Education and Training

The following are questions and answers from January Office Hours – Veterans Readiness and Employment (VR&E) Handbook Updates

Question 1: Can VR&E be used for Master programs?

Answer: A Veteran Readiness Counselor (VRC) will develop a plan based on the rehabilitation needs of the Veteran. After the plan is developed, the VRC will send the authorization in the Invoice Payment Processing System (IPPS) for the program that is approved, which can include a graduate level program.  

Question 2:  Regarding Chapter 31, How does an SCO create approved Non-College Degree (NCD) Chapter 31- only programs, especially for online delivery?

Answer:  Chapter 31 benefit utilizes approved Chapter 33 (Ch33) and Chapter 30 (Ch30) programs. If a program is not approved under Ch30 and Ch33, the Veteran Readiness Counselor would need to follow procedures for a request for a CH31 only waiver (per individual student).

Question 3: Can Chapter 33 students transfer to Chapter 31?

Answer: If a Veteran/Service member is found entitled to Chapter 31 by a Veteran Readiness Counselor (VRC), the student can elect Chapter 31 and transfer over; however, the change can only be done at the beginning of a term.

Question 4: Why are VR&E counselors asking SCOs to redo certifications because they can’t see different term dates? 

Answer: If a certification is not seen or associated with a case, the Veteran Readiness Counselor (VRC) will contact the SCO for an updated certification.

Question 5: Will there ever be a standard Academic Worksheet that all counselors send out? 

Answer: There are currently no plans to create a standard academic worksheet.

Question 6: I need help to submit an invoice in Tungsten who do I contact? 

Answer: For assistance, please consult the following resources: Phone Number: 877-353-9791 or email at vafsccshd@va.gov  

Question 7: When having trouble getting a VR&E file closed so the student can use their Chapter 33 benefit, is there any way to escalate this? The student was not paid at all for Autumn term and the VR&E office keeps saying submitting the closure date to Chapter 33 is 'pending'. 

Answer: The Veteran may contact the VR&E Officer if they are unable to get this resolved with their counselor.

Question 8: If SCOs receive the authorization then they can process the VR&E benefit, correct? 

Answer: Correct! The best practice is to make sure that there is no current enrollment that was completed for that term under another chapter.

Question 9: Should VR&E affect federal student loan eligibility? It does not affect federal grant money, but there seems to be confusion as to whether VR&E should since it's an employment program rather than an entitlement.  

Answer: This is a question for a tax advisor or the lending institution.

Question 10: Are VR&E students required to submit their DD-214 (Certificate of Release or Discharge from Active Duty) Form to the school? 

Answer: No

Question 11: For Chapter 31 VR&E, does the case manager have to approve the students’ classes in order to certify, or is it the advisor's responsibility to make sure classes are part of the degree.? 

Answer: The SCO certifies that the classes are required classes toward the approved degree. The VR&E Case Manager also verifies that the classes are required for the degree.

Question 12: A student is taking a Graphic design class that starts on February 22^nd. Would the student have to fill out another application?

Answer: If the student is already participating in VR&E, they would not need to fill out a new application. If the students’ case was closed, then they would need to reapply. If the student is in the program, the plan indicates what program is approved under VR&E. 

Question 13: If an SCO cannot get VR&E to approve our school as a customer on tungsten. It says our school address is wrong and it is not, we sent them our school bank info on the sheet we turn in.  

Answer: For assistance, please consult the following resources:  Phone Number: 877-353-9791 or email at vafsccshd@va.gov  

Question 14: Due to employee turnover, we have accounts that have not been billed to VR&E. This is prior to Tungsten installation. How should we go about billing for these old accounts? 

Answer: SCOs, please contact your local RO (Regional Office), let them know what invoices are outstanding and the RO will need to research if payment had been made. If the RO verifies that payment was not made, the Veteran Readiness Counselor (VRC) can send an authorization in the Invoice Payment Processing System (IPPS) for the period that was not paid, and the school should be able to invoice.

Question 15: Is there a centralized VR&E Call Center for students who are having trouble with their application or intake process? 

Answer: No, there is no centralized VR&E Call Center.

Question 16: Where is the list of VR&E Officer Contact Information?

Answer: Please visit the following VR&E Officers Contact Information link: VR&E Officers Contact Information.pdf (va.gov) or call the VBA (Veterans Benefits Administration) Call Center at 1-800-827-1000

Question 17: Are SCOs allowed to certify online remedial courses for VR&E students?  

Answer: This topic is currently under review. SCOs will be updated at a later time.

Question 18: For VR&E, does the school report net tuition and fees or those that are assessed?

Answer: VR&E should be billed only for the actual cost of tuition and fees assessed by the institution, for any and all students, for the program of education after the application of:

• Any waiver of, or reduction in, tuition and fees; and

• Any scholarship, or other Federal, State, institutional, or employer-based aid or assistance that is provided directly to the institution and specifically designated for the sole purpose of defraying tuition and fees. 

