veterans benefits administration ncacva school certifying official conference measurement and pay...

VETERANS BENEFITS ADMINISTRATION

NCACVA School Certifying official Conference

Measurement and Pay IssuesNon college Degree (NCD) Programs

Jodie BalderEducation Liaison Representative

US Dept. of Veterans Affairs

October 13, 2015


85/15 RatioWhat is it?

The law prohibits paying benefits to students enrolled in a course when more than 85% of the students enrolled in the course are having all or part of their T&F paid by the

school or VA (referred to as VA students)

• If the ratio of VA students to non-VA students exceeds 85% at the time a VA student enters or reenters (after a break in enrollment) the student is not entitled to VA benefits.

• The ratio for each separately approved program must be computed individually

• The ratio for programs at each separately approved branches must be computed individually (not combined with main campus)

• These requirements do not apply to students under:– CH35 (Dependents & Survivors Educational Assistance Program – DEA) or, – CH31 (Vocational Rehabilitation) students– IMPORTANT: You must still count CH35 and CH31 students as VA students when computing

the 85/15 ratio

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85/15 RatioHow do you Calculate it?

The calculation is a comparison between the total number of students enrolled VS those receiving VA or School funding

Example: There are 20 total students enrolled in a Barber program18 of them receive VA or School funding 2 do not receive VA or school funding 18/20 = .9 or 90%

• In this example the program would be suspended because the 85/15% ratio has been exceeded

• No new VA students (other than CH35 or CH31) can be certified in that program

• Currently enrolled students can remain certified and in receipt of VA educational assistance unless they have a break in enrollment (such as an LOA)

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85/15 RatioWhat Happens if it is Exceeded?

• If it is found on a Compliance Survey, SAA Visit, Liaison Visit, through your own record keeping or by any means that you have a program that has exceeded the 85/15 ratio or is on the cusp of exceeding it:

– Your program will be suspended if the ratio was exceed and you cannot certify any new VA students (other than CH35 or CH31) in that program

– Currently enrolled students can remain certified and in receipt of VA educational assistance unless they have a break in enrollment (such as an LOA)

– You will be required to submit 85/15 ratio calculations every quarter to the ELR and SAA (and possibly supporting documentation as well)

– At the start of the next quarter if the calculations show that your program is no longer in violation of 85/15 you can once again begin enrolling and certifying VA students

• NOT retroactively!• If the VA student enrolled and started training while the program was suspended

NO VA benefits are payable

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85/15 Ratio 35% WaiverWhat is it?

The 35% waiver only waives the reporting requirement NOT the calculation or prohibition to exceeding 85/15

– If the school certifies that 35% or less of TOTAL student enrollment in the SCHOOL receives VA or school funding the requirement to report every quarter can be waived

– Can be a full or partial waiver (ie may be granted to specific programs only)

– Required only once and if granted, remains in effect unless the percentage exceeds 35%• In which case the school must then compute the 85/15 ratio for all programs and submit to VA

– IMPORTANT! Does not remove the requirement for the school to monitor and calculate the 85/15 % ratio for all programs

• If at any time, after you have been granted a 35% waiver, you find a program that is about to exceed or has exceeded or the 85/15 ratio you must:

– Notify the ELR– Not certify any new VA students in that program

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Questions

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Pre-Certification

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

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

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

– You can see in VA Once if a student was previously certified to VA by another school - must request those transcripts even if the student didn’t list the training

• Schools must evaluate that education and training for Prior Credit

– Must obtain official transcripts

• Even for training for which the student did not utilize VA benefits

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Credit for Prior TrainingMust be obtained

• Generally, schools must receive all transcripts:

– Programs on terms: Within two (2) semesters or the equivalent

– Not on terms: Within 25% of the certified period for short programs

– Not on terms: Up to 2 months from the start of the program for longer programs

IMPORTANT: Check your SAA approval for specific transcript info

• Schools must grant credit, as applicable, and reduce training time proportionately

– Notify student and retain in student’s records

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Credit for Prior TrainingTranscripts not Received ~ NEW POLICY

If you have not received official transcripts by the end of the period specified in your SAA approval letter you will not terminate the student’s award however:

Obtaining official transcripts is a requirement of your approval by the State Approving Agency (SAA)

If it is found on a compliance that you are routinely not obtaining official transcripts your SAA approval will be suspended or withdrawn

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Questions

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Clock Hour MeasurementAre you reporting the correct hours?

