veterans benefits administration june 2013 certifying official 101 for new school certifying...

VETERANS BENEFITS ADMINISTRATION June 2013

Certifying Official 101 For New School Certifying Officials

Michael Jurkowski: Education Liaison RepresentativeVA Regional Processing Office, Buffalo, NY

VETERANS BENEFITS ADMINISTRATION

What is a School Certifying Official?

A School Certifying Official (SCO), sometimes referred to as a Veterans Certifying Official (VCO), is a person at an educational institution or training facility whom VA has delegated the authority to sign enrollment certifications, other certification documents and reports relating to VA Education Benefits. There may be more than one SCO for each institution.

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BASIC TERMINOLOGY• BDN – Benefits Delivery Network• DOD – Department of Defense• ELR – Education Liaison Representative• IHL – Institution of Higher Learning (Degree Granting)• LTS – Long Term Solution (Chapter 33 Processing)• NCD – Non College Degree school (Non-Degree Granting)• NOBE – Notice Of Basic Eligibility (Chapter 1606)• RPO – Regional Processing Office• SAA – State Approving Agency• TIMS – The Image Management System• WEAMS – Web Enabled Approval Management System

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SCO Basic Responsibilities

• Keep VA informed of the enrollment status of veterans and other eligible persons.

• Keep SAA or VA (as appropriate) informed of new programs, changes in programs, institutional changes, etc.

• Apprise supervisors of any internal problems which may effect service to VA students.

• Keep up to date on current VA rules and benefits.• Assist VA students in applying for education benefits.• Maintain records of VA students and make available for

inspection.

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VA Regional Processing Offices

•Connecticut •Delaware •District of Columbia •Maine •Maryland

•Massachusetts •New Hampshire •New Jersey •New York •Pennsylvania

•Rhode Island •Vermont •Virginia •Foreign Schools

The VA has 4 Regional Processing Offices (RPOs) nationwide that process GI Bill claims.The Buffalo RPO is responsible for 12 States, DC and most Foreign Schools.

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Available ResourcesAvailable Resources• VA Education Liaison Representative (ELR) or Education

Compliance Survey Specialist (ECSS) • State Approving Agency (SAA)• www.gibill.va.gov website (Submit A Question)• SCO Handbook and VA-ONCE Handbook (VA-ONCE website

for any updates)• VA Toll-Free numbers:

– SCO Only Hotline: 1-855-225-1159 (don’t give out to students)– Education Center: 1-888-442-4551 (for students)– General VA Info: 1-800-827-1000– VA Debt Management: 1-800-827-0648

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GI Bill WebsiteGI Bill Website

www.gibill.va.govwww.gibill.va.gov

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GI Bill Website (GI Bill Website (www.gibill.va.govwww.gibill.va.gov))

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VETERANS BENEFITS ADMINISTRATION 9


Eligibility & Program Basics

VA Education Benefit Programs

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• Post 9/11 GI Bill (Chapter 33) / Transfer of Entitlement / John D. Fry Scholarship

• MGIB-Active Duty (Chapter 30) • MGIB-Selected Reserve (Chapter 1606)• Reserve Education Assistance Program

(Chapter 1607/REAP)• Dependent’s Educational Assistance (Chapter

35/DEA)• Veterans Retraining Assistance Program (VRAP)• Vocational Rehabilitation & Employment (Chapter

31/VR&E)


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Common Ground • Eligibility is based, for the most part, on length and type of

military service and honorable discharge.• Can’t receive more that 48 months of entitlement under any

combination of VA Education programs.• Programs of study at schools and training establishments

must be approved for VA benefits.• These approvals are done by State Approving Agencies (SAA)

and VA ELRs. • Work Study Program is available for students training at

three-quarter training time or greater.


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Education Benefits may be used for: College courses leading to a degree Business/technical/vocational courses leading to a certificate or

diploma Tests for a license or certification or National Exams Apprenticeship or OJT training Foreign schools (degree program only) Correspondence courses Entrepreneurship courses Flight (need private pilot license first) Accelerated Pay (High Tech programs) Tutorial Assistance (if needed) Tuition Assistance Top-up (Ch30 only)


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EntitlementEntitlement• The number of months and days of full-time benefits an individual

originally receives or has remaining. • Maximum of 36 months for MGIB programs / Post 9/11 GI Bill (CH30

and CH33 may be extended to end of term).• DEA provides 45 months, VR&E affords 48 months.• Maximum of 48 months under any combination of programs

(Example: If a claimant used 36 months under MGIB chapter 30, they may use an additional 12 months of Chapter 1606 or 1607 benefits).

• Entitlement charged based on Training Time (Rate of Pursuit for CH33) and the actual period the student attended (IHL/NCD).

• Entitlement can be transferred under the Post 9/11 GI Bill Transfer of Entitlement (TOE) program.