Exception: Loans and any funds provided under section 401(b) of the Higher Education Act of 1965 (20 U.S.C. 1070a), such as Pell grants, should not be used to reduce the amount billed to VR&E.

Question 19: Why will some VR&E Counselors approve residential fees and others do not? The residencies are required for the program. 

Answer: The Veteran Readiness Counselor (VRC) should approve all fees that are required of all students to pay.

Question 20: How can School Certifying Officials be informed of counselor changes? We have many VR&E recipients that do not know who their counselor is due to turn over. 

Answer: The VR&E counselor should be listed on the authorization. Should a counselor leave, you are always welcome to contact the VR&E officer to obtain the new counselor information.

Question 21: On a new calendar year, does the SCO or the Chapter 31 student requests a new purchase order (PO) number? 

Answer: The Veteran Readiness Counselor (VRC) will send the purchase order to the school for new semesters.

Question 22: We receive a purchase order (PO) number for several terms but we bill by the module. Can we invoice by the module, or do we have to certify for the all terms covered in the product order on one invoice? 

Answer: Schools bill by the term, after the end of the drop/add period. SCOs do not need to bill for all terms listed on the purchase order.

Question 23: Can the authorization form include the student's name? We must go into the Tungsten system to look up who it belongs to.

Answer: VR&E will look into this request.

Question 24: VR&E seems to be having a problem seeing our certifications. Is there a way to solve this situation with Enrollment Manager?

Answer: The Veteran Readiness Counselor (VRC) should submit a trouble ticket to the CWINRS (a case management system) team to report issues.

Question 25: What happens after an SCO submits a credit memo through Tungsten? What is the turnaround time for a debt letter? 

Answer: The turnaround time will vary by office, but should not be more than two weeks.

Question 26: Is there any guidance or updates on who notifications from Tungsten come to? We are having to check a former employee's email to receive purchase order notifications etc.

Answer: For assistance, please consult the following resources: Phone Number: 877-353-9791 or email at vafsccshd@va.gov

Question 27: Is there a step-by-step procedure in learning how to request for a debt invoice to VR&E in Tungsten, when an SCO receives the overpayment from VR&E?

Answer: For assistance, please consult the following resources: Phone Number: 877-353-9791 or email at vafsccshd@va.gov

Question 28: Will SCOs ever be able to search Tungsten by student last name instead of product order number?

Answer: VR&E will look into this request.

Question 29: Who is the best point of contact to make sure SCO’s user account in Tungsten is "connected" to their school? As the SCO, do I need access to Tungsten or is that just our Business Office since they will invoice through Tungsten?

Answer: Only the business office will need access to Tungsten.

Question 30: If a school only offers remedial classes hybrid can they be certified if there is a need for the student?

Answer: VR&E is currently researching this question and will provide additional information at a later date.

Question 31: If I have a student or counselor who emails a product order number, but the SCO is unable to locate on Tungsten, what is the best way to retrieve it? What if the SCO is still seeing an old SCOs information on some new product orders, how can we update our information for VR&E?

Answer: For assistance, please consult the following resources: Phone Number: 877-353-9791 or email at vafsccshd@va.gov

Question 32: Who can a VA student contact if they have a conflict with their VR&E counselor?

Answer: A VA student may contact the counselor’s supervisor if there are concerns that cannot be resolved with their counselor.

Question 33: Will VR&E discuss the Akademos book vendor new process? Although, this is not for all schools those who use this vendor more information would be helpful.

Answer: If Veteran Readiness Counselor (VRC) or Student do not understand the Akademos process, they should reach out to Akademos for the procedures.

Question 34: What is the process when a Veteran Readiness Counselor (VRC) changes? Our experience has been that invoices start getting declined. Does a new product order need to be sent by the new counselor?

Answer: The PO is still valid.  The site administrator is able to transfer it to the Veteran Readiness Counselor.

Question 35: When trying to use the VR&E Officers Contact Information the link included in the handbook shows the site cannot be reached. Is this an SCO issue or a VR&E handbook issue?

Answer: The VR&E link has been updated.  Thank you for letting us know!

Question 36: If a student request certification for Chapter 31, can the SCO certify them without getting a product order authorization prior?  

Answer: No

Question 37: My school needs to get set up with Tungsten. Who do I contact? 

Answer: For assistance, please consult the following resources: Phone Number: 877-353-9791 or email at vafsccshd@va.gov

Question 38: Should the student initiate their counselor to send an authorization, or should the SCO be reaching out for it? 

Answer: Veteran Readiness Counselor (VRC) will initiate an authorization. If the SCO doesn’t receive one or have questions, please feel free to reach out to the VRC. 

Question 39: Is the student debt for withdrawn students calculated in the same way as Chapter 35 meaning will there be a debt letter sent?  

Answer: If there is a debt, the Veteran would receive a debt letter.

Question 40: Do students have an obligation to fulfill certain codes of conduct as a requirement of their VR&E benefits? For example, if an SCO has a veteran harassing staff and refusing to work with the staff members, is this something that should be reported to their counselor? 

