Compliance Surveys
Illinois Certifying
Officials
Workshop
June 4, 2015
VETERANS BENEFITS ADMINISTRATION
TRAINING OVERVIEW
VETERANS BENEFITS ADMINISTRATION
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Training Overview
-
Purpose and Authority
Objectives
Documents Reviewed
VA Enrollment
VA Education Benefit Chapters
Access to Institutional Records
Types of Facilities Surveyed
PL111-377 (SAA & VA Who conducts surveys)
Preparation, Scheduling, Conducting, & Post Survey
Additional Training (Remote Surveys, IHL Flight, Dual
Majors, 85/15, Graduation, Failing Grades, Repeat
Courses)
Purpose and Authority
Compliance surveys are conducted in order to ensure
that schools and training establishments, and their
approved courses, are in compliance with all applicable
provisions of the laws administered by VA.
Authority:
Title 38
38 CFR
M22-4
VETERANS BENEFITS ADMINISTRATION
Objectives of Compliance Surveys
Compliance surveys have five principal objectives:
(1) Verify the propriety of payments of educational benefits to eligible individuals
under the provisions of the laws administered by VA;
(2) Provide a reasonable basis for cooperating with SAAs;
(3) Assist school or training officials and eligible individuals in better understanding
their responsibilities and the procedural requirements of VA;
(4) Determine, on the basis of facts disclosed from document reviews and personal
visits, whether there are deviations from the responsibilities and requirements by
eligible individuals, schools or training establishments; and
(5) To assure that proper action is promptly taken through appropriate channels for
the correction of existing discrepancies, or for the discontinuance of benefits in the
event correction is not accomplished.
VETERANS BENEFITS ADMINISTRATION
Documents Reviewed
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Institutional Records for Review Types of and evidence of institutional advertising
Updated 22-8794 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 22-1919 Conflicting Interest Certification for
private institutions as appropriate
Non VA student record review to confirm charges
same or similar to VA student enrollment
VETERANS BENEFITS ADMINISTRATION
Documents Reviewed
-
Institutional Records for ReviewVA work study student records as appropriate
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
Verification of enrollment limitation
VETERANS BENEFITS ADMINISTRATION
Enrollment Certification
VETERANS BENEFITS ADMINISTRATION
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Guidance to SCO
Records to Review Prior to Certification
•
•
•
•
Ensure student has applied/accepted as a student
Prior credit evaluation completed or pending
Degree program approved
Student term registration schedule
– Confirm modality of instruction
– Confirm length of period to certify
– Confirm subjects apply to program
• DAR – Degree Audit Record
• Student Account Ledger for charges – net charges
VETERANS BENEFITS ADMINISTRATION
Enrollment Certification
• VA Form 22-1999, Enrollment Certification
used by the SCO/Institution for certifying:
• Exercised reasonable diligence in meeting all
applicable requirements for the following
seven (7) criteria:
VETERANS BENEFITS ADMINISTRATION
Enrollment Certification
- The institution has exercised diligence in meeting all
applicable requirements of Title 38 USC and any failure by the
institution to meet any requirements of the law will be
reported promptly to VA
- The institution agrees to report promptly to VA any
enrollment change and any change due to unsatisfactory
progress, conduct or attendance. Promptly means within 30
days of the enrollment change.