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Period of Eligibility• “Delimiting Date”: The first day after a claimant's period of

eligibility expires. Benefits are not payable on or after the delimiting date.

• Period of eligibility varies by program.• CH1606, CH1607 and CH35 Delimiting Dates may be

extended to the end of the term.• Delimiting Dates may be extended for a disability that

prevented training.• May be extended for additional active duty periods.


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VA Education Benefit Programs Post-9/11 GI Bill MGIB-AD MGIB-SR REAP VRAP DEA

Minimum Length of Service

90 days active aggregate service

(after 9/10/01) or 30 days continuous if

discharged for disability

2 yr. continuous enlistment (minimum duty varies by service

date, branch, etc.)

6 yr. commitment (after 6/30/85)

90 days active continuous service

(after 9/10/01)

Have Honorable Discharge and not

have eligibility to any other VA Education

Benefit

Not applicable

Maximum # of Months of Benefits

36 36 36 36 12 45

How Payments Are Made

Tuition and Fees: Paid to school

Housing stipend: Paid monthly to student

Books & Supplies: Paid to student at the beginning of the term

Paid to student. Amount of benefit based on Training

Time.


Time.


Time.

Paid to student. Can only receive benefits

for Full-Time Training.


Time.

Duration of BenefitsGenerally 15 years

from last day of active duty

Generally 10 years from last day of active

duty

Ends the day you leave Selected

Reserve

Generally 10 years from the day you

leave the Selected Reserve or the day you leave the IRR .

No Payments after March 31, 2014

Spouse: 10 - 20 years

Child: Ages 18-26

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VA Applications For Education Benefits

• VA Form 22-1990 – Veterans, all chapters• VA Form 22-1990e – Family members receiving transferred

benefits (not dependents)• VA Form 22-1990t – Tutorial assistance• VA Form 22-5490 – Eligible dependents, Fry Scholarship• VA Form 22-1995 – Change of Program/ Change of Place of

Training • VA Form 22-5495 – Eligible Dependent Change of

Program/Change of Place of Training• VONAPP – Online Application for all benefits. Required for the

VRAP benefit

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SCO Duties and Responsibilities

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Reporting / Monitoring Requirements

• Basic forms to use are:– Enrollment Certification (VAF 22-1999)– Notice of Change in Student Status (VAF 22-1999B).

• Must report all enrollments and changes within 30 days. • VA-ONCE is the web based online certification system.• Must monitor unit subjects pursued and certify only those

that apply to the student’s current program.• Must monitor student’s grades to ensure (s)he is making

satisfactory progress and report unsatisfactory progress.• Must monitor student’s conduct and report when student is

suspended/dismissed for unsatisfactory conduct.19


Reporting / Monitoring Requirements

• Must be able to monitor financial aid use by Post 9/11 GI Bill students and be able to identify scholarships, grants, and other aid that a Post 9/11 student receives.

• Must be able to identify mandatory fees and report such fees for Post 9/11 GI Bill students.

• Must ensure that ledgers contain all debits and credits, and that all are clearly identified.

• Must administer and monitor the Yellow Ribbon program at schools that participate.

• Must maintain all records related to the certification, payment and progress of students receiving VA Education Benefits.

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Monitoring and Reporting Changes to Programs

SAA approves programs for all private for profit schools, all non accredited schools, all non registered OJT and Apprenticeship programs, and all original approvals for all schools.

VA approves all changes to accredited public and private not for profit IHLs & NCDs, flight schools, correspondence schools, registered OJT/Apprenticeship facilities, and federal OJT facilities.

Changes include but are not limited to: • New programs and changes in current programs• Changes in tuition and fees• Changes in academic policies and procedures (school catalogs)• Changes of address, phone numbers, certifying officials• Change in the school name• Any other information the SAA or VA requires

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Relationships Within Your InstitutionRelationships Within Your Institution

• Maintain a close relationship with Registrar, Bursar, Financial Aid and any other school entity that can provide the information you need to do your job as a SCO.

• Maintain a close relationship with veteran and dependent students in receipt of benefits such that they are aware of your reporting and monitoring responsibilities and their own responsibilities.

• Establish procedures to monitor attendance of students in receipt of VA Education Benefits to avoid overpayments of benefits.

• Establish procedures such that you are notified of any changes in a student’s enrollment, financial aid, tuition and fees or any other change that would impact their Education Benefits.

• Utilize available resources to assist you in doing your job: such as the VA Work-Study program, campus Veterans Clubs or Organizations, VA Annual Reporting Fees, etc.

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Keep Informed of VA Rules & PoliciesKeep Informed of VA Rules & Policies

• Give e-mail address to ELR to be included on mailing list.

• Download and review the School Certifying Official’s Handbook.