Answer: Yes

Question 41: I too had the issue with the link within the handbook to the portable document file (PDF).

Answer: This has been fixed, thank you.

Question 42: It still takes Enrollment Manager (EM) two days to send Enrollments from EM over to VR&E Representatives. Can they not reject invoices until after 48 hours of not receiving the EM certification? SCOs don't have control over how quickly EM processes certifications.

Answer: It takes the Veteran Readiness Counselor (VRC) 24-48 hours to receive the EM certification. Invoices should not be billed until after the add/drop period.

Question 43: How does a school reimburse the VR&E program for an overpayment of a student's tuition and fees?  

Answer: When a facility is overpaid, the facility submits a credit memorandum via the Tungsten Network.

Question 44: Any suggestions on whom to contact for help, when an SCO cannot find anyone to help on processing of VR&E credit/debt questions? 

Answer: The SCO may contact Tungsten or the Veteran Readiness and Employment Officer (VREO).

Question 45: The (regular) SCO Handbook says that if the SCO has already certified a student for Chapter 33 that they cannot terminate the certification and re-certify under Chapter 31. Is there a certain timeframe on that? If we certified for Chapter 33 and then a few weeks later get an authorization for Chapter 31, can the SCO terminate at that point, or no if Veterans Affairs (VA) has sent tuition payment to the facility already?

Answer: The Veteran elects Chapter 31 for a beginning of a term, there will be a date of election for the benefit. The authorization will have dates that cover Chapter 31. If the SCO has already certified under Chapter 33, they should reach out to takes the Veteran Readiness Counselor (VRC) for guidance. Do not terminate Chapter 33 benefits until the term has ended.

Question 46: Tungsten always says i have no customers, what am i supposed to do with authorization numbers? 

Answer: For assistance, please consult the following resources: Phone Number: 877-353-9791 or email at vafsccshd@va.gov

Question 47: Does this mean that a Non-College Degree (NCD) that teaches remotely so they are ineligible for Chapter 33 could receive VR&E only approval for our programs? 

Answer: Chapter 31 utilizes approved Chapter 33 and Chapter 30 programs. If a program is not approved under Chapter 30 & Chapter 33, the Veteran Readiness Counselor (VRC) would need to follow procedures for a request for Chapter 31 only waiver (per individual student).

The following are questions and answers from January Office Hours – Debt Management Center (DMC) Updates

Question 1: Currently, we are unable to obtain DMC letters via email. Are you working to improve this process?

Answer: Schools can contact DMC via Ask VA (AVA) to request a debt letter copy and DMC can attach the letter copy in the response.  This is on the list of enhancements; DMC knows schools would like to see- email notification. No estimated time of arrival on when this could become a reality at this time.

Question 2: We have a debt letter for 1 cent. Do we really have to return a penny?  

Answer: Veterans Affairs (VA) is working on a solution where those debts for under $5 are not created. The SCO does not need to send DMC payment for a penny. The debt currently remains in the system even though do not pursue collection, so if the school incurs a debt for the same student in the future, the penny balance would flow through to DMC at that time along with the new debt amount.

Question 3: Debt letter correspondence should be delivered electronically via encrypted emails to points of contact (POC). United States Postal Service mail is too slow from Regional Processing Offices (RPO).

Answer: This is written in law, so DMC does not have an option to not send via regular mail.

Question 4: If my department has a debt but DMC is not listed as a vendor in our system, and we don’t have a credit card to pay that debt, what do we do?

Answer: DMC can accept payment via check in the mail and on www.pay.gov. DMC can accept credit card or automated clearing house (ACH). DMC cannot accept electronic funds transfer (EFT) payments, so DMC wouldn't be able to add banking information from DMC to your system.

Question 5: The information on the back of debt letters to dispute a debt instructs SCOs to an email address that has not been monitored since March 2022. When will this be updated?

Answer: DMC is working on updating the letters. DMC is hopeful it will be completed in the next couple months.

Question 6: Does DMC still send out a letter of all debts? Is there a way that we can check them all online in the works? 

Answer: DMC knows schools want electronic notification, no estimated time of arrival (ETA) on that. What SCOs can do in the meantime to make sure they don't miss a letter is request a debt list by facility code from DMC in Ask VA (AVA).

The following are questions and answers from January Office Hours – School Certifying Official (SCO) Handbook Updates 

Question 1: It would be helpful to have more information about the Incomplete grades. Are you saying that students have to pay back tuition and fees while they are working on a non-provisional Incomplete, and then if they finish, they get the money back? This has been very confusing to me.

Answer:  Yes, if your school allows an incomplete to remain in a student's record indefinitely it must be reported to the Veterans Affairs (VA) at the time it is assigned as VA does not pay for nonpunitive grades. In such cases, a debt will be created for the course from the first day of the term, as if a nonpunitive grade were reported. If the student successfully completes the course or receives a punitive failing grade and the school reports the change in status to VA, payment will be made for the course.

