March 25, 2015 ♦ Atlanta Southern Regional School Conference ♦ Atlanta, GA Created by Ron...

March 25, 2015♦

Atlanta Southern Regional School

Conference♦

Atlanta, GA

Created by Ron Scoggins & Katherine Snyder

January 2014Revised March 2015

IHL FLIGHT TRAINING WORKSHOP

Ron ScogginsLead Education Liaison RepresentativeUS Dept. of Veterans AffairsVA Central Office Education ServiceSouthern Region

Katherine SnyderProgram Specialist

Florida Dept. of Veterans’ Affairs

State Approving AgencyFlight Chair, NASAA

Flight Training and the GI Bill ®® ®

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TOPICS•Getting Started• Contracted Vocational Flight School Approval• Contracts/MoUs/Agreements• Miscellaneous Policies and Requirements

•General Requirements for All Flight Courses•Certifying the Enrollment of VA Students in Flight Programs•How the Various GI Bill Programs Pay Benefits and to Whom•Compliance Surveys•Licensing and Certification•Vocabulary Unique to the Professional Aviation Vocation•Questions

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Getting Started

Determining whether specific SAA approval is required for degree programs with a component of flight/aviation:YESIf a school is not considered to have “deemed approved” programsIf a school with “deemed approved” programs utilizes services from a vocational flight school, i.e., “under contract”NOIf a school with “deemed approved” programs is approved by the FAA under Part 141 and utilizes its own flight line, instructors, TCOs, syllabuses, etc.

Credit hour certificate and non-degree programs of flight training may not be approved under any circumstances nor may students be certified by an IHL as a credit hour non- degree studentIf the IHL is also approved as a vocational flight school, then they may certify those students as vocational flight students subject to the rules for vocational flight schools and subject to the Chapter 33 annual cap for vocational flight schools, currently $11,562.86

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Getting StartedContracted Vocational Flight School Approval

Applying for IHL Contracted Degree Program ApprovalUtilize Appropriate SAA Application/Request for Approval Form

Use the SAA Catalog Submission and Program Approval/Modification Form (or equivalent*) to request approval of individual degree programs for which the school has a contract, MoU, or other agreement for use of space, equipment and/or instructors, aka degree programs “under contract”

* Each state will have its own application/request for approval form

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IHLs with Degree Programs “Under Contract” If a school does not have its own flight line and must make arrangements

with a Part 141 flight school to provide flight training, then the flight school contractor must be approved by the SAA with jurisdiction over flight schools for veterans’ training, and the contracted course section of the application applies and the following must be attached: Copy of contract/MoU/agreement Copy of flight school’s Air Agency Certificate Copy TCO and Syllabus for each course offered as part of the degree

If at any time an IHL changes its contract from one flight provider to another, it needs to notify the SAA immediately so that (if all is in order) the approval of their flight degree programs may continue uninterrupted

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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 Only courses listed on the Air Agency Certificate and Letter of

Authorization may be considered for approval If a Pilot School wishes to obtain approval of a course not currently listed

on these documents, they must obtain approval from their FSDO and obtain a new or revised Air Agency Certificate

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Training Course Outline (TCO) Description of purpose of course 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

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Training Course Outline (TCO) The SCO needs to have this information because it directly impacts flight

costs and provides information needed in order to better monitor compliance with the contract Although the SCO may not be directly involved in monitoring and enforcing the

terms of the contract, the SCO must know the people who have that responsibility and establish a good working relationship with them to ensure enough information is made available to the SCO to allow that person to make timely and accurate reports to VA on flight students

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Syllabus There is one (1) syllabus approved for 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 specifically designed to prepare students to take and pass the

FAA written exam for the course

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Syllabus (cont.) 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 syllabuses and for minimum hours

is usually listed “as needed.” For GI Bill® approval, flight schools may request approval of pre/post hours

totaling no more than 25% of the minimum flight hours in each course. This is also true for the flight courses the IHL for which the IHL contracts with the flight school.

