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Education and Training

School Certifying Officials COVID-19 FAQS

Updated as of August 10, 2021. 

From the beginning of the COVID-19 emergency period, we have been working with Congress to preserve GI Bill® benefits for those impacted by in any way by this emergency. In the Spring of 2020, the President signed a series of laws that gave VA the authority to continue certain payments of education benefits, as well as the Monthly Housing Allowance (MHA) to GI Bill students during this emergency. These laws enhance and expand benefits for GI Bill beneficiaries who may have been affected by during this period.

These frequently asked questions address recent legislation on GI Bill benefits, including Public Law 116-128, the Student Veteran Coronavirus Response Act of 2020 (Public Law 116-140), and the Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020 (Public Law 116-315).

Reminder: COVID-19 legislation that permits students to receive MHA at the resident rate, while taking approved converted (online) courses, will end on December 21, 2021. When enrolling for courses in 2022 or any subsequent term, students will need to enroll in approved resident classes to continue receiving their MHA at the resident rate. Additionally, if a student is enrolled in converted courses that continue past December 21, 2021 AND have been receiving their MHA at the resident rate due to COVID-19, their MHA will be reduced to the online rate on December 22, 2021.

Table of Contents

Institutions of Higher Learning (IHL) Specific Questions
Change in modality
Changes in enrollment and approvals.
Student enrollment changes
Discontinuing training or operations

Non-College Degree Program Specific Questions
Change in modality
Student enrollment changes
Discontinuing training or operations

OJT/Apprenticeship Program Specific Questions
Changes in enrollment
Change in modality
Discontinuing training or operations

FAQs for Work Study Site Supervisors

Institutions of Higher Learning (IHL)

Change in Modality (Conversion from Resident to Online)

Q1) What is considered a “converted course”?

A "converted course" is defined as a course that a school previously offered as resident (in-person) training prior to March 1, 2020, but is now offered as online training due to COVID-19. To qualify as a converted course, the course must be part of a program approved by the State Approving Agency (SAA) prior to March 1, 2020.  Keep in mind, the law only authorizes VA to pay GI Bill MHA payments for converted courses at the resident rate from March 1, 2020, to December 21, 2021.

Q2) Can an IHL offer programs that were not previously approved by the SAA due to COVID-19?

No, only programs previously approved by the SAA prior to March 1, 2020 will be available for IHLs to continue enrollments of GI Bill students. It is critical that the program that the course is part of is officially approved by the SAA to qualify as a “converted course.” If you are currently seeking approval for any new programs you must contact the SAA.

Q3) What is the impact on IHLs when a resident course has been converted to online due to due to COVID-19 emergency?

  1. For courses converted after submitting an enrollment certification:
  • An IHL which converts an approved residence training modality course to an online training modality for that course (distance learning), should not submit changes when the conversion is the only factor.  The law authorizes this special authority from March 1, 2020, to December 21, 2021.
  • Educational institutions which convert modalities as described above do not need to submit enrollment adjustments for the current term.
  • Only converted courses – SCOs cannot certify resident credit hours to VA for online courses when there is no approval for a resident training counterpart.
  • The new law applies equally to current and new students enrolled in the converted courses.
  1. For courses converted before submitting an enrollment certification:
  • An IHL which converts from resident to online instruction as previously described may submit certification of resident courses, which were converted to online instruction, as resident if the start date of the term is prior to December 21, 2021.
  • Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.
  • Enter Standard Remark “COVID-19 Residence Courses Taken Online” located within VA-ONCE.

Normal reporting requirements for all other changes should be completed per the SCO Handbook (change in start/end date, change in credit/clock hours, etc.).

Q4) What happens to a Post-9/11 GI Bill student’s MHA when a program’s modality changes due to the COVID-19 emergency?

If a student has questions related to the impact of COVID-19 on their education benefits, please direct them to call 888-GIBILL-1 (888-442-4551) between 7 a.m. - 6 p.m. Central Time, Monday-Friday.

Based on the new laws, Post-9/11 GI Bill students, who pursue resident (in-person) courses which have been officially converted to online instruction solely due to the COVID-19 emergency, will continue to receive the MHA rate for resident training. The laws authorize this special authority from March 1, 2020, to December 21, 2021.

