Education and Training.

Question 1: We have an apprenticeship and I'm wondering if programs like ours would need to report to the State Approving Agency (SAA) or Veterans Affairs (VA) if our company, but not our apprenticeship, became subject to an investigation?

Answer: You should contact the State Approving Agency (SAA) if your company becomes the subject of an investigation.

Question 2: What about the tuition and fee (T&F) money paid to the school? The student attended and we provided the education and services. Shouldn’t the service member also be responsible for that debt?

Answer: Section 203 only transfers student debt to the servicemember and only when the servicemember fails to complete the service qualifications that allowed them to Transfer Eligibility to their family members. Any T&F or Yellow Ribbon debt will continue to be placed on the school. The school should continue to follow normal procedures to debt the student, if applicable. Any student debt based on a change in student enrollment would legitimately be associated with that student and school, as per current procedure.

Question 3: Are we now required to monitor Veterans Employment Through Technology Education Courses (VET TEC) students for 6 months after they gain employment?

Answer: Criteria for the new High-Tech program are still being developed. As schools become approved for this new program, requirements will be conveyed to School Certifying Officials (SCOs).

Question 4: When do you anticipate Enrollment Manager (EM) to update with the specialized comment on rounding out?

Answer: We anticipate Enrollment Manager and Digital GI Bill® (DGI), the Chapter 33 processing system will be updated in time for Spring 26 enrollment. Both systems require updates to accommodate section 208 of the Dole Act.

Question 5: Does a provisional watch count as punitive action?

Answer: Education Service is still determining policy for this provision. As more information becomes available, schools will be notified. 

Question 6: For the new Chapter 33 Rounding Out option to be compensated later, is there anything in particular that would need to do within EM so that you all know to go back later once the new system is implemented?

Answer: Once EM and DGI are updated additional guidance will be provided. In the interim, SCOs should track Chapter 33 students who have chosen to wait until our systems are updated to receive the full-time housing rate. When EM has been updated, SCOs can retroactively certify any term(s) in question. 

Question 7: Study Abroad Changes and Rounding Out: It is my understanding that students no longer need to take the additional classes to get the full-time housing allowance for their Final Term, we have a student who under this new change effective January 2, 2025, would qualify for the full-time rate even though he is only taking 4 units instead of 12.

My concern is whether we can confidently advise students on this update, as many are aware of Veterans Affairs (VA) policy changes and are eager to know when it will take effect. The challenge seems to be that the VA doesn’t yet have a clear way to track these students, as there is no option or indicator in EM when certifying their final term.

Can you provide guidance on the best way to move forward?

Answer: The revised Rounding Out rules found in the Dole Act only apply to Chapter 33 students. Once EM and DGI are updated additional guidance will be provided. If the student doesn’t wish to wait to receive retroactive payment for Spring 2025 or later, they may follow the existing Rounding Out rules. In the interim, SCOs should track Chapter 33 students who have chosen to wait until our systems are updated to receive the full-time housing rate. When EM has been updated, SCOs can retroactively certify any term(s) in question.

Question 8: Veterans Employment Through Technology Education Courses (VET TEC) slide. The employment of the individual by the provider for a period of one year, is this employing the students by our company? Are there benefits for the student as far as paid internships?

Answer: Criteria for the new High-Tech program are still being developed. As schools become approved for this new program, requirements will be conveyed to School Certifying Officials (SCOs).

Question 9: What about Veteran Readiness and Employment (VR&E) Chapter 31 students, they receive Monthly Housing Allowance (MHA) under most circumstances if eligible for Chapter 33 when inducted into Chapter 31 VR&E?

Answer: Please direct all questions regarding Chapter 31 students to the student’s VR&E Counselor.

Question 10: Where can we find more information about the digital transcripts. We are a small Non College Degree (NCD) Non-Term clock hour school with only one VA student. Are we required to make their official transcript in digital format? 

Answer: All accredited institutions must make available the transcript to any VA student enrolled in any program. For non-accredited institutions of higher learning, they are only required to make available the transcript to student enrolled in a standard college degree program; the requirement does not apply to non-college degree programs. Emailing a portable document format (PDF) transcript satisfies the requirement.

Question 11: Per legislation, starting August 1st, we will have to provide students with a digital copy of their official transcript. Our university policy is that if a student has a hold with our Bursar’s Office, they are not allowed a copy of their transcript. Does the new law trump our university policy? Regardless of if a student has a hold on their account, will we have to provide a student with a copy of their transcript?

Answer: Yes, the law requires VA beneficiaries to be able to receive a transcript upon request.   

