Education and Training

Question 1:

Why do we have to evaluate credit, if the student tells us that their prior training isn’t at all related to our program and we know we won’t be able to grant the student any prior credit?

Answer:

One of the criteria for approval of any school for Veterans’ training is that it reviews and grant prior credit as appropriate for the VA student’s program. Title 38, Code of Federal Regulations, Sections 21.4253 and 21.4254 requires every approved school to have and enforce a policy regarding transfer courses, credits, and previous experience. ​Schools must evaluate prior credit, grant credit as appropriate, notify the student of the evaluation, and shorten the program certified accordingly.

Question 2:

How about if we accept transferable credits, but the student wants to retake the class.

Answer:

If in accordance with your school’s approved prior credit policy, the student’s successfully completed course transfers in, you may not certify to VA the student’s enrollment for that course.

Question 3:

If a student's job is paying the fee for the program, and the student wants to get housing payments from the VA do they have to request their prior credits?

Answer:

Yes.

Question 4:

If a student did start a prior college but did not attend, do you still need the documentation from that college?

Answer:

No, if the student never successfully completed a course, certificate, or program at the school, no prior credit exists (from that organization to request).

Question 5:

If professional regulations in the state require only in-person //on premise training - to give credit - we would need to confirm that training was only on premises training.

Answer:

Please follow your school’s published prior credit policy. If your published policy does NOT currently reflect the state’s licensure requirements, or those of your program, work with your SAA to ensure that it does.

Question 6:

Does all this apply to schools that utilizes clock hours instead of credit system?

Answer:

This policy applies to all approved programs at any school approved to offer Veterans’ training.

Question 7:

What if student is only be able to provide the diploma or degree they have earned, is it good enough?

Answer:

Follow the school’s approved prior credit policy. If the school's approved prior credit policy requires that the student has attained that diploma or that degree, proof of the diploma or degree would be sufficient, wouldn’t it? If the requirement is that the student complete XYZ course within a diploma, certificate, or degree, then a diploma or certificate may not be sufficient. Note that if the school certifies a student for a course that they have already successfully completed, and the school’s prior credit policy allows for transfers of that course, the school will need to terminate the student’s enrollment in that course, and VA will assign school and student debt, as appropriate.

Question 8:

I assume chapter 31 students are exempt.

Answer:

No. Chapter 31 students are not exempt from this requirement.

Question 9:

If a student had to drop from our program due to grades and is scheduled to attend again this year starting with the quarter that they weren't passing, do I not bill for the second quarter? They earned no credit since he wasn't passing.

Answer:

This question is based on a specific situation. Generally, when a student returns to a program after a break in enrollment, the school would need to perform a prior credit evaluation to identify any interim training or experience since the last evaluation, document the findings, shorten the program/adjust the tuition and fees as appropriate, and notify the student. Then the school would then certify the student accordingly.

If this student failed your program, or a portion of the program, that they are now returning to complete, the school may certify enrollment for any portion of that program they have not already successfully completed.

Question 10:

Is this retroactive, do we have to acquire transcripts for prior students?

Answer:

This is not a change, and the school is subject to review for any students enrolled for the last three years prior to any scheduled compliance survey. Failure to do so could result in a referral to SAA which could lead to a suspension. Be sure to perform this exercise for all students enrolled from this point forward.

Question 11:

We do accept prior credit however prior credit would need to be approved by the state's department of licensing & regulations as they would be licensing the graduate. This process does require time for a response, does this mean we would have to wait for a response and proceed with enrollment until then?

Answer:

The school has a requirement within statute to evaluate credit for previous training. The statute does not mandate you accept the prior credit, only that you gather, review, and examine it to make that determination. Please work with your SAA to ensure that your prior credit policy addresses any concerns related to your state’s licensure requirements.

Question 12:

What is the difference between the Military Transcript and the JST?

Answer:

The differences are the issuing body and scope. You may have Veterans come to you with military transcripts issued from their service, depending upon when the transcript was issues. Currently JST can provide military transcripts for all services save that of any training specific to Air Force personnel. If the Air Force member participated in training conducted under any of the other four military services, JST can provide a transcript reflecting successful completion of that training for the Air Force member, former member, or retiree.

Question 13:

Do we ask our Chapter 35 students to provide a copy of their parents JST?

Answer:

No. Each student is providing information related to the prior training they have completed. Whatever training the parent of a student has successfully completed is not relevant that student's own experience, training, and accomplishments.

Question 14:

Our school policy states that our student must test-in for credit from previous school, but the student refuses to take the test. What should we do?

Answer:

Follow your school’s published policy, to include any policies regarding admission requirements.

Question 15:

If you only offer credit for classes completed in the last five years, can you limit your transcript request to that period?

Answer:

Yes, if that’s the school's approved published policy.

Question 16:

Do we have to get transcript from all the colleges of the students prior to beginning the course?

Answer:

VA does not dictate the timeline within which you must receive proof of prior training; however, the SAA may have a set timeframe within which you must do so. If you certify a student for a course that you later discover the student has successfully completed, and it is your school’s policy to accept prior credit of that nature, you will need to terminate that student’s enrollment for that course causing VA to assign school and student debt, as appropriate.

Question 17:

We asked the student for their DD-214. Do we also need to ask for DD Form 295 or JST?