VA will afford these same protections to new and incoming students, which means there is no requirement that a student must have a previous history of taking resident courses at the school for these laws to apply. In order to receive their MHA at the resident rate, the new student must be enrolled in officially “converted courses” at a rate of pursuit greater than 50%.

Q5) What should I know about changes to VA Work Study?

VA can continue to pay students the VA Work Study allowance at the full-rate of 25 hours per week even if the student is unable to work those hours due to the COVID-19 emergency. Initially, this protection was only available for students who were already participating in a work-study program on March 1, 2020. These students were allowed to extend their VA Work Study contracts and continue to participate in the VA Work Study program through the end of fall 2020 semester.

Effective October 1, 2020, new VA Work Study students can receive similar COVID-19 protection. Facilities must be able to offer work to students in good faith knowing that the facility will remain in working capacity to allow the VA Work Study student to fulfil their hours. If a facility is later impacted by the COVID emergency and must close or offer reduced hours, then the student can continue to earn up to 25 hours per week as long as 1 hour of that contract period was worked.

Q6) Will there be any impact on tuition and fee payments when only the modality changes from resident to online within a term due to COVID-19?

Tuition and fees reporting requirements will not change due to the COVID-19 emergency.

Example: Schools should review changes in fees associated with online modality, prorated building fees, etc. Note: Fees must be defined in the school’s catalog or supplemental and listed on the school’s billing statement or invoice.

Q7) Will GI Bill students be allowed to continue or start remedial/deficiency level courses at IHLs that convert to online instruction (distance learning) due to the COVID-19 emergency?

  1. For courses converted after sending an enrollment certification.
    An approved IHL which converts an approved resident Remedial/Deficiency course to online training for that course, may continue to certify these credit hours to VA as resident credit hours during the authorized period: March 1, 2020 through December 21, 2021.
  1. For courses converted before sending an enrollment certification.
    An approved IHL may continue to certify Remedial/Deficiency courses due to the COVID-19 emergency as required as resident to online conversion if the start date of the term is prior to December 21, 2021.
        ●  SCO must continue to use the R/D Credit hours section of VA-ONCE or on the VA Form 22-1999 Enrollment Certification .
        ●  When using VA-ONCE, SCO must enter Standard Remark “COVID-19 Residence Courses Taken Online” Or write it on the paper form.

Changes in enrollments and approvals

Q8) If an IHL creates a new vacation break, or extends the length of a break (which may include a change in term dates) due to the COVID-19 emergency, what steps should SCOs take?

IHL SCOs must make their SAA aware of any changes in term dates. Current published commencement dates that fall within 7 days (1 week) still apply if a school makes a change.

For updates to break length, please refer to the SCO Handbook, which states to always include inclusive dates of official school vacation periods of 7 or more consecutive days when certifying non-standard enrollment periods for all benefits in VA-ONCE non-standard remarks. Schools do not need to report vacation periods on standard length terms. This remains true during the COVID-19 emergency.

  • If there is a change in enrollment dates, the SCOs must adjust all elements of the enrollment certification to match actual enrollment time frame (includes break time and end date).
  • Specific instructions for amendment reporting are in the SCO Handbook.
  • Standard and Non-standard term lengths are identified in the SCO Handbook.

Q9) Should IHLs report enrollment changes when they temporarily change from a standard grade scale (A, B, C…) to Pass/Fail grading or another grading system due to the COVID-19 emergency?

No. There is no need to report a conversion from a standard grading scale to a Pass/Fail grading scale or similar grading systems. However, depending on the IHL’s grading policy, classes taken Pass/Fail may result in a non-punitive grade if the student fails the class. Rules about non-punitive grades have not changed.

  • Although VA does not typically make payments for classes resulting in non-punitive grades at the end of the term, if COVID-19 is reported as a mitigating circumstance for the student’s receipt of a non-punitive grade (i.e., Fail in a Pass/Fail class), VA will pay for the class.
  • Refer to the SCO Handbook for more information about reporting non-punitive grades and mitigating circumstances.

Similarly, the outcome for a grade registered as “No Credit” (NC) would be the same as described above for failing a Pass/Fail course. A ‘NC’ course outcome would require the SCO to report an end of term adjustment (or sooner if the grade was assigned prior to the end of the term). If the change is reported as COVID-19 related, liberal mitigating circumstances would be accepted.