Question 2: Where can we get updates on new policies for the GI Bill®? I recently found out through another SCO that Chapter 33 benefit extension (if the benefit runs out during the term) now applies to dependents, if they are the "last to exhaust the benefit?" Why aren't we getting updated on new policies regularly?

Answer:  Updates to policy and laws/regulations are sent out via GovDelivery. Please ensure you are signed up for GovDelivery emails. The following information regarding benefit extension for Transfer of Entitlement beneficiaries was sent to SCOs on March 15, 2023 (Update on Transfer of Entitlement (TOE)).

Question 3: Does the SCO Handbook have the details on how to know the student's benefits approvals?

Answer: If the SCO is asking, how they can determine what benefit a student has been approved for, they can find this information in Enrollment Manager on the student’s Benefits tab.

Note: This information will not be available until the student has applied and been issued a Certificate of Eligibility (COE).

Question 4: Why are hybrid developmental courses now being treated differently than all other courses? A Hybrid course is a hybrid course (requiring face-to-face contact). Why would these no longer be eligible for VA benefits if the student is required to be on campus? 

When did the change for remedial/deficiency (r/d) classes happen? I don't see it in any updates, but it just appeared that we cannot certify online only OR hybrid r/d. Why did this change happen?

Answer: Hybrid developmental courses were never approved to be certified for Veterans Affairs (VA) students. The Handbook updates were made to ensure that point was clear for SCOs; it did not change the rule. Remedial and deficiency courses are treated differently than curriculum courses because the law treats them differently. 38 C.F.R 21.4267 does not allow a remedial/deficiency course to be approved by the State Approving Agency (SAA), if it is offered in whole or in part by distance learning.

Note: An unapproved course cannot be certified to VA. 

Question 5: Are SCOs required to report unofficial withdrawals due to a student stopping attendance? These are typically discovered at the end or after the term has ended. 

Answer: Yes, as found in the SCO Handbook under “Last Date of Attendance/Effective Date”: If a student is administratively withdrawn or stops attending without officially withdrawing, the actual last date of attendance must be determined and reported.

Use one of the following methods to determine the last actual date of attendance: (1) attendance records, (2) grading reports, (3) last date on which examination or other papers filed, or (4) last day of activity in the instructor's records.

Note: A signed statement from the student as to the last day of his or her attendance may not be used as the sole means of verifying attendance.

Question 6: Chapter 35 students’ certifications are being put in the wrong file if they’ve used Chapter 33 Transfer of Entitlement (TOE) before. The worst part of this is that they sit in limbo and neither the student nor the school is informed that the processing has stopped.

Answer:  Veterans Affairs (VA) is aware of this issue and are working these on a case-by case basis to correct the problem in the system.

Note: Please provide the student’s name, and date of birth (DOB) to the National Training Team-Schools (NTT-S) email box at EDUTRAINING.VBACO@va.gov

Question 7: VA has informed at least one of our students that their certification was not processed because our SCO did not submit the certification through Enrollment Manager (EM). That was blatantly false, as we’ve only been using Enrollment Manager or VA Once for more than a decade. Blaming any school because of Enrollment Manager issues is unacceptable. 

Answer: We apologize for any miscommunication. There have been instances where an SCO submitted a certification through EM, but the customer service representatives and Veterans Claims Examiners cannot see the certification on the VA side.  

Note: Please provide the student’s name, and date of birth (DOB) to the National Training Team-Schools (NTT-S) email box at EDUTRAINING.VBACO@va.gov  

Question 8: For institutions that have one year to make up an “I” grade (non-punitive) the students had one year to make up the I grade. If we reduce immediately then we are penalizing the student financially. Why can’t we report through ask a question to dairy the “I” grades for one year and reduce after one year? Or can the school monitor the I grades for one year and report the reduction if the student does not complete the I grade. I would rather the VA continue to dairy I grades so it is reported and then check with us if it has been successfully completed.   

Answer: Some institutions allow the assignment of an "I" (incomplete) grade on a provisional basis only. These institutions require a student to remove the "I" grade within a specified time (e.g., by the end of the term following the term for which the "I" grade was assigned). Institutions that have and enforce such a policy are not required to report the assignment of an "I" grade at the time it is assigned.

If the incomplete course for which the “I” grade was assigned is not completed within the institution’s specified completion time and the “I” grade is replaced with a non-punitive grade, the non-punitive grade must be timely reported to VA. The SCO should amend the certification, reduce the hours and tuition and fees as appropriate, and report the nonpunitive grade as “Student completed term, but non-punitive grades assigned for one or more course(s)”. When a letter grade (i.e., A-F), or other punitive failing grade is assigned, no report to VA is needed.

Question 9: Is the "I" (incomplete) grade policy that VA gave us is same as an unofficial withdrawal (UW) grade?

Answer: Each school assigns different meanings to assigned grade types so we cannot answer that question. For VA purposes, an “I” (incomplete) is a grade given when a portion of required coursework has not been completed due to unforeseen reasons and that there is still a possibility of earning credit. A final grade is assigned when the work agreed upon has been completed or if the work is not completed a punitive or nonpunitive grade is then assigned.

