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Education and Training

Veterans Apprenticeship and Labor Opportunity Reform Act (VALOR)

”VALOR Act” – Registered Apprenticeship Sponsors Frequently Asked Questions

 The VALOR Act (PL-115-89) is a law now codified under 38 USC 3672(c) that simplified the Department of Vetarans Affairs (VA) Education Benefits approval process for Registered Apprenticeship programs having National Program Standards.  The Act provided for a single State Approving Agency (SAA) to approve multi-state Registered Apprenticeship programs* rather than requiring the SAA in every state approve them individually.  The law also specified the headquarters state SAA is the approval authority in all states the program is located.

*A multi-state Registered Apprenticeship program covered by the VALOR Act is “a non-Federal Registered Apprenticeship program operating in more than one state that meets the minimum national program standards, as developed by the U.S Department of Labor.”

Question:  What are the benefits of being approved through the provisions of the VALOR Act versus a Non-VALOR approval?

Answer:  There are many benefits to approving multi-state Registered Apprenticeship programs under the VALOR Act.  For the sponsors, there is only one SAA to work with rather than SAAs in all the states who may each have slightly different processes and have different scheduling priorities to complete the approval of the programs.  Therefore, the VALOR approval process is typically faster than waiting for SAAs in all of the states to take similar actions. With an expedited approval process, beneficiaries can start training sooner and receiving benefits sooner also.

Question:  What is meant by the term “approval?”

Answer:  VA beneficiaries can only receive benefits while attending/training at “approved” facilities.  SAAs within each state are mandated by federal law to review programs at facilities requesting approval for adherence to applicable laws, regulations, and policies.  If the programs are found to meet the criteria, the SAA then approves them and reports this information to the VA for upload into a database later used to process payments for the beneficiaries.  If the facilities/programs later fall out of compliance, the SAA may suspend or withdraw the approval.

Question:   Who can request VALOR Act approval?

Answer:  Registered Apprenticeship sponsors that have National Program Standards that have been approved by U.S Department of Labor (DOL), Office of Apprenticeship (OA), Washington, D.C., may request VALOR approval.  Sponsors of interstate commerce carrier programs that meet the requirements may also apply.  The entity applying must be identified on the cover of the standards of apprenticeship (may not be a participating employer, however participating employers are considered to be operating a Registered Apprenticeship program under the standards of the sponsor.)

*Federal agencies may apply to DOL to operate a multi-state apprenticeship program and these programs may be eligible for approval.  SAAs do not approve federal programs so federal sponsors should contact the VA directly at federal.approvals@va.gov to continue the approval process.

Question:   What is a Registered Apprenticeship sponsor?

Answer:  The U.S. Department of Labor (DOL) describes a Registered Apprenticeship program sponsor as any employer, association, committee, or organization that operates a Registered Apprenticeship Program. This entity assumes the full responsibility for administration and operation of the apprenticeship program. Sponsors can be a single business or a consortium of businesses. Alternatively, the sponsor can be a workforce intermediary, such as an industry association or a labor-management organization. Community colleges and community-based organizations can also serve as sponsors of apprenticeship programs.

Sponsors design and execute apprenticeship programs, provide jobs to apprentices, oversee training development, and provide hands-on learning and technical instruction for apprentices. The programs operate on a voluntary basis, and they often receive support by collaborating with community-based organizations, educational institutions, the workforce system, and other stakeholders. 

Question:  What criteria must a Registered Apprenticeship sponsor satisfy for GI Bill® approval under the VALOR Act?   

Answer:  The sponsor must have an apprenticeship program approved by DOL, have standards signed by DOL OA Administrator, and the programs have been approved under National Program Standards. The SAA will review the program for compliance with any other applicable guidance once the request for approval has been received.   

Question:  How is approval under the VALOR Act requested?