Answer:

It depends upon your school's approved prior credit policy; however, the DD-214 is typically insufficient for identifying course level completion.

Question 18:

Can the school request military transcripts from JST or does the veteran have to request them?

Answer:

The student requests them and authorizes release to the school officials. When the student logs in to request that JST send the transcripts to the school, they will search for the school and select the institution from the list provided. They should then select the correct institution in the resulting search results. On the next page, they acknowledge the consent statement and click Yes. If the school is not listed, the school should contact jst@doded.mil to request your school be added.

Please visit the website for the Joint Services Transcripts for more information.

Question 19:

If the student went to a college that is no longer operating, how would we go about requesting that transcript?

Answer:

Even if a school has closed, your student may be able to obtain transcripts from the National Clearing House. For more information, please visit their website and read their fact sheet on transcript ordering.

Question 20:

Is it best policy to require a student to submit a military transcript when they turn in their COE and DD-214 for all military students?

Answer:

VA does not require schools to obtain either a COE or a DD-214 from your students. Your school MAY require them as part of your school's published policies, and you MAY require the transcripts as part of your published prior credit policy. How and when you require them for admission/enrollment in your program is an institutional decision. The school must publish all institutional policies and get them approved by the SAA of jurisdiction for your campus.

Question 1:

Answer:

If the books are required to be purchased from the school by every student without exception and if the following conditions are met, a book fee may be certified to VA.

Before a fee can be certified to VA, it must meet ALL the requirements stated below:

• Be listed in the school’s approved catalog as a fee;
• Be listed on the student invoice/payment ledger as a fee;
• Be listed in the enrollment agreement/contract between the student and school as a fee;
• Not be considered a preadmission or penalty fee; and
• Be mandatory or otherwise required of all students, without exception.

Please contact your Education Liaison Representative (ELR), if you’re unsure if your book fee meets all these requirements.

Question 2:

How does a student get paid for books & supplies?

Answer:

VA pays the books and supplies stipend as a lump sum equivalent of up to $83 per month and is prorated by eligibility level. The enrollment certification triggers this stipend, and, when allowed, the stipend is paid directly to the student without any additional action on the part of the school or the student.

Question 3:

Is the stipend listed as books and supplies when they receive?

Answer:

The stipend is deposited directly into the student’s account. They receive – separately – a notification from VA with information regarding the benefits award. The student should contact the Education Call Center if they’re unclear on the origin of VA Education benefits they receive.

Question 4:

If the student opts in on tools and books, that is okay?

Answer:

You may only certify fees that are mandatory and charged to every student enrolled in the program without exception. If the student can “opt in” or “opt out,” then this fee is not mandatory and thus may not be certified to VA.

Question 5:

We were including the fee for the guard card application that we complete for the student. All students must pay this fee. Is this allowed?

Answer:

Only fees that are both mandatory and assessed before a student can attend a program are certifiable by schools. Fees, and whether they are pre or post enrollment fees must be noted in the school’s catalog or supplement and listed on the school’s billing statement or invoice. Contact your ELR if you are still unsure as to whether you can certify the supplies fee to VA.

Question 6:

We require a background check for all students prior to enrollment; however, it is also part of the tuition for all students and rolled into the fees?

Answer:

Generally, fees may not include expenses to satisfy enrollment or admission pre-requisites (costs associated with program enrollment requirements that a student must complete prior to admission or enrollment; out-of-pocket expenses paid by the student to qualify for admission, e.g., permits to operate training equipment, drug screening, background checks, etc.). However, such expenses may be certified as fees if a school does not require students to complete all admission requirements prior to enrolling and starting training, but only if the fees are charged equally to all students regardless of whether some students may, or may not, have already completed those requirements prior to admission (i.e., the fee must be mandatory for all students without exception).

Important to note: If a student cannot continue a program due to not completing an admission requirement after starting training, all tuition and fees paid by VA will be considered school debts.

Question 7:

One out of our three approved programs require students to have supplies purchased from our school, so technically it's not required by "all" students because we have 2 other programs that do not require the same supplies. Can we certify for the fee for veterans in this specific program?

Answer:

If all the students in a given program are required to purchase those supplies – and ALL students in that program must purchase those supplies from the school without exception – the fee may be certified. Please ensure that it meets all the other stated requirements (see Question 1 above) and contact your ELR if you are still unsure as to whether you can certify the supplies fee to VA.

Question 8:

Can supplies and tools used in labs be included in lab fees?

Answer:

If all the students in an approved program are required to purchase those supplies – and ALL students in that program must purchase those supplies from the school without exception – the fees may be certified. Please ensure that it meets ALL the other stated requirements below:

• Be listed in the school’s approved catalog as a fee;
• Be listed on the student invoice/payment ledger as a fee;
• Be listed in the enrollment agreement/contract between the student and school as a fee;
• Not be considered a preadmission or penalty fee; and
• Be mandatory or otherwise required of all students, without exception.

Contact your ELR, if you’re unsure if your lab fee meets all these requirements.

Question 9:

We require registration fees paid by the student. Can I certify for the registration fee?

Answer:

If the school’s policy is to charge a registration fee to every student without exception, yes, you may. Please review the answer to Question 1 above to ensure your mandatory fees meet all stated requirements.