Note: The IHL must make SAA aware of any change in grading system.

Student enrollment changes

Q10) If a student withdraws from school due to the COVID-19 emergency and cannot continue training while the IHL continues to offer course instruction, what steps need to take place?

All normal VA reporting rules still apply and SCOs should review the IHL’s published attendance policy and “Incomplete Grade” policy. SCOs should report the withdrawal based on the attendance policy and report COVID-19 as mitigating circumstances (MIT-C). The student’s last day of attendance should be reported as the effective date.

When a student drops a course due to the COVID-19 emergency, SCOs must report the adjusted credit hours (or termination as applicable), along with the “COVID-19” remark in VA-ONCE or written on the paper form to VA.  Liberal mitigating circumstances will be applied, but the student may incur some debt. VA’s Debt Management Center (DMC) has suspended sending debt notification letters until September 30, 2021. Students can request temporary collection suspension of preexisting debt or arrange for extended repayment plans.

Additional debt questions: Institutions with questions or concerns regarding a VA debt should contact DMC at their dedicated email for SCOs: DMCEDU.VBASPL@va.gov.  

In these situations, the law does NOT allow VA to continue to pay thestudent’s MHA payments beyond the last day of attendance. If the school’s policy allows "Incomplete Grade" or "Leave of Absence" as an option, SCOs must follow normal established procedures.

Note: If a student had to withdraw due to the COVID-19 emergency, please be aware there are new remarks added to VA-ONCE to be used to support mitigating circumstances.

Q11) Will there be acceptable circumstances (due to the COVID-19 emergency) that an IHL SCO may not meet the thirty-day requirement to report an enrollment change?

Late reporting (30 days from reporting event) is always a concern of VA. During the COVID-19 emergency, VA understands that institutions face additional challenges making timely enrollment amendments or adjusted certifications. VA asks that the institution make every attempt to complete the changes within a reasonable amount of time. 

Note: VA will consider your mitigating circumstances when completing a compliance survey.

Discontinuing training or operations

Q12) If a school transitions from resident to online classes to continue the training of some students, but must discontinue training in select programs (entire program of education; not just some courses) affecting other students, what steps should the school take?

  • Students enrolled in programs suspended due to the COVID-19 emergency will continue to receive their MHA at the same rate payable before the change of enrollment, for up to a total of four weeks, during the March 1, 2020 to December 21, 2021 period. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify. Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.
  • When the IHL resumes regular operations, if the institution has the same or new term dates, all standard enrollment procedures remain in place.

Q13) If a school transitions from resident to online classes to continue the training of some students, but must discontinue training in select courses (only select courses are discontinued) affecting some students, what steps should the school take?

  • Students enrolled in programs suspended due to the COVID-19 emergency will continue to receive their MHA at the same rate payable before the change of enrollment, for up to a total of four weeks, during the March 1, 2020 to December 21, 2021 period. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify. Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.
  • When the IHL resumes regular operations, if the institution has the same or new term dates, all standard enrollment procedures remain in place.
  • For IHLs that convert modalities, follow the instruction in Q2 for certifying changes to training modalities.

Q14) If a student is enrolled in a standard IHL degree program involving flight training and the school ceases the flight training due to the COVID-19 emergency, what steps should SCOs take?

SCOs should review the “Incomplete Grade” policy and apply that procedure, if applicable. When the training can continue, the student should complete the flight training portion without any further reporting requirements to VA when a punitive grade is assigned. Normal non-punitive grade requirements have not changed.

Q15) If an educational institution or program temporarily ceases operation due to the COVID-19 emergency, what steps should the school take?

If a student has questions related to the impact of COVID-19 on their education benefits, direct them to the   or have them call 888-GIBILL-1 (888-442-4551) between 7 a.m. - 6 p.m. Central Time, Monday-Friday.

If a school closed (permanently or temporarily) or took any of the actions listed below due to COVID-19, on or after March 1, 2020, students may be eligible to receive their MHA at the rate payable before the closure or enrollment change for up to a total of four weeks between March 1, 2020, and ending on December 21, 2021. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify.