Question 12: Digital transcripts Section 207 slide. I understand it goes into effect on 8/1/2025, and that it applies to any semester after that effective date. We provide a digital unofficial transcript in our student portal, but this is stating that we’ll need to also have an official transcript in that portal available to students?

Answer: Yes, Section 207 of the Dole Act requires schools to make a digital copy of a student’s official transcript available.

Question 13: I asked if the digital transcript requirement was for both unofficial and official also, so an official transcript must have the registrar seal on it. The law states “Official”. I have a question regarding the language of “each eligible person or veteran”. Can we get clarification of who is an “eligible person”? The Dept of Education hasn’t required digital transcripts as of now, but I realize it may be coming.

Answer: For the purposes of Section 207 of the Dole Act, an eligible person is any individual receiving VA educational assistance benefits.

Question 14: Please clarify if section 207 applies to accredited Institutions of Higher Learning (IHLs)? If so, we make the official electronic transcript available to all students (including Veterans and VA beneficiaries) for purchase ($20) through Parchment. Does this meet the requirement? Or are educational institutions being asked to provide the official digital copy of the transcript to each Veteran or VA beneficiary for free?

Answer: Yes, Section 207 applies to both accredited and nonaccredited schools. The law does not state the transcript must be provided for free.  

Question 15: Does the effective date of Jan 2, 2025, for Section 204, impact a letter I received on 28 Jan 2025? The notice came to my school for a debt in the student’s name.

Answer: Section 204 relates to Risk-Based Surveys Notice to Educational Institutions. Section 203 only transfers student debt to the servicemember and only when the servicemember fails to complete the service qualifications that allowed them to Transfer Eligibility to their family members. Any T&F or Yellow Ribbon debt will continue to be placed on the school. The school should continue to follow normal procedures to debt the student, if applicable. Any student debt based on a change in student enrollment would legitimately be associated with that student and school, as per current procedure.

Question 16:  For the recoupment of benefits, does the VA send the school a debt letter for the tuition and fees that was paid for previous terms, or is the service member/Veteran placed in a debt status for all the entitlements paid out?

Answer: Section 203 only transfers student debt to the servicemember and only when the servicemember fails to complete the service qualifications that allowed them to Transfer Eligibility to their family members. Any T&F or Yellow Ribbon debt will continue to be placed on the school. The school should continue to follow normal procedures to debt the student, if applicable. Any student debt based on a change in student enrollment would legitimately be associated with that student and school, as per current procedure.

Question 17: What happens if a student uses Rounding out in their final term, drops courses, and then requests Round out again?

Answer: Students may use Rounding Out only once per program. If a student drops courses, including the remaining required course(s), they may not Round Out again during that program.    

Answer: Under current rounding out rules, students may round-out to reach up to full-time enrollment. Once full-time has been reached, no additional courses may be certified. Please see the SCO Handbook for the additional information regarding what courses can be added under the Rounding Out provision. Policy for the new Rounding Out rules described in Section 208 are still being developed. 

Question 19: In today's training it said that transfer of benefit debt will go to the service member if they do not meet their contractual agreements. How is this possible if schools receive debt which we return then must go after the student to recoup tuition and fee funds? Is this only referring to housing allowance debt? 

Answer: Section 203 only transfers student debt to the servicemember and only when the servicemember fails to complete the service qualifications that allowed them to Transfer Eligibility to their family members. Any T&F or Yellow Ribbon debt will continue to be placed on the school. The school should continue to follow normal procedures to debt the student, if applicable. Any student debt based on a change in student enrollment would legitimately be associated with that student and school, as per current procedure.

Answer: The Rounding Out provision applies to all benefit chapters. However, the Dole Act Section 208 update is related to the Monthly Housing Allowance (MHA), which is a provision of Chapter 33 benefits only. Please refer to the SCO Handbook for the Rounding Out procedures for non-Chapter 33 students.

Answer: All Chapter 35 beneficiaries will be required to verify their enrollment every month once their claim is processed in Benefits Manager (BM). Beginning in April 2025, select Chapter 35 beneficiaries will be processed in BM. Starting in Fall 2025, all Chapter 35 beneficiaries will be processed in BM. Chapter 35 degree seeking students will receive communication of when to begin and how to verify their enrollment (Chapter 35 students in NCD programs already verify their enrollment each month). SCOs will also receive notification when we are nearing the release to assist in determining what terms will be impacted.

Answer: Once EM and DGI are updated additional guidance will be provided. If the student doesn’t wish to wait to receive retroactive payment for Spring 2025 or later, they may follow the existing Rounding Out rules. In the interim, you should track Chapter 33 students who have chosen to wait until our systems are updated to receive the fulltime housing rate. When EM has been updated, you can retroactively certify any term(s) in question.

