Compliance and Reporting
As a School Certifying Official (SCO), you’re not just submitting enrollment certifications—you’re also responsible for making sure your school stays in compliance with VA rules and policies. This includes reporting changes promptly, maintaining accurate records, and cooperating with compliance surveys conducted by VA, their representatives, or, in the case of supervisory visits and risk-based surveys, your State Approving Agency (SAA).
This section gives you an overview of what compliance means in your role, what VA looks for during reviews, and how to stay on track.
Your Responsibilities
As an SCO, you’re expected to:
- Submit certifications and updates accurately and on time
- Report changes to enrollment, program details, or tuition promptly
- Keep clear, organized records for each VA student
- Respond to requests for information or documentation
- Complete required training each year (if applicable)
- Notify VA of any changes in your SCO designation
These responsibilities help protect students’ benefits and keep your institution in good standing with VA.
VA Compliance Surveys
Most schools will periodically undergo a compliance survey conducted by VA, or agents of VA. VA currently contracts with an organization, St. George Consulting, Inc. (SGC), a management consulting company. This organization performs a number of routine compliance surveys on our behalf. These reviews help verify that:
- Students receiving VA benefits are properly enrolled and progressing
- Certifications match actual enrollment status and training time
- Records are complete, consistent, and accessible
- The school is following all VA program rules and SAA-approval requirements
Surveys are usually scheduled in advance and involve reviewing a sample of student files. You’ll be asked to provide records like enrollment records, transcripts, tuition and fee breakdowns, attendance logs (if applicable), and flight logs (if applicable).
Risk-Based Surveys and Targeted Reviews
In addition to routine compliance checks, VA and SAAs may conduct more focused reviews based on specific risk factors:
- Risk-Based Surveys look at patterns that may indicate non-compliance—like sudden spikes in VA enrollment, frequent student complaints, or irregular tuition increases. These are conducted by SAA.
- Targeted Risk-Based Reviews are unannounced and may be triggered by serious concerns such as allegations of fraud, deceptive advertising, or legal actions. These may be conducted by VA or SAA.
These surveys are designed to protect students and ensure benefit funds are used properly. They’re not common, but it’s important to be aware of them and to keep records current and accurate at all times.
How to Stay Compliant
Good habits make compliance easier and help you prepare for any review:
- Keep all student certification records in one place, or accessible, if housed in another department
- Document any changes made in Enrollment Manager (and why)
- Save copies of VA Forms, enrollment confirmations, tuition breakdowns, and communications that are not available in Enrollment Manager
- Submit certifications and amendments promptly (within 30 days from the start of the term or date of change)
- Stay current with VA training and guidance
Tip: Think of your records as a story—someone unfamiliar with your school should be able to understand what was certified and why.
Helpful Resources
What’s Next?
Now that you know how to stay compliant, explore the next section to learn how to avoid common certification errors, and what to do if you make one.