VETERANS BENEFITS ADMINISTRATION
Enrollment Certification
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The 85/15% enrollment ratio requirement has been satisfied
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Student certified is not an owner or officer of the school nor is the student
certified an official authorized to sign enrollment certifications
-
The institution holds no power of attorney agreement authorizing the
institution to negotiate VA educational assistance allowance checks
-
No course certified is a repetition of any course previously satisfactorily
completed except as permitted by VA regulations
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The course or courses certified (added: excluding DEEMED approved
institution degree programs) are approved by the State Approving Agency and
are generally acceptable to meet requirements for the student’s objective
VETERANS BENEFITS ADMINISTRATION
Benefit Chapters
VA education benefit chapters reviewed on compliance surveys are:
Chapter 30 – MGIB
Chapter 32 – VEAP (Vet Edu Asst Program)
Chapter 33 – Post-9/11 GI Bill
Chapter 35 – Dependent Education Assistance
Chapter 1606 – MGIB Selected Reserves
Chapter 1607 – REAP (Reserves Edu Asst Program)
(VRAP administered under Chapter 30 – ended March
2014, Fry Amendment administered under CH33
CH33TOE and Yellow Ribbon Program
Excluded: Chapter 31 Vocational Rehabilitation Benefit
VETERANS BENEFITS ADMINISTRATION
Access to Records
• The Buckley amendment (Public Law 93-380) requires that
institutions receiving Federal funds administered by the
Department of Education must obtain the student's consent to
release information from school records.
• It has been determined that school records relating to VA
benefits fall into the "financial aid" category and are therefore
exempt from the provisions of the Buckley amendment.
• Therefore, the VA (and SAA) shall have access to the records of
VA beneficiaries as well as non-VA students without the
written consent of the student in order to monitor the school's
compliance with the law.
VETERANS BENEFITS ADMINISTRATION
Access to Records
• Title 38 CFR 21.4209 – Provides VA & SAA access to any
institutional records as condition of approval
• VA and SAA exempt from Family Education Rights & Privacy
Act (FERPA)
• Access to VA and non VA student academic and financial
records
• Access to review Institutional Advertising Materials
• Principles of Excellence
• Student Interviews
VETERANS BENEFITS ADMINISTRATION
Types of Facilities Surveyed
• VA compliance surveys are conducted at the following types of
active facilities as of October 1, 2014 (FY15)
–
–
–
–
–
Institutions with 300 plus VA certified VA beneficiaries – 100%
Institutions of Higher Learning – (less than 300) – as required
Non College Degree Institutions – 100%
Vocational Flight Training Schools – 50%
Training Establishments – 100%
• Apprenticeship (APPR)
• On-the-Job training (OJT)
• Federal and Nationally approved OJT and APPR facilities – excluded in FY15
– Director, Education Service, may act for the Secretary and may waive compliance
surveys at institutions with a demonstrated record of compliance. St Louis CELO did
request ELR staff to review and submit waiver requests for schools that had met
demonstrated record of compliance – meaning no compliance survey at these
institutions in FY14.
VETERANS BENEFITS ADMINISTRATION
Who Conducts Surveys
Effective October 1, 2011 per Public Law 111-377 both VA and State
Approving Agency (SAA) staff conduct compliance surveys.
Noted facts:
- sample student size decreased effective 10/1/13 for
schools with higher VA student enrollment
- institutional source documents may not be required to be
retained by VA or SAA following on site compliance surveys
- Increased efforts to conduct remote surveys in FY14
VETERANS BENEFITS ADMINISTRATION
COMPLIANCE SURVEY
VETERANS BENEFITS ADMINISTRATION
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Requested Documents
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Institutional Records for Sample Student Records:
Copy of unofficial transcript
Copy of Degree Audit Report (DAR)
Copy of Student Account Ledger
Verification of prior credit evaluations
Copy of Student term registration schedules
Identifying start date, end date
Identifying modality of instruction
Captures non-standard term dates by subjects
Progress Standards (GPA)
Obtaining LDA or last activity to confirm
withdraw of subjects for student records
VETERANS BENEFITS ADMINISTRATION
Compliance Surveys
Each survey conducted by VA consists of a random sample of VA student records
for those who have been certified and awarded benefits at that institution.
Sample size is based on total VA student awarded enrollment total. NOTE: We
review minimum of 10 VA student records unless there are fewer than 10 students
enrolled (excluding Chapter 31) and maximum of 45 students for facilities with VA
student populations of 100 or more.
Purpose of the sample size is to validate and confirm institutional certifications
and practices – to ensure accurate and timely reporting to VA by the designated
SCO.