VA pays clock hour programs based on an approved finite total number of clock hours:

• The approved total clock hour length of each program listed in your State Approving Agency (SAA) approval letter

• VA does not pay based on months, weeks and/or what the school may allow over and above state required hours

• You cannot certify for more than the SAA approved hours

– The only exception is if there is documented evidence that a student FAILED a portion of the training and is required to repeat that training

– Keep track of total hours completed

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Clock Hour MeasurementAre you reporting the correct hours?

Certify the ‘scheduled’ number of clock hours per week (ie the number of clock hours they are contracted to attend each week)

not the minimum required to be full-time

• Certifications should be submitted within 30 days after the start of class

• Do not report an average number of hours per week

• Certified hours will be compared with those listed on the enrollment agreement and schedules on compliance surveys

• Certify the beginning and ending date of the entire program unless your official SAA approved school calendar shows official terms, mods, units or blocks of training

• You cannot certify arbitrary blocks of training if your official SAA approved calendar does not show those breakdowns

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How to Determine What Length to Certify

Are You Reporting the correct length?

Based on the beginning date, ending date and number of clock hours per week, you should not certify a student for more than the approved number of total hours

EXAMPLE: Cosmetology program approved by the SAA for 1500 total hours The student has contracted to attend 35 clock hours per

week.

1500/35 = 42.86 weeks • You can certify this student for 43 weeks (43 x 35 = 1505 total hours)

– SAA and VA will not cite a school if the clock hours certified are in excess of the approved hours for a program by 10% or less.

– Remember: You cannot use the minimum hours required for FT in this calculation!

• I have a worksheet that allows you to plug in dates and clock hours that will calculate the proper ending date (including the additional 10% allowed) for you.

– IMPORTANT: You must add 1 day to the ending date when using the spread sheet! 13


NCD CLOCK HOUR LENGTH CALCULATION WORKSHEET

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YOU ARE NOW REQUIRED TO USE AND PLACE THIS CALCUATION SHEET IN ALL VA

STUDENTS FILES

It will be checked for and used on compliance surveys


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)

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Questions

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Attendance & Progress PoliciesKnow them!

Know and understand your SAA approved attendance and progress

policies

Often times, they are different than the policy for your Non VA students

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Standards of ProgressMonitor and Enforce!

• Ensure you are monitoring VA students’ progress– Your catalog and/or SAA Approval will tell you at what points in a student’s training

progress must be evaluated

• VA student’s enrollment must be terminated for not achieving satisfactory progress

• Law requires VA educational benefits be terminated 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

• If your policy allows for probation/warning there must be a clear, definite point in time when:

• A VA student will be placed on probation/warning (cannot be indefinite)• Report probation/warning through RightNowWeb (RNW)

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Standards of ProgressWhen & How to Terminate in VA Once

• For unsatisfactory progress:

• SAA approval generally does not allow for certification of a student for more than two consecutive months while they are not meeting progress standards

– CHECK your individual SAA Approval for specifics for your school

• Terminate the cert and report the last day attended prior to violating the standards of progress policy (LDA/EFF box)

• Choose “unsatisfactory attendance, progress or conduct” from the drop down menu for reason

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Attendance PolicyMonitor i t !

Ensure you are monitoring VA students’ attendance

• Programs measured on a clock hours must maintain attendance records for each class– A student’s schedule an attendance record and is not sufficient for this purpose– 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 and LOAs must be documented

• 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 and actually observes the student signing in

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Attendance PolicyAdjust ing & Terminat ing

• Clock hour programs are to be certified based on “scheduled” hours of attendance

• Adjustments based on weekly changes in attendance are no longer reported to

• If the student misses classes (due to their own fault), the school should apply its SAA approved attendance policy as appropriate:

– IMPORTANT: As VA is paying for these missed days, no extension to the end of the period certified is allowable

– If you extend their end date based on missed class days for which VA has already paid the student, you are in effect certifying the student for those hours twice

– These types of missed hours are why VA allows for a 10% overage above the approved length and should be adequate to cover an allowable amount of missed classes

– IMPORTANT: Not only are you not allowed to extend the student’s length of training certified to VA, you cannot bill VA for any additional T&F charged to a student

who has not completed the required hours by the end of the contracted or certified period.

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Attendance PolicyAdjusting & Terminating

• Schools are required to enforce their attendance policies and terminate the student accordingly if the student is not meeting published attendance standards as approved by the SAA and shown in your SAA approval letter:

– Verify and understand what your SAA approved attendance policies are

– Terminations due to unsatisfactory attendance are submitted via VA Once and “Unsatisfactory Attendance, Progress or Conduct” should be chosen from the drop down menu in VA Once when terminating.

