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VETERANS BENEFITS ADMINISTRATION

IHLs with Flight Degrees

1April 18, 2017

Oregon Association of Veteran

School Certifying Officials


How Flight Courses Are Offered

Vocational Flight programs

• These are non-college degree or certificate programs designed to train students in operating aircraft per FAA regulations.

Flight Degree programs (in-house)

• These are degree programs at IHLs which have their own “flight line”. Meaning the IHL itself provides the flight training pursuant to FAA regulations (either Part 61 or Part 141). The training is not being provided by another educational institution through a contract. Individuals conducting the pilot training must be FAA approved flight instructors (CFI) and must be staff employed directly by the IHL (possibly through personal contracts with individual flight instructors) and not contracted through/by another institution (such as a vocational flight school).

Flight Degree programs (contracted)

• These are degree programs at IHLs which do not have their own “flight line” but have contracted with either a vocational flight school or another IHL which does have its own flight line to provide the flight training pursuant to FAA regulations.

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Flight Degree In-House Programs

• An IHL with an in-house flight training program will have it’s own flight line. Meaning it will operate or manage the flight training itself. It will directly hire it’s own instructors. It does NOT contract with any third party to conduct any training for any of the required courses so there will be no MOU or contract. This would not preclude an IHL from contracting for non-instructional services such as the use of aircraft, aircraft maintenance, or hangar use, etc.

• An IHL with an in-house flight training program will conduct the training under either the Part 141 regulations or under Part 61 regulations. This is a reference to the section of the Federal Air regulations (FARs) which specify requirements to train students for pilots licenses and ratings. This can be found in Title 14 CFR 141 or Title14 CFR 61 respectively.

• If the IHL has an in-house program operated under Part 141 regulations it will have documentation showing the FAA has approved their training program. It essentially establishes the school as a pilot school or pilot training facility. It will have an Air Agency Certificate (AAC), TCOs (Training Course Outline) and syllabus.

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• If the IHL is approved by FAA for a Part 141 program always review the specific programs which the FAA approved for the school. This should be documented on the AAC. If, for example, FAA only approved Instrument and Commercial then the facility should not be training in a CFI or ATP course etc.

• An IHL with an in-house flight training program operated under Part 141 could require training hours in excess of the hours specified in their FAA approved TCO and syllabus and still obtain VA approval. However, the schools catalog should define the number of flight training hours for each flight related class required for the flight degree.

• Part 61 training does not prescribe a standard FAA curriculum. This usually cannot be approved for VA training. BUT an IHL with an In house flight facility can do so since there is no law in place stating they can’t as there is with a vocational flight facility and IHL facility contracted with a vocational flight facility

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Flight Degree In-House Programs


Private pilot courses could be a part of any degree program offered and approved by VA

The IHL can choose any number of hours that it wants to declare “required hours of training” in its program. The school may publish required flight hours that exceed FAA minimum requirements or exceed the hours required in the school's approved Part 141 syllabus. However, those hours must then be required of all students, VA and non-VA alike, and meet any requirements of your licensing and/or accrediting agency.

Training can be under Part 61 or 141

Fees associated with FAA written and practical test could be included in the tuition and fee amount certified to VA provided all students in those programs are required to pay that fee to the school without any exception

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Special Notes For In-House Programs


An IHL with a flight degree program could also contract with another IHL which has it’s own FAA approved flight training program or with a VA approved vocational flight school to provide the flight training for it’s students.

• The contracted vocational flight school will have a Part 141 AAC, TCO and syllabus. It will have it’s own certified flight instructors who conduct the flight training per FAA requirements.

• The IHL must have an MOU or Contract with the vocational flight school (third party).

• The vocational flight school to which the IHL has contracted must have its own separate VA approval of their flight training programs. The flight training programs at the vocational flight school must maintain VA approval in its own right.

• The flight training hours which the IHL requires for its degree program must be limited to the number of flight training hours approved for the programs at the vocational flight school. (For example; if commercial pilot training is a component of the degree program at the IHL the flight training hours required for this commercial pilot degree program will be limited to the number of flight training hours VA approved for the commercial pilot program at the vocational flight school.) 6

Flight Degree Contracted Programs


• After August 1, 2016, private pilot training cannot be part of any VA approved program (although could be a prerequisite to enter the program). An IHL in this situation could potentially offer a private pilot class and list this class in their catalog. But, this class could not be required for any VA approved program.

• For terms beginning after December 31, 2015, credits or charges for any elective courses involving contracted private pilot training may not be certified to VA.

• The training hours are limited to the hours approved by the FAA for the contracted facility. This is shown on the Training Course Outline (TCO) or Syllabus which the FAA approved at the contracted facility.

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Special Notes For Contracted Programs


Special Notes Regardless of the Type of Program

• Students should fly the number to hours required to obtain a satisfactory grade in the course. The hours a school lists in its catalog should be the hours of training “required” to obtain the learning objectives (which the school may choose to describe in terms of “proficiency”). Since the listed hours are those that are “required” (meaning those hours that must be completed) it is not logically possible to complete the training prior to the listed hours. A student cannot complete a course before doing what is required to complete the course.

• If a student does not complete all hours required for a course by the end of the enrollment period as provided in the VA approved school catalog and certified to VA the student should receive an “I” grade until such time as he/she does complete the required number of hours. No additional tuition or fees should be certified to VA. Standard “I” grade guidelines would apply.

