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WACRAO 2014 WISCONSIN CERTIFYING OFFICIAL WORKSHOP JUNE 17-18, 2014

WACRAO 2014 WISCONSIN CERTIFYING OFFICIAL WORKSHOP JUNE 17-18, 2014. GREETINGS. Day 1 – All SCO’s. Apprenticeship Program – Kathy Wellington RPO Updates Complaint System Communications with VA Communications with ELR & SAA Student Responsibility. SCO Concerns. Principles of Excellence

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WACRAO 2014 WISCONSIN CERTIFYING OFFICIAL WORKSHOP JUNE 17-18, 2014

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  1. WACRAO 2014 WISCONSINCERTIFYING OFFICIALWORKSHOPJUNE 17-18, 2014

  2. GREETINGS

  3. Day 1 – All SCO’s • Apprenticeship Program – Kathy Wellington • RPO Updates • Complaint System • Communications with VA • Communications with ELR & SAA • Student Responsibility

  4. SCO Concerns • Principles of Excellence • SCO monitoring has increased substantially due to increased enrollments and certification requirements • CH33 – 3rd party tuition payments • Institutional debts from CH33 – DMC & TOP

  5. RPO UPDATES • RPO Updates/Legislative Updates • RPO Education Outreach Section re-organization effective June 1, 2014 • VA Central Office November 2013 policy on unearned punitive F grades • RPO automated Chapter 33 processing (LTS) Long Term Solution • Updated on DEEMED approved institutions

  6. RPO UPDATES • VA & SAA Compliance survey Updates • VA Annual Reporting Fees for calendar year 2013 • Paperless enrollments – VAONCE • WI IHL stats – 120/137 • WI NCD stats – 25/42 • Direct Deposit – tuition and fee payments • VA has issued 29.8 billion dollars in Post 9/11 GI Bill benefit payments to 985,000 individuals since program inception as of September 2013.

  7. RPO UPDATES • RPO Updates/Legislative Updates • VA Central Office advisory March 28, 2014 Program withdrawn and benefits continue – Chapter 33 • VA Central Office advisory September 30, 3013 Certifying Sales Taxes as Fees • VA Central Office policy – CH33 Yellow Ribbon Program IHL contribution – restricted or unrestricted institutional scholarships • Books considered as fees- If a school charges every student for books required for their program and does NOT allow them to purchase outside that office, they may be include it with tuition and fee charges

  8. RPO UPDATES • RPO Updates/Legislative Updates CH33 Parking Fees –this fee is not specifically excluded by regulation therefore are included as a payable fee as long as all students have to pay this fee to the institution. VA Central Office advisory April 21, 2014 – CH33 Fees involving lab costs – there are instances when a lab fee is mandatory for all students in a particular course during a particular enrollment period. This is an acceptable fee to certify. However during enrollment periods when the lab fee is waived lab fees are not certified. NOTE: A lab fee does not have to be charged during every term of enrollment in order to be considered mandatory.

  9. RPO UPDATES • RPO Updates/Legislative Updates • New – May 16, 2014 from VA Central Office • Effective immediately VA Education Call Center representatives are prohibited from releasing documents (such as Certificates of Eligibility, Award Letters, etc) to veterans and beneficiaries, veterans service organizations, school certifying officials, or other entities based on a telephonic request. • Written requests which include FAX, RNW, as well as regular mail from authorized individuals may be honored.

  10. RPO UPDATES • RPO Updates/Legislative Updates • New – May 16, 2014 from VA Central Office • WHY? • VA General Counsel has determined that telephonic requests for documents from a claimant’s VA records are not sufficient to meet requirements and are prohibited. • PER: • Clarification on Freedom of Information (FOIA) and Privacy Act (PA) Requirements for Telephonic Requests of Documents Related to VA Education Benefits

  11. RPO UPDATES • The Post-9/11 Veterans Educational Assistance Improvements Act of 2010 (Public Law 111-377) amended section 3322 of title 38, United States Code, by adding subsection (h) which bars duplication of eligibility based on a single event or period of service. Because of this addition, individuals cannot- • Use the same period (beginning on or after August 1, 2011) of active duty service to establish eligibility for the Post-9/11 GI Bill and chapter 30, chapter 32, chapter 1606, or chapter 1607, or • Establish eligibility under both the Fry Scholarship provision of the Post-9/11 GI Bill and chapter 35 (DEA) based on a parent’s death (i.e. a single event) in the line of duty on or after August 1, 2011.