• Download and review the VA-ONCE online Guide.• Review the information on the www.gibill.va.gov and

the www.va.gov websites.• Attend VA and SAA training opportunities.• Enroll in VA on-line training.

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Maintain Student VA Records & Make Available to VA & SAA

• Retain file of VA papers submitted & records of academic progress, program pursuit, tuition & fee debits/credits, wages paid for Apprenticeship/OJT, etc.

• Maintain records for at least three years following the student’s last date of attendance.

• Ensure that your records are kept in a safe place and that the privacy of your VA students is protected.

• Make available all school records (VA & non-VA) to representatives of the SAA and VA when requested for a Compliance Survey.

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What Records Should You MaintainWhat Records Should You Maintain• Copies of VA paperwork & certifications that you submit.• Your school’s transcript, grade reports, tuition payment/refund records, records

of tuition & fee payments from other sources (& full identification of those sources on a detailed payment ledger), drop slips, registration slips (for those courses dropped during drop/add), transcripts from previous schools with evaluations of same, student’s school application, records of disciplinary action, program outline (to track proper courses taken), enrollment agreement, degree audits, etc.

• For NCD schools must include monthly attendance reports including first and last day attended, copies of documentation for excused absences, class schedules, etc.

• For Apprenticeship/OJT: wages paid, hours works, training completed, etc.• For Flight Schools: type of training completed and hours of training, costs of

training, etc.

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Provide Assistant to VA StudentsProvide Assistant to VA Students

• Refer students to the GI Bill Website www.gibill.va.gov for information VA Education Programs and Applications for Benefits (VONAPP).

• Provide student with contact information for VA:– GI Bill information 1-888-442-4551– VA General Information 1-800-827-1000– www.gibill.va.gov “Submit A Question” link to ask a question.

• Assist students in filling out applications for benefits when possible.• Strongly encourage students to read and maintain all correspondence that they

receive from the VA (*Please be aware that we don’t send Award Letters to schools).

• Disseminate and/or post information on VA education benefits and programs, and contact points.

• Ensure that VA students are aware of their responsibilities to the school and VA.• Maintain a relationship with VA students such that they keep you informed of any

changes they make.

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New VA Students: What To Do?Please Note: The following discussion points are not all-inclusive. For detailed information, review School Officials’ Handbook or contact ELR

•Provide VA students with a copy of approved attendance, academic, and disciplinary policies (Catalog, handbook, or copies of policies).•Insure student aware of requirements that may be unique to VA benefits:

– Federal VA benefits are not the same as other federal aid - including Title IV – Fulltime by school or Title IV standards might not translate to fulltime for VA

standards or payments– Schools are required to inform VA of changes in enrollment or of

unsatisfactory progress under approved policies for attendance, academics, and discipline

– Reduction in, or withdrawal from, hours certified for benefits could result in a VA student debt to VA (*** Debts under the Post 9/11 GI Bill can be very large and past due debts can adversely impact a student’s credit rating ***).

•Inform the student of any school policies in place, such as reporting to the SCO periodically to verify continued enrollment or reenrollment.

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Certifying Enrollments For VA Students

• VA Students must be pursuing an approved program of study at your school. They are unable to “just take courses.” However students may take elective courses provided those courses are part of their program of study.

• Insure that “visiting” or “transient” VA students provide you with a copy of permission from their primary school to take (specified) courses at your school before you certify. You should report to the VA that these courses will apply to their degree program at their primary school.

• If a student is concurrently enrolled/certified at two approved schools, even different branches of the same school, only one school can certify as primary school. The other school certifies as secondary (transient, guest, or visiting school). For the most part, a student can only receive payment for one program of study at a time.

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Certifying Enrollments For VA Students

• Certify only courses required for graduation in the student’s approved program of study. Courses must not have been previously satisfied by transfer credit, military credit, or already taken/passed according to current program standards. (Students may in some instances repeat a course if that course is a requirement for graduation and they need a higher grade to graduate.)

• Certify each semester or accelerated term (module, half term, mini term, etc.) individually, from the first day of classes through the last day of the term. VA issues payment based on the actual beginning and ending dates of each term.

– Schools approved on semester/quarter hour basis enter semester hours for given term.– School approved for clock hour programs enter clock hours per week of attendance

according to student class schedule for the certified term or program.

• For Post 9/11 students, certify net tuition and any mandatory fees. Subtract out any tuition-specific scholarship, discount, other tuition aid (except for Title IV funds such as a Pell Grant) from the reported tuition and fees.

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Monitoring VA Student Enrollments and Reporting Changes

• Monitor VA student enrollments on a regular basis to enable submission of payment-related changes within 30 days after the effective date.

• Submit changes to VA via VA-ONCE or VA Form 22-1999b.