Answer: The sponsor will contact the SAA in the state in which the sponsor is headquartered (HQ) to complete and submit the following documents:

  • VA Form 22-8865, Employer's Application to Provide Job Training using the sponsor’s HQ address which may be different than the address of the Registered Apprenticeship Program Manager listed in the standards. Training does not have to be occurring at the HQ location.  The wage rate and journeyman wage may be left blank.
  • DOL standards signed by the DOL OA Administrator: must include the appendices that document the Work Process Schedule and related instruction (for additional programs added later, an Appendix A and the OA bulletin should be provided).
  • VA Form 22-8794, Designation of Certifying Officials

The Certifying Official (SCO) is a representative of the employer or sponsor who is authorized to sign and submit information to the VA to certify a VA trainee’s enrollment, hours trained, changes in employment status, and any other circumstances that affect the amount or duration of the trainee’s educational assistance benefits. The Certifying Official(s) does not have to be physically located at HQ, and records do not have to be maintained at HQ.

  • Provide name and locations of any other training facilities (if the Sponsor)

Question:  How do I find my SAA?

Answer: Select your state at this link for the SAA Director’s contact information – you can use a general mailbox if noted or contact the Director – name is asterisked.  NASAA State Contacts – NASAA (nasaa-vetseducation.com).

Question:  Will I ever have to contact the SAA again?

Answer:   You must contact the SAA again any time there are changes that affect your approval.  This includes but is not limited to a change of job title, hours and/or training, or additional programs, as changes will require further review and approval from the SAA.  Other changes such as telephone number, facility address or point of contact should also be reported but those need to be reported to the Education Liaison Representative (ELR) and not the SAA. 

Question:  Do sponsors have any other responsibilities?

Answer:  Yes, additionally the sponsor will agree to:

Question:  What must the VA Certifying Official do for each apprentice?

Answer:  Responsibilities as a VA Certifying Official include:

  • Maintain appropriate work progress records per DOL 29.5 (b)(6)- Periodic review and evaluation of the apprentice’s performance on the job and in related instruction and the maintenance of appropriate progress records.
  • Grant advanced standing or credit per DOL 29.5 (b)(13) for demonstrated competency, acquired experience, training or skills for all applicants equally, with commensurate wages for any progression step so granted.
  • Annotate completion per DOL 29.5 (b) (15) Recognition for successful completion of apprenticeship evidenced by an appropriate certificate issued by Registration Agency.
  • Complete, submit to VA through Enrollment Manager (EM), and maintain in your records, initial VA Enrollment Certification (be sure to include and prior credit granted). This is how the entire training period information is reported and it must be submitted for the trainee to receive benefits.
  • Each month complete, submit to VA through EM, and maintain in your records, monthly hour certifications of training. Submit each month for each trainee to report hours worked plus hours of related training completed during the period shown on the form. Vacation periods, sick time, military leave, or hours not worked due to strikes or layoffs, cannot be certified.  The form must not be submitted until the end of the period shown on the form.  (Note: The trainee must work at least 120 hours each month to receive full training allowance.  If the trainee does not work at least 120 hours, benefits will be reduced in proportion to the number of hours less than 120 worked).  If this is not submitted monthly trainee will not receive benefits.  The information you report on the form must be accurate and supported by your records.
  • Report any changes in trainee status to the VA within thirty days of the date of the change.
  • Report Progress (Outcome Measures) for all beneficiaries (completion-last date of employment, transfer, or termination).
  • Maintain records supporting these certifications. Records normally maintained by a business establishment are usually adequate to include attendance, paid leave, and progress in training for each objective listed in the OJT/APP program.
  • Maintain these records for at least three years following completion of the training program.
  • Make these records available for inspection by authorized representatives of the government.

Question:  How does the sponsor submit enrollment certifications and certify trainee hours?

Answer:  Initial enrollment will be submitted once, and hours will be certified monthly electronically through Enrollment Manager (EM). 

Question:  What is Enrollment Manager?

Answer:  EM is VA’s Web-based system for certifying the enrollment and changes in enrollment of trainees. Access is accomplished through the Internet and is available to all facilities approved for Veterans’ training. EM functions with any internet browser.  All users need to create an ID.me or Login.gov account to have secure access to EM.  See EM Frequently Asked Questions.

Question: How do I create a ID.me or Login.gov account?

Answer:  Create your ID.me or Login.gov account.