  12. GI Bill web site • Provides information on VA education benefit chapter eligibility and usage • Identifies approved institutions on gi bill web site • Provides State listing of institutions approved for YRP • Contains institutional address, name of SCO with phone number and email • Provides students with researching schools and provides for on line complaint system

  13. Education Benefit Chapters • Montgomery GI Bill (MGIB) Chapter 30 – Veterans • Montgomery GI Bill-Selective Reserves Chapter 1606 for Members of Reserves or National Guard • (REAP) Chapter 1607 – mobilized under DOD Title 10 (called to active duty) • Dependents Educational Assistance Program Chapter 35 (spouse, children, surviving spouse • (Public Law 110-181 – affecting Ch 1606/1607) enacted January 28, 2008 • Post-9/11 GI Bill (Chapter 33) – veterans & dependents TOE • Fry Amendment – CH33 dependent benefit death of service member • VRAP – awarded benefits under Chapter 30 – closed March 2014

  14. Principles of Excellence Executive Order 13607 signed by the President on April 27, 2012 established principles of excellence for Educational Institutions serving service members, veterans, spouses, and other family members Objective: designed to strengthen oversight, enforcement, and accountability within the Department of Veterans Affairs education benefit programs and DOD TA programs. Established a centralized compliant system which became active in March 2014 – within initial 3 weeks – 900 complaints

  15. Principles of Excellence • Educational institutions participating in the Principles of Excellence program agree to the following guidelines: • -Provide students with a personalized form covering the total cost of an education program. • -Provide educational plans for all military and Veteran education beneficiaries. • -End fraudulent and aggressive recruiting techniques and misrepresentations. • -Accommodate Service members and Reservists absent due to service requirements. • -Designate a point of contact to provide academic and financial advice. • -Ensure accreditation of all new programs prior to enrolling students. • -Align institutional refund policies with those under Title IV, which governs the administration of federal student financial aid programs.

  16. Principles of Excellence – Student Complaints Types of Complaints: Recruiting/Marketing Practices, Accreditation, Financial issues (e.g. tuition/fee charges), student loans, post-graduation job opportunities, change in degree plan requirements, quality of education, grade policy, release of transcripts, transfer of credits, refund issues, and other. GI Bill web link for submitting a complaint: http://www.benefits.va.gov/GIBILL/Feedback.asp OTHER: is a general category that may involve complaints about VA approval or processing applications or enrollments

  17. Principles of Excellence – Student Complaints Other types of complaints may involve: - student questioning SCO certification based on applying VA reporting requirements - student questioning institutional refund of tuition - student questioning amount of Title IV funding - student questioning CH33 Rate of Pursuit BAH based on term length and equivalent credits - student questioning VA action on eligibility based on their military service and/or DOD information

  18. Principles of Excellence – Student Complaints VA student can submit complaint on GI Bill web site: Process: - VA Central Office Education Service reviews complaints and forwards to school SCO or designee; - School is requested to provide VA with a response or if VA will refer to another government agency if appropriate. - VA will review the response and provide a response to student complaint - VA may also contact institution as appropriate

  19. Role of the IHL • When feedback is received for a school, VA will contact school on behalf of the student and work toward a resolution • –The School Certifying Official (SCO) on record will be contacted • –Institutions will have an opportunity to appoint another representative other than the SCO to handle complaints • •Complaints should be handled within 60 days from submission • •Complaints and their resolution(s) will be forwarded to the FTC Consumer Sentinel Network • –These complaints will be accessible by over 650 federal, state, and local law enforcement agencies

  20. SCO Communication with VA • Right Now Web to St Louis RPO via email • National Education Call Center at 1-888-442-4551 • SCO Hotline number at National Education Call center at 1-855-225-1159 • ELR – 612-970-5456 or email at john.johnson11@va.gov

  21. VA Student Responsibility • Promptly notify SCO of changes to enrollment • - Understand benefit programs • - Application process to VA • - Progress and pursuit • - Contacting VA – inquiries concerning benefit eligibility and benefit payments • - Understand cause and effect of enrollment changes

  22. Student Contacting VA • Students can access GI Bill web site to contact VA by email • Students can call VA at National Education Call center at 1-888-442-4551 • Students can access GI Bill web site for extensive information pertaining to benefit programs, searching for schools, comparison shop for schools, and search FAQ’s • E Benefits access

  23. E-Benefits • The eBenefits web portal is an online resource for tools and benefits-related information. • The portal serves Wounded Warriors, Veterans, Service Members, their families, and their caregivers. • Two main services: • A catalog of links to military and Veteran benefits on other sites • A personalized workspace giving quick access to online tools that enable you to apply for benefits, download your DD-214, see your benefits status online, and more

  24. E-Benefits Registration • There are two levels of eBenefits registration, Basic and Premium. • Basic Registration (Level 1 access) enables you to view general eBenefits information. This level of access does not allow you to view information about yourself from VA and DoD systems. • Premium Registration (Level 2 access) provides you the highest level of access to eBenefits. With Level 2 access, you will have a secure, personalized eBenefits account that pulls information from your DoD and VA records.