VETERANS BENEFITS ADMINISTRATION
Surveys - Scheduling
-Majority of compliance surveys involve travel meaning a number of institutions may be
scheduled for a given week (Monday – Friday). We strive to not schedule at institution peak
workload periods however this may not always occur based on travel plans.
-A call to the primary SCO is done to schedule a date(s) and time for conducting the survey in
addition to providing institution with names of students in the sample size to be reviewed.
-A letter or email will be furnished the SCO of the student names and the institutional records
to copy for our review.
-The institutional records copied will be retained by VA and SAA to include in our compliance
survey records – PII data is safeguarded and necessary as internal quality reviews by VA are
conducted to ensure all aspects of the compliance survey were accurately reviewed and
completed. (procedures changed for FY14)
PII data can be shredded following a reasonable period from date of closed survey
(normally within 90 days)
VETERANS BENEFITS ADMINISTRATION
Conducting Survey
The onsite compliance survey may involve one or more individuals based on the
size of the sample VA student records to review.
We will schedule an entrance briefing with the primary SCO and other institutional
staff to describe and explain purpose of our visit and to confirm the requested
records were provided for our review.
The second step is to review the student records and compare to VA Form 22-1999
and VA Form 22-1999b submissions to validate accurate and timely reporting to VA.
Questions and confirmation of additional data will be made to the SCO during the on
site compliance survey to validate last date of attendance, withdraw dates, or any
other action requiring justification or clarification.
The last step on the on site survey will be the exit briefing. The purpose of the exit
briefing is to provide institution with survey results based on the findings with
emphasis to identify the root cause of the exceptions.
VETERANS BENEFITS ADMINISTRATION
Remote Survey
VETERANS BENEFITS ADMINISTRATION
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REMOTE SURVEY
REMOTE REVIEW OPTION
To make more efficient use of time and funds expended for travel, ELRs, and
ECSS have the option of conducting remote compliance reviews at those IHL
and NCD facilities willing and able to participate.
The remote review is based on documents submitted by the school and VA
records. The remote review can be used as a means of shortening time on
site, even when the survey site visit is done as usual.
Schools are not required to participate, and the ELR and the ECSS are not
required to conduct any survey by remote review even at participating schools.
The remote review is necessarily less extensive than a review during a site
visit. It is not intended to replace the site visit, but rather to supplement it.
ELRs are encouraged to take advantage of the remote review option.
However, its use in any particular case depends on the ELR's best judgment.
VETERANS BENEFITS ADMINISTRATION
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When to Conduct A Remote Survey
A remote survey can be conducted only if the following conditions do not apply:
- The school is newly approved, and has become active for first time
- The last compliance survey site visit was over five years ago
- The previous compliance survey disclosed serious discrepancies
- The remote review discloses possible discrepancies that cannot be resolved by
telephone or by submission of additional documents
- An allegation of possible fraud has been received
- The compliance survey specialist decides a site visit is necessary based on school’s
compliance history, the SCO’s training and experience, and results of liaison visits or
SAA supervisory visits
VETERANS BENEFITS ADMINISTRATION
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Dear [Name of Certifying Official]:
The Department of Veterans Affairs (VA) is modernizing the way we do compliance reviews.
The most significant change is to offer the option of remote compliance reviews. Your
participation is requested, but it is not mandatory. This letter will tell you more about remote
compliance reviews.
Training Overview
What is a Remote Compliance Review?
A remote compliance review is conducted in the VA regional office using documents obtained
from the school and found in VA records. The remote review may be:

completed without a regular on-site-visit to your facility, or

used as a preliminary review of documents prior to the regular on-site visit.
What Will be Needed to Participate?
To conduct a remote review, we need you to submit to this office, copies of specified documents
regarding each student to be surveyed. You may send documents to us by mail or by fax. At a
minimum, these would include:

Transcripts and course schedules

Account statement
It is anticipated that during the review of documents, questions may arise concerning a student’s
enrollment. These issues probably can be resolved with a phone call. In some cases, additional
documents may need to be submitted.