• Schools are required to terminate a student’s certification with VA within 30 days of the date on which the student stops attending a program

– The LDA/EFF date will be the last date attended whether they officially withdraw or just stop showing up for classes

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Attendance & Progress Compliance Surveys

• Although changes to weekly attendance do not need to be reported by the school and will not be cited on a compliance survey:

– The person conducting the compliance survey will be looking closely at your attendance and progress standards and each students’ fulfillment of both

– If discrepancies are found regarding certifying beyond the approved length or lack of termination for violation of attendance/progress standards the school will be cited

– Overpayments will be created on the school and/or student

– The schools VA approval can be suspended or withdrawn

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Last Dates of Attendance ~ Graduation

Amending vs. Terminating

Although VA cannot require you to report graduation data it is highly encouraged and recommended, as this data is being used to provide GI Bill Outcome Measures for the GI

Bill Comparison Tool that students use to choose a school

– For a completion/graduation date equal to the end date certified:

• Terminate the cert for ‘End of Term or Course’ effective the ending date certified (LDA/EFF box)

– For a completion/graduation date prior to the end date certified:

• Terminate the cert for ‘End of Term or Course’ effective the last date attended (LDA/EFF box)

– For a completion/graduate date after the ending date certified: Only allowed with a documented failure or LOA reported to VA

• Amend the ending date to reflect the correct extended end date (based on approved length) then Terminate for “End of Term or Course’ effective last date attended (LDA/EFF box)

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Last Dates of AttendanceWhen Not to Graduate in VA Once

You should not report graduation data at all for the following students:

• If the student didn’t complete his/her program until after the end date certified to VA

• Example: Student certified from 1/15/15 - 12/11/15 & on 12/11/15 they had not completed their required 1500 hours due to missing classes. They finally graduated on 05/23/16.

• If the student reached his/her delimiting date before graduating

• Example: Student was certified through 6/17/15 but reached his/her delimiting date on 3/15/15 (ie the date on which they are no longer eligible for VA

benefits).

• If the student exhausted his/her entitlement prior to graduating

• Example: Student was certified through 6/17/15 but entitlement exhausted on 2/10/15.

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Leave of Absence (LOA)

LOAs must be treated differently for Non CH33 and CH33 students. If a student misses more than 14 consecutive class days (and the school was open and class was available) you have to:

• CH33: You have to “adjust” the cert– I sent a power point that shows you how to submit a CH33 LOA

• NON CH33: a. “Terminate” the cert effective the last date attended

b. Do a brand new cert when the student returns.

c. report the return date as the begin date and the modified completion date (if their ending date has been extended) as the end date for the cert.

d. You cannot extend the student for a longer period of time than the length of the LOA

e. You cannot extend past the approved program length

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Questions

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Pro Rata Refund Policy

IMPORTANT: This section only applies to NC schools. As an NCD school you fall under the approval authority of the state in which the school resides, therefore the SAA over branches in other states may not treat things the same as the SAA in NC. There are two statutes under which SAA’s process approvals—38 US Code section 3675 (titled “approval of accredited courses”), and 38 US Code section 3676 (titled “approval of nonaccredited courses”).

The NC SAA in NC uses section 3676 for all NCD schools that are not accredited by the Southern Association of Colleges and Schools (SACS). So while they recognize that you may be accredited by another body, such as NACCAS, that does not change the statute under which the NCSAA processes your approvals. This is allowed under the laws governing VA educational assistance benefits and is fully supported by VA.

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• Schools must refund T&F on a pro rata basis when a VA student under ANY VA chapter withdraws or does not enroll after paying for courses, in whole or part. – NOTE: This is not only applicable to CH33 Post 9/11 but is required for all VA

students

• The refund for the VA student must be calculated separately from and without regard to any refund that may be due from other sources.

• All funds the school received from the VA went towards the student’s tuition and fees, so the entire amount of the tuition paid by the VA must be used in the pro rata calculation.

• Any fee amount that is for unissued/unconsumed items should be added to the refund amount to be returned to the student.

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• After the VA refund is calculated, if it turns out that the school’s institutional refund policy would provide the student a more favorable refund amount, then the school’s refund should be provided.

• VA regulations allow a 10% deviation in the refund from an exact pro rata amount.

• VA regulations allow school to retain up to $10 of any registration fee that was charged.

• Schools must make prompt refunds, no more than 40 days after the student stops attending (unless the student is on an LOA and has advised the school that they intend to return).