  25. E-Benefits Registration • Both levels require a DoD (DS) logon. • With a DS logon, you can use a single user name and password to access various websites, including many VA and DoD sites • All DoD sponsors, veterans spouses, and other beneficiaries who are registered in the Defense Enrollment Eligibility Reporting System (DEERS) can obtain a DS logon

  26. BREAK

  27. Experienced SCO Overview2:15 – 3:15pm • Recap of benefit chapters • Approval Criteria • Modality of instruction to certify • Standard Term & nonstandard term certification • Sunday – Saturday start date of term (mult-iterm) • Overpayments and TOP • In-depth case study examples – complex • VA compliance surveys

  28. Importance of Certifying Officials

  29. Education Benefit Chapters • Montgomery GI Bill (MGIB) Chapter 30 – Veterans • Montgomery GI Bill-Selective Reserves Chapter 1606 for Members of Reserves or National Guard • (REAP) Chapter 1607 – mobilized under DOD Title 10 (called to active duty) • Dependents Educational Assistance Program Chapter 35 (spouse, children, surviving spouse • (Public Law 110-181 – affecting Ch 1606/1607) enacted January 28, 2008 • Post-9/11 GI Bill (Chapter 33) – veterans & dependents TOE • Fry Amendment – CH33 dependent benefit death of service member • VRAP – awarded benefits under Chapter 30 – closed March 2014

  30. VA Application Forms • VA Form 22-1990 – All Chapters except Chapter 35 for original claims • VA Form 22-1990e – Chapter 33 Transfer of Entitlement • VA Form 22-5490 – Chapter 35 original claims and Fry • VA Form 22-1995 – All Chapters except Chapter 35 & • VA Form 22-5495 – Chapter 35 subsequent claims • *do we need 1995 & 5495 changing programs at same schools - NO • ALL CAN BE COMPLETED AND SUBMITTED ON LINE AT GI BILL WEB SITE VONAPP – (preferred method)

  31. VA Access to Records • CFR 21.4209 – Title 38 provides VA & SAA access to any institutional records as condition of approval • VA and SAA exempt from FERPA concerning privacy of student records • Access to VA and non VA student academic and financial records

  32. VA Interface with DOD • VA can access DOD data base to obtain and verify: • Military service dates, type of discharge, contributions, kickers, reserve/guard deployments under Title 10 • AGR32 military service • Transferred benefits to spouse or dependents under Chapter 33 by serviceperson

  33. RPO Interface with VA Regional Offices • VA RPO must verify spouse and dependent eligibility under Chapter 35 Dependent Education Assistance program. • RPO obtains confirmation from VA RO where veteran claims folder is located to confirm spouse and or dependents are properly listed and veteran is rated for VA service connected disability rating to qualify for Chapter 35 benefits.

  34. Institutional Approval (IHL & NCD) • Accredited – institution’s accrediting agency recognized by U.S. Department of Education (Public or Private) • Non-Accredited – institution may have: • Accrediting agency not recognized by US Dept of Education • SAA does not recognize accrediting agency • or has no accrediting agency approval • * May not be under State licensure by WI Education Approval Board (EAB)

  35. DEEMED approved facilities • Public Law 111-377 enacted August 1, 2011 provided for Institutions of Higher Learning (IHL) to be deemed approved for degree programs only if: • Institution accreditation recognized by US Dept of Education • Licensed by State as Institution of Higher Learning • Did not change requirements for all NCD and private profit IHL institutions

  36. DEEMED approved facilities • VA assumed approval authority for Deemed approved institutions (public and private non-profit Institutions of Higher Learning) • Effective late 2013 VA transferred approval authority back to SAA for institutional approval and non college degree programs at Deemed approved institutions – degree programs are deemed approved • SAA retained approval function for all other institutions

  37. Modality of Certifications – CH33 • Resident – lecture, lab, or shop instruction • On line – distance learning or independent study • Blended/hybrid – combination resident and on line instruction- differences undergrad and graduate level • Remedial – subjects required as determined by institution as deficiency (resident instruction only) • Practical Training (internships, externships, etc) NCD schools – must be resident instruction and no on line instruction