Question 10: How do we know when our 85/15 exemption needs to be renewed?

Answer: The information will be on your 35 percent exemption approval letter. Visit the following link: 35 Percent Exemption for more information on renewing the 35 percent exemption. 

Question 11: Are SCOs supposed to report all F grades to the VA?

Answer: Due to many variables with schools grading systems and terminology, as well as varying requirements for reporting based on the type of school (e.g. accredited vs nonaccredited schools) and circumstances around the assignment of an F grade, more information is required to answer this question.  

Question 12: Is there an update for reporting leave of absence (LOA) since the custom remark is no longer available?    

Answer: This question was covered in the Non-College Degree (NCD) Training Session held 01/24/2024. If an SCO was unable to attend, the information, including a recording of the webinar is available on the NCD webpage at the following link: NCD Webinar Series - Education and Training (va.gov) 

Question 13: Can you clarify the reporting dates for students who start a few days outside the published term dates? If a student starts 5 days after the published term date, then they are certified for what the school published? Or the date they actually start school? What if the end of their class is after the end of the published term date? 

Answer: If a course’s first day of class is within 7 calendar days from the published standard term start date the SCO should certify using the published term date. For example, if the published term start date is 01/15/2024 and the course’s first class meets any day from 01/15/2024 through 01/22/2024, the SCO will certify using 01/15/2024. If the first class meets after 01/22/2024, the SCO will certify using the date of the first class. The same is true for courses that finish more than 7 calendar days prior to the published term end date. If the SCO’s school has a designated exam week that a student is required to attend, the SCO will certify through the end of the designated exam week, however. 

Question 14: Do all State Approving Agencies have access to the Uniform Application for school programs? 

Answer: Yes, all State Approving Agencies (SAAs) have access to the Uniform Application.  

Question 15:  The SCO Ratio recommendation, why is the ratio so low? We have SCOs with triple the old ratio and no issue. They are dedicated, doing no other tasks. Is the ratio based on the assumption of other tasks?

Answer: This change is due to increased complexity of monitoring and reporting GI Bill® students. This number should be adjusted as appropriate by the educational institution when the SCO’s duties are expanded beyond certifying GI Bill beneficiaries’ enrollments. 

Question 16: If enrollment for a Graduate student is Fulltime at 8 credits, where in Enrollment Manager (EM) are we allowed to verify this? 

Answer: Chapter 33: If the SCO is certifying a standard-length term for a Chapter 33 student, enter 8 in the Full-Time Modifier box in EM. 

If the term is a nonstandard length term and the SCO’s school publishes a full-time modifier for nonstandard terms, enter that published full-time modifier in the Full-Time Modifier box.  If the SCO’s school does not publish a separate full-time modifier for nonstandard terms, the SCO must follow the instructions in the SCO Handbook to determine what should be entered in the Full Time Modifier box.

If the program is showing in EM as a Non-College Degree (NCD) program, the SCO will need to reach out to your ELR to determine if the program should be approved as an Institution of Higher Learning (IHL). If the program remains approved as an NCD, do not certify a full-time modifier.

Non-Chapter 33: If the student is a non-Chapter 33 student, the SCO select the training time that their school deems the student from the Training Time drop down menu. 

Question 17:  What is the best way to report a tuition decrease after the student has been terminated in the Veterans Affair (VA) enrollment portal?

Answer:  If a student has been terminated in Enrollment Manager and there is a reduction in hours that was not reported prior to terminating the certification, the SCO must:

• Recertify the term as originally certified (Ensure to select the Veterans Benefits Administration (VBA) Remark “Correcting previously terminated enrollment. Notice of Change in Student Status to follow)” so T&F (tuition and fees) are not released again
• Submit and amendments, including the missing amendment
• Re-terminate the certification

If the tuition decrease is due to the SCO not reporting the correct T&F, and the student did not have any change in hours, the SCO must:

• Re-certify the term as originally certified, but provide the corrected T&F
• Re-terminate the certification

Question 18: When doing a Risk Based Survey, I thought was indicated that 90/10 was for for-profit institutions. Am I remembering this correctly? We are non-profit. We pulled documentation for it for the State Approving Agency.

Answer: Correct, for-profit institutions of higher education participating in Federal financial student aid (FSA) are now required to include funds provided by Veterans Affairs (VA) into their calculation of amounts received from federal funding sources. It is not required for non-profit institutions.

Question 19: I have calendar reminder from previous SCO about reapplying for 35% waiver. Where/how do I submit this? 

Answer:  Visit the following link: 35 Percent Exemption for more information on renewing the 35 percent exemption. Submit it through the EDU File Upload Portal.

Question 20: I noticed that within Enrollment Manager, Chapter 31, Chapter 30, Chapter 35 and Chapter 1606 benefits have a limit of 120 days for future certifications. At the last time of searching the content of the SCO Handbook, it still indicated 180 days. Will this be updated in the SCO Handbook? 