• Schools cannot require the VA Student to request the funds

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HOW TO CALCUATE A PRO RATA RUFUND:

• Calculate the number of clock hours the student completed

• Divide the completed clock hours by the total approved clock hours

• Example: A program is approved for 1500 total clock hours & costs $10,000 The student completed 1000 total clock hours

1000/1500 = .6666 or 67% $10,000 x 67% = $6700The school refunds $3300 to the student The school keeps $6700

• Any debt with VA is the student’s responsibility unless:

– The student never showed up for any classes or,– The student showed up for only the first day of class and then stopped attending

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Questions

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Certifying TuitionAre you report ing the correct

dol lar amounts for Chapter 33?

• Non Ch33 students: You do not need to certify T&F unless they are on active duty or training at less than ½ time.

• CH33 students: Certify the net tuition and allowable fees

– NET Tuition is the amount of tuition remaining after deducting:

• Any school, local, state, private aid etc that can only be used toward T&F

– If it can be used towards other things such as books, room, board etc it does not have to be deducted

• Any Federal Funds, other than Title IV Financial Aid, such as:

– MYCAA

– ROTC Scholarship

– GETA

• Title IV Financial Aid (Pell Grants, Stafford Loans etc) do not need to be deducted

• Loans from any source do not need to be deducted

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• For CH33 students certify only allowable fees can be certified

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

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• Validity of Fees (cont.)

– A school charges a fee for a kit/book, but allows students to purchase items in that kit or that book on the open market

• This fee is not mandatory and cannot be certified to VA

– A school charges for a kit/book and will not allow any student, under any circumstances, to have fee waived if they purchase the items on the open market

• This kit/book can be certified as a fee to VA

• This policy must be clearly stated in your catalog/contract etc

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Questions

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Tuition & Entitlement ChargesChapter 33

Entitlement is charged differently at stand alone NCD schools than it is at IHLs

THE RULE:

• If T&F are certified entitlement is charged based on T&F certified• Academic cap = 12 months of entitlement• One Day of Entitlement Used = Academic Year T&F Cap/360 days (30 day months)

– $21,084.89/360 = 1 day of entitlement for each $58.57 paid

• If no tuition and fees are certified, entitlement will be charged based on the rate of pursuit (ROP)• Days of entitlement charged = Payable RoP (not rounded) multiplied by the

Payable Days divided by 30– Student enrolled for 4 months at FT uses 4 months of entitlement

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Certifying Tuition ~ Schools on a term Basis

Chapter 33

• Example:– First student enrolled FT 8/10/15 – 3/10/16 with T&F of $3,000.

• Student is enrolled at 100% ROP for about 7 months, VA will charge the student about 1 ½ months of entitlement

– $21,084.89/360 = 1 day of entitlement for each $58.57 paid

– Second student enrolled 8/10/15 – 3/10/16 with T&F $22,500• Student is enrolled at 100% ROP for about 7 months, VA will charge the

student about 12 months of entitlement– $21,084.89 max T&F paid so 12 months entitlement charged

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Tuition & Entitlement ~ Not on Terms

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 school bills in increments but 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

– Once the student is billed, amend the certification to increase the T&F certified

• IMPORTANT: The LDA/EFF date = beginning date certified40


Certifying Tuition ~ Not on termsChapter 33

Example: Program runs 1/15/15 – 12/14/15 $15,000 total net T&F School bills the students $5000 at the each of the 1st 3 quarters

• INITIAL CERT: School will certify 1/15/15 – 12/14/15 and $5000 T&F

• School will amend the cert when student is billed on 4/15/15:– Amend the cert and report $10,000 T&F

• LDA/EFF date = 1/15/15• VA will send the school $5,000 T&F (or % due if student is less than 100% eligible)

• School will amend the cert when the student is billed on 7/15/15:– Amend the cert and report $15,000 T&F

• LDA/EFF date = 1/15/15• VA will send the school $5,000 T&F (or % due if student is less than 100% eligible)

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Tuition & Entitlement ChargesChapter 33

THE RULE:

• If T&F are certified entitlement is charged based on T&F certified• One Day of Entitlement Used = Academic Year Tuition Cap / 360 days• 2015-2016 academic year: $21,084.89 / 360 = $58.57

– 1 day of entitlement charged for each $58.57 paid

• If no tuition and fees are certified, entitlement will be charged based on the rate of pursuit (ROP)• Days of entitlement charged = Payable RoP (not rounded) multiplied by the