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Syllabus (cont.) Each flight lesson specifies the knowledge to be learned, maneuvers to

accomplish, procedures to follow for each flight lesson as well as how long each lesson should take

Includes a time distribution chart that lists all lessons, how long each should take, and totals all hours – the hours listed in the syllabus are the maximum hours that may be approved and paid for VA training

The FSDO-stamped copy must be submitted for approval for VA training

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Obtaining ApprovalAs required by Title 38 CFR 21.4263, flight school approval criteria includes, but is not limited to:

Meeting the two-year rule Being financially sound Maintain all records pertaining to the training they give for at least three

years following each student’s last date of training Have and enforce reasonable standards of progress and attendance Have the capability to identify the last date of training

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Finding a Flight SchoolIHLs may check to see if a flight school is already approved for veterans training:

Go to WEAMS Public:http://inquiry.vba.va.gov/weamspub/buildSearchInstitutionCriteria.do Enter Program Type as “Flight” using the drop-down menu Click on your state

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Finding a Flight School

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Finding a Flight School

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Training Centers Training Programs – Part 142

Although it is rare for a Training Center to enter into a contract with an IHL, with several approved training centers in Florida it is possible such a contract could be entered into at some time in the near futureTraining Centers (TCs) are approved by the FAA under this provision of the FARsThis part allows a TC to offer an entire course through the use of flight simulatorsAlmost always for large aircraft which would be extremely expensive to fly for training purposesExamples include A320, B727, DC10, Lear Jet, Cessna Citation, Sikorsky S71, etc.All elements for approval are the same as for Part 141 Pilot Schools with the exception that all elements found in TCOs and Syllabuses are found in the one training center documentOnce again, the minimum training hours listed in the training center document are the maximum hours that may be approved for VA training

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Cash Tickets/Student Ledgers/Invoices These are the basic documents that record all payments made for pursuit of

flight courses We require them to verify that costs certified to VA for reimbursement are

accurateAs it relates to IHLs… These documents are key to the IHL to verify the accuracy of the amounts of

which the flight school invoices the IHL and must contain the following elements: Name and identifying information of the student 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, and tail number Per hour charge Total charges Signature of instructor and student 18


Flight Course Training Records The official record of each flight and ground school lesson completed Required by the FAA to verify that training has been given Flight schools often use the Jeppesen supplied tri-fold (or similar) training

record, electronic records such as Paperless 141, record training in the syllabus on special lesson sheets, or devise their own record

Like the FAA, we use them to verify that training and hours certified to VA have been given

As it relates to IHLs… This is likened to a college instructor’s records of students’ class work in

academic courses and is just as important to the IHL as academic records. In fact, they are the basis for the grades assigned by the IHL for each course students pursue.

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Flight Course Training Records (cont.) Must contain the following elements:

Name and identifying information of the student Exact approved name of the course being pursued Date of training for each lesson Aircraft flown for that lesson to include make, model and tail number Amount of time expended in completing that lesson

May be compared to the FSDO-approved syllabus The elements of the lesson completed A grade for that lesson

Once again, is equivalent to an IHL instructor’s grade book or grade records Instructor signature and comments Student signature

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Ground School – what may and may not be approved Ground school must be actual face-to-face training with an instructor,

either in a group classroom setting or one-on-one Ground school offered through online training cannot be approved for

stand alone vocational flight schools Ground school may be offered through computer generated lessons, but

only at the flight school with an instructor immediately available to answer questions and direct study with times recorded by the instructor

If a particular flight course includes online ground school that may not be approved, the flight portion of the syllabus may still be approved and paid if appropriate

Exception: If an IHL is FAA approved to offer ground school under Part 141 or 142, then all or part of the ground school may be approved for pursuit through an online mode of delivery as long as they are measured in credit hours and apply to a college degree.

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Prior Training Flight schools must grant credit for all appropriate prior education and

training without regard to the wishes of the veteran, just the same as with all IHLs

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) Credit may be given for up to no more than 50% of the course requirements for training

received at another Part 141 certified school Credit may be given for up to no more than 25% of the course requirements for training

given under Part 61

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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Standards of Progress Like any other school approved for GI Bill® training, flight schools must

have and enforce standards of progress The SAA has certain minimum standards which are included in their

recommendation to VA for final approval Typical standards are tied to stage checks (e.g., failure to pass two stage

checks will result in termination of the student’s VA education benefits) Records must be maintained to reflect that the student was terminated

and why Because those standards are specifically geared to flight training, IHLs

should adhere to the flight school’s standards of progress

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Refund Policies For their VA students, flight school refund policies must be pro rata Not a problem for ‘pay as you go’ If student pays on account then drops, the refund must be for all funds still

on account that have not been applied to appropriate training already given prior to the drop

Records must be maintained to verify that the refund was given and for the correct amount

As it Relates to IHLs… Should an IHL choose to have this type of pro rata refund policy, refunds

such as this would be easy for IHLs to administer since all flight schools are required by the FAA to maintain detailed progress and attendance records

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These are schools that own/lease their own aircraft, hire their own flight instructors and are approved by the FAA under Part 141 with their own air agency certificate, and their own TCOs and syllabuses, i.e., they are also a flight school.No separate SAA application/request for approval form is necessary since the program would be “deemed approved”