 COVID-19-related school actions include:

   ● closed (temporarily or permanently) 
   ● reduced the number of credit hours a student could attend
   ● shortened semesters periods
   ● was delayed
   ● relocated
   ● converted to online training
   ● disapproved or canceled a program
   ● modified or made a program unavailable due to COVID-19 after March 1, 2020

 Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.

Non-College Degree (NCD) Schools

Change in Modality (Conversion from Resident to Online)

Q16) What impact do these laws have on NCD schools who have converted resident courses to online due to COVID-19?

  1. For courses converted after sending an enrollment certification.
  • VA will continue to pay benefits for an NCD which converts an approved residence training course to online training (distance learning) due to the COVID-19 emergency (when the conversion is the only change). The law authorizes this special authority from March 1, 2020, to December 21, 2021.
  • Educational institutions which convert from resident in-person) to online training do not need to submit enrollment adjustments for any terms certified as resident training.
  • Only converted courses apply – SCOs cannot certify resident credit hours to VA for online courses when there is no prior approval for a resident training counterpart.
  • These laws apply equally to current and new students enrolled in the converted courses.
  1. For courses converted before sending an enrollment certification.
  • NCDs which convert from resident to online training, as described above, may submit certification of resident courses which were converted to online training as resident courses if the start date of the term is prior to December 21, 2021.
  • Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.
  • Must enter Standard Remark “COVID-19 Residence Courses Taken Online” located within VA-ONCE.

Note 1: If an NCD resumes normal operation of a resident course prior to December 21, 2021, the school must resume certification of the actual training modality (i.e., resident training or distance education), and may only continue to certify online courses if distance education has been approved by the SAA. (In most cases, distance learning is not approvable at stand-alone NCD schools). The NCD should also cease utilization of the "COVID-19 Residence Courses Taken Online" remark.

Note 2: Normal reporting requirements for all other changes should be completed per SCO Handbook (change in start/end date, change in credit/clock hours, etc.).

Q17) Can NCD education or training institutions offer programs that were not previously approved by the SAA?

No. Only programs previously approved by the SAA will be available for NCDs to continue to report enrollments of GI Bill students. If the NCD has recently converted classes to online training, it is critical that the course is part of an officially approved program by the SAA to qualify as a “converted course.” If you are currently seeking approval for any new programs you must contact the SAA.

Q18) Will there be acceptable circumstances due to the COVID-19 emergency, where an NCD SCO is unable to meet the thirty-day requirement to report an enrollment change?

Late reporting (30 days from reporting event) is always a concern of VA. During the COVID-19 emergency, VA understands that institutions face additional challenges with timely enrollment amendment or adjustment certifications. VA asks that the institution make every attempt to complete the changes within a reasonable amount of time. VA will consider your mitigating circumstances when completing a compliance survey.

Q19) What happens when an approved program at an NCD education or training institution temporarily ceases resident (in-person) training because of COVID-19, but has the capability to convert training to an online?

  1. For courses converted after sending an enrollment certification.
  • An NCD with a current SAA-approved program may continue to train and report enrollments to VA. Students who pursue resident courses which have been converted to online training solely due to COVID-19 will continue to receive their MHA at the resident rate. The laws authorize this special authority from March 1, 2020, to December 21, 2021.
  • SCOs do not need to report modality changes due to COVID-19 for any current enrollments submitted to VA.

Other types of changes to the student’s enrollment status may affect payments. Non-COVID-19 related changes must still be reported per normal requirements.

  1. For courses converted before sending an enrollment certification.
  • NCDs which convert from resident to online training as described above can submit certification of resident courses which have been converted to online training as resident courses.
  • Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.
  • If any adjustments were made to the start or end date, these adjustments need to be reported to VA so accurate payments can be completed.
  • Enter Standard Remark “COVID-19 Residence Courses Taken Online”.

Notes:

  • The effective dates of the new laws allow NCD schools to continue training for converted programs/classes/courses due solely to COVID-19. When an NCD goes back to normal operations for resident courses, the school will continue to submit enrollment certifications to VA without the requirement of the additional “COVID-19 Residence Courses Taken Online” remark.
  • NCD schools not currently approved to offer online courses will not be allowed to continue to offer online courses after December 21, 2021.

Q20) For an NCD training institution that has an approved program which includes classroom and practical training, and the institution is only able to convert the classroom portion to online training, but unable to convert the practical training to online, what steps should SCOs follow to submit VA enrollments?