Question 10:

What is the difference between registration fee and application fee?

Answer:

An application fee is typically a fee that the organization charges before a student enrolls, and it is not refundable in any way. A registration fee is tied to an enrollment period and is only charged after a student is enrolled.

Question 11:

So, we no longer deduct Pell Grants from tuition and fees when certifying?

Answer:

Title IV funds are specifically excluded from the types of aid deducted when calculating net tuition and fees for Chapter 33 students.

Question 12:

How is housing handled for Chapter 33 student?

Answer:

The Monthly Housing allowance (MHA) is paid directly to the student at the beginning of each month for the previous month. MHA will only be paid while the student is not on active duty (e.g. MHA payments will stop immediately on the day a member enters on active duty or will begin the day after when a member is released from duty when enrolled and otherwise eligible). The housing allowance is prorated by the student’s length of service percentage (e.g., length of service determines benefit level) and the student’s rate of pursuit (RoP). The MHA paid is based upon the Department of Defense’s Basic Allowance for Housing (BAH) for an “E-5 with dependents” and the zip code of the campus or training location where the student physically attends the majority of their courses. More information on monthly housing allowance benefits can be found on the GI Bill^® website.

Question 13:

Should all chapters be prorated? Or just chapter 33?

Answer:

Generally, you would not need to report tuition and fees (T&F) for non-Chapter 33 certifications but if T&F are required for a non-Chapter 33 (<½ time for Chapter 35 or on active duty or < ½ time for Chapter 30), you will need to prorate the same way as you would for Chapter 33 students. In these cases, when T&F are required, if all the T&F are reported on the first enrollment period subsequent enrollment periods will not be able to be processed at all. For non-Chapter 33 certifications it does not affect the entitlement charge, but it does affect payment.

Question 14:

Do I understand that a 1000-hour course can be prorated into two pay periods?

Answer:

If the program is organized (delivered or billed) over multiple enrollment periods, yes, you should prorate tuition across the enrollment periods. If there are two, then yes, you would prorate tuition and fees over two.

Question 15:

Our school is 600 hrs, and we charge full tuition up front. Do we have to prorate now?

Answer:

Tuition certified to VA should be prorated across multiple enrollment certifications. If the 600-clock hour program is achieved over one module/term/enrollment period, there is nothing to prorate. If it is completed over multiple enrollment periods, tuition and fees should be prorated.

Question 16:

Prorating tuition. Is this only if your program is done in modules? If you are a straight clock hour in total, you still can certify full tuition and fees rather than prorate, correct?

Answer:

Yes. If there’s only one enrollment period, meaning you certified enrollment with one certification from the start date to the end date of the program, there is not need to prorate the tuition and fees.

Question 17:

Is it MANDATORY that we have to split the tuition for an NCD program? Or are we still allowed to submit in one certification for the entire program?

Answer:

If there’s only one enrollment period, you could not prorate the tuition and fees.

Question 18:

If a student receives full Tuition & Fees paid on his/her behalf, we should just certify Clock Hours and Tuition Amount. Second (Dual Enrollment Certification) should reflect Clock Hours and $0.00 T&F due to payment on student’s behalf?

Answer:

No, if all tuition & fees are paid by a source that requires that the school deduct that amount from tuition & fees certified to VA, then zero must be reported on the initial cert and any amended certification submitted to VA; however, if the monies paid on their behalf does NOT need to be deducted, you would certify the net tuition and fees and refund the student.

Question 19:

We are a cosmetology/barbering school. We include the testing and licensing fees in the contracted fees for ALL students. We don't host the state board testing at our school, state board proctors off-site do it. The Fee covers the cost of registering for the state board exams and their initial application and licensing fee upon graduation.

Answer:

Third party fees are not reimbursable to schools. Licensing and Certification fees could be reimbursed by VA using the Licensing and Certification benefit. Information on this benefit is located here. When as part of the program’s tuition and fees, the school includes a fee for a certification exam, the student is required to take the certification exam for successful completion of the SAA-approved program, the fee is charged to ALL students attempting the program, and the fee meets all other stated requirements (see question 1), it may be a valid fee and could be certified to VA. Questions specific to fees certifiable at your school (valid fees) should be referred to the ELR so, they can provide guidance specific to your programs.

Question 1:

With hour variances, how should it be reported IF the student is either ill or on active duty and their absences fall OUTSIDE of the attendance requirements?

Answer:

It is incorrect to certify a scheduled weekly clock hour variance for the purpose of reporting absences due to illness or being called to active duty – they are separate issues and reported differently.

Attendance must be monitored and the policy enforced. In order for schools to know if students are in violation of a policy, detailed records must be monitored. It is not enough to just have the policy available in the student’s file during a compliance survey visit. Schools must take appropriate action (i.e., terminate the enrollment certified to VA for any student who is in violation of the policy).

It is incorrect to certify a scheduled weekly clock hour for the purpose of reporting absences due to illness or being called to active duty – they are separate issues and reported differently. 

Attendance must be monitored, and the policy enforced.  For schools to know if students are in violation of a policy, they (schools) must monitor and maintain detailed records.  It is not enough to just have the policy available in the student’s file during a compliance survey visit.  Schools must take appropriate action (i.e., terminate the enrollment certified to VA for any student who is in violation of the policy).  