What About Privacy?
The privacy of items sent to VA will be maintained, and appropriate disposal will be made of
those not retained for record purposes. Even though Public law 93-380 (Buckley Amendment)
restricts access to student records, Title 38, United States Code, Section 3690(c) says records and
accounts of students receiving VA benefits must be made available for review.
What Do I Need To Do?
We would appreciate it if you would advise us of your institution's willingness to participate in a
remote compliance review. You may use the suggested format shown on the enclosure,
SUGGESTED REPLY. A reply envelope is enclosed for your convenience.
Our office will determine whether a regular survey or remote review will be conducted in each
case. If you have any concerns or questions, you may contact Joyce Winston, Education
Compliance Survey Specialist, at 312-980-4221.
Sincerely yours,
CELO Name
Chief Education Liaison Officer
Enclosures: Self Addressed Envelope
Compliance Survey List
TO: Surveyor Name
Address
FROM: [School Name]
[School Address]
_____ Yes, I would like to be considered for the remote survey option. I understand that I may
have to mail or fax copies of documents. I also understand that even if my school is selected for
this option, a visit by a VA representative could be necessary.
_____ No, I would not like to be considered for the remote survey. (If answer is no, please provide
the date the records will be available for onsite review)
Reasons (optional):
Comments and/or Questions:
Signature:
Printed Name:
Title:
Compliance Survey Findings
•
Common errors involve:
– Not reporting changes or terminations (occasional instances or for all students)
– Not reporting net charges correctly or YRP contributions incorrect
– Not reporting unearned F grades – discontinued per VACO policy Nov 2013
– Not reporting distance learning correctly
– Late reporting of enrollments or enrollment changes to VA
– Failure of institution to evaluate or monitor prior credit evaluations
– Certifying credits that do not apply to program requirements
– Certifying remedial subjects when offered on line
– Incorrectly reporting LDA – last day of attendance on withdrawing
– Certifying incorrect program name or type of training
– Not reporting unsatisfactory progress or probation
– Lack of institutional records to support certifications to VA
– Certifying programs not approved by VA or SAA
VETERANS BENEFITS ADMINISTRATION
Post Survey Actions
Evidence of non compliance may involve overpayments to both institutions and
students noted on compliance surveys.
Reporting errors of 30% or greater may result in an expanded review and a sample
size of 95%. The expanded sample size also includes those already reviewed in the
initial sampling.
A total reporting error of 50% or greater may develop into a 100% review of VA
student records.
VETERANS BENEFITS ADMINISTRATION
Survey Referral Procedures
Procedures
1. Once student record has been identified for referral, have SCO amend. Adjust, or terminate as
needed and select the standard remark “COMPLIANCE SURVEY REFERRAL – PLEASE NOTIFY
SPECIALIST AS INDICATED BELOW”. Additional non-standard remark should also be created to
indicate “SURVEY CONDUCTED by John Doe. Please notify [email protected] when correction has
been made. SCO should submit referral when complete.
2. Print one copy of referral doc for SCO’s records, another to become part of the compliance survey
records (in addition to necessary documentation of error/discrepancy.)
3. Repeat steps 1 & 2 until all identified students have been corrected.
4. Advise SCO to make similar corrections to affected students not reviewed as part of survey as soon
as possible following completion of survey. However in this instance, once student record has
been identified for correction, SCO should amend, adjust, or terminate as needed and select the
standard remark “ COMPLIANCE SURVEY CORRECTION – NOTIFICATION NOT REQUIRED”. (These
records are not controlled.)
VETERANS BENEFITS ADMINISTRATION
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Post Survey Actions
VA and SAA will prepare narrative reports for the survey findings.