If a school closed (permanently or temporarily) or took any of the actions listed below due to COVID-19, on or after March 1, 2020, students may be eligible to receive their MHA at the rate payable before the closure or enrollment change for up to a total of four weeks between March 1, 2020, and ending on December 21, 2021. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify.

COVID-19-related school actions include:

● closed (temporarily or permanently)
● reduced the number of credit hours a student could attend
● shortened semesters periods
● was delayed
● relocated
● converted to online training
● disapproved or canceled a program
● modified or made a program unavailable due to COVID-19 after March 1, 2020

Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.

Student enrollment changes

Q21) When an NCD training institution (which had temporarily ceased all operations) resumes operations, what steps should SCOs take for VA students who do not return for training?

If a school closed (permanently or temporarily) or took any of the actions listed below due to COVID-19, on or after March 1, 2020, students may be eligible to receive their MHA at the rate payable before the closure or enrollment change for up to a total of four weeks between March 1, 2020, and ending on December 21, 2021. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify.

COVID-19-related school actions include:

● closed (temporarily or permanently)
● reduced the number of credit hours a student could attend
● shortened semesters periods
● was delayed
● relocated
● converted to online training
● disapproved or canceled a program
● modified or made a program unavailable due to COVID-19 after March 1, 2020

Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.

Q22) If a student becomes ill due to COVID-19 and they cannot continue training while the NCD institution continues to offer course training, what steps need to take place?

If a student has questions related to the impact of COVID-19 on their education benefits, direct them to the COVID-19 Student FAQs or have them call 888-GIBILL-1 (888-442-4551) between 7 a.m. - 6 p.m. Central Time, Monday-Friday.

All normal VA reporting rules still apply and SCOs should review the IHL’s published attendance policy and “Incomplete Grade” policy. SCOs should report the withdrawal based on the attendance policy and report COVID-19 as mitigating circumstances (MIT-C). The student’s last day of attendance should be reported as the effective date.

When a student drops a course due to the COVID-19 emergency, SCOs must report the adjusted credit hours (or termination as applicable), along with the “COVID-19 remark” to VA.  Liberal mitigating circumstances will be applied, but the student may incur some debt. VA’s Debt Management Center (DMC) suspended sending debt notification letters until September 30, 2021. Veterans can request temporary collection suspension of preexisting debt or arrange for extended repayment plans.

In these situations, the law does NOT allow VA to continue to pay the student’s MHA payments beyond the last day of attendance. If the school’s policy allows “Incomplete Grade” or “Leave of Absence” as an option, SCOs must follow normal established procedures.

Q23) What happens if the student resumes attendance?

An NCD educational institution will complete standard enrollment practices associated with any prior withdrawal by a student.

Note: If the student returns during the March 1, 2020 to December 21, 2021 timeframe, the school may continue to report converted courses to VA in accordance with guidance provided in the FAQs.

Discontinuing training or operations

Q24) What does the SCO do when an NCD training institution temporarily or permanently ceases operations due to COVID-19?

If a student has questions related to the impact of COVID-19 on their education benefits, direct them to the COVID-19 Student FAQs or have them call 888-GIBILL-1 (888-442-4551) between 7 a.m. - 6 p.m. Central Time, Monday-Friday.

If the NCD training institution closed (permanently or temporarily) or took any of the actions listed below due to COVID-19, on or after March 1, 2020, students may be eligible to receive their MHA at the rate payable before the closure or enrollment change for up to a total of four weeks between March 1, 2020, and December 21, 2021. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify.

COVID-19-related school actions include:

   ● closed (temporarily or permanently) 
   ● reduced the number of credit hours a student could attend
   ● shortened semesters periods
   ● was delayed
   ● relocated
   ● converted to online training
   ● disapproved or canceled a program
   ● modified or made a program unavailable due to COVID-19 after March 1, 2020

Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.

Q25) What happens when an NCD training institution temporarily ceases operations due to the COVID-19 emergency and cannot offer a program via online training?

If the NCD training institution closed (permanently or temporarily) or took any of the actions listed below due to COVID-19, on or after March 1, 2020, students may be eligible to receive their MHA at the rate payable before the closure or enrollment change for up to a total of four weeks between March 1, 2020, and December 21, 2021. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify.

