UNDERSTANDING VETERAN REQUIREMENTS

OVERVIEW

- DECIPHERING VETERAN DOCUMENTS- NCD VETERAN ATTENDANCE

- VETERAN COMPLIANCE SURVEYS

DECIPHERING VETERAN DOCUMENTS

- DD214s

Armed Forces Member/Veteran• Requirement- Serving/served on AD (including basic training) in the Army, Navy,

Air Force, Marines, or Coast Guard.- National Guard or Reserve only considered veterans if called to

active federal duty by presidential order for a purpose other than training.

- Any service characterization except dishonorable. Includes fraudulent entry provided entire period of service was not voided.

- Service academy/preparatory school students for at least 1 day are veterans if service characterization was not dishonorable.

- The possession of a DD214 does not mean the person is a veteran.

DD FORM 214- Block 2: Department, Component and Branch

- Army/RA = Regular - Army/USAR = Reserve - Army/ARNGUS = National Guard

- Navy – USN = Regular- Navy – USNR = Reserve

- USMC – 11 = Regular- USMC – K1 = Reserve

- Air Force – REGAF = Regular- Air Force – AFRC = Reserve- Air Force – ANGUS = Air National Guard

- Homeland Security – USCG = Regular - Homeland Security – USCGR = Reserve

DD FORM 214- Block 12.c.: Record of Service - Net Active Service This Period

- Determine length of active service for DD 214 period. Note: Guard/Reserve personnel can have more than one DD 214.

- If the member was AD, served 1 or more days, and did not receive a dishonorable discharge (Block 24) they are considered a veteran even if they committed a military crime or were discharged for conduct/performance (Block 28). Fraudulent entry is acceptable permitted their entire period of service was not voided.

Block 18: Remarks- If the member was Guard/Reserve they must have been called to AD by presidential orders for

purposes other than training. - If the member served for purposes other than training it will be identified stating where they

served and the dates. - If service was anything other than dishonorable and meets the criteria list above then the member

is a veteran. - Title 32 v. Title 10 is typically specified here. - If the Guard/Reserve member was on active duty for training only then they are not considered a

veteran for financial aid purposes. This can be determined by looking at blocks 2, 11, 12.c, 18, 23, 24, & 28.

DD FORM 214

- Block 23: Type of Separation- This entry depends on the Character of Service (24). If block 24 is anything

other than Honorable you will typically see “Discharge” or “Discharged”.- If member was Guard/Reserve and on AD for training you will see

“Release from active duty training” or “Release from IADT” or “Released from active duty”.

- AD members will have “Released from active duty”.

- Block 24: Character of Service- DD 214 must have a Service Characterization of anything other than

dishonorable to be considered a veteran.- Block 28: Narrative Reason for Separation

- “Completion of Required Active Service” “Fraudulent Entry” “Misconduct (Serious Offense)” “Completion of Initial Active Duty Training”

QUESTIONS?

DECIPHERING VETERAN DOCUMENTS

- MILITARY ORDERS

Military Orders

• Types of military orders– TDY– Training– Deployment– Memorandum– Forms– Title 10 vs 32

Form Breakdown- Issuing service

- Component (e.g. Guard, Reserve, AD)- Issue date

- Depends on why orders are being submitted.- Itinerary (i.e. dates & destination)- Purpose

- All services do this differently and there are different formats, depending on type of orders, within each service.

QUESTIONS?

DECIPHERING VETERAN DOCUMENTS

- COMMANDING OFFICER STATEMENTS

COMMANDING OFFICER STATEMENTS• Who has authorization to sign?

– Commanding officer• Officer v. Enlisted v. Civilian

– By Direction (similar to proxy)– Signing “For” Commander

• What is the document stating?– Honorable service– Active Duty v. Training– Dates– Letterhead

QUESTIONS?