If school has its own flight line and Part 141 approval, then special approval of that degree program is not required; however: We still need the AAC, TCO and Syllabus when you submit a catalog

Most of the payment procedures on the following slides also apply to schools with their own flight line

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Getting StartedIHLs with Their Own Flight Line

Must clearly identify the IHL offering the degrees and the flight school providing the flight training

Each course for which training is being given must be identifiedLocation where flight training is givenClear identification as to method of payment for instruction given

Students pay the flight school and are considered to be flight school students – flight school certifies the enrollment of students as vocational flight students

Students pay the college, register for college flight course, are considered to be students of the college, the college pays the flight school – IHL certifies the enrollment of students as college students

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Getting StartedContracts/MoUs/Agreements

Where students pay the college and the college pays the flight school, rates of payment must be clearly delineated Flat rate – one fee for flight training regardless of time taken or aircraft

flown Pay by hour – college pays flight school based upon hours completed and

specific aircraft flown Flight and ground hours upon which charges to VA are based must not

exceed hours approved on the FSDO-stamped syllabus for each course at the flight school

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List of limitations for training given - examples: Least expensive aircraft must be utilized except where required by the

course 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

listedOther obligations and restrictions on the college and the flight school.

Examples include, but are not limited to: Disposition of unused funds (refunds) Who will supervise which personnel Who is obligated to pay personnel salaries Where records are maintained and who maintains them

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Things to avoid on MoUs that would not be approved by an SAA: Arrangements to sub-contract some instruction to a non-approved school Provisions to offer any part of the training under Part 61 Provisions to allow for additional flight hours beyond the minimum

requirements of the flight school’s syllabuses Any clauses that would allow the IHL to alter the flight school’s FSDO-

approved Part 141 courses in any way

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Missed and Make-up Flights Where flights cannot be conducted because of inclement weather,

mechanical problems, illness, unavailability of instructors, etc., a policy for making up such missed flights, including time limits, must be delineated in the MoU, school catalog and any program material Because of concerns regarding keeping students current in training and skills,

time limits for making up missed flights cannot be as liberal as with other courses for which an incomplete grade has been issued

In no case may students fly and be certified to VA for more than the minimum hours required in the course syllabus

It should be rare that students need to make up flights after the end of the enrollment period Frequent such occurrences would be a red flag

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Getting StartedMiscellaneous Policies and Requirements

Standards of Progress & Attendance For the flight courses, standards are set by the flight school and are

specific for all subjects containing elements of flight training. This includes standards of attendance/frequency of scheduling and taking flight lessons to ensure that flight skills are maintained. A suggested standard would require students schedule flights every week and

at a frequency to ensure they will complete all flights within the term. Failure to schedule any flights for two consecutive weeks will result in the student being dropped from the course as of the date of the last flight for failure to attend

Flight school standards relate to individual lesson grades and stage checks may contain a probationary period which is generally linked to the number of poor lessons grades and/or failed check rides

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Standards of Progress & Attendance (cont.) IHL and flight school must have a system in place to notify IHL, in a timely

manner, of failure to progress satisfactorily or failure to schedule/show up for flight lessons, e.g., did not schedule flights for two weeks

Regardless of the fact that the flight school may have given late notice to the IHL of a change, the IHL is still held responsible for reporting all changes/terminations within 30 days Hence the importance of open and continuous lines of communication

between the flight school and the IHL and between appropriate elements of the IHL and the SCO

Typical standards are tied to stage checks, e.g., failure to pass two stage checks will result in termination of the student’s VA education benefits

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Standards of Progress & Attendance (cont.) Records must be maintained to reflect that the student was terminated

and why, along with the date the IHL was notified of the unsatisfactory progress by the flight school

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Refund Policies Whether flat rate or pay by hour, refunds of unearned fees, i.e.,

flights/lessons not completed, must be made to the student or VA as appropriate for the student’s GI Bill® and in accordance with your school’s approved refund policy and/or included in the MoU with the flight school

Records must clearly indicate how the refund was calculated If pay by hour plan is implemented, then refunds are generally a moot

point unless students pay on account

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Term Dates/Enrollment Periods IHLs use standard and accelerated term dates just the same as for non-flight

students Flight courses are certified in appropriate credit hours just the same as any other

non-flight students

Course Descriptions Flight courses should be described in the IHL’s catalog the same as any other course The course title/description should clearly indicate the flight objective (instrument

rating, commercial pilot, certified flight instructor, etc.) Should include all required hours of flight, ground school and pre/post

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Course Descriptions

Notice that this Commercial Pilot Flight - Helicopter course includes 20 hours of dual flight and 15 hours of ground instruction*

This must match the required hours in the FSDO-stamped syllabus *Ground instruction in this case is likely pre/post

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Course Descriptions

Notice that this Commercial Pilot Ground School course description does not make mention of the required hours. Hours are not required to be listed within the course description; however, if added, must match the FSDO-stamped syllabus.