Using Enrollment Manager, SCOs will Amend the enrollment, check Termination, select Unsatisfactory attendance, progress, or conduct from the Amendment Reason drop-down list, enter the last date the student was actually physically in attendance in class prior to violating the school’s approved attendance policy in the Amendment Effective Date field.

If called to active duty, the SCO will report a withdrawal or interruption in training. If a student terminates or interrupts a non-college degree program that is not offered on a term, quarter, or semester basis (the program may be offered on a block or unit basis), the school will need to report the amendment reason as Withdrawal or interruption (Non-College Degree programs not on a term basis).

Question 2:

Are we to include T&F each time there is an amendment to the enrollment? Could doing this create an overpayment to the school (since the initial and all subsequent amendments show T&F)? Should T&F just be included in the initial enrollment?

Answer:

When an amendment using Enrollment Manager, the original tuition and fees amount is displayed. This amount can be edited if there is a change; otherwise, leave the original tuition and fees amount alone.

Question 3:

If a student is called to active duty, how would we report this to the VA in enrollment manager? We typically would put the student on a leave of absence on the school’s side, etc.

Answer:

If called to active duty, the SCO will report a withdrawal or interruption in training. If a student terminates or interrupts a non-college degree program that is not offered on a term, quarter, or semester basis (the program may be offered on a block or unit basis), the school will need to report the amendment reason as Withdrawal or interruption (Non-College Degree programs not on a term basis).

Question 4:

When I have amended a cert due to increase of hours. I am not sure what needs to be selected so I have been choosing increase. If this is wrong, what should I be choosing? Also, when would I know when the cert has been approved? I have several certs that I have put in this year, and they have not been fully approved.

Answer:

You should only report scheduled” increases. Only CH33 and automated CH30 certs will update from "under VA review". All others will not update to show when they are processed as VA systems are not fully integrated yet. BUT if you have any that have not been paid, you should call the SCO Hotline.

Question 5:

If a student requests Back Dated Certification, is the Dual Certification required?

Answer:

Yes. PL 116-215, Section 1010 requires second certification for all Chapter 33 students. See the School Certifying Officials (SCO) Handbook under the sub-topic “Two Certification Requirement Effective August 1, 2021” for more information.

Question 7:

With a student that is scheduled for 30 hours per week, and they have missed school but are within our attendance policy how do we report a graduation date AFTER what is contracted?

Answer:

When following the instructions provided by VA via Ask VA (AVA), providing that documentation (from AVA) during compliance should be sufficient to support your actions.

Question 8:

Can you please put together a training on how to calculate the amount of money a student will have to pay out of pocket if they do not have enough 33 benefits to cover the entire tuition?

Answer:

There are many variables as it relates to benefit levels and types of benefits. When it comes to determining a student’s benefit, or lack thereof, it is best that the student communicates directly with VA via the Education Call Center.

Question 9:

Submitting amendment for graduation after the end date. Student passes a technical exam such as a commercial driving test after their scheduled end date. How do we report this correctly in EM?

Answer:

You do not report program completion (graduation does not apply for NCD programs; “End of Term or Course” does) for students who complete the program AFTER the enrollment period ends. You do not report program completion (graduation does not apply for NCD programs; “End of Term or Course” does) for students who complete the program AFTER the enrollment period ends. For example: A student's enrollment period is from October 30, 2023 to November 25, 2023. The student completed hours on November 26th or later, so completion does not need to be reported.

Question 10:

If a student has not completed their program hours on the end date of their enrollment certification, can the enrollment be extended?

Answer:

Unless the student has failed a portion of the program while still meeting standards of progress, you may not extend the program hours.

Question 11:

Would we have to change a student’s enrollment every week if they are not attending the scheduled hours every week?

Answer:

No. You would only change the scheduled clock hours due to the school’s schedule. If a student is absent but those absences fall within the school’s attendance policy, you do not report the change. If the student fails to maintain standards of progress to include the attendance policy, you must follow your school’s published policy and terminate the certification as appropriate.

Question 12:

So just to clarify, if a student fails a specific class within the program, they can repeat that particular class within the program, right? What if the student fails the class due to attendance?

Answer:

VA may pay benefits for a student to repeat the portion of the class they failed only if they continue to meet the school’s standards of progress and attendance standards.

Question 13:

If a student attends 30 hours a week when in classroom and then 35 hours when they go out to clinic, do I need to do an amendment for the weeks the students are out to clinic?

Answer:

The beginning date, ending date, and number of clock hours a student is scheduled to attend each week must be reported. If clock hours per week vary and the benefit amount is affected, the variance must be reported for calendar weeks, Sunday through Saturday, between the beginning and ending dates. 

In your situation, the benefit amount will not be affected by the change in clock hours when the student goes to the clinic, so you would not submit an amendment to increase the number of clock hours when the student attends those weeks. Moreover, you run the risk of exceeding the number of clock hours approved for the program, if you were to do so.

Question 14:

We offer an EMT and Paramedic course. I was told a few years back to wait until the end of the semester to amend the clock hours because the clinical hours varying so much! I have not been making these amendments weekly. This is a year-long course. How should I be handling the clinical hours variance? Do we have to report these clinical hours on a weekly basis, or at the end of the semester for a paramedic program?