• Examples of Changes to report: – Failure to meet academic, attendance, disciplinary policies– Voluntary or involuntary withdrawal from school during a term– Failure to start a term already certified– Leave of absence (clock hour programs). – Military leave (document in student file)– Class schedule changes or drops resulting in reduction in/lower number of hours certified

(semester, quarter, or clock hour programs)– Academic probation (document in student VA file).

• Document in student VA file all information to support the reported change.

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VA Education Benefit Payments

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Basics Of VA Education Benefit Payments

• For all Non-Chapter 33 programs, payments are made directly to students based on their eligibility, Training Time and enrollment period.

• Payments for Apprenticeship or On-The-Job Training programs are made to trainees based on eligibility, length of training program and what “step” they are in the training program.

• Correspondence and Flight Training payments are made to students based on eligibility and approved cost of program.

• Chapter 33 students can receive payment for Tuition and Fees (paid to school), Books and Supplies, and a Monthly Housing Allowance.

• Some Chapter 33 students may also be eligible for “Yellow Ribbon” payments.

• Eligible students may also receive additional payments for a College Fund “Kicker” or “Buy-Up.”

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Training Time Measurement Non-Chapter 33 Programs

Training Time will determine the rate of payment and entitlement charge for Non-Chapter 33 Programs

•Undergraduate training is normally measured by VA as 12 semester or quarter hours = Full Time during a standard term.•Graduate students are normally measured by VA based upon the training time certified by the school

Will accept school’s certification as to the number of credits required by a graduate student to be full-time during standard term

If the term is of non-standard length, the VA computes “equivalent credit hours.” Payment is then based on which method gives the higher training time (the same for undergraduate courses as part of a graduate program).

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TRAINING TIME EQUIVALENCY TABLE – FULL TIME = 12 OR MORE SEMESTER HOURS

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Semester 15 Hrs.Per to19 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Term 12 or more FT FT FT FT FT FT FT FT FT FT FT FT FT FT FT 11 3/4 FT FT FT FT FT FT FT FT FT FT FT FT FT FT 10 3/4 FT FT FT FT FT FT FT FT FT FT FT FT FT FT 9 3/4 3/4 FT FT FT FT FT FT FT FT FT FT FT FT FT 8 1/2 3/4 3/4 FT FT FT FT FT FT FT FT FT FT FT FT 7 1/2 3/4 3/4 3/4 3/4 FT FT FT FT FT FT FT FT FT FT 6 1/2 1/2 1/2 3/4 3/4 3/4 FT FT FT FT FT FT FT FT FT 5 -1/2 1/2 1/2 1/2 1/2 3/4 3/4 3/4 FT FT FT FT FT FT FT 4 -1/2 -1/2 -1/2 1/2 1/2 1/2 1/2 3/4 3/4 FT FT FT FT FT FT 3 1/4 1/4 -1/2 -1/2 -1/2 -1/2 1/2 1/2 1/2 3/4 3/4 FT FT FT FT 2 1/4 1/4 1/4 1/4 1/4 1/4 -1/2 -1/2 -1/2 1/2 1/2 3/4 FT FT FT 1 1/4 1/4 1/4 1/4 1/4 1/4 1/4 1/4 1/4 1/4 1/4 -1/2 1/2 3/4 FT

Number of Weeks Per Term

USING THE TABLE: In determining whole weeks in the course, disregard fractions of 3 days or less and consider fraction of 4 days or more as a full week. Determine training time by reading across the credit hour line to the number of weeks per term column. EXAMPLE: 5 semester hours in 10 weeks is 3/4 time. (This is the same result obtained from using the formula specified in 38 CFR 21.4272(g): 5 X 18 = 90 divided by 10 = 9 sem. hrs. which is 3/4 training.)


TRAINING TIME EQUIVALENCY TABLE – FULL TIME = 12 OR MORE QUARTER HOURS

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USING THE TABLE: In determining whole weeks in the course, disregard fractions of 3 days or less and consider fraction of 4 days or more as a full week. Determine training time by reading across the credit hour line to the number of weeks per term column.

Number of Weeks Per Term Quarter 10 Hrs.Per to13 9 8 7 6 5 4 3 2 1

Term

12 or more FT FT FT FT FT FT FT FT FT FT 11 3/4 FT FT FT FT FT FT FT FT FT 10 3/4 FT FT FT FT FT FT FT FT FT 9 3/4 FT FT FT FT FT FT FT FT FT 8 1/2 3/4 FT FT FT FT FT FT FT FT 7 1/2 3/4 3/4 FT FT FT FT FT FT FT 6 1/2 1/2 3/4 3/4 FT FT FT FT FT FT 5 -1/2 1/2 1/2 1/2 3/4 FT FT FT FT FT 4 -1/2 -1/2 1/2 1/2 1/2 3/4 FT FT FT FT 3 1/4 -1/2 -1/2 -1/2 1/2 1/2 3/4 FT FT FT 2 1/4 1/4 1/4 1/4 -1/2 -1/2 1/2 1/2 FT FT 1 1/4 1/4 1/4 1/4 1/4 1/4 1/4 -1/2 1/2 FT


Basics Of Post 9/11 GI Bill PaymentsThere are 3 primary payments under the Post 9/11 GI Bill (Chapter 33)

– Net Tuition and Fees (and Yellow Ribbon) paid to the school*• Private Schools and Non-Degree Schools have an Annual Cap (adjusted each

school year, Aug. 1st to July 31st) • Public School will receive In-State Tuition and Fees.