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Course Sequencing School’s approved catalog must have the degree program outlined As a best practice, the program outline should sequence course pursuit to

reflect a healthy mix of flight and general education/academic courses each term

Students should not be allowed to take all flight courses up front, sometimes called front-loading

Since FAA rules require a certain sequence of flight training, i.e., from one course to another, front-loading should not normally be a problem For instance, all students must take private pilot course first and absolutely cannot

pursue any other flight courses concurrently. The credits awarded for that course are normally insufficient for award of the monthly housing allowance (MHA). Thus, Chapter 33 students must take additional academic courses in the program to receive the MHA.

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Certifying the Enrollment of VA

Students in IHL Flight Programs

85-15% Ratio First, determine if the degree program has more than one “track”

Tracks, as referenced here, should not be confused with majors, minors, concentrations and such, although the ratio is calculated separately for those as well

Tracks are not different curriculums, but rather are different arrangements to pay for courses

Rather than pursuing their flight training at the IHL or as the IHL’s students at the IHL’s contracted flight school, do students have the option of going to a flight school on their own and paying the flight school directly, then having their credits transfer back to the IHL? Each of these is considered to be a separate track

Is there more than one type of payment plan? If so, then each payment plan is considered to be a separate track

Calculate ratio separately for each “track”, major, concentration, etc., if any Example: A “Turbine Transition option” would require a separate ratio

calculation

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Certifying the Enrollment of VAStudents in IHL Flight Programs

85-15% Ratio (cont.) 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, aka ‘supported’ students

Non-VA (15%) portion of ratio includes all other students officially registered in that degree program

You must calculate the ratio before certifying a VA student in the program for the first time

Unless 35% waiver has been granted, schools must report the ratio to the your ELR each standard term and for the summer

The fact that a school has the 35% waiver of reporting requirements does not relieve them of the obligation to ensure they still meet the ratio in each program

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Why an 85-15% Ratio? Requiring that at least 15% of the students in a program are willing to shell

out their own hard-earned money for that program allows the free market to determine that: The course is of sufficient quality to attract students who are spending their own

money The course is of good value and not overpriced

This helps keep prices lower, otherwise the school cannot attract sufficient non-VA/supported students to stay in balance with the ratio

The ratio was promulgated by Congress after the original World War II GI Bill® to maintain the integrity of the GI Bill®. It is still valid and works well.

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Completing the Enrollment Certification (VA Form 22-1999) Enter the exact name of the program as found in WEAMS and your catalog 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 – flat rate

Public schools enter only the in-state rate Private schools enter the actual total charges (there should be no state

differential) Enter actual charges – if Chapter 33 student is eligible at less than the 100% level,

VA’s claims examiners will assume what you certify is the actual total in-state charges and pay the appropriate reduced rate

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Completing the Enrollment Certification (VA Form 22-1999) Enter total charges – pay as you go

Public and private schools same as previous slide with respect to in-state and out-of-state

Calculate the minimum cost that the student will incur and certify that amount up front

At end of course, calculate actual charges and submit an amended enrollment to VA In no case may additional flight or ground hours be certified for payment beyond

the hours approved in the Part 141 syllabus Date submitted must be no later than 30 days after the first day of the term,

end of drop/add, or date veteran requested the school to certify (documented), whichever is later Time limit is for certifying credit hours pursued. School may take longer to certify tuition and

fees or amended tuition and fees.

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What to Do When a Student Drops/Withdraws from a Flight Course Always report last date of training with a 1999b Punitive and non-punitive grade policies apply Generally speaking, the school’s refund policy prevails

As we discussed earlier, such policies must be delineated in the MoU, school catalog, and program materials, and may actually be the refund policy of the flight school and/or be different from the IHL’s general refund policy.