Answer: The SCO Handbook has not changed and correctly shows 120 days. Only certifications under Chapter 33 can be submitted up to 180 days before the start of a term. 

Question 21: Do I contact my Education Liaison Representative (ELR) if we are moving campus? 

Answer:  If the facility is moving locations, the SCO must notify their State Approving Agency.

Question 22: Is there a way that a mass email be sent out when updates to the SCO handbook are made? 

Answer: This was done in the past and based on SCO requests, it will be instituted again going forward. As Veterans Affairs (VA) does not maintain an email database for SCOs the notifications will go out via GovDelivery.

Question 23: Will a student get the full allotment for a month in regard to On-the-Job Training/Apprenticeship (OJT/APP), if they get certified in mid-month? 

Answer:  Yes, an OJT/APP trainee whose hours are retroactively certified will receive the full amount they are due. The date on which the Certifying Official submits the hours does not affect the trainee’s payment.

Question 24: Should we as SCO submit VA Form 22-1999b if students graduate or should the student do this? 

Answer: A student cannot submit any enrollment forms to Veterans Affairs (VA); only a designated Certifying Official can. If the SCO doesn’t belong to a facility with a permanent exemption from Enrollment Manager (EM) use, a termination must be submitted in EM. If the SCO’s school is one that has a permanent exemption, graduation should be reported on a VA Form 22-1999b.

Question 25: Does VA still process tuition and fee offsets due to student debts?

Answer: Tuition and Fee debts are no longer established for students based on the law change.

Question 26: Are newly eligible Chapter 35 students, parent adjudicated 100% permanent and total (P/T) after August 2023, really have no time limits on using their benefits? SCOs have seen this on recent certificates of eligibilities (COEs), but don't recall having heard about this in the Office Hours or via other resources.

Answer:  As this does not affect how an SCO certifies it was not covered in Office Hours, that is accurate. However, Chapter 35 beneficiaries will no longer have a time limit (delimiting date) if they meet any of the following criteria:

• Became an eligible person on or after August 1, 2023;
• Became an eligible person prior to August 1, 2023, and turned 18 on or after August 1, 2023, or;
• Became an eligible person prior to August 1, 2023, and completed secondary schooling on or after August 1, 2023.

Additionally, a beneficiary’s eligibility will no longer be limited by age if they meet the above criteria. A child beneficiary eligible under these provisions may continue to receive benefits beyond the age of 26. A child beneficiary who first applies for benefits after the age of 26 and meets the above criteria would also be eligible.

Note: While these beneficiaries have no delimiting date, eligibility to benefits may still terminate for other reasons, such as the veteran no longer meeting the chapter 35 eligibility criteria, or if a beneficiary ceases to be an “eligible person” due to a divorce, re-marriage, etc.  

Question 27: Will VA start talking about 38 U.S.C. §3691A(b) creating new obligations for schools to take the following actions when a student withdraws due to receiving orders for a period of service? 

Answer: Veterans Affairs (VA) understands that schools have questions regarding how Public Law 117-328, specifically as related to 38 U.S.C. §3691A(a)(2)(B), will be administered on your campus. VA sent a bulletin on 11/17/2023, providing an update, but procedures for schools have not been finalized because system changes required in Enrollment Manager are not yet in place. Official Guidance is anticipated in the SCO Handbook by May 2024. VA anticipates necessary, related updates to Enrollment Manager in Release 6 (early May 2024).

The following are questions and answers from January Office Hours – Study Abroad

Question 1: The corporate email addresses are notoriously slow, sometimes taking weeks or months for a response. Should schools with study abroad programs go ahead and request the extension facility code now?

Answer: Section 9 Study Abroad facility code requests are not going to the corporate mailboxes referenced; requests should be sent to the applicable regional e-mail box provided during training and in the School Certifying Official Handbook.

Additionally, we are asking School certifying Officials (SCOs) to only send a facility code request if they already have a Veteran student to certify under Section 9. This will assist with timely processing and limit potential unneeded facility codes being assigned. 

Question 2: If section 9 of Public Law 117-333 was enacted January 5, 2023, why are we just receiving this information? Is it retroactive for terms beginning on or after January 5, 2023?

Answer: It is retroactive for terms beginning on or after January 5, 2023. Department of Veteran’s Affairs has procedures for retroactive certification in place that will be provided to the SCOs when their Study Abroad Section 9 Extension Facility Code request is processed. Students who are due additional housing based on the foreign Institution of Higher Learning (IHL) rate will receive retroactive payment.

Question 3: Study Abroad can only be charged to Veteran’s Affairs (VA) for the instate tuition and fee amount, correct? The Veteran is then responsible for the study abroad fees?

Answer: For Chapter 33 students, fees specific to study abroad can only be certified if the study abroad course is required for the degree. If it applies to the degree but is not required to graduate, fees specific to the study abroad cannot be certified. Please refer to the table in the School Certifying Official Handbook.

Question 4: What happens if the approval is not received after five years?