– Books and Supplies Payment paid to the student*• Books and Supplies is a maximum of $1000 per school year.

– Monthly Housing Allowance paid to the student• Payment issued at the end of each month of attendance. • Monthly Housing Allowance (MHA) is based on school location, Rate of

Pursuit (ROP), and type of training (Distance or In-Residence). Active duty students and TOE spouses of active duty members not eligible for MHA.

* Tuition and Fees payments and Books and Supplies payments will be released no sooner than 14 days prior to the beginning of the term.

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Basics Of Post 9/11 GI Bill Payments

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• Payments under Chapter 33 are prorated based on a student’s eligibility level. • The eligibility level is determined based on Aggregate length of credible active duty

after September 10, 2001:


Basics Of Post 9/11 GI Bill PaymentsEffective Oct. 1, 2011, the Post 9/11 GI Bill was expanded to include the following types of training (all payments prorated for eligibility level):

•Non-degree schools (NCD)– Net Tuition and Mandatory Fees up to the Annual Cap, paid to school – Entitlement charge is based on tuition and fees paid each school year– Monthly Housing Allowance paid to student– Books and Supplies paid to student based on length of term ($83.33 per full month)

•Vocational Flight Training– The actual net costs not to exceed Annual Cap of $10,330.00 – Entitlement charged based on amount of Cap paid

•Correspondence Training– The actual net costs not to exceed Annual Cap of $8780.50 – Entitlement charged based on amount of Cap paid

•Apprenticeship and On-The-Job (OJT) Training– Monthly Housing Allowance based on “Step” – Books and Supplies Payment maximum of $1000 per year ($83.33 per full month)

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Payments To Schools*•Net Tuition and Mandatory Fees capped at $18,077.50 per year (2012-13) for Private Schools and all Non-Degree Schools (subject to the student’s Eligibility Level). The Cap will be paid first until it has exhausted.

•All net In-State Tuition and Mandatory Fees paid at Public School (subject to the student’s Eligibility Level).

•Yellow Ribbon payment for student’s eligible at the 100% level may also be paid at eligible schools. Will pay up to 50% of the unmet net charges, not to exceed what the school pays. Non-degree schools not eligible for Yellow Ribbon.

•“Restored Rates” (Grandfather) tuition and fees payments for some students at Private Schools.

*VA will only pay what a student is entitled to receive and that payment may not always be what the student was charged by the school.



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Payments To Schools – “Net Charges”

•VA will pay the actual net cost for tuition and fees charged per term.

• The net cost can only be charged (and reported to VA) after an assessment has been made by the school, identifying any and all waivers, scholarships, grants or other benefits that would cause a reduction in tuition and fees for the student during the term being certified.

• This includes any scholarship(s), or other Federal, State, institutional or employer-based aid or assistance (other than loans and any funds provided under section 401(b) of the Higher Education Act of 1965 (Title IV)) that is provided to the institution and is specifically designated for the sole purpose of defraying tuition and fees.


Basics Of Post 9/11 GI Bill PaymentsExample Of How Monthly Housing Allowance (MHA) Will Be Determined:

•Rate of Pursuit (ROP) determines how much entitlement is charged per month and how much, if any, housing allowance will be paid. MHA will only be paid when ROP is greater than 50%.

•ROP is the measure of training time obtained by dividing the number of credit hours (or clock hour equivalent) a student is enrolled in by the number of credit hours (or clock hour equivalent) considered to be full-time at the school (or what is considered Graduate Full-Time). The resulting percentage (rounded to the nearest hundredth) will be the individual’s Rate of Pursuit.

•Greater than 50% ROP would normally be 7 or more credits taken during a standard semester (15-19 weeks) or standard quarter (10-13 weeks)

• Example:– Student is taking 7 credits for a standard semester– ROP = 7 / 12 = .58 or 58%– For MHA payment, this will be rounded to 60% of the BAH (E-5 with dependents rate) and if the

student is less than 100% Elig. Level, it will also be adjusted based on the eligibility percentage.

• For Non-Standard term (or summer session), VA will calculate Equivalent Credit Hours (ECH) and use that to determine Rate of Pursuit.

