend the ending date in VA Once to 2/28/18. You should also add a remark to the cert such as “School was closed for Christmas & New Years from 12/24/17 to 1/2/18. Student’s ending date has been extended by 10 days.”

27. Extensions Beyond the Allowed Hours End Date
Clock hour programs not on terms/mods
If the student has a documented failure and the school’s SAA approved policy is to require the student to retake the failed training you can recertify the hours for that training even if it causes the end date to be past the Allowed Hours End Date.
You can only extend for the number of hours failed
EX: Student originally certified 4/23/17 – clock/wk for a 1500 hour program. Student failed the 2 week/70 hour protégé training.
Amend the end date to include the additional 70 hours (3/2/18)
Add a remark “Student failed a 70 clock hour protégé training which must be repeated. Ending date extended to 3/2/18.

28. Extensions Beyond the Allowed Hours End Date
Clock or credit hour programs on terms/mods
EX: Student enrolled in a 30 credit hour program. Originally certified:
FL 17 for 12 credits
SP 18 for 9 credits
Will be certified FL 18 for 9 credits (for a total 30crs)
Student failed a 3 credit hour course during the FL 17 term & must repeat it during the SP 18 term.
Adjust the SP 18 cert and increase the student to 12 credits.
Add a remark “Student failed a 3 credit hour course during FL 17 and is required to retake it this term.”
When you certify FL 18 I would also add a remark “Student failed 3 cr course during FL 17, was required to repeat it in SP18. Therefore total of 33 hours certified for program”

29. Graduating Students in VA Once
Reporting graduation/completion data to VA for CH33 students is
mandatory for all terms/programs that started 1/1/18 or later.
You report graduation/completion by Terminating the cert in VA Once.
NCD schools, approved in clock or credit, should choose “end of term or course” from the from the drop-down menu for termination reason
Graduation/completion should only be reported if the student was using VA benefits at the time they graduated/completed
You should not report graduation/completion for the following students:
NON Term Based:
If the student didn’t complete the required clock hours by the ending date certified to VA
EX: Student certified for a 1500 program through 5/10/19. The student missed classes and doesn’t complete the 1500 hours and graduate until 6/15/19. You will not terminate that certification for graduation/completion.
Term Based:
If the CH33 student reaches his/her delimiting date in a term prior to the term during which they graduate
If the CH33 student reaches the end of his/her entitlement in a term prior to the term during which they graduate
If the student did not receive VA benefits (for any reason) during the term in which they graduate
If you certified a student and they graduated on a date prior to the ending date certified the LDA/EFF date when you terminate them for graduation should = the date they completed.
EX: Student certified 1/10/18-12/13/18. Student completed the required hours 11/30/18. When you terminate for ‘End of Term or Course’ the LDA/EFF date should = 11/30/18.

30. NCD Program ReCAP Certify Scheduled weekly hours Report LOAs
Do not adjust for missed classes
Terminate for unsat attendance or progress if applicable
CANNOT extend past Approved hours for missed classes
Report LOAs
Via Adjust for CH33
Terminate for Non CH33
CANNOT extend past Approved hours for LOAs
Can extend past Approved hours for school closures
Can only extend for the same number of days/hours the school was closed
Remember to add remark
Report failures if required
CAN extend a student passed the Approved hours if documented failure requires recertification of training
Report graduation when warranted

31. MISC Reminders
You must get official transcripts from all previously attended colleges/tech schools
It does not matter if the student actually used VA benefits at prior schools
You must perform a prior credit evaluation
The cost of books, kits & supplies:
Should be included on a CH33 cert if they are mandatory for all students AND
ONLY If they books/supplies cannot be purchased from any outside source
You must add the VA Course Code when entering approved programs into VA Once
VA Once will populate the “Objective code” with the same code as chosen for course code
If there is not an exact match use “Not Elsewhere Classified” code
All students except CH33 must verify their enrollment each month with VA to receive payment
Students in NCD programs approved in credit hours and terms/mods can “round out” in their last term before graduation if not FT w/ remaining required classes.
Only CH33 and Voc Rehab (CH31) send payment directly to school

32. Contact Us WEBSITE: www.benefits.va.gov/gibill
FACEBOOK:
TELEPHONE: GIBILL-1 ( )