NCD VETERAN ATTENDANCE

OVERVIEW

• Clock Hour Measurement• Attendance Policy• Standards of Progress• Enrollment Periods• Prior Training• Approved Course Program Length• Certifying Tuition

Clock Hour Measurement• One clock hour = 60 minutes of instruction

• Classroom/Theory/Lab – Allows for 10 minutes to change classes each hour, which can be included

in the total hours of instruction (must deduct if not changing classes) – Also allows for 10 minutes to changes subjects even if students remain in

the same classroom (e.g., finish talking about gasoline motors and switch to studying diesel motors)

• Shop Practice – Allowance for 15 minute break in morning; another in the afternoon. Can

be included in total hours of instruction. Shorter breaks allowed for part-time enrollment

Clock Hour Measurement

• All clock hours reported to VA must exclude any lunch or meal breaks

– The morning and afternoon breaks may not be combined for a half hour lunch

Clock Hour Measurement• Certify the actual number of clock hours per week the student

is scheduled to attend, not the minimum it takes to be full-time

– Certified hours will be compared with those listed on the enrollment agreement and schedules

– No averaging unless it does not change training time or rate of pursuit to less than full time or less than 100%

Clock Hour Measurement

• How the Difference Affects Payment of Benefits – Training Time (Chapters 30, 35, 1606 and 1607)

Clock Hour Measurement

• How the Difference Affects Payment of Benefits – Sample Calculations for Rate of Pursuit (Chapter 33)

Attendance Policy• Know and understand your SAA approved attendance policy – Often times, it is different than the policy for your other

students

• Policy for VA students may be a percentage of course hours or total number of absences

Attendance Policy

• Ensure you are monitoring VA students’ attendance – Maintain detail in file

• We must see a record of every day the student was scheduled; the number of hours per day the student was scheduled; and how many hours the student actually attended

• Excused absences must be documented • Attendance records must be a daily record of the student’s actual

attendance and must be “positive” rather than “negative” records

Attendance Policy• All NCD programs measured on a clock hour basis must maintain

attendance records for each class • A student’s schedule is not an attendance record and not sufficient for this

purpose • All instructor-led classes must have a roll book or other record maintained

by the instructor to verify each student’s attendance – Often, a physical sign-in sheet is used for this purpose and is sufficient

as long as the class instructor maintains constant control over it so that s/he actually observes the student signing in

Attendance Policy

• Enforce the policy if a student fails to meet attendance standards – Student’s benefits must be terminated is s/he violates attendance

standards

• Ensure you submit within 30 days of the student’s last day of attendance prior to violating the attendance policy

Attendance Policy• Example:

– Attendance is verified on a monthly bases by the SCO. Students who, for any reason, miss more than 15% of the total scheduled course hours in a calendar month are considered to be in violation of the attendance policy and their VA education benefits will be terminated for unsatisfactory attendance.

• Example: – A VA student’s enrollment will be terminated if s/he has more than three

(3) absences in any calendar month.

• One size does not fit all – Check with your State Approving Agency if you have questions regarding your approved attendance policy

Attendance Policy• Example:

– In order to show that the cause of unsatisfactory attendance has been removed, students must show good attendance (as defined) for one calendar month after being terminated for unsatisfactory attendance. After such time, the student may be recertified for VA education benefits.

• One size does not fit all – Check with your State Approving Agency if you have questions regarding your approved attendance policy

Standards of Progress• Know and understand your SAA approved Standards of Progress policy for

VA students – Must relate to graduation requirements

• Ensure you are monitoring VA students’ progress • There must be a clear, definite point in time when a:

– VA student will be placed on probation (cannot be indefinite) • Report probation through RightNowWeb

– VA student’s enrollment will be terminated for not achieving satisfactory progress • Law requires VA educational benefits be discontinued when

student fails to make satisfactory progress toward completion of training objective (Title 38, USC, Section 3675(b)(1))

• Report termination for unsatisfactory progress through VA-ONCE

Enrollment Periods• Schools not operating on a term basis

– Typically, this category includes many public NCD schools and private cosmetology, massage therapy, barbering, etc., schools which operate their courses on the principle of competency-based instruction, open entry/open exit (each student learns the course material at his/her own pace and receives a certificate of completion when all competencies have been learned). Students just starting the course and others ready to complete the same course will be in the same classroom/shop at the same time with the same instructor. For such courses, a SOP may require specific grades/scores at the end of each grading period with probationary periods of one or two grading periods.