Payable Days divided by 30. – Student enrolled for 4 months at FT uses 4 months of entitlement– If ROP is less than 100% entitlement charged is prorated

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Chapter 33

• Important because if a school charges all tuition up front:– T&F certified should be prorated between enrollment periods

– Important because of the way entitlement is charged:

• If one term/mod lists all T&F for an entire program, entitlement is charged based on T&F certified

• If subsequent terms/mods are certified with no T&F, entitlement will be charged based on the rate of pursuit for those terms/mods

-Results in VA student’s entitlement getting hit twice

– Prorating tuition between the enrollment periods also allows VA to calculate the correct amount of a payment/overpayment if there is a change in the enrollment

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Chapter 33

• EXAMPLE: Multiple Periods of Enrollment– Student enrolled in the terms below at FT and all T&F are charged up front:

• Aug 15th – Dec 14th 30 clock hours $3,000 reported to VA• Jan 15th – May 14th 30 clock hours No T&F reported• Jun 15th – Oct 14th 30 clock hours No T&F reported

– First Term Charge: Approx 1 ½ months of entitlement • Based on total T&F of $3,000 ($3,000 divided by $58.57 = 51.22 days used)

– Second & Third Terms: 4 months for a total of 8 months entitlement• As there are no T&Fs paid for the other 2 terms VA charges entitlement based on Rate of

Pursuit (1 month for each month enrolled)

– TOTAL ENTITLEMENT USED: 9 ½ months of entitlement • 1 ½ months for the first term + 8 months for terms 2 and 3

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Chapter 33

• Same student enrolled FT for the following periods and charges:

• Aug 15th – Dec 14th 30 clock hours $1,000 T&F certified

• Jan 15th – May 14th 30 clock hours $1,000 T&F certified

• Jun 1st – Oct 14th 30 clock hours $1,000 T&F certified

– TOTAL ENTITLEMENT USED: 1 ½ months • $1,000/ $58.57 = 17.07 days of entitlement each term

• 17.07 x 3 TERMS = 51.21 total days or approx 1 ½ months

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School ResourcesEducation, Training & Information

GI Bill website: http://www.benefits.va.gov/gibill/ (for schools and veterans)

Education Call Center: 1.888.442.4551 (veterans and dependents)

SCO Hotline: For SCO use ONLY – 1-855-225-1159

VA Debt Management Center: • Phone number: 800.827.0648• Email address: [email protected]

Right Now Web~RNW (VA’s Internet Inquiry System in the “Ask a Question” section of the GI Bill website): https://gibill.custhelp.com/app/utils/login_form/redirect/ask (for schools and veterans)• Status of individual unusual/complex cases• Individual cases that have been pending for a longer than usual time• Hardship cases• Written response

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Questions?

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Quiz Time!

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Certifying T&F

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Scenario #1 – A student is pursuing a certificate program which costs $20,000 and the program is broken into 5-week terms. The school is actually billing the student $20,000 on the first term.

• Question #1: Should the school report $20,000 on the first term, or divide the total cost of the program by the total number of terms and report the amount from the calculation on each term certified?


Certifying Modular Programs

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• Answer #1: The School should not report $20,000 on the first term for the entire program. The school should break-up the tuition and fees and apply them to each term proportionately.

• Why? The student will be charged entitlement twice. First on the T&F and then on ROP.


Extended Term Dates

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Scenario #2 – A student is pursuing a 1500 hour program over 53 weeks. The student does not complete the required 1500 contact hours by the end of the 53 week period due to his/her inability to commit to full time attendance.

• Question #2: Should the school extend the end date for the term certified to the VA to compensate for the extra time needed to complete the required contact hours?


Extending Term Dates

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• Answer #2: The School should not report a change in end date for the program as the student has already been paid for the approved number of hours in the program. We will pay a student to be in the classroom for the approved program hours and no more.

• If the student had an LOA reported to VA, you can extend the student for the length of the LOA up to the approved number of hours. We will still pay a student to be in the classroom only for the approved program hours and no more.


Reportable Fees

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Scenario #3 – ABC Beauty College requires that all students purchase a supplies kit for their certificate program. This kit includes two textbooks that ABC College writes and can only be purchased at the school.

• Question #3: Can the SCO certify the supply kit as fees even though it contains textbooks?


Reportable Fees

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• Answer #3: Yes the SCO can certify that supply kit as fees if ALL students are required to purchase that kit and the textbooks can not be purchased ANYWHERE else.

• In addition, the supply kit fee must be specifically labeled as a fee in the catalog, enrollment agreement, and student payment ledger

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