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• Independent Study courses, also called Distance Learning or Online Learning, are courses that are offered without any regularly scheduled conventional or laboratory sessions or with a limited number of class or laboratory sessions (“Hybrid” course).

• Independent study courses must be accredited and either lead to1. a standard college degree or 2. a certificate that reflects educational attainment offered by an Institution

of Higher Learning (IHL).

• Non-accredited schools cannot certify distance learning/independent study courses. Courses offered in whole or in part by independent study cannot be approved at non-accredited schools.

• Remedial/deficiency courses offered by Independent Study (Distance Learning or Online) cannot be approved.

• Post 9/11 GI Bill students taking only Independent Study (Distance or Online Learning) courses will be paid a lower Monthly Housing Allowance (maximum of $648.00 per month for Full-Time training).

Independent Study(Distance Learning / Online Study)

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Independent Studyvs In-Residence vs Hybrid

Undergraduate Resident Training

• Must have regularly scheduled classes & meet at least once every 2 weeks

• Total hrs of instruction (based on 50 minutes per hour) must >/= the # of credits awarded multiplied by the number of weeks in a term

– 3cr over 16 week = 48 total hours in class*– 3cr over 5 week = 15 total hours in class* *And must meet at least once every 2 weeks

• ““In class”In class” does not mean the student is in class working independently at his or her own pace with a teacher in the room to answer questions.

Graduate Resident Training

• Consists of 2 regularly scheduled standard classes per term, research (on or off campus), or a combination of both.

Independent Study, Online, Distance Ed

• These are all treated the same by VA• Interaction between the student and the

instructor (who is physically separated from the student) through the use of communications technology instead of regularly scheduled, conventional classroom or laboratory sessions.

• Communications technology includes (but is not limited to):– Open Circuit TV– Computer technology– Wireless communication devices

• Any course, including “hybrid” or “blended "that does not meet the requirements for Resident Training is considered Independent Study.

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VETERANS BENEFITS ADMINISTRATION44

Post 9/11 GI Bill Payments to Schools Post 9/11 GI Bill Payments to Schools and and

Debt IssuesDebt Issues


Factors Impacting Payment Of Tuition and Fees Under The Post 9/11 GI Bill

The amount of Tuition and Fees that VA will pay for each term under the Post 9/11 GI Bill depends on many factors, such as:

– What was actually certified by the school about the term (begin date, end date, tuition and fees, credits, etc.)

– What the student’s Eligibility Level is on the first day of the term and what the student’s Eligibility Date is

– How much entitlement does the student have remaining when the term began – How much of the Private School Annual Cap (or prorated Cap) is remaining– Is the student eligible for “Restored Rates”– Did the net tuition and fees change during the term– Were enrollments and any changes accurately reported to VA– Is the student eligible for “Yellow Ribbon”– Did the student make any changes in enrollment during the term

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What Creates School Debt

Never return money to the VA unless specifically requested to do so by VA

1. The student did not attend any classes certified for the enrollment period.

2. The student was not enrolled in your school, but your school was paid by VA.

3. The student withdrew from all classes or terminated enrollment on or before the first day of the certified enrollment period (if the student reduces, the debt is a student debt).

4. VA sent duplicate payments for the enrollment period.

5. The school submitted an amended enrollment only showing a reduction in tuition and fee charges or a reduction in Yellow Ribbon amount, or both.

6. VA paid more than the amount reported on the certified enrollment or more than the student was entitled to receive.*

7. The student died before the term started or during the term.


School Debts - ExamplesExamples of instances when a School Debt could be created:

•The student is certified and paid for that term and then does not attend any classes for that certified term (or summer session) and the student is terminated (VA-ONCE Termination of student before term began).

•The Student is paid at a higher eligibility level than they are entitled to receive for a term and then at a later date the student is determined to be eligible at a lower level (conversely, a student paid at a lower eligibility level who is, at a later date, determined to be eligible at a higher level, would have an additional payment(s) issued by VA. **It should be noted that the school will not receive any notification of these actions in most cases other than the payment, payment report and debt letter.)

•A reduction in tuition and fees is reported (“Amend” in VA-ONCE) to VA for a term already paid. (If the reduction in tuition and fees is associated with a change in hours, then the debt would be student debt).

•The student is paid more than they were entitled to receive for a term. For example: A Compliance Survey finds that an inappropriate fee was certified and paid for a term and VA makes a correction to the award to remove that fee.


Changes To Enrollments

• Report all reductions and increases, even if the Tuition and Fees remain the same. Under Chapter 33, all changes to credit hours have the potential of impacting payment.

• For a complete withdrawal, the Tuition and Fees payment will be prorated based on the length of time the student attended. The fact the school refunded money has no bearing on the VA payment. VA will pay for the time attended.