Answer: All VA beneficiaries, including Chapters 30, 1606 and 35 are certified in Enrollment Manager. Benefits Manager is an internal system used by VA to process enrollment certification submitted by schools via EM.

Answer: All payments are affected if a student rounds out and adds additional courses under the Rounding Out provision, as applicable tuition and fees and Yellow Ribbon are reported for all courses certified. Section 208 of the Dole Act allows a Chapter 33 student to receive full-time Monthly Housing Allowance (MHA), without adding courses in addition to their remaining required course(s), so neither tuition and fees nor Yellow Ribbon would be affected.

Answer: Schools do not need to be approved by the State Approving Agency for GI Bill benefits in order to be a VET TEC Provider. Details on applying through VA to become a VET TEC provider will be released when they are available.

Answer: Rounding out may be used for Non-College Degree (NCD) schools offering courses in credit hours and operating on a term, block, or unit basis.NCD schools offering programs on a clock-hour basis are not authorized to use Rounding Out.

Answer: Students may use benefits from both parents concurrently. Students must apply under both sponsors and must contact their VA Regional Processing Office (RPO) directly to request concurrent payment under both sponsors. This can be done in writing or via Ask VA (AVA). If the student has properly applied and notified the RPO that they would like concurrent benefits, the SCO is only required to submit the enrollment certification under one parent. However, it is suggested that you enter a remark on the certification indicating that the student wants concurrent benefits.

Answer: Yes, both objectives should be reasonably related to the same career field. 

Answer: Custom remarks no longer exist in Enrollment Manager for Chapter 33. If you are trying to report scheduled weekly clock hour changes for a program where the scheduled hours change during the program:

• Submit the initial certification under the lowest number of weekly clock hours
• Amend the certification (on a Sunday to Saturday basis) for each instance the weekly hours change up or down.

Note: SCOs should not report a change to weekly clock hours if the change is due to absences that do not violate your school’s attendance and progress standards. If absences do violate attendance or progress standards and the student is suspended, you will terminate the certification and select Unsatisfactory conduct, attendance or progress as the termination reason.

Answer: The law does not allow for payment of VA benefits for zero-credit full-time status. Zero- credit coursework may not be certified. 

Question 38: Will the Edith Nourse Rogers Science Technology Engineering Math (STEM) programs be required to be approved by our State Approving Agency (SAA)? If our Web-Enabled Approvals Management System (WEAMS) does not reflect our STEM programs, how do we fix that? Do our STEM programs need to show on our WEAMS 22-1998 Report in order to select the STEM box in Enrollment Manager?

Answer: All programs must be approved by the State Approving Agency (SAA) for VA benefit payment, excluding Veterans Employment Through Technology Education Courses (VET TEC) and Foreign approvals, which are approved by VA. A STEM program does not require any additional specific STEM Scholarship approval by the SAA.The program must be approved by the SAA and listed on your 22-1998 WEAMS Report, but the STEM indicator in WEAMS is not used and the 22-1998 will likely reflect ‘No’ in the STEM indicator field, even if your school has programs that qualify as STEM programs. When a student applies for the STEM Scholarship, VA will determine STEM program eligibility and notify the school. Only upon notification of STEM program eligibility should you check the STEM Scholarship check box on the student’s Programs Tab in Enrollment Manager.

Answer: If you have already reported the tuition and fees based on the original enrollment and a student reduces their credits, you must amend the certification to report the new credits and the tuition and fees that would have been charged had the student originally only enrolled in the reduced number of credits. If you have already reduced the credits but failed to report the reduced tuition and fees, you must amend the certification and report the tuition and fees that would have been charged had the student initially enrolled only in the reduced number of credits. Please see the SCO Handbook section ‘Reductions and Withdrawals (Chapter 33)’ for additional information.

Answer: You are correct:

• U.S. Public Schools: The actual net cost for in-state tuition and fees after the application of any Federal funds and any waiver, scholarship, aid, or assistance [other than loans and funds provided under section 401(b) of the Higher Education Act of 1965], provided directly to the institution and specifically designated for the sole purpose of defraying tuition and fees.

• Private and Foreign Schools: The lesser of the actual net cost for tuition and fees after the application of any Federal funds and any waiver, scholarship, aid, or assistance [other than loans and funds provided under section 401(b) of the Higher Education Act of 1965], provided directly to the institution and specifically designated for the sole purpose of defraying tuition and fees, or up to the academic year cap.