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• If a student does not begin his/her flight training hours on the date certified to VA (or within the current guidelines prescribed for commencement dates) the school should send an amended certification reporting the new beginning date for the credit hours associated with that training

• The same is true if student completed all hours required in a class prior to the certified end date the school should send an amended certification (based on current guidelines prescribed for end dates)

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Special Notes Regardless of the Type of Program


FAA Authorization for Flight Training

Whether in-house or contracted, if the flight training provided by the IHL is offered under Part 141 provisions the IHL should provide the following documents during any compliance survey. The IHL should not simply refer the surveyor to the contracted training facility for these documents.

Air Agency Certificate (AAC)

– Issued by the Flight Standards District Office (FSDO) of the FAA

– Includes a Letter of Authorization which should provide slightly more detail on the specific programs approved by FAA

– Is typically valid for two years

– Only courses listed on the AAC and Letter of Authorization may be considered for VA approval

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Training Course Outline (TCO)

– There is one TCO for each Part 141 course approved by FSDO

– Define the purpose or objective of the course

– Specify where the training will be conducted and which airports will be used for instruction

– Specify which aircraft or type of aircraft and any flight training devices (FTD) which FSDO approved to be used during any training for the course

– Will either specify the name of the Chief Flight Instructor and Assistant Chief Flight Instructor or outline the required qualifications for the individuals occupying these positions

– Will be specific to an individual flight school (not an “off-the-shelf” product).

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Syllabus

– Similar to the TCO, there will be one syllabus for each Part 141 course approved by FSDO

– It is approved with and accompanies the TCO (the TCO and syllabus could be one document in some cases)

– Could be a creation of the flight school or an “off-the-shelf” type product (Jeppeson)

– It is a lesson-by lesson outline of how the course is to be pursued

– Each lesson specifies the knowledge to be learned, maneuvers to accomplish, procedures to follow for each flight lesson. Should also specify how long (hours) each lesson should take and the total of all training hours

– The ground school section specifies lesson-by-lesson the knowledge to be learned and how long (in hours) each lesson should take. Ground school is not to be confused with preflight briefings or post-flight critiques (pre/post) which are associated with an actual flight lesson.

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Additional flight related documents to review during survey

As well as reviewing the AAC, TCO and syllabus for any Part 141 program, the surveyor should review the following whether for a Part 141 or for a Part 61 program.

• Flight training records for each student included in the survey. These could be a Jeppesen supplied tri-fold training record or the school could devise their own. In any event there should be some type of documentation showing:

– Exact approved name of the course being pursued

– Date of training

– Flight or ground school lesson number

– Duration of training in hours and tenths of hours

– Aircraft flown including make, model, horse power (HP) and tail number (Note: simulators will not have HP or tail number, but instead will have FAA simulator number and simulator level)

– Signature of instructor and student

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Catalogs and Addendums

• Specify the number of flight training hours required in each class required for each degree program, track or concentration offered. See C&L Advisory 223-15-01 dated September 1, 2015, and addendum dated October 7, 2016.

• Ground training hours could be a component of any flight training class required for the degree program and should be listed in the class description for each flight training class

• School should publish costs of tuition and fees for each degree program, track or concentration offered and all students should be charged the same

• No program previously considered “deemed approved” may be considered to be approved for VA educational assistance until the SAA of jurisdiction verifies that those applicable conditions and requirements are met

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• Standards of Progress and Attendance

– Follow the IHL school’s VA approved policy

• Refund policy

– Accredited IHLs would follow CFR 21.4253

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Catalogs and Addendums


Prior Training

• Schools must evaluate and grant credit as appropriate for all prior education and training without regard to the wishes of the veteran

• The FAA 50% and 25% rules with regard to transfer of prior Part 141 training do apply for GI Bill benefits - FAR 141.77(b)

• Pilot schools may grant credit for training given at another FAR Part 141 pilot school but for no more than 50% of the required hours in the syllabus

• Pilot schools may grant credit for training given under FAR Part 61 or for experience based upon an evaluation of the CFI, but for no more than 25% of the required hours in the syllabus

• The request for prior training, evaluation of same, and proper application to the student’s current course must be documented

• All appropriate training transferred must be deducted from the student’s program with the hours of dual and solo flight, ground school shortened proportionately, and cost reduced appropriately

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Restrictions on Enrollment

• VA shall not approve an enrollment in any course for an eligible veteran, which more than 85 percent of the students enrolled in the course are having all or part of their tuition, fees or other charges paid for them by the educational institution or by the VA

• Calculations must be submitted no later than 30 days after the start of the term

• The 85/15 calculations should be based on each program, course or track in the same manner as any other degree program

• May be waived in whole or in part

• See CFR 21.4201 Restrictions on Enrollment. The advisory 223-15-01 dated September 1, 2015, and the addendum to this advisory dated October 7, 2016, as it relates to separate tracks or concentrations within a program of education.

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VETERANS BENEFITS ADMINISTRATION 18

14 CFR 141 14 CFR 6138 CFR 21.4201 38 CFR 21.423338 CFR 21.4252 38 CFR 21.425338 CFR 21.4254 38 CFR 21.4263

38 CFR 21.4235

Compliance and Liaison Advisory 223-15-02 dated December 4, 2015Addendum to C&L Advisory 223-15-01 dated October 7, 2016Advisory: Clarification and Guidance Regarding “Deemed Approved” Programs dated October 28, 2015

Reference

VETERANS BENEFITS ADMINISTRATION 19

GI Bill® is a registered trademark of the United States Department of Veterans Affairs (VA). The absence of the registration symbol ® does not constitute a waiver of VA's trademark rights in that phrase

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