The contract/MoU/agreement with the flight school must specify the financial arrangements for handling funds when students drop/withdraw

The contract/MoU/agreement should always include a policy that provides payment only for flight training actually given

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What to Do When a Student Drops/Withdraws from a Flight Course (cont.) Flat rate – because flight training is very costly, a non-refundable flight fee is

not a best practice and is not recommended Best practice for refund – calculate cost of training given through date of

drop/withdrawal Deduct cost of training given and refund the remainder of the unearned fees (pro

rata) Pay as you go – generally, a refund of fees is not a factor since payment is

only made for actual training given It students pay on account, then the procedure above regarding flat rate fees

should be followed to refund unearned fees

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Cancelled or Postponed Flight Training In rare instances, students may not be able to complete all flight

training/lessons within the term due to inclement weather, mechanical problems, scheduling problems, etc.

The school must have a policy in place for these types of situations Schools may utilize their standard incomplete grade policy; however, for the

sake of helping the student to maintain flight proficiency, it is a best practice to require less time to make up missed flights than is allowed for other incomplete grades

Example: The student is allowed up to 90 days after the end of the term to complete the flight training or be assigned a failing grade

If flight fees are ‘pay as you go’, the flight charges may then be submitted to VA for reimbursement as an amended certification In no case may flight hours beyond the minimum approved be charged to VA In no case may a penalty fee be charged to VA

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How the Various GI Bill Programs Pay Benefits and

to Whom

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How the Various GI Bill® ProgramsPay Benefits and to Whom

Chapter 1606 Monthly payments to the student There is no level of benefit payment for chapter 1606 – all payments are

at the 100% eligibility level – current full-time monthly benefit is $367.00 Payment for training to the school is between the student and the school Entitlement is charged at the rate of one (1) month for each full-time

month paid Students must verify enrollment each month to receive benefits

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Chapter 35 Monthly payments to the student There is no level of benefit payment for chapter 35 – all payments are at

the 100% eligibility level – current full-time monthly benefit is $1,018.00 Payment for training to the school is between the student and the school Entitlement is charged at the rate of one (1) month for each full-time

month paid

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Chapter 33 Benefits payments are paid based on length of creditable service For less than the full service required, students are eligible at a

percentage of the full-time rate Payments are separate for:

Housing allowance Books and supplies Tuition and fees

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Chapter 33 (cont.) Reimburse each school for up to 100% of all approved charges

All payments subject to the student’s level of eligibility For public IHLs, payment is for all allowed costs of in-state tuition and fees with

no yearly limit For private IHLs, payment is for all allowed costs of tuition and fees up to an

academic year cap Academic year is August 1 through July 31 Current yearly cap (2014-15) is $20,235.02 Cap for previous academic year was $19,198.31 Both the monthly amount paid and yearly cap are subject to the student’s level of

eligibility (e.g., student eligible at the 80% level will have payments made to the school at the rate of 80% of the actual charges certified and the yearly cap is $16,188.02 (80% of yearly cap))

At IHLs that participate, Yellow Ribbon may be an option for veterans who have reached the academic year tuition and fee cap 53


If They Have a Choice, Which GI Bill® Should They Use? If they are eligible for more than one GI Bill® and/or have an opportunity

to change from one to another, veterans should go to the website below and use the Comparison Tool/Payment Rates to determine which GI Bill® would most advantageous for her/his situation. Alternately, veterans may call the nationwide toll free education number also listed below:

http://www.benefits.va.gov/gibill/comparison_tool.asp VA Toll Free Number: 1-888-442-4551

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Compliance Surveys

Entrance interview With SCO and others as school or auditor sees fit

Review of advertising to ensure compliance with the law Past 12 months of advertising (website, publications, television and radio

spots, etc.) to ensure not false or misleading; no promises of placementReview of 85-15% ratio

Based upon the total enrollment for the term as opposed to training for the prior 30 days as with flight schools Remember the ratio must be calculated separately for each track We will check a random sampling of non-VA files to ensure those students are

paying for their program out of their own funds

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Compliance Surveys

Records must be available at time of visit Review pre-survey checklist provided to you by the SAA or VA

Ensure all items are addressed Hard copy or electronic records Ask questions before visit if unsure

IHL Documents Registration documents - application, enrollment agreement Class schedules Transcripts Drop slips; withdrawal documentation Tuition payment ledgers; detailed record of tuition and fees Yellow ribbon documentation Reporting fee fund documentation

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Compliance Surveys

Records specific to flight For schools that contract their flight training or have their own flight

line, offer training under Part 141, and charge pay as you go: Copy of contract/MoU/agreement with the flight school (N/A for schools

that have their own flight line) Each current course TCO and FSDO-stamped syllabus Flight school progress records

Signed by instructor and student Flight school student cash tickets/ledgers/invoices Current AAC (we will also review for revocation before the survey at the

FAA Website)