Answer: All students certified within the five-year period (prior to State Approving Agency (SAA) approval review of the third-party contract/written agreement) can receive education benefits, if entitled. 

In the event the SAA is unable to approve an Institution of Higher Learning (IHL) agreement with a particular foreign school before the end of the five years, any students still enrolled at the foreign school will be allowed to complete the period of study abroad as certified.

Question 5: If a SCO already certified a student for study abroad for spring do they need to redo their certification?

Answer: This question does not provide enough information on the student’s study abroad enrollment.

In general, please review the certified term to see if the student’s study abroad includes an unapproved contract or written agreement with a foreign IHL. If the study abroad certified qualifies under Section 9, you should recertify after first requesting a Study Abroad Section 9 Extension Facility Code. VA has procedures for retroactive certification in place that will be provided to the SCO when their Study Abroad Section 9 Extension Facility Code request is processed.

If no contract or written agreement exists, please ensure the study abroad, as certified meets the existing study abroad, or study overseas opportunities listed in the School Certifying Official Handbook.  If it meets the requirements for existing study abroad or overseas opportunities, a Study Abroad Section 9 Extension Facility Code should not be requested, and recertification is not required.

Question 6: The study abroad case study said to certify actual dates of the trip instead of scheduled dates of the term. We previously asked our Education Liaison Representative (ELR) this question and have always been told to certify our set dates of the term. For example, when we go to the student's schedule it will only show the set dates of the term. You are saying now that we should be certifying based on dates of travel for the study abroad and not what is shown on their class schedule as the dates of the term?

Answer: Certification dates for study abroad courses follow the same rules as for any other course. If the start and end dates of the study abroad course fall within seven calendar days of the term’s official start and end dates, the published dates should be used. If a school publishes official alternate (nonstandard) term dates for a study abroad course, the official nonstandard term dates should be used. Please see the Enrollment Periods Section of the School Certifying Official Handbook for additional information.

Question 7: Is the previously existing method of "Instructor Led Enrollment" still authorized for use?

Answer: Yes, it was listed in the first slide as a way to study overseas.

Question 8: Our United States (U.S.) university has its own campus in England. This international campus must have its own facility code, correct? We encourage all our students to take advantage of study abroad. General Education courses are offered at this campus. Can our Veteran students take advantage of this study abroad program and still receive a monthly housing allowance?                   

Answer: This falls under ‘Overseas Campus of a U.S. based School Enrollment. On the table in the School Certifying Official Handbook, the U.S. based IHL uses a main, branch, or extension campus facility code (as appropriate) for the overseas location. A Study Abroad Section 9 Extension Facility Code should not be requested for this type of campus. Please reach out to your SAA if you have additional questions regarding approval of your overseas campus.

Question 9: Just to confirm, a student can't use their education benefits unless the study abroad portion is necessary for the completion of their program. Correct?

Answer: The student must be enrolled in courses that will apply to their degree program (approved program for VA purposes). Study abroad can be certified to VA if the course applies to the student’s approved degree program. For Chapter 33 students, fees specific to study abroad can only be certified if the study abroad is required for the degree. If the study abroad applies to the degree but is not required to graduate, fees specific to the study abroad cannot be certified.

Question 10: Can a student Study Abroad if it is not required for their degree?

Answer: The student must be enrolled in courses that will apply to their degree program (approved program for VA purposes). Study abroad can be certified to VA if the course applies to the student’s approved degree program. For Chapter 33 students, fees specific to study abroad can only be certified if the study abroad is required for the degree. If the study abroad applies to the degree but is not required to graduate, fees specific to the study abroad cannot be certified.

Question 11: So, we are taking steps back to how it was before this last change, we just must receive approval with the SAA and get a facility code now?

Answer: Section 9 of Public Law (PL) 117-333 bridges a gap when a foreign IHL and/or contracted study abroad is not approved for VA benefits. Prior to the passage of Section 9 on January 5, 2023, unapproved contracted study abroad training between a U.S. based Institution of Higher Learning (IHL) and a foreign Institution of Higher Learning (IHL) was not certifiable. Section 9 makes the training certifiable and gives the U.S. based IHL five years to get the arrangement approved.

Question 12: How many semesters can a student study abroad?        

Answer: Only as many as required by the school to meet their degree requirements.

Question 13: If the study abroad course is approved at the U.S. IHL for the student to take, why must the foreign IHL also be approved?

Answer: Title 38 United States Code (U.S.C.) 3680A, sets out conditions for the approval of enrollment in courses for VA education benefits. Specifically, subsection (f) states the Secretary may not approve the enrollment of an eligible Veteran in a course if the course is provided under contract by another educational institution and the educational institution providing the course under contract has not obtained approval for the course. Consequently, pursuant to Title 38 U.S.C. 3680A(f)(2), it was previously determined that a U.S. based IHL could only certify study abroad training at a foreign IHL if both the contracted training and the foreign IHL were approved for education benefits.

Section 9 of Public Law 117-333 modified Title 38 U.S.C. 3680A(f) (2) and now authorizes VA to pay benefits for study abroad training at a foreign IHL when the contracted training and/or the foreign IHL are not yet approved. 