Answer:

Remember first that you would only submit changes when the change in schedule affects the benefit amount. With that in mind, know that schools must report changes in enrollment within 30 days of any change. Please refer to the slides on Scheduled Weekly Clock Hour Variance for instructions on how to submit the amendment in Enrollment Manager to document any change in schedule where the benefit amount is affected.

Question 15:

On Enrollment submissions I get some denied due to holidays, but less than 7 days, so I'm not required to submit the break. The processor says student is over their hours on the class, as it has to be extended each day of the holiday to allow the 100 hours for the course. I have yet to have someone be able to let me know what can be done to keep this from happening. Any recommendations I can do from my end?

Answer:

Our systems currently lack the ability to capture information on administrative closures and holidays during the certification process. In the event where it becomes a factor, our procedure is that you would communicate those approved administrative/holiday closures and provide substantiating documentation when the claims examiner reaches out to you. Proactively, and if you’re aware ahead of time that the certification will exceed the approved length, you could engage with VA via Ask VA to submit the substantiation (e.g., a published, SAA-approved calendar listing relevant closures) when you submit the certification. You would need to submit separate inquiries for each student affected.

Question 16:

Are T&F added with the initial enrollment now, or do we have to still wait the 60 days?

Answer:

Dual certification isn’t appropriate for NCD clock hour programs. You should report T&F upfront. You still need to perform the second certification for all Chapter 33 students due to PL 116-215, Section 1010. See the School Certifying Officials (SCO) Handbookunder the sub-topic “Two Certification Requirement Effective August 1, 2021” for more information.

Question 17:

With a student that is scheduled for 30 hours per week and they have missed school but are within our attendance policy how do we report a graduation date AFTER what is contracted?

Answer:

You do not report program completion (NCD programs complete/IHL programs graduate) when the student doesn’t complete the program AFTER the enrollment period ends.

Question 18:

So just to clarify, if a student fails a specific class within the program, they can repeat that particular class within the program, right? What if the student fails the class due to attendance?

Answer:

VA may pay benefits for a student to repeat the portion of the class they failed only if they continue to meet the school’s standards of progress and attendance standards.

Question 19:

What is the minimum number of weekly clock hours for a student to receive Monthly Housing Allowance (MHA)?

Answer:

Chapter 33 students are entitled to MHA when their Rate of Pursuit (or RoP) is more than 50%. Schools certify actual clock hours the student is scheduled/contracted to attend each week. VA calculates RoP by dividing the number of clock hours pursued by the number of clock hours considered to be full-time. The resulting percentage is the student’s RoP. 

Examples: If full-time is 18, then RoP:

• 9 clock hours is 50% (9 ÷ 18 = 50%)
• 10 clock hours is 56% (10 ÷ 18 = 56%) 

Active-duty personnel receiving chapter 33 benefits or spouses of active-duty personnel receiving Transfer of Entitlement (ToE) benefits are not eligible for the housing allowance.

Question 20:

If a program is approved for 700 clock hours; 600 theory (classroom) and 100 practical (classroom yet hands on with public). If the student decides to complete the 600 theory at 18 hours per week before beginning the final 100 practical in the classroom with the general public, does the final 100 hours need to be amended to be 22 hours per week?

Answer:

The SAA determines that a program is primarily theory or primarily shop/practice when it reviews the program for approval. In your example, SAA would likely determine that a program where the students spend more than 50% of their instruction in the classroom would be theory based, and as such, 18 clock hours is full time for the entirety of the program. Remember that you must certify the scheduled/contracted number of clock hours per week, not mirror the full-time measure.

Question 21:

Our schedules hours per week aren't the same due to clinical scheduling and holidays. Do we have to report variances every week since we won't ever hit our average number hours based on total hours divided by number of weeks.

Answer:

When the benefit amount is affected, you need to report these instances within 30 days of the event. You must not “average” your hours because this interferes with the total number of clock hours for which the program is approved.

Question 22:

Would the same approved hours standard be applicable to on-the-job training?

Answer:

Yes. OJT/Apprenticeship programs are also approved for a finite number of clock hours based on the approved training plan.

Question 23:

With a student that is scheduled for 50 hours/week (Required to attend 200 hours before graduating) and they have missed school but are within our attendance policy how do we report a graduation date AFTER what is contracted?

Answer:

If the student completed outside the enrollment period, you would not report the "End of Term or Course" to VA via Enrollment Manager.

Question 24:

We have a program twenty-six weeks in length authorized for 810 hours. We certify for 35 hours per week. There are a total of eleven holidays during the program, which we cannot report. Because of this, we are routinely denied initial certification for exceeding by more than 10% the authorized hours for the program, even though the actual number of hours is well within that 10% limit. Is there no way to account for weeks shortened by holidays?

Answer:

Our systems currently lack the ability to capture information on administrative closures and holidays during the certification process. In the event where it becomes a factor, our procedure is that you would communicate those approved administrative/holiday closures and provide substantiating documentation when the claims examiner reaches out to you. Proactively, and if you’re aware ahead of time that the certification will exceed the approved length, you could engage with VA via Ask VA to submit the substantiation (e.g., a published, SAA-approved calendar listing relevant closures) when you submit the certification. You would need to submit separate inquiries for each student affected.