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Compliance Surveys

Records Specific to Flight (cont.) For schools that contract their flight training or have their own flight

line, offer training under Part 141 and charge a flat rate: Copy of the MOU/contract with the flight school (N/A for schools with

their own flight line) Flight school’s/IHL’s Part 141 air agency certificate TCO and syllabus for each flight course Ground school and flight records detailing the flight/ground training given

with total hours given for each type of flight (dual/solo) as well as ground school

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Compliance Surveys

Records must be available at time of visit (cont.) FAA website links:

Pilot Schools - http://av-info.faa.gov/PilotSchool.asp Training Centers - http://av-info.faa.gov/TrainingCenter.asp

Pilot School will show up if AAC is still valid

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Compliance Surveys

Commencement of courses First day of classes for the semester, quarter or part of term

Program certified Must be same as what VA beneficiary is enrolled in and pursuing

Review transcripts, registrar records, application, etc. If they do not agree, update records and/or certification

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

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Compliance Surveys

Previous education and training The school must maintain a written record that clearly indicates that appropriate

previous education and training has been evaluated and granted, with training time shortened and tuition reduced proportionately, and the veteran so notified For flight courses, the FAA places certain restrictions on how much credit may be

granted, even when considering training completed at another college or Part 141 flight school

Part 141 Pilot Schools may transfer credit that composes no more than 50% of the hours in the school’s syllabus for training completed under Part 141 at another

certificated flight school 25% of the hours in the school’s syllabus for training completed under Part 61

This varies from college transfer policies that allow credit for all work successfully completed at certain other colleges

The flight school will process the prior credit under Part 141 rules, but the IHL needs to be aware of these rules and ensure that the flight school follows them and grants credit as appropriate

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Compliance Surveys

Certifications must be accurate and prompt Ensure enrollment dates are correct Ensure tuition and fees are properly reported dependent upon whether the

school charges flight pay as you go or flat rate For pay as you go schools may certify up front the minimum charges they know

all flight students will incur then certify the actual charges (if more than the minimum charges) at the end of the term as an amended certification

Utilize degree program/audit sheets to ensure courses certified apply to program requirements not already satisfactorily completed

NOTE: This is why it is extremely important that the SCO have open communication with her/his own school’s finance/bursars office and registrar, and the appropriate officials at the flight school who can provide the training and billing records the SCO needs to properly certify enrollments to VA

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Compliance Surveys

Certifications must be accurate and prompt (cont.) Ensure that prior credit has been obtained, evaluated and granted as

appropriate. It would not be unusual for a student applicant to have already obtained some flight licenses and ratings for which credit must be granted toward the degree program An IHL cannot, under any circumstances, require a student to pursue a license or rating at

that IHL or contract flight school if the student already possesses that license or rating from the FAA

All certifications must be submitted within 30 days of the latter of any of the following three (3) things: Start of term End of drop/add VA student’s request for certification of benefits

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Compliance Surveys

Terminated or Interrupted Training Must be promptly reported Last dates of training must be able to be identified during visit and

notification must be made to VA within 30 days of student’s last date of attendance Maintain drop/withdrawal slips in file The last date of training should be easy to obtain for flight courses because flight

training requires accurate records of dates of training given

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Compliance Surveys

Satisfactory Progress Monitor unofficial transcripts Monitor progress records from flight school

Ensure you have a good line of communication with the flight school or the element within your own school that would have access to those documents

Maintain documentation in files Standards of Progress must be monitored and policy enforced Report probation to VA via RightNowWeb

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Compliance Surveys

Standards of Progress Academic Probation

Promptly notify VA when a student is placed on probation Via ‘Right Now Web’ (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

Notifications must include: Student’s name in the text VA file number in the text “Academic Probation” in the subject line Supporting documentation to be maintained in VA student files only

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Compliance Surveys

Standards of Progress (cont.)Academic Probation (cont.)If multiple students are being reported, you may submit a single notification by using the spreadsheet (page 76 of the online SCO handbook, 4th edition, 09/30/14 or https://gibill.custhelp.com/app/answers/detail/a_id/1436/kw/academic%20probation):

Advise students of counseling services available to them under Chapter 36 http://www.benefits.va.gov/vocrehab/edu_voc_counseling.asp Students complete VA Form 28-8832

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Compliance Surveys

Standards of Progress (cont.)Academic Suspension

SCOs must promptly report to VA when a student is no longer meeting the standards of progress for your school

Terminate the last term during which the student is entitled to payment In VA-ONCE, specify reason as “Unsatisfactory Attendance, Conduct or

Progress” Ensure the end date of the term is correct LDA/Effective date defaults to end date of term If the student is not returning, you must still terminate