Enrollment Periods

• Schools not operating on a term basis (cont.) – With all NCD programs which do not operate on a term basis, the

school should enter the exact date on which the student first attends and the exact date on which the student will last attend (i.e., the first day of actual classroom attendance and the last day of actual classroom attendance are to be reported).

Prior Training • Schools must ask students to list all previous education and training

– To include where they attended, when they attended and in what program(s) they were enrolled

– Do not ask the student if they want any credit transferred in – irrelevant; mandatory and the students have no choice in the matter

• Schools must evaluate that education and training – Must obtain official transcripts

• Regardless of whether student previously utilized VA benefits

Prior Training • In most instances, schools must receive all transcripts:

– Within two (2) semesters or the equivalent – Within 12 weeks if program is at least six (6) months long – Prior to the start of the course if less than six (6) months long

• If applicable, schools must grant credit and reduce training time proportionately – Notify student and retain in student’s records

Prior Training Independent Study/ Online Training-Prohibited

• Courses/programs taught in whole or in part in an independent study, online, distance learning, hybrid or blended format are not approved at any NCD school –This also means that study labs where the students come in when they want to during certain hours, cannot be approved

• All courses approved at NCD schools must strictly be offered in a traditional classroom, laboratory or shop setting (i.e., students physically in the same room at the same pre-scheduled time with a live instructor)

Prior Training Approved Course/Program Length-Certification

• Must not certify more hours than the SAA has approved –VA will only pay for student to be in the seat in the classroom for the number of clock hours approved

• Keep track of total hours completed

Prior Training Approved Course/Program Length-Certification

• Course/Program name certified must match what is listed in the WEAMS report (aka VA Form 22-1998) –Incorrect wording may impact whether payment is made –If WEAMS is correct, then update VA-ONCE –If WEAMS is incorrect, then submit a request to have it updated with correct information

Certifying Tuition Are you reporting the correct dollar amounts for Chapter 33?

• Certify the net tuition • Certify only allowable fees

– Validity of Fees – Before a fee can be certified to VA it must meet all of 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; and –Be “mandatory” or otherwise “required” of all similarly circumstanced students…

Certifying Tuition Are you reporting the correct dollar amounts for Chapter 33?

• Validity of Fees (cont.) –A school charges a fee for a kit, but allows students to purchase items in that kit on the open market – this fee is not mandatory and cannot be certified to VA. –A school charges a kit fee and will not allow any student, under any circumstances, to have fee waived if they purchase items on the open market. School may allow credit to students who purchased the same kit at another branch of the same school and have now transferred to a second branch of that school.

Certifying Tuition Pro Rata Refund Policy - Nonaccredited courses/programs

• The refund policy must be pro rata or more advantageous to VA students than pro rata –Must be pro rata to the very end

• Example: Student drops out after completing 75% of the course; the school must refund 25% of the tuition to the student

• An accredited school could possibly have a non-accredited program to which the pro rata refund rule would apply

Certifying Tuition Chapter 33

• If a school charges all tuition up front –Tuition certified to VA should be prorated between enrollment periods –Proration at nonaccredited schools is interwoven with the pro rata refund policy –Important because of the way entitlement is charged – If one enrollment period lists all tuition and fees for an entire program,

entitlement charged based on tuition and fees certified – If subsequent enrollment periods are certified with $0.00 in tuition

and fees, entitlement will be charged based on the rate of pursuit (results in VA student’s entitlement getting hit twice)

Certifying Tuition Chapter 33

• If a school does not charge all tuition up front –Tuition certified to VA should be submitted in the same increments as which it is billed to the students –Important because if the school bills in increments, certifies all charges to VA up front, then the student drops, VA will charge the student with a large debt for tuition and fees that have not actually yet been charged

Certifying Tuition Entitlement

• All Stand-alone NCD Schools (not part of a college or university) –VA charges entitlement differently than how they charge it for IHLs – Essentially, VA charges 12 months of entitlement for each $20,235.02

paid for tuition and fees, prorated up to that yearly maximum. This comes out to one day of entitlement charged for each $56.21 paid ($20,235.02 divided by 360 days – VA computers calculate every month as 30 days in length).