Question 25:

My 1606 student attended the class, but they had to continue clinicals to get the skills that and the ambulance crew they rode did not go out on very many calls.

Answer:

If the student failed a portion of the program, while continuing to meet the school’s standards of progress, the student may receive benefits while repeating that portion of the program.

Question 26:

If a student is needing more hours to complete the program, due to deficiencies in certain objectives, how do we do this? This would be after the student has completed ALL required hours, and the "extension" in hours is in our student handbook for up to 120 additional hours. Is there a way for the student to keep getting their living stipend during this time (they'd be full time clock hours)? The tuition would not change for the student (we don't charge extra).

Answer:

If a student fails a portion of the program, while continuing to meet the school’s standards of progress, and they must repeat that portion to successfully complete the program, you may certify the student for that repeated portion of the program. You should initiate a conversation with VA via the Ask VA portal to substantiate the excess clock hours so the student may receive benefits for that repeated portion.

Question 27:

I understand VA will not pay to extend student graduate date due to absences, but if the date extended due to LOA's, will the VA pay for it?

Answer:

If the student left the program for a period and meets requirements for reentry to the program, then yes, the student may receive benefits for the total number of clock hours for which the program is approved.

Question 28:

Do we need to amend or post variance for Christmas vacation/break if it's already calculated into their end date?

Answer:

No. Schools should report Vacation Periods for programs measured in clock hours for the purpose of NCD program length validation. EM will accept vacation periods of seven (7) or more days. When hours certified exceed the approved program length, VCEs will develop with certifying officials to substantiate the reason for the overage.

Question 1:

How long are the 35 percent exemptions granted for, and how often do I need to submit the 35% exemption form?

Answer:

For all types of educational and training institutions, the 35 percent exemption expires 24 months from the date of issue. Visit our website for information on when to apply for re-approval of the 35 percent exemption.

Question 2:

Our 35 percent exemption was granted on 08/10/2022- I have been filling out the forms & saving them for each enrollment period. Will I be notified by an ELR on when to request a new 35% exemption and submit reports?

Answer:

The 35 percent exemption must be renewed every 24 months. Instructions on when and how to submit the 35 percent re-approval is on our website and vary according to whether your school is accredited or nonaccredited, but you will need to submit records, regardless of accreditation status, for any enrollment periods beginning between 08/10/2022 and 08/26/2022. Submit the exemption request and 85/15 calculations using the EDU File Upload Portal.

Question 3:

If our school was already granted the 35 percent exemption, do I still have to submit any calculations?

Answer:

Please review your 35 percent exemption letter and/or visit the website for information on your reporting requirements. Reporting and record keeping requirements vary according to accreditation status.

Question 4:

Do I need to submit 85/15 if I have less than 10 VA students? We have fewer than 35% VA students.

Answer:

It depends. Depends upon if you have an approved 35 percent exemption and if your school is approved as accredited or nonaccredited. Depends upon if you have non-VA supported students enrolled in that program. Recommend you review the 85/15 webpages and Frequently Asked Questions. for more information. And if you still can’t find an answer circle back to us with more specifics.

Question 5:

If we are an accredited school and have the 35 percent exemption then we don't need to do the 85/15 reporting, is that correct?

Answer:

Generally, that is correct; however, I recommend you read your exemption letter carefully. The letter will provide any specifics of the requirements for your school. Visit our website for more information on the 35 percent exemption.

Question 6:

If our school is nonaccredited and we have the 35 percent exemption, do I need to do the 85/15 reporting?

Answer:

Nonaccredited schools are required to monitor enrollment ratios and maintain compliance with 85/15. If a program exceeds 85 percent supported student enrollment, you will need to self-report to VA at the routine reporting date and continue reporting until the program is no longer out of compliance. Please visit our website for more information on what to do when a program is out of compliance with 85/15. Remember that 85/15 reports may be requested at any time and will be reviewed on compliance. All 85/15 calculations must be retained and provided when requested by VA, State Approving Agency (SAA), and authorized Government representatives.

Question 7:

If we start students 360 days a year, do I complete 360 forms?

Answer:

Unless the program is otherwise exempt from the 85/15 rule, you need to create a report anytime a student could enter, as shown in your approved catalog/calendar/enrollment contract. As presented during the webinar, all reports created during the quarter will be submitted to VA within 30 days of the end of the quarter. Visit our website for more information on 85/15 reporting requirements.

Question 8:

We enroll every 2 weeks clock hour program. How often do we calculate 85/15?

Answer:

Anytime students are scheduled to start the program (this is published in your approved school calendar/catalog), then you’ll calculate 85/15, unless the program is otherwise exempt from this requirement. Visit our website for more information on 85/15 reporting requirements.

Question 9:

We run four programs every six weeks. When I calculate for a program, do I list the other three programs even though they might not be starting on that same day? (They are already in session). Or do I need to do one for each program when it begins?

Answer:

Anytime students are scheduled to start a program (as published in your approved school calendar/catalog), you’ll calculate 85/15, unless the program is otherwise exempt from this requirement. If the program is not scheduled to start, then you would not include that program on the report. Visit our website for more information on 85/15 reporting requirements.