If the student is academically suspended and submits documentation to appeal and the suspension status is overturned, you do not terminate the certification

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Compliance Surveys

How do tuition and fees compare to other students’ charges? Tuition and fees charged to VA beneficiaries must be the same or less than

charges to other similarly circumstanced students Some non-VA student files are randomly selected for this purpose

Authority: Title 38 USC, Section 3690(c)

Schools found charging veterans more than similarly circumstanced non-VA/supported students are subject to having their approval immediately withdrawn

38 CFR 21.4210(d)(4)(i)

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Compliance Surveys

Once the compliance survey visit is complete Exit interview will be conducted

With SCO or others as school or auditor sees fit Site visit report – addresses findings and any corrective action that may be

necessary If corrective payment action is required (i.e., changes that affect payment of

benefits), referrals will be submitted to the VA Muskogee Regional Processing Office for action OR we may work with the school to assist them in correcting via VA-ONCE

A letter is sent to the school (to the highest administrator, with copy to the SCO) Identify student records reviewed Detail any discrepancies/findings Specify corrective action (if any) required by the school

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Compliance Surveys

Findings/Common Errors (in no particular order) Student flying and being certified for more flight hours (and associated

charges) than the course syllabus requires Notice of termination for unsatisfactory pursuit sent more than 30 days after

the last flight or ground school class Administrative withdrawal date certified instead of last flight or ground school

class Flight course taken out of sequence as listed in the school’s catalog Refund of fees after termination is not prorated for the flight lessons not taken

(pay as you go/pay on account) 85-15% ratio does not include supported students in the 85% portion of the

ratio VA students charged more than non-VA students for the same course The IHL has not sought prior approval of its contractual arrangement and it is

found that the flight school is not approved for GI Bill® training

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Compliance Surveys

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Licensing and Certification (LACAS)

Following is the link that will take you to the information regarding Licensing and Certification (LACAS). It gives complete instruction on how a veteran may seek reimbursement for LACAS exams not covered under GI Bill® benefits:

http://www.benefits.va.gov/gibill/licensing_certification.asp Pamphlet: http://www.benefits.va.gov/gibill/docs/pamphlets/lc_brochure.pdf Individuals may also go to the following link to search for approved

exams and to find the appropriate address for submission (name and address of organization issuing license is required when submitting to VA for reimbursement):

http://inquiry.vba.va.gov/weamspub/buildSearchLCCriteria.do

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Licensing and CertificationLACAS

Items eligible for reimbursement under LACAS: FAA examiner’s fee for the check ride

IHLs – Items not necessary to request through LACAS Rental of the aircraft for the check ride (because IHL and not vocational

Submit on 22-1999 for Chapter 33

Entitlement Student is charged one (1) month of entitlement for every test VA pays

May not always be in the student’s best interest

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Enter “Commercial Pilot” for example as in the following screen as well as “Both” in the LAC Category type, and do a search by country (USA), then click Submit:

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Once there, click on Commercial Pilot to get the next screen:

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Click on Institutional Profile and that will give the institution name and address for submission:

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Vocabulary Unique to the Professional

Aviation Vocation

Air Agency Certificate: The Air Agency Certificate is issued by the FAA to flight schools authorizing them to offer courses of instruction leading to pilot’s licenses and ratings. Air Agency Certificates list the specific flight programs approved by the FAA for the school to which the certificate is issued. Certificate validity dates vary, but are always indicated on the certificates. A Letter of Authorization must accompany an Air Agency Certificate.

Chief Flight Instructor: The Chief Flight Instructor is the person in charge of all flight training at a flight school. Chief Flight Instructor qualifications are contained in the Federal Aviation Regulation (FAR), 14 CFR Part 141.35. The FAR requires each school to designate a Chief Flight Instructor.

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Definitions

Federal Aviation Administration (FAA): The federal government organization primarily responsible for the advancement, safety and regulation of civil aviation. The FAA establishes regulations and policies prevailing over flight, including flight training, flight schools, and certificates issued, and it oversees the development of air traffic safety and control.

Federal Aviation Regulations (FARs): The FARs are a compilation of FAA regulations governing all aspects of flight training, air carrier operations, medical requirements for pilots, aviation safety, aircraft maintenance training, airfield and airspace operations within the US, its territories and their respective boundaries.