• For a reduction or an increase, the school should report the Tuition and Fees for the new credits as if those were the number of credits the student originally enrolled in. Don’t factor in any refunds or current balance due. The payment that is due the student (or overpayment created) will be based on the time spent at each number of credits and the cost associated with those credits.


Changes To Enrollments • For a student who attends a term and then withdraws, reduces or increases after the first

day of the term; the adjustment to the Tuition and Fees will be pro-rated based on the length of time attended.

• For a complete withdrawal, the VA will determine the length of time that a student attended as a percentage of the total length of the term (based on 30 day months) and this percentage of time attended will determine the amount of the Tuition and Fees that the student will be entitled to receive.

• For a reduction or increase, when the effective date of the change is after the term began, the Tuition and Fees payment the student is entitled to receive will be:

– prorated based on the number of days that the student was enrolled in original number of hours certed and the cost of those hours and the number of days the student was enrolled in the reduced or increased hours and the cost of those hours.

– The end of the month/term rule will apply (This means that for VA payment purposes

only, the reduction will be effective the first day of the month following the reduction or the end of the term, whichever comes first).



• Example of a complete withdrawal (Terminate) and subsequent overpayment:

Term runs from 8/27/2012 to 12/18/2012 and the Tuition and Fees payment was $10,000. The student withdraws from all courses on 10/02/2012 (LDA).

• Total length of the term (based on 30 day months) = 112 days• Total days attended (8/27/2012 to 10/02/2012) = 36 days• Percentage of term attended = 36/112 = 32%

• Amount student is due for period attended = $10,000 x 32% = $3200

• Overpayment to student = $6800

• No overpayment of Books and Supplies if the student attends any part of the term

• Monthly Housing Allowance will terminate effective Last Date of Attendance



• Example of a reduction that occurs during the term and the subsequent overpayment:

• Term is: 8/27/2012 to 12/18/2012 for 12 credits• Reduction from 12 to 6 credits effective 11/21/2012• Using the End of Month/Term Rule, the reduction is effective 12/01/2012• Tuition and Fees for 12 credits is $3000.00 and tuition and fees for 6 credits is $1500.00 • Total length of the term (based on 30 day months) = 112 days_______________________

Number of days enrolled for 12 credits = 94 days (8/27/2012 to 11/30/2012)Percentage of term at 12 credits = 94/ 112 = 84%Percentage of $3000.00 tuition and fees for 12 credits due = $3000.00 X 84% = $2520.00

Number of days enrolled for 6 credits = 18 days (12/01/2012 to 12/18/2012)Percentage of term at 6 credits = 18 / 112 = 16 %Percentage of $1500.00 tuition and fees for 6 credits due = $1500.00 X 16% = $240.00

_____________________________

• Add $2520 + $240 = $2760.00 is the new amount the student is entitled to receive for this term based on the reduction from 12 to 6 credits. Overpayment on the student will be $240.00 ($3000.00 paid for 12 credits minus the $2760.00 that student is due as a result of the reduction to 6 credits on 11/21/2012).



When tuition and fees have been paid for multiple terms and then a termination occurs, you may have a situation where both the student and school will be charged an overpayment.

Begin End Crs. Tuition &Fees 05/15/2013 06/16/2013 3 $650.00 06/18/2013 07/20/2013 3 $650.00 07/25/2013 08/16/2013 3 $650.00

In this example, the VA paid the school $1950.00 for the three summer sessions. Student then withdraws from school on 06/28/2013 (LDA) and doesn’t return.

Student is responsible for overpayment of T&F for the period from 06/29/2013 to 07/20/2013; which will be 67% of T&F for that session or $435.50. Student is only entitled to payment for time attended during that second session. Since the student completed the first session, student was entitled to all the T&F paid for that session.

School will be responsible for overpayment of $650.00 in T&F paid for the third session (07/25/2013 to 08/16/2013) since student withdrew prior to beginning of that session.


Benefits Overpayment

• With CH33, overpayments tend to be far more complex and much larger than with other benefit types.

• Responsibility (either student or school) for the overpayment will depend upon the circumstances that caused the overpayment and how the claim was processed by VA (Overpayment of TOE benefits can be collected from both the student and the veteran/serviceperson who transferred the entitlement).

• Report all changes as soon as possible to the VA to avoid unnecessary overpayment of the Monthly Housing Allowance.

• If a student attends and then reduces or withdraws, the Books and Supplies payment will not have to be repaid (If the student did not attend or reduced before the beginning of the term, the Books and Supplies payment, if paid, will have to be repaid).

• VA will not pay a Private School more than $18,077.50 Annual Cap (or the prorated amount based on the student’s Elig. Level) during any School Year.


VA Paid School Too Much – First Steps

• Check with the VA Certifying Official at the school to see what was certified to the VA and that the enrollment information sent to VA was correct and current.