Question 10:

When submitting 85/15, if certain programs offered have zero enrollment, do we have to list them or can we leave them off the report?

Answer:

You must list all programs that would start that day, as listed in your school’s approved catalog/calendar. See our website for instructions on how to report enrollment of fewer than 10 supported students.

Question 11:

Is "supported " classified as VA only or does that also include Title IV?

Answer:

Title IV alone does not constitute support for 85/15 purposes. Only VA and Institutional (school) support are considered when evaluating whether a student is "supported" for the purposes of 85/15. Visit our webpage on this topic for more information.

Question 12:

Are Chapter 31 students considered un-supported?

Answer:

The authority for Chapter 31 benefits falls under Title 38. Any student receiving VA benefits under Title 10 and/or Title 38 is a supported student every single time. However, Chapter 31 beneficiaries are not impacted by 85/15. They can always enter programs exceeding 85 percent supported students, and VA can award benefits. Chapter 31 students are, and will always be, “supported” for the purposes of the 85 percent rule. Visit our webpage on this topic for more information on supported and nonsupported students.

Question 13:

Can I grant a non-Veteran a scholarship and count them as non-supported?

Answer:

It all depends on if the aid is restricted or not. Visit our website for more information about restricted aid. If you have questions about a specific scholarship, you'll want to contact your ELR who will be able to assist you based on the specifics of the scholarship.

Question 1:

The guidance provided in this webinar for Leave of Absence (LOA) reporting is the 4th different set of guidance I’ve received on how to report LOA’s for Chapter 33 since custom remarks were eliminated (sources have been previous NCD webinar during Q&A, Enrollment Manager support calls - 2 separate calls to confirm consistency in guidance, Claims Examiner response to a certification which was received last week and now this webinar). When I went through Ask VA previously for a LOA, I received a response that “this is not something we can assist with ask your ELR” (ELR then sent me to SCO hotline). Is the guidance shared in this webinar for LOAs relatively new to where Ask VA reps will be aware of this process?

Answer:

This is not typical, and you may have encountered a training issue. Please continue to report LOA via Ask VA until such time as 1) we give you updated instructions and/or 2) the EM system has updated with an enhancement to allow for the ability to report LOA.

Question 2:

LOA - More confusing now than ever. If we wait until a student, taking less than 30 days actually returns; then won't this create an issue with the students MHA?

Answer:

Yes, it will affect their MHA because VA students aren’t entitled to benefits while on a leave of absence. Please advise your students accordingly.

Question 3:

Are there going to be changes in EM so that we can actually submit an approved LOA.

Answer:

Yes, there are scheduled enhancements to EM that include a way to report the leave of absence (LOA).

Question 4:

Custom remarks can’t be made in Enrollment Manager. How are we supposed to put that a student is returning or going on an LOA?

Answer:

For Chapter 33 students, it’s true that there’s currently no way to report the LOA in EM. You can report the LOA for non-Chapter 33 students in EM by providing that information in remarks when submitting the amendment extending their enrollment period, as applicable, but as they don’t receive MHA or tuition and fees, terminating their enrollment until such time as they return from their LOA works, too.

Question 5:

We must wait until the student is on an LOA for 30 days BEFORE we report? Won’t that cause more confusion? If a student is gone for 32 days and we report on day 31 that they were out for 30 days, they would be back by the time VA even received the info?

Answer:

If the student is on an LOA of fewer than 30 days, we recommend you wait until such time as you know if and when the student is going to return to report the LOA. If the student is going to be out for greater than 30 days, terminate the student’s enrollment.

Question 6:

So, do we not report LOA's under 30 days via enrollment manager we do so via help desk? Our school has a 5-day minimum for an LOA.

Answer:

Yes. The current guidance is that you report the LOA via Ask VA.

Question 7:

Previously for non-Chapter 33 students, guidance for LOA was not to terminate but extend enrollment for length of LOA and use custom remark to explain dates of LOA. Nothing else was done if student returned as scheduled. Only terminate if student did not return. Has this changed?

Answer:

You can report the LOA for non-Chapter 33 students in EM by providing that information in remarks when submitting the amendment extending their enrollment period, as applicable, but as they don’t get MHA or tuition and fees, terminating their enrollment until such time as they return from their LOA works, too.

Question 8:

Is there going to be a change to Enrollment manager so we can actually report a LOA?

Answer:

Yes. We do plan to include a way to report LOAs for NCD programs in a future enhancement to Enrollment Manager.

Question 9:

Reentering after a withdrawal? Make the amendment adjustment to the dates and certify?

Answer:

If and when the student returns from an LOA, we recommend you communicate with VA via Ask VA, regarding the LOA before you do anything in EM.

Question 10:

If there is a LOA that is say three or five days, do those also need to need reported to Ask VA?

Answer:

Yes, if the student is on a true "leave of absence" as defined by your school's policy, and not simply absent while keeping within the school's approved attendance policy, the student isn’t entitled to benefits for these days. You’ll need to report the leave of absence to VA and extend the length of the student's enrollment period accordingly

Question 11:

How do you change enrollment for a student that is an active reservist, and his 2 weeks may fall during your 10-week course?