Question 14: Does the program have to be required? Most are not, but students take classes applicable to their degrees.

Answer: The student must be enrolled in courses that will apply to their degree program (approved program for VA purposes). Study abroad can be certified if the course applies to the student’s approved degree program. For Chapter 33 students, fees specific to study abroad can only be certified if the study abroad is required for the degree. If the study abroad applies to the degree but is not required to graduate, fees specific to the study abroad cannot be certified.

Question 15: If both schools are eligible to certify education benefits, but they are

registering and paying through the U.S. based home school, we just request an extension code now? What if the study abroad program can be applied towards multiple programs and isn't linked to only one program?

Answer: A Study Abroad Section 9 Extension Facility Code should be requested when the U.S. based IHL has an unapproved contract or written agreement with a foreign IHL for a study abroad course. The contracted foreign IHL may or may not already be VA approved.

If your school has an SAA approved contract or written agreement with a foreign IHL that has VA approval (for example, the foreign IHL has its own facility code assigned by VA), a Study Abroad Section 9 Extension Facility Code should not be requested or used when certifying. These programs were already able to be certified and should continue to be certified under your regular facility code.

“Per program” varies based on how a school has study abroad set up. One example, a school offers two study abroad programs that qualify under Section 9, “a semester in Germany at Germany University” and “a semester in Australia at Australia University”. The school would only have two five-year approval windows to track (based on the date the first Veteran student is certified for each), regardless of how many individual degree programs qualify to participate in each study abroad. Another example, a school offers a study abroad specific to students enrolled in the Bachelor of Arts (BA) International Banking program. The study abroad allows the student to choose from three foreign IHLs to do their International Banking study abroad term with. If this is the only study abroad qualifying under Section 9 that the school offers, they would have only one five-year window to track which starts when the first Veteran student in the BA in International Banking is certified. 

Question 16: What if the study abroad program is at an approved international school? Can we continue to process their enrollment certification because the program tuition is much higher, and we do the billing for the program?  Even if the other school processes the enrollment, they receive the tuition, and the student still has a bill on our end?

Answer: Certification is not decided by which school certification is most advantageous to the student and an unapproved contracted study abroad can qualify under Section 9 whether the foreign IHL is approved or unapproved by VA. The only time a foreign IHL can certify a Veteran student is when:

• The Veteran student enrolls and registers directly with the foreign IHL as a degree seeking student.

The Veteran student enrolls and registers directly with the foreign IHL as a guest student after a U.S. based IHL has sent the appropriate Parent School letter to the foreign IHL. The credits from the foreign IHL must be transferable back to the student’s degree program at the U.S. based IHL. A Guest/Parent relationship involving a foreign IHL is treated the same as with a U.S. based guest school.

Question 17: What if the study abroad program can be applied towards multiple programs and isn't linked to only one program?  This is very common for my school. Any major can take study abroad as it occurs in general education courses.   

Answer: The certification of study abroad will be based on the study abroad or studying overseas opportunity the student registers for on their enrollment.  School Certifying Officials (SCOs) must review   the student’s opportunity against the table and information in the School Certifying Official Handbook to determine how the student’s enrollment will be certified.

Tracking of the five-year approval window is per program. Therefore, a U.S. based IHL that offers more than one Section 9 qualifying unapproved contracted study abroad will have multiple approval five-year timelines to track.

“Per program” varies based on how a school has study abroad set up. One example, a school offers two study abroad programs that qualify under Section 9, “European Studies” and “Asian Studies”. The school would only have two five-year approval windows to track (based on the date the first Veteran student is certified for each), regardless of how many individual degree programs qualify to participate in the study abroad. 

Question 18: What type of study abroad does not need an extension?

Answer: If your school has an SAA approved contract or written agreement with a foreign IHL that is approved with VA (for example, the foreign IHL has its own facility code assigned), a Study Abroad Section 9 Extension Facility Code should not be requested or used when certifying. These programs were already able to be certified and should continue to be certified under your regular facility code.

Additionally, these previously existing methods to study overseas using education benefits have not changed and a Study Abroad Section 9 Extension Facility Code should not be requested or used when certifying:

Instructor Led Enrollment - The student is matriculated into a U.S. based IHL degree program approved for education benefit funding and attends classes that may meet domestically, internationally, or both. These types of arrangements usually come in the form of cultural immersion led by an instructor of the U.S. based IHL. A student typically spends time at the domestic campus and then travels to a foreign country to continue their studies with the instructor and classmates. The student’s credits will be granted by the U.S. based IHL.

Overseas Campus of U.S. based School Enrollment - The student is matriculated into a U.S. based IHL degree program approved for education benefit funding but attends classes at an approved branch or extension campus of that U.S. based IHL, located overseas.   

The chart found in the Study Abroad section of the School Certifying Official Handbook shows in which scenarios a Study Abroad Facility Code should be used (see the “Which Facility Certifies” column).