Certifying Tuition Entitlement

• Example 1 –First student enrolled Jan 15th through May 14th for 30 clock hours per week with a tuition charge of $3,000. Although this student is enrolled at 100% ROP for about 4 months, VA will charge the student only about 1 ½ months of entitlement. This is based upon dividing the $3,000 total charges by the daily rate of $56.21 (as calculated above). The result of 53.37 days is roughly 1 ½ months.

Certifying Tuition Entitlement

• Example 2 –Second student enrolled Jan 15th through May 14th for 30 clock hours per week with a tuition charge of $20,500. Although this student is enrolled for only 4 months at a ROP of 100%, VA will charge the student 12 months of entitlement because VA paid the maximum $20,235.02 for the academic year.

Certifying Tuition Entitlement

• Multiple Periods of Enrollment –Same first student enrolled for the following periods and charges: – Aug 15th – Dec 14th 30 clock hours $1,000 total charges – Jan 15th – May 14th 30 clock hours $1,000 total charges – Jun 1st – Oct 14th 30 clock hours $1,000 total charges

–Although this student has been enrolled for a total of 12 months of enrollment at the 100% ROP, VA will charge only 1 ½ months of entitlement based on the total charges of $1,000 each enrollment period ($1,000 divided by $56.21 = 17.79 days of entitlement each enrollment period for a total of 53.37 days or roughly 1 ½ months)

Certifying Tuition Entitlement• Multiple Periods of Enrollment

–Same first student enrolled the same way; however, all tuition and fees are charged up front for the first enrollment period. If you don’t prorate, more entitlement is charged: – Aug 15th – Dec 14th 30 clock hours $3,000 – Jan 15th – May 14th 30 clock hours No charges – Jun 15th – Oct 14th 30 clock hours No charges

• –In this case, VA would charge about 1 ½ months of entitlement for the first enrollment period based upon the total charges of $3,000. Since there are no charges for the other two (2) enrollment periods VA then charges entitlement as they would for the other GI Bill programs (i.e., one (1) month for each month enrolled at 100% ROP. This means VA would charge about four (4) months entitlement each for the last two terms for a total of eight (8) months. Combined with the two (2) months VA charged for the first term, that means this student would be charged a total of ten months

Certifying Tuition Entitlement

• Same second student enrolled for the following periods and charges: – Aug 15th – Dec 14th 30 clock hours $6,833.33 total – Jan 15th – May 14th 30 clock hours $6,833.33 total – Jun 15th – Oct 14th 30 clock hours $6,833.33 total

• Based again upon a daily rate of $56.21, VA would charge about 122 days (roughly 4.1 months) for each of the first two (2) enrollment periods, then the remaining 3.9 months for the last enrollment period for a total of 12 months of entitlement used.

Certifying Tuition Entitlement

• Same second student enrolled for the same periods; however, all tuition and fees are charged up-front for the first term/period: –Aug 15th – Dec 14th 30 clock hours $20,500 total –Jan 15th – May 14th 30 clock hours No charges –Jun 15th – Oct 14th 30 clock hours No charges

• As you may have surmised by now, VA would have charged 12 months of entitlement for the first term since they would have paid a year’s worth of total charges. Then, with no charges for the last two (2) terms, VA would charge about four (4) months entitlement for each of those terms. That means the student would have used up a total of about 20 months of entitlement even though enrolled for a total of only 12 months.

QUESTIONS?

VETERAN COMPLIANCE SURVEYS

Overview

• Compliance Survey Objectives• Preparation • On – Site Review• Common Findings• Post Survey

COMPLIANCE SURVEY OBJECTIVES• Routine reviews of selected students’ records to verify that payments of

GI Bill benefits were properly made to your VA students • Assist School Officials in better understanding their responsibilities and

the procedural requirements of VA • Conducted in order to ensure schools and training establishments, along

with their approved courses and programs, are in compliance – To determine, on the basis of facts disclosed from document reviews

& personal visits, whether there are deviations from the responsibilities & requirements by eligible individuals, schools or training establishments