Findings of reporting discrepancies will involve referrals to the RPO for
award actions
Findings of no reporting discrepancies however late reporting is noted
and evaluated
Findings of approval criteria is referred to the SAA at all institution is for
appropriate review, investigation, and necessary corrective action
A letter is sent to the institution to acknowledge the compliance survey that
conveys the results of our visit. (Normally discrepancy issues are noted during our
exit briefing)
VETERANS BENEFITS ADMINISTRATION
Survey Referral Procedure
Procedures Continued
5. Forward notice of referral to RPO based on locally determined procedures currently in place.
6. Work-in-progress controls should be established by the ESU/SAA to ensure that corrective action is
completed within 30 days. Corrective action may be ascertained by review of the BDN/LTS record
even though a formal response has not been received. Requests which have been pending more than
30 days without either corrective action or a response should be brought to the attention of the CELO
at the RPO.
7. If during the compliance survey, it is determined that the school has already correctly submitted a
22-1999b, regardless of whether it was submitted within 30 days of the effective date of the change
or not, the survey specialist does not have to submit a compliance survey referral. (However, if the
22-1999b was not submitted within 30 days of the effective date of the change, the survey specialist
must address the timeliness of the submission of the VAF 22-1999B in the narrative.)
VETERANS BENEFITS ADMINISTRATION
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Compliance Survey Referral Pilot Procedures
Advantages
Referral becomes part of veteran’s file at the school.
SCO learns correct certification method, rather than merely notified of errors via compliance survey findings letter.
Fosters collaborative effort between Survey Specialist/SAA Staff and SCO.
Corrections submitted to VCEs in standardized format, rather than that of free-form referral document.
Improves survey timeliness as preparing referrals is no longer an additional step of the post-survey process.
Future enhancements such as dedicated ‘Compliance Referral’ doc type in VA-Once would permit system routing of
referrals in TIMS, which would dramatically improve controls and allow for survey data collection. LTS may be able to
auto-process in some instances, as well as collect survey data. (Similar to graduation rate data collection process.)
Allows for collection of error data outside of survey sample. This aspect of surveys has never been collected. SCOs
are instructed to make corrections of all student records with errors similar to those noted from survey sample. This
would enable VA to see if corrections were made and track affected students, overpayments, etc.
VETERANS BENEFITS ADMINISTRATION
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Survey Referral Procedures
Requirements
School must be actively using VA-Once. This excludes all APP/OJT Training Facilities,
Correspondence Institutions and schools using paper enrollment documents.
Must review entire survey sample to determine that error/discrepancy rate will not exceed
30% error rate. (If rate exceeds 30% or fraud is suspected, use standard referral methods.)
Creation of VA-ONCE standard remark “COMPLIANCE SURVEY REFERAL – PLEASE NOTIFY
SPECIALIST AS INDICATED BELOW”. This would be used in conjunction of a non-standard
remark with the name and e-mail of the ECSS/SAA that conducted the survey.
Creation of VA-ONCE standard remark “COMPLIANCE SURVEY CORRECTION –
NOTIFICATION NOT REQUIRED”. This would allow for tracking of errors brought to light
from the survey of students outside of the survey sample.
VETERANS BENEFITS ADMINISTRATION
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Summary
VA does maintain a tracking system on a fiscal year basis for all
compliance surveys conducted as well as:
- Name of institution and type
- Date of compliance survey
- Individual who conducted the survey
- number of VA student records reviewed
- number of VA students records with discrepancies
This information is reported to VA Central Office, Washington, DC on a
periodic basis to confirm institutional compliance.
VETERANS BENEFITS ADMINISTRATION
IHL FLIGHT PROGRAMS
There is a limit on the number of flight hours that can be certified
for a student participating in a standard degree program involving
flight training.
In accordance with 38 U.S.C. §§ 3452(b), 3680(a) and (g) and 38
C.F.R. § 21.9510, VA can only pay for flight hours that are required
and necessary to reach the program’s objective. The required hours
should be clearly stated in the course syllabus and must be the same
requirement for all students enrolled in the program. If the school
has elected not to clearly state required hours in their syllabus then
the school has implicitly adopted as its required hours the minimum
required hours as stated in the FAA approved TCO.