Answer:

Follow the instruction given for reporting an LOA of fewer than 30 days. Wait to report the termination/LOA until such time as you are certain of the student's return status. Communicate the leave of absence (LOA) scenario via Ask VA: “Student on leave of absence effective (last date of attendance). Resume (date of return). No change in tuition and fees.” For the purposes of Compliance Surveys, you should retain a copy of ALL communications with VA related to this action.

Question 12:

I understood that end calculation can only include vacation days that are 7 days, or longer, for NCD clock programs.

Answer:

For the majority of programs, VA typically does not need to know about holidays/vacation period of less than 7 days because they do not impact the way VA calculates the validation. For the majority of programs, holidays/vacation period of less than 7 days are a moot issue. Some programs are structured (e.g., short number of total program hours) in a way that calculations are impacted by holidays/vacation period of less than 7 days. Routinely speaking for the majority of programs, VA does not need for you to explicitly report holidays/vacation period of less than 7 days.

Question 13:

When you say the VA does not pay for extensions, does that mean they won't cover the cost/purchase of extending if applicable or will not accept certifications beyond the initial enrollment period?

Answer:

VA will not pay for extensions due to a student’s absence. If a program is extended because the student has failed a module or other portion of the program, VA may pay for the student to retake the failed portion of the program.

Question 14:

Processors have now been told to deny any Enrollments that go over the allowed hours. No explanation from the SCO will be accepted any longer.

Answer:

Confirmed that the currently approved procedure is that the claims examiner WILL develop with the certifying official for clock hour overages. You may have encountered a training issue.

Question 15:

When will NCD schools be able to submit vacation/holidays for one day in Enrollment Manager? Right now, it is required for 7 days or more.

Answer:

If and when a future enhancement of Enrollment Manager includes a way to reports school admin days and holidays, we’ll let you know.

Question 16:

For the example you provided about beginning and ending dates. How do you report the 2 days, that will extend the completion date when we can only report a vacation of 7 days or more? Essentially do we just add two days?

Answer:

You must certify the length of the student’s enrollment period – beginning to end - as reflected in the approved school calendar, catalog, and/or the student’s enrollment agreement.

Question 17:

Do we still need to wait 10 mins to submit another cert for CH33 students?

Answer:

Yes. When reporting subsequent actions for a single ch33 student at least 10 minutes after the previous action to ensure its outside a single automation cycle. For all non-Chapter 33 students, a change should be reported the following day. If another change is required for the same student, it should be submitted on day #3 and so on.

Question 18:

If a student completes the NCD course prior to the reported end date, how do we modify the date to report the correct date in EM?

Answer:

You need to submit two amendments. First edit the End Date; Second report End of Term or Course.

Question 19:

So, if a student completes their course after the original end date, because they had some absences, we DO NOT change the end date to the actual last day of attendance?

Answer:

That’s right. You do not.

Question 20:

If a student fully completes 8-week program one day early based on local policy, do we need to adjust the end date of the entire program one day early, or can we leave it as previously submitted. I think I understood that we do need to redo the end date.

Answer:

For programs certified with one begin date to the one end date, as you find in competency-based programs, you would modify the end date if the student completed the program PRIOR to the end date certified. Be sure that you’re following your SAA-approved catalog/calendar.

Question 21:

Please confirm, if a student completes the program after the End of Term Date, we are not required to report the End of Term or Course to VA. When the student completes the required hours. We do not extend the End of Term date due to absences.

Answer:

Yes.

Question 22:

We have been using Graduation vs End of Term. We hold graduations for our students. Is that incorrect that we have been using Graduation.

Answer:

When a student completes an NCD program while using VA benefits, you need to select "End of Course of Term” when reporting the termination in Enrollment Manager. If you haven’t done so in the past, just do so point forward.

Question 23:

Am I understanding, if a student does not pass our satisfactory academic policy the first time, they have to be terminated?

Answer:

Please contact your SAA with questions related to your school’s approved policies.

Question 24:

We are a clock hour school. If a student doesn’t complete their required 90% of hours to graduate by their contracted graduation date and they have to continue past their graduation date for a week or two. Do we still graduate them out of enrollment manager on their actual graduation date?

Answer:

Do not extend the End Date due to absences; however, you will still want to report End of Term or Course which will automatically display the Amendment Effective Date as the last day of the enrollment period previously certified. You would not change this date.

Question 25:

So, if our VA student actually has to stay past the original ACD - we still chose "End of Term' to graduate them; plus, VA does not care that the students actual end date was possibly a week or two later, correct? (For example, a school closes for a week due to a blizzard which means the student will miss the ACD.)

Answer:

Excluding temporary school closures due to a natural disaster, which is a completely different issue, if the student is extended for absences within the student’s control, you would NOT extend their enrollment. If the student is still using benefits, you will still want to report End of Term or Course which will automatically display the Amendment Effective Date as the last day of the enrollment period previously certified. You would not change this date.

Question 26:

When you are amending the enrollment and you select other, there is no option for mitigating circumstance. Per the handbook it states you should select “Withdraw after drop period - non-punitive grades assigned (Typical Termination)” but we do not have punitive grades organized.

Answer:

You should report the amendment reason as Withdrawal or interruption (Non-College Degree programs not on a term basis). If applicable, VA will develop directly to the student for evidence of mitigating circumstances.