• Scheduled to previously approved facilities to monitor and assure continued acceptability of approval – To assure that proper action is promptly taken through appropriate

channels for the correction of existing discrepancies

COMPLIANCE SURVEY - PREPARATION• VA will establish and maintain a schedule of compliance surveys and

inform SAA of which schools it has been assigned to visit – Schedules will be prepared before the beginning of each fiscal year – Certain number of schools assigned to the SAA; VA retains the

balance • Visits conducted at approved schools and facilities with veterans

enrolled during the previous federal fiscal year (October - September) • Several schools visited per week to reduce costs

– Same geographical location • Majority of compliance surveys we conduct involve travel meaning

a number of institutions may be scheduled for a given week (Monday – Friday). We strive to not schedule at institution peak workload periods however this may not occur based on travel plans.

• May be more than one person conducting visit if at a large school

COMPLIANCE SURVEY - PREPARATIONHow are student files selected?

• Randomly chosen by the SAA or VA employee who will be conducting the visit (to identify any pattern of error) – (no longer chosen by the school or training facility as they were with SAA supervisory

visits)

• VA reports (RCS 20-0259-60 & COIN 289); TIMS or VA-Once used to obtain random sample

• RCS – Records Control Schedule • COIN – Computer Output Identification Number • The institutional records copied will be retained by VA and SAA to include

in our compliance survey records – PII data is safeguarded and necessary as internal quality reviews by VA are conducted to ensure all aspects of the compliance survey were accurately reviewed and completed.

COMPLIANCE SURVEY - PREPARATIONHow many files must be reviewed?

• Depending upon the size of your VA student population – Sample Size is based on total VA Student awarded enrollment total - No fewer than 10

(unless you have less than 10 current enrolled VA students) ~~~Expanded ~ If review of the initial sample reveals overpayment errors in 30 percent or more of the cases, or discrepancies of any type in 50 percent or more of the cases reviewed, the survey will be expanded using a sample equal to the size of the initial sample. The survey specialist may exercise his/her discretion to expand any survey based on professional judgment and not to expand surveys in cases of repeated minor errors.

• VA Student Population Records to Review 0 to 99 10 100 to 199 15 200 to 299 20 300 to 399 25 400 to 499 30 500 to 599 35 600 to 699 40

700 or more 45

COMPLIANCE SURVEY - PREPARATIONHow will we notify you?

• Email, phone call or fax to inform you of our visit – Advance notice provided

• VA and/or SAA will call the primary SCO to schedule a date(s) and time for conducting the survey in addition to providing institution with names of students in the sample size to be reviewed.

• A letter or email will be furnished the SCO of the student names and the institutional records to copy for our review.

• Survey Confirmation Letter emailed or mailed – Confirm date and time of appointment – Provide school official with names of student files required and

items/types of records to be reviewed – Schedule face-to-face interviews with students, if applicable

COMPLIANCE SURVEY - PREPARATIONWhat Records & Accounts are needed for the survey?

• Institutional Records Needed for Student Records: – Copy of unofficial transcript – Copy of Degree Audit Report (DAR) – Copy of Student Account Ledger – Copy of Student term registration schedules

• Identifying start date, end date • Identifying modality of instruction • Captures non-standard term dates by subjects • Verification of prior credit evaluations • Progress Standards (GPA) • Obtaining LDA or last activity to confirm withdraw of subjects for

student records

COMPLIANCE SURVEY – ON-SITE REVIEWWhat happens when we arrive?

• Entrance Interview – Typically with certifying official – Others included as school (Student Accounts, Financial

Aid, Registrar, etc.) • as the facility, SAA, or Compliance Survey Specialist sees fit

COMPLIANCE SURVEY – ON-SITE REVIEWRecords and Accounts

• Are your records/files available? – Records and accounts of VA beneficiaries and other students must be

provided for examination GUIDANCE

– Review checklist provided to you by SAA or VA (whoever is conducting the visit) • Ensure all items are addressed • Ask questions if unsure

– Must have records available at time of visit

COMPLIANCE SURVEY – ON-SITE REVIEWCommencement of Courses

• Did the student begin when certified? – Date certified must agree with start date

GUIDANCE – IHL: First day of classes for the semester or quarter – NCD: First day the student is actually physically in class – Flight: Date of first flight or ground school lesson – OJT/Apprenticeship:

• For OJT - first day on the job • For registered apprenticeships - the date of indenture or the first

day on the job, whichever is later

COMPLIANCE SURVEY – ON-SITE REVIEWProgram Certified

• Is the correct program certified? – Program certified must be the same as what the VA beneficiary is

enrolled in and pursuing GUIDANCE

– Review transcript, registrar records, enrollment agreement • If they do not agree, update records and/or certification

– Monitor WEAMS (22-1998) reports – Ensure program certified is exactly as appears on WEAMS

COMPLIANCE SURVEY – ON-SITE REVIEWPrevious Education & Training

• Is There Prior Credit? – Record and evaluation of all previous education and training must be

maintained in files • Must review and evaluate acceptance of prior credit after no

more than two semesters (or equivalent). If additional information is received at a later date, the evaluation can be revised.

• The school must maintain a written record that clearly indicates that appropriate previous education and training has been evaluated and granted, with training time shortened and tuition reduced proportionately, and the VA and the veteran so notified (mandatory – not a suggestion!)

COMPLIANCE SURVEY – ON-SITE REVIEWPrevious Education & Training (cont.)

GUIDANCE • Make available for review all transcripts from previous institutions • Review VA Forms 22-1990, 22-5490, 22-1995, 22-5495 for indication of

any previous education & training • Take note of previous institutions in VA Once • Review school application or other documentation • Record prior credit submitted and total granted

COMPLIANCE SURVEY – ON-SITE REVIEWRecords

• Are your records accurate, current and complete? – Records of enrollment, correspondence lessons serviced, flight

training hours or OJT/APP hours must be accurate, current and complete

GUIDANCE – IHL: Registration documents, class schedules, transcripts, drop slips,

withdrawal documentation, tuition payment ledgers, etc. – NCD: Attendance records, registration documents, class schedules,

transcripts, drop slips, tuition payment ledger, etc. – Flight: Follow the Student Checklist that is supposed to be

maintained in your files – OJT/APP: Records of hours worked and wages paid to include pay

and leave records, and records of training given

COMPLIANCE SURVEY – ON-SITE REVIEW• Records and Accounts• Commencement of Courses• Program Certified• Previous Education & Training• Records• Accurate & Prompt Certifications• Terminated or Interrupted Training• Progress and Grades• Satisfactory Progress• Charges• Percentage of Enrollment• Timely Changes• Information furnished to students

COMPLIANCE SURVEY – ON-SITE REVIEW• Enrollment Limitations• Refund Policy• Repeat Discrepancies• Advertising • Power of Attorney• Independent Study• Practical Training• Cooperative Courses• Tutorial Assistance• Conflicting Interests Certification• Contractual Arrangements• Advance Pay• Nonduplication of Benefits• Yellow Ribbon Program

COMPLIANCE SURVEY – COMMON FINDINGS• Common errors involve:

– Not reporting changes or terminations – Not reporting net charges correctly – Not reporting unearned F grades – Not reporting distance learning correctly – Late reporting of enrollment changes to VA – Failure to monitor prior credit evaluations – Certifying credits that do not apply to program requirements – Certifying remedial subjects when offered on line – Incorrectly reporting LDA – last day of attendance on withdrawing – Certifying incorrect program name or type of training – Not reporting unsatisfactory progress or probation – Lack of institutional records to support certifications to VA – Certifying programs not approved by VA or SAA

COMPLIANCE SURVEY – POST SURVEYWhat happens when the survey is complete?

• Before We Leave – Exit interview conducted

• With Certifying Official and others as school or auditor sees fit

• After We Leave – Compliance Survey site visit report – Referrals submitted to Buffalo Regional Processing Office

• Occurs only if findings affect payment

COMPLIANCE SURVEY – POST SURVEYWhat happens when the survey is complete?

• After We Leave (cont.) – Letter to school (sent to highest administrator with copy to certifying

official) • Identify student records reviewed • Detail any discrepancies/findings • Specify corrective actions (if any) required by the school or facility

• Schools and facilities are not the only ones audited… – A random sample of compliance survey files are reviewed each

quarter for quality assurance

QUESTIONS?