  38. Modality of CertificationsNon CH33 • There is no distinction by VA for non Chapter 33 education benefit award of benefits and treated as credit value other than: • Remedial – subjects required as determined by institution as deficiency (resident instruction only) • Practical Training (internships, externships, etc) NCD schools – must be resident instruction and no on line instruction

  39. Resident or Distance(Chapter 33) • In-residence training for undergraduate students consists of regularly scheduled standard class sessions (at least once every two weeks).  The total number of hours of classroom instruction (based on 50 minutes of instruction per hour) must equal, or be greater than, the number of credit hours awarded for the course multiplied by the number of weeks in the term. • In-residence training for graduate students consists of at least two regularly scheduled standard class sessions, research (either on or off campus), or a combination of both.

  40. Evidence to Review when Certifying Enrollments • Student application & matriculation • Acceptance into program • Institutional evidence of transfer credits • Prior institutions • Military academic transcripts • Other – perhaps life experience, CLEP etc • Student account ledger – CH33 for T & F • Student term registration data • Existing transcript to verify no repeat subjects

  41. Evidence to Review when Certifying Enrollments • Rounding out in last term prior to completion • Academic probation • Student placed on academic suspension • Subject substitution • Remedial subjects pursued on line rather than resident instruction • What evidence have you reviewed to substantiate need for remedial instruction subjects • Repeating subjects based on grade posted and institutional standards

  42. Non College Degree School Certifying Enrollments • Student application & enrollment agreement • Start date is actual first date of scheduled instruction • Weekly schedule based on Sunday – Saturday hours • Varying weekly scheduled hours of instruction * • Institutional evidence of prior training evaluation • Student account ledger – CH33 to determine T&F • Certify appropriate tuition and fees per term prorated amount if charged full tuition and fees but school organized on term basis

  43. VA Enrollment Forms • PAPER DOCUMENTS • 22-1999 Enrollment Certification • 22-1999b Change of Status • VAONCE • NEW CERT – Multiple term CERT • AMEND • ADJUST • TERMINATE

  44. Yellow Ribbon Program VAONCE Student BIO page must display as benefit chapter 33Yellow to add YRP fields • Annual cap for 2013-2014 is: $19,198.31 • Annual cap for 2014-2015 is: $20,235.02 • VA Academic Year for CH33 (8/1 – 7/31) • Public IHL – restricted to in-state tuition and fees without YRP for nonresident tuition based on YRP agreement requirements

  45. ELR Request • Attempt to limit enrollment changes to VA until after the drop/add period (normally last 5-7 days after term starts • VA is receiving numerous enrollment adjustments changing credits before terms have even started • Refrain from submitting these changes until drop/add limited days is over – 25% of RPO documents are in this category.

  46. Certifying Terms • Single term • Multiple term • Start date of subjects • *nonstandard term impact on rate of pursuit • Reporting tuition and fees CH33, active duty, & -1/2 to RPO • Resident v/s non resident tuition • Public YRP – Private YRP • Modality – resident, distance, remedial, blended/hybrid, practical (internship)

  47. Calendar Week Rule • Certifying starting dates within term, quarter, and semester: • VA requires institutions to certify start dates as the official calendar that is published by the institution for terms. However when a start date of subjects begin after the calendar week of the published term start date – the SCO must certify those credits using the start date of the subject scheduled first class session. • This results in multiple term enrollment certification due to different start dates.

  48. Calendar Week Rule • Example: Fall Semester published dates are 9/3/14 – 12/12/14 • Student registration schedule identifies total of 12 cr • 9 credits have start date of subjects on 9/3 – 9/5 • 3 credits have start date of subject on 9/9/14 • Proper certification would show: • 9/3/14 – 12/12/14 9 credits • 9/9/14 – 12/12/14 3 credits • * Basis is that first scheduled class session for 3 credits is not within the same week of 9/3/14 (Sunday – Saturday)

  49. Certifying Terms • Non College Degree Institutions • Organized on terms • Not organized on terms If not organized on term basis and based on weekly scheduled clock hours certify weekly scheduled hours of instruction Identify the projected completion date as end date

  50. RPO processing of enrollments • Chapter 33 Post-9/11 GI Bill • Certify 1 semester or quarter at a time • Certify non-standard terms for up to length of a term, Qtr, or Sem • Enrollment does not include T and F • Enrollment includes T and F • Later submission of T and F - AMEND • 14 day T and F release time frame • Multiple terms • LTS – automated processing – CH33 only • VAONCE – NEW CERT, NEW Multiple term CERT, AMEND – use for submitting tuition and fees

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