VETERANS BENEFITS ADMINISTRATION
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IHL FLIGHT PROGRAM
•
38 U.S.C. § 3680(a)(1) states that “no amount shall be paid to any[one]…not pursuing a course in
accordance with…the provisions of such regulations as may be prescribed by the Secretary
pursuant to subsection (g) of this section.
•
38 U.S.C. § 3680(g) states that “[t]he Secretary may, pursuant to regulations which the Secretary
shall prescribe, determine and define with respect to an eligible veteran and eligible person the
following: (B) Pursuit of a course or program of education or training.
•
38 C.F.R. § 21.9510 defines pursuit as “work, during a certified enrollment period, towards the
objective of a program of education. This work…must be necessary to reach the program’s
objective. (emphasis added).
•
38 U.S.C. § 3452(b) requires any curriculum must be generally accepted as necessary to fulfill
requirements for the attainment of a predetermined and identified educational objective.
VETERANS BENEFITS ADMINISTRATION
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IHL FLIGHT PROGRAM
The objective of this standard college degree program is not “to obtain a pilot’s license.” If that were
the objective then this program should be reviewed for possible reclassification as a vocational flight
program Rather, as a standard college degree program, the program of education’s objective must be
described in terms of an educational objective.
The school must then state how much training (i.e., how many flight hours) is required in order for a
student to obtain such knowledge. [Please note that the required amount of training must be the
same for all students in the “program of education” and must be based on what is generally accepted
as necessary to meet the educational objective.
The required training time cannot be written in terms of “training to proficiency” or any other
subjective standard by which one student is required to train more than other students. If the
students have individualized training requirements then each individual student is in a separate
program of education subject to all statutory requirement for approval (e.g., 85/15 requirements).]
Once we establish the amount of flight hours necessary to obtain the educational objective, then 38
U.S.C. § 3680(a) statutorily prohibits VA from paying for any flight hours that exceed the established
necessary hours. Since these excessive training hours are not payable they should not be included on
the certification.
VETERANS BENEFITS ADMINISTRATION
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The statutory prohibits paying for training in excess of what is necessary that highlights the fact that if
a program involves costs whereby training is paid by VA on a per-unit basis (e.g., price per hour of
flight time, price per hour of lab time), then that course must have a specific and identified required
amount of training.
To approve a program with a per-unit basis costing without a specific and identified required amount
of training would render VA incapable of fulfilling our statutory obligation because we would not be
able to determine if we could pay for any units of training because we would be unable to determine
if each incremental unit of training was necessary.
However, this dilemma does not exist with courses that have a set fixed rate for training whereby VA is
not charged incrementally for each additional hour of training. In those situations, 38 U.S.C. 3680(a)
does not require VA to access the necessity of each additional training hour because there are no
costs associated with each additional training hour. It is sufficient for VA to know that the course is
required as a part of the program and the cost for the course is X dollars. Section 3680(a) does not
stand as an obstacle here because we are certain that the training is necessary and we are only being
asked to pay for what is necessary.
VETERANS BENEFITS ADMINISTRATION
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Dual Majors
VETERANS BENEFITS ADMINISTRATION
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Dual Majors
M22-4, Part III, Chapter 6, Programs of Education.
Enrollment in dual majors at an institution of higher learning (IHL) is not
considered a “dual objective” for the purposes of M22-4, Part III, Chapter 6,
6.04(d)(1).
SAAs will not have to individually approve a VA student's program of education
if the student is enrolled in dual majors as long as both majors are approved
programs offered by the (IHL). SAAs will continue to review, approve, and
ensure compliance with the IHL’s policy regarding dual majors.