Question:  What is my facility code?

Answer:  A facility code is a unique code assigned by the VA to designate each facility approved to provide training or education to eligible veterans or dependents.  The code identifies some characteristics of the facility including the profit status, the facility type, and the state where it is located.  You will be provided a facility code by the VA if the SAA approves the program and VA accepts it. If the program is approved, you will be given a VA Form 22-1998, Web Enabled Approval Management System (WEAMS) Report, which will have the facility code and will be provided with your initial approval and each time an update is made to the approval.  It is important to review the VA Form 22-1998 report each time it is received and respond with any inaccuracies.

Question:  What is VA Form 22-1998, WEAMS Report?

Answer:  Each time your facility’s information is updated in our WEAMS, VA will send you an updated VA Form 22-1998, WEAMS Report. Carefully review the document to verify that the information is correct. The programs listed on this report match what is approved by the SAA.  Please contact your SAA if there are any questions or discrepancies.

Question:  What hours can be certified to the VA?

Answer:  Only training hours worked plus hours of related training completed during the period can be certified to the VA for payment. Vacation periods, sick time, military leave, or hours not worked due to strikes or layoffs, cannot be certified. Full time status is reached when a trainee’s work and training hours equal 120 hours per month.

Question:  When should monthly hours be certified?

Answer:  Monthly hours should not be certified until the month has ended.

Question:  Is it better to certify training from one location, such as the HQ, or from each location where training is conducted?

Answer:  The sponsor should discuss certification with the ELR then make the decision to certify centrally from HQ for all locations or from each training location (however, the same Certifying Official may certify all).  This decision is an important one as it will determine if the Veteran receives the housing allowance of the HQ address or that of their training location.  This amount can vary greatly, but we do allow the sponsor to make this decision. However, this decision is one or the other, meaning all will be certified from HQ or each location will need to be certified under their own facility code.  If central certification is decided, one facility code will be assigned.  If certifications will be completed by each training location, a facility code will be assigned for each one and a VAF 22-8794 form will be needed for each location.

Question:  What if no training takes place at the HQ address?

Answer:  The sponsor can turn in a VAF 22-8794 with HQ address even if no training occurs at that location, or a VA form 22-8794 can be submitted with a different training site’s address (if the person is managing records elsewhere).

Question:  How can the sponsor help the trainee to begin receiving benefits?

Answer:  If the trainee does not yet have a Certificate of Eligibility, the veteran or eligible person who would like to receive VA benefits while training at your facility must submit an Application for VA Education Benefits (VA Form 22-1990) to the U.S. Department of Veterans Affairs (VA) so a determination of their eligibility may be made.  Trainees may obtain general education benefit information, assistance regarding payment issues, and specific education benefit eligibility, by calling our toll-free telephone number 1-888-GIBILL1 or 1-888-442-4551. If the trainee has already received benefits, he or she would complete a VA form 22-1995, change of place of school or training.

Question:  Can a veteran in a Registered Apprenticeship program that has been approved for VA Education benefits get retroactive benefits?

Answer:  A VA beneficiary can only receive benefits while the program is approved by the SAA.  It is possible for the SAA to approve the program retroactively.

Question:  What if I am a participating employer operating programs under the standards developed by a Registered Apprenticeship Sponsor whose program(s) meet VALOR criteria?

Answer:  Unless you are a Registered Apprenticeship sponsor that has National Program Standards approved by DOL OA, Washington, D.C., you do not have programs that meet the VALOR Act criteria.  You do, however, have a DOL Registered Apprenticeship program, and should be permitted to apply to the SAA in the state which you are operating, even if the employer’s name is not listed on the front page of the standards. The participating employer would have a participation agreement within the DOL Standards package, the participating employer would need to send a VAF 22-8865, the standards, and their signed employer participation agreement to each SAA for which they have a training facility.  The approval is still streamlined, but unfortunately, does not meet VALOR Act requirements, that is why the employer may have to submit multiple applications.

GI Bill® is a registered trademark of the U.S. Department of Veterans Affairs (VA). See more information about education benefits offered by VA.
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