• VA will pay based on the information that is received from the school. If what VA has paid (adjusted for Eligibility Level) matches what has been reported by the school on the enrollment certification, there is no overpayment by the VA at this point: since VA has paid what the school has reported.

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VA Paid School Too Much – First Steps (cont.)

• Check to see if the student’s enrollment has changed from what was originally certified to the VA.

• If there have been changes to the student’s enrollment, check to see if those changes were reported to the VA and the information regarding those changes (such as changed credit hours, new tuition and fees and effective date of a reduction or termination) was accurately reported to the VA.

• If the information regarding any change wasn’t reported to the VA, the VA Certifying Official should submit an Amended or Adjusted certification to show the change in the student’s enrollment or tuition and fees charged.

• If the VA Certifying Official has reported the necessary changes to the student’s enrollment, check to see when that Adjustment of Amendment was sent to the VA. It may take some days for the VA to process the change in the enrollment, create the overpayment and send notification.

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VA Paid School Too Much – First Steps (cont.)

• Once VA does process the change(s) to the enrollment, VA will send a letter to the school explaining the overpayment if the debt was set up on the school.

• You should wait for the letter from VA Debt Management before returning any money to the VA. If you return money to the VA before the overpayment is set up in VA’s system, it may be returned to the school. (Please be aware that if the VA processes the changes to the enrollment and creates a debt on the student; the school will not be notified of this; schools are only notified when school debt is created).

• If you have sent the changes to the enrollment and have waited several weeks and still have not received an overpayment letter from the VA; review the circumstances that created the overpayment to ensure that the debt was actually school debt and not student debt. If it is legitimate school debt, then contact the ELR to check on the status of the debt.

• You may also want to contact the student to see if they received a debt letter from VA as a result of the changes to enrollment reported.

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When The VA Pays Too Little Or Pays Nothing

• There may be instances when the payment you receive from the VA may be less than what you were expecting. In most instances there will be a legitimate reason why the VA paid less than what was expected (most payments made by the Chapter 33 system have been automated to pay what is certified on the VA-ONCE certification based on what the student is entitled to receive for the term being paid).

• In those cases where you do receive a payment that is less than what you expected to receive, you should once again check with the VA Certifying Official to ensure that all Enrollment Certifications and Changes to Enrollments have been submitted to VA and that the information on the certifications are correct.

• If the all the necessary information has been sent to the VA and the VA has had enough time to process all the enrollment information; then you should consider other issues that may have impacted the payment.

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Most underpayments are caused by one or more of the below:

•The student’s Eligibility Level may have changed. The student may have originally been informed that they were eligible at a higher level than they should have been.

– For example, a student is issued a COE showing 100% eligibility and the school certifies based on that but when the award is processed, VA notices that some of the active duty service the student had was not qualifying for Chapter 33 eligibility. VA would notify the student of this reduction in their Eligibility Level in the Award Letter we send. However, the VA would not notify the school.

•The student did not become eligible for Chapter 33 until after the term began. In this case the payment would also be prorated from the date of eligibility.•The student has exhausted their Private School Annual Cap. VA will not notify the school when the Annual Cap is exhausted. Only the student will receive an award letter showing the amount used and remaining under the Annual Cap.


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• The student may be receiving benefits under a program other than Chapter 33, such as the MGIB Chapter 30 program for part or all of the term. Only Chapter 33 will provide payments to schools. All the other benefit programs pay the student a monthly stipend.

• The student may have exhausted all their Chapter 33 entitlement and therefore the tuition and fees payment for the term was prorated. For example, if a student only had 2 months of entitlement remaining and the term was 4 months long, VA would prorate the payment to only pay 50% of the tuition and fees (or a lesser amount for someone eligible as less than 100%).

• A student may have reduced their hours or withdrawn completely and then the school submits the Enrollment Certification and Change to Enrollment, showing the reduction or termination. In this case, VA would only pay for the period the student attended, even if the student wasn’t due a refund by the school.

• A change in the student’s enrollment was reported with an effective date that is during the term. Changes to enrollments (such as a reduction or termination) that occur during the term will cause the VA payment to be prorated (or if there is an overpayment, the overpayment will be prorated as well).


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Contact Information• For Students:

Toll free: 1-888-442-4551 for Education QuestionsToll free: 1-800-827-1000 for other VA questionsSubmit a Question via www.gibill.va.gov

• For School VA Certifying Officials only: Local Education Liaison Representative (ELR)

Certification, regulatory requirements, VAONCE assistanceHardship cases (i.e. certified student has no payment or communication from VA and has exhausted other contact resources)

• National Hotline for School Certifying Officials 1-888-225-1159General questions on student eligibility, claim status, payment status

Allow a passage of time before making an inquiry re: a 1999

• Schools may establish account/make inquiry direct to the Buffalo RPO via www.gibill.va.gov “Submit A Question”.

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QUESTIONS?

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