VETERANS BENEFITS ADMINISTRATION
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Survey Review of Dual Majors
During VA site visits, or during compliance surveys, if VA reviews a case for a
student who is pursuing dual majors, we should ensure the student is not enrolled
in courses outside either major and that the courses are approved.
In addition, SAAs do not need to approve minors taken as part of an approved
major even if pursuit of the minor field will require the student to extend the length
of his or her program beyond what is normally required for graduation. This is a
deviation from chapter 6.04(d)(3). On compliance visits, if ELRs or compliance
survey specialists review a student's file and the student has a declared major
and is enrolling in courses for a minor, we should ensure that the courses are
approved.
Apply these approved deviations to any award, and any review of cases on
compliance reviews from this date forward whether or not the student pursued
the course or enrolled in the course before the date of this policy advisory.
VETERANS BENEFITS ADMINISTRATION
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The 85/15 Rule
85
VETERANS BENEFITS ADMINISTRATION
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Restrictions on Enrollment (85/15 Rule)
• 38 U.S.C 3680A(d)
• 38 CFR 21.4201
• Prohibits paying benefits to students enrolled in a course
when more than 85% of the students enrolled in the
course are having all or part of their tuition, fees, or other
charges paid to or for them by the school or VA
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85/15 Rule
• If ratio of VA students to non-VA students exceeds 85% at the time a VA
student enters or reenters (after a break in enrollment) the student is
not entitled to VA benefits
• Requirement does not apply to CH 31 or 35
• Must count students receiving CH 31 or 35 benefits as VA students
when computing the ratio
VETERANS BENEFITS ADMINISTRATION
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85/15 Rule
Statement of Assurance of Compliance With
85/15 Enrollment Ratios
VA needs this information to determine your compliance with the requirement that no more
than 85% of students in any one program are VA-eligible students. Submit a copy of the
computation no later than 30 days after the beginning of each term (quarter, semester, or
module). If your calendar is based on a school year instead of terms, these reports will be
required every 12 weeks. Compute the full-time equivalency for part-time students, divide
by two, and add the quotient to the number of full-time students. E-mail the computation
to INPUT YOUR EMAIL ADDRESS.
If your total VA student enrollment is 35% or less, we will grant a waiver from periodic
reporting of the percentage of students enrolled. You will still need to monitor your
enrollment and report to VA if the VA enrollment in any one program exceeds 85% of the
total enrollment in that program.
VETERANS BENEFITS ADMINISTRATION
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85/15 Rule
If your total VA student enrollment is more than 35%, you will need to continue to compute the VA student enrollment
for each program approved for Veterans Benefits. You’ll also need to send updated reports for each program within 30
days of the start of each term (quarter, semester, or module) or every 12 weeks.
Date of Calculation: _______________
Number of
VA Students
Program Name
Total
Enrollment
VA Student Percentage
Totals
_____________________
School Official’s Signature
VETERANS BENEFITS ADMINISTRATION
__________
Date Signed
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Graduation Reporting
VETERANS BENEFITS ADMINISTRATION
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Reporting Graduation
Dear School Officials,
There have been many questions/concerns about reporting graduation in VA Once.
Schools are required to track and report graduation for students who are using VA benefits during the term they graduate in. There must be an active
certification for that term. Please do not report graduation if the student did not graduate in a term where benefits were used. Below are some FAQs
about the retroactive reporting of graduation.
Will schools need to report grades?
No. Institutions are not to begin reporting grades to VA
How far back should schools go to report graduation/completion data for Post-9/11 GI Bill?
Institutions should report graduation/completion data from August 1, 2009. Graduation should only be reported if the student completed the
program within a term that was certified for benefits.
Why is VA focusing on the Post-9/11 GI Bill only and not on other benefit programs?
Post-9/11 GI Bill benefits represent an overwhelming majority (over 80%) of all education benefits, and should therefore effectively convey trends in
student Veteran success at any institution.
How do you report graduation if a student doesn't graduate from the institution? Example: student transfers from a 2 year to 4 year institution
If the student does not graduate, you should not report it
What if a student exhausts benefits and doesn't use benefits in the last term? How do we report graduation if they graduate after exhaustion?
