veterans benefits administration flight training aveco july 2015
TRANSCRIPT
VETERANS BENEFITS ADMINISTRATION
Flight Training
AVECO July 2015
VETERANS BENEFITS ADMINISTRATION
Flight Training
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Overview• Aviation programs at Institutions of Higher Learning (IHL)
• Deemed Approved versus Non-Deemed Approved degrees
• Contracted versus “In-House” flight training
• FAA Approval (Part 141 and Part 61)
• Training Course Outline
• Certifications, billing, and documentation
• 85/15 Regulations (CFR 21.4201)
VETERANS BENEFITS ADMINISTRATION
Aviation Programs at IHL’s
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• Changes effective August 1, 2011 (PL111-37)
• VA Central Office Education Service directive to conduct Compliance Surveys
at Public IHL’s with aviation programs in April and May 2015
• Flight training is not approved for non-college degree programs (certificates
and diplomas)
VETERANS BENEFITS ADMINISTRATION
Deemed Approved versus Non-Deemed Approved
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“Deemed Approved”: Public and private non-profit accredited institutions
Non “Deemed Approved”: Proprietary Profit institutions
• SAA approval is required for degree programs with a component of flight/aviation:If a school does not have “deemed approved” programsIf a school with “deemed approved” programs utilizes services from a vocational flight school, i.e., “under contract”
• SAA Approval is not required: If a school with “deemed approved” programs is approved by the FAA
under Part 141 or Part 61 and utilizes its own flight line, instructors, Training Course Outline (TCO)
VETERANS BENEFITS ADMINISTRATION
Contracted versus “In-House” flight training
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IHL’s with Degree Programs Under Contract
• If a school does not have its own flight line and must contract with a Part 141 flight school to provide flight training, then the flight school must be approved as a separate facility by the SAA with jurisdiction over flight schools
• Documents needed for approval: - Copy of contract- Copy of flight school’s Air Agency Certificate- Copy TCO for each course offered as part of the degree- Other documents as required by SAA
• If at any time an IHL changes its contract from one contractor to another, the IHL must notify the SAA immediately for the updated approval of its flight degree program
• Part 61 training cannot be contracted
VETERANS BENEFITS ADMINISTRATION
FAA Approval
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Air Agency Certificate• Issued by the Flight Standards District Office (FSDO)• Includes a Letter of Authorization• Is valid for two (2) years• Specifies all the courses that the school is authorized to offer under FAR Part
141 (TCO)• Only courses listed on the Air Agency Certificate and Letter of Authorization
may be considered for approval• If the flight school wishes to obtain approval of a course not currently listed in
these documents, the FSDO must approve and revise the Air Agency Certificate
VETERANS BENEFITS ADMINISTRATION
Training Course Outline
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Training Course Outline (TCO)
• Description of rating
• Specific aircraft and Flight Training Devices (FTDs – mockups of airplane
cockpits with varying degrees of complexity) that may be used for the course
by make and model
• Restrictions on use of FTD (limited hours and for which specific flight lessons
may be used)
• Airports that may be used in training
• Name of Chief and Assistant Chief Flight Instructor
VETERANS BENEFITS ADMINISTRATION
Training Course Outline Continued
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• Each Part 141 course approved by the FSDO
• It is approved with and accompanies the TCO
• It is a lesson-by-lesson outline of how the course is to be pursued
• 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 and post-flight
critiques (pre/post) which are always associated with actual flight lessons
* Pre/post is rarely ever enumerated in Part 141 syllabi and minimum hours are
usually listed “as needed”
VETERANS BENEFITS ADMINISTRATION
Certifications, billing, and documentation
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• SCO certifies course credits, tuition, and fees• IHLS can only certify tuition and fees that are charged to the student by the
institution (flight fees cannot be paid to contracted school by the students)• Flight fee limitations:
Least expensive aircraft must be utilized except where required by thecourse syllabus or the FAA
Minimum hours required in course syllabus are the maximum allowed for VA students
All training must be completed by end of term, with exceptions defined and listed (If Incompletes “I”s are assigned, school Incomplete policy must be followed)
FAA check ride costs cannot be included in the certification of fees
VETERANS BENEFITS ADMINISTRATION
Certifications, billing, and documentation
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Certification of aviation courses
• Enter term dates (these should be in most cases the same as for all other
students)
• Enter credit hours just the same as non-flight degree students
• Enter total charges up to TCO requirements
• Public schools enter only the in-state rate
• Private schools enter the actual total charges (there should be no state
differential)
VETERANS BENEFITS ADMINISTRATION
Certifications, billing, and documentation
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Documentation- what the SCO should have on file
1. Training Course Outline (TCO)• For every flight lab, are there pre-requisites?• What courses are required for the degree?
2. Valid FAA Air Agency Certificate
3. Account statement• Actual flight charges for minimum requirements (based on TCO)• Are there discounts?
4. Flight Log• Showing actual charges and flight time/instruction for each student
VETERANS BENEFITS ADMINISTRATION
85/15
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• Determine if the degree program has more than one “track”
• Tracks, as referenced here, should not be confused with majors, minors, and
concentrations, although the ratio is calculated separately for those as well
• Calculate ratio separately for each “track”, major, or concentration
• VA (85%) portion of ratio includes VA students and any students receiving a grant,
waiver, discount, scholarship, etc., directly from the school and which has rules that
have the effect of excluding VA students (regardless of whether or not they are
receiving GI Bill® benefits) from receiving that school assistance
• Non-VA (15%) portion of ratio includes all other students registered for that term
• You must calculate the ratio before certifying a VA student in the program
VETERANS BENEFITS ADMINISTRATION
Findings of Compliance Surveys 2015
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• Violations of 85/15
• IHL’s not calculating and tracking 85/15 by term and major/track
• Charging over TCO minimum requirements
• Lack of communication between SCO and Aviation Department or Contracted
Flight School
• No supporting documentation maintained by SCO when certifying charges
• Contracted Flight training not approved
VETERANS BENEFITS ADMINISTRATION
Summary
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• SCOs should be in contact with ELR & SAA for technical assistance on
certifying flight training
• SCOs must have access to flight records
• Schools should review the communication and work flow process between
SCOs and Aviation program
• Minimum requirements must be published by schools
VETERANS BENEFITS ADMINISTRATION 15
Questions?