School closure reasons:

  ● closed (temporarily or permanently)
  ● reduced the number of credit hours a student could attend
  ● shortened semesters periods
  ● was delayed
  ● relocated
  ● converted to online training
  ● disapproved or canceled a program
  ● modified or made a program unavailable due to COVID-19 after March 1, 2020

Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.

Q26) If an NCD school transitions select programs from resident (in-person) to online classes to continue the training, but must discontinue other training programs, what steps should the school take?

  • Students enrolled in programs suspended due to the COVID-19 emergency will continue to receive their MHA at the same rate payable before the change of enrollment, for up to a total of four weeks, during the March 1, 2020 to December 21, 2021 period. SCOs should consult the SCO Handbook and SCO training materials regarding Isakson and Roe, sections 1102 and 1103 for instructions on how to certify. Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.
  • When the IHL resumes regular operations, if the institution has the same or new term dates, all standard enrollment procedures remain in place.

Q27) When an NCD training institution (which had temporarily ceased all operations) resumes operations, what steps should SCOs take to ensure returning VA students receive proper payments?

SCOs would use the initial enrollment certification affected by the COVID-19 emergency to amend the new end date to cover the hours required to complete the NCD program. SCO should also amend tuition and fees when:

  • An increase or decrease is identified for specific fees associated with the continuation of training (admin fee, consumable products, etc.)
  • SCOs must report in non-standard remarks the time period changes due to the COVID-19 temporary cease of operations (last day of training and the first day of resuming training).

Q28) What happens when an NCD vocational flight training institution temporarily ceases operations due to COVID-19?

When this occurs, the NCD vocational flight institution should submit current flight hours per standard reporting requirements based on the last day of training (time to report will be extended). VA will process and pay benefits for qualifying tuition and fee costs to the NCD flight institution.

Q29) What happens when NCD vocational flight training institution resumes operations:

When an NCD vocational flight institution resumes operations for flight training, you should record normal resumption of monthly flight training reported to VA using VA-ONCE.

Note: Flight medical certification must remain current.

On the Job Training (OJT)/Apprenticeship

Changes in enrollment

Q30) Will there be acceptable circumstances, due to the COVID-19 emergency, where an OJT or Apprenticeship training establishment SCO may not meet the thirty-day requirement to report an enrollment change?

Late reporting (30 days from reporting event) is always a concern of VA. During COVID-19, VA understands that institutions face additional challenges with making timely amendments or adjustment certifications. VA asks that the institution make every attempt to complete the changes within a reasonable amount of time. VA will consider your mitigating circumstances for the aforementioned when completing a compliance survey.

Change in Modality (Conversion from Resident to Online)

Q31) Under the new laws, what happens when an OJT or Apprenticeship establishment can convert trainee programs from resident to online training due to COVID-19?

The laws allow payment for trainees only if the facility site is capable of converting from on-site to online training without disrupting the completion of the program with hours counted toward journeyman status. SCOs can provide monthly training hours via VA-ONCE or using a PDF attachment (VA Form 22-6553d-1 or agency letterhead) through our “Ask A Question” portal.

Note: VA highly recommends submitting documents via electronic means. Facsimile submissions are no longer accepted. Mailed documents are acceptable but may delay trainee payments.

Discontinuing training or operations

Q32) What does the SCO do when an OJT/APP training institution temporarily ceases operations?

COVID-19 legislation may allow trainees to continue to receive benefits in certain situations. SCOs should consult the SCO Handbook and training concerning sections 1106 of the Isakson and Roe Act for detailed instructions on how to certify correctly.

Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.

Q33) What happens when an OJT or Apprenticeship establishment temporarily ceases trainee program (examples: Veteran may still be working but not training: Employer is open, lay-off or furlough of the trainee, etc.) due to COVID-19 but the facility is continuing operations?

COVID-19 legislation may allow trainees to continue to receive benefits in certain situations. SCOs should consult the SCO Handbook and training concerning sections 1106 of the Isakson and Roe Act for detailed instructions on how to certify correctly.

Note: There will be more information on these COVID-19 provisions in the coming weeks to address any additional actions needed for addressing previously impacted enrollments.