If the student graduates after they exhaust their benefits, do not report it.
Will schools report on an individual basis for students or will they supply a grand total of graduations?
Institutions are to report on an individual basis, through VA-ONCE, actual graduation/program completion for all users of the Post-9/11 GI Bill. This
information should be reported from August 1, 2009 (inception program) through present. Graduation should only be reported if the student
completed the program within a term that was certified for benefits.
To email questions on graduations outcome measures, please go to VAVBAWAS/CO/Outcomemeasures [email protected]
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WALKAWAY GRADES
VA’s regulations covering school reporting requirements are contained in
section 21.4203 of title 38, Code of Federal Regulations. Subsection (d), in
particular, states that “When a veteran or eligible person interrupts or
terminates his or her training for any reason, including unsatisfactory
conduct or progress, or when he or she changes the number of hours of
credit or attendance, this fact must be reported to VA by the school in a
form specified by the Secretary [emphasis added].”
However, section 21.4253 of the same part only requires accredited
schools to maintain attendance records if the school has an established
attendance policy.
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WALKAWAY GRADES
Questions & Answers
Note: The questions and answers below deal with requirements for schools to
report any/all changes in attendance. Reporting requirements for non-attendance
due to an interruption (e.g. a leave of absence), changes in enrollment (e.g.
voluntary or involuntary reductions or terminations), violations of established
policies for attendance or conduct, or for corrections to information previously
certified in error are separate issues and remain unchanged.
Question 1: Do the regulations require all schools, including those that are
accredited and don’t have an attendance policy, to report changes in attendance?
Answer 1: No. Only schools that have an attendance policy are required to report
pertinent changes in attendance.
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Walkaway Grades
Question 2: Are schools required to report any changes in attendance, or only
those that violate the schools attendance policy?
Answer 2: Schools with an established attendance policy must monitor compliance
with that policy, enforce the policy, and report terminations due to violations of the
policy to VA without delay. However, absences that do not violate the established
attendance policy don’t need to be reported. Schools that don’t have an established
attendance policy are not required to report changes in attendance.
Question 3: If a student completes a period of enrollment with a failing punitive
grade (i.e. an F) assigned, does the school need to report the last date of
attendance during that enrollment period?
Answer 3: No. The last date of attendance during a period of enrollment does not
need to be reported if a student completes the enrollment period with a punitive
grade and does not violate the school’s standards of conduct, progress, or
attendance during that term.
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REPEAT COURSES
A student may receive VA education benefits to repeat a course required for graduation in which a
punitive failing or other unacceptable grade was assigned.
If the student passed the course the second time: The grading policies of many institutions permit
replacement of a punitive grade with a creditable passing grade following successful repetition of a
failed course. The result of these policies is that the earlier failing grade loses its punitive character
and becomes nonpunitive.
What you should do: When such grade replacements occur do not report these grade replacements to
VA. VA will automatically concede that mitigating circumstances exist for the nonpunitive replacement
grades.
If the student does not successfully complete the course the second time: Is the second grade
punitive or nonpunitive? In some instances the second failing or other unacceptable grade assigned is
nonpunitive in nature, even though it may be the identical grade previously received for the course.
For example, an institution's grading policy may provide that only one pursuit of the course is
considered when computing accumulated credits attempted and overall GPA.
What you should do: If the second grade for the course imposes no additional penalty toward
meeting
graduation
requirements,
it is a nonpunitive grade and must be reported to VA.
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BENEFITS
ADMINISTRATION
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Questions?
VETERANS BENEFITS ADMINISTRATION
CONTACT INFORMATION
Joyce Winston
Education Compliance Survey Specialist
Department of Veterans Affairs
2122 West Taylor Street
Support Services Division #147
Chicago, IL 60612
312-980-4221
312-980-4504(fax)
[email protected]
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