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Definitions

Fixed Base Operator (FBO): A commercial business granted the right by an airport to operate on the airport and provide aeronautical services such as fueling, hangaring, tie-down and parking, aircraft rental, aircraft maintenance, flight instruction, etc. When referring to Part 141 pilot schools this term is applied to the primary location listed on the air agency certificate and satellite operations under that same air agency certificate located at other air fields

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Definitions

Fixed Wing: An aircraft is described as “fixed wing” when it derives the majority of its lift from a stationary or variable geometry wing, as opposed to a helicopter, which derives its lift from rotors (rotary wing). Fixed wing aircraft may be powered by engines attached or built into its fuselage or wings.

Flight Engineer Courses: The flight engineer course is a separate program with skills and requirements described in 14 CFR Part 63, Subpart B. Although the FAA has only one flight engineer certificate, it also approves courses leading to endorsements to the certificate for the aircraft on which the engineer is qualified to serve. The SAA must approve a flight engineer program offered by a school and the additional add-on training endorsements. A VA student may receive benefits for the endorsements.

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Definitions

Flight Programs: Flight training programs are formal courses leading to FAA certifications or ratings to operate aircraft. (NOTE: Pursuit of a private pilot’s license, except as part of a degree program, is not approvable for veteran students). All flight training must be received from an authorized instructor. Commercial Pilot: The course of instruction leading to licensing as a

commercial pilot, authorized to operate aircraft for hire. This is the initial program approvable for VA training.

Instrument Rating: A course of instruction leading to certification to operate an aircraft in instrument meteorological conditions (IMC); during periods of low visibility.

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Definitions

Flight Programs (cont.): Certified Flight Instructor (CFI): Course of instruction leading to

certification as a flight instructor, authorized to conduct ground or flight training I accordance with the privileges and limitations listed on the holder’s flight instructor certificate.

Additional Flight Instructor Qualifications: Certified Flight Instructor-Instrument (CFI-I): A course of instruction

qualifying the CFI to provide ground and flight instruction in all phases of flight planning, flight, and air traffic control procedures when operating in instrument meteorological conditions.

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Definitions

Flight Programs (cont.): Additional Flight Instructor Qualifications (cont.):

Certified Flight Instructor Single Engine Land (CFI-ASEL – as opposed to seaplane) and Certified Flight Instructor-Multi Engine Land (CFI-AMEL): A course of instruction qualifying the CFI to provide ground and flight instruction in single-engine aircraft (ASEL) or multi-engine aircraft (AMEL), respectively.

Other: specific qualifications for unique aircraft or unique capabilities, such as aerobatic instructor qualifications are addressed in the FARs.

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Definitions

Flight Programs (cont.): Airline Transport Pilot (ATP): A course of instruction qualifying the

commercial pilot to perform duties and responsibilities as an airline pilot.

Additional Aircraft Type-Rating Certificates: Courses of instruction that qualify pilots to operate specific types, categories or classes of aircraft.

Ground School Instructor Certification: A course of instruction qualifying a person to provide instruction in the ground training aspects of flight training. Specific details are contained in 14 CFR Part 141, Appendix H.

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Definitions

Flight School: A school, other than an IHL, or an entity such as an aero club, located in a state, that has been issued either a pilot school certificate or a provisional pilot school certificate by the FAA which specifies each course the school is approved to offer under 14 CFR Part 141.

Flight Standards District Office (FSDO): The FSDOs are regional offices located throughout the US. FSDOs promote safe transportation by setting standards and regulations for oversight of airmen, air operators and air agencies. They approve flight and ground training curricula at flight schools under their geographic jurisdiction. FSDOs issue Air Agency Certificates.

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Definitions

Flight Simulators: A flight simulator is a replica of a specific type, make or model of aircraft, which includes the assemblage of equipment and computer programs necessary to represent aircraft operations in ground and flight conditions. Simulators must have visual systems providing out-of-cockpit views, and have a full range of capabilities of the systems installed in the device as described in 14 CFR, Part 60.

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Definitions

Flight Training Device (FTD): An FTD is a replica of aircraft instruments, equipment, panels and controls in an open flight deck area or an enclosed aircraft cockpit replica. It includes the equipment and computer programs necessary to represent aircraft operations in ground and flight operations. An FTD need not have a motion or a visual system.

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Definitions

Instrument Meteorological Conditions (IMC): IMC means weather conditions below the minimums defined as Visual Flight Rules. The rules cover the time and area of the sky with limited visibility when pilots must use navigational instruments to take-off, fly and land the aircraft. FAA air traffic controllers dictate all aircraft maneuvers on the ground by their radar and other flight guidance instruments.

Instrument Flight Rules (IFR): IFRs are the rules governing the procedures for conducting flight under Instrument Meteorological Conditions (IMC), and are determined by FAA air traffic controllers.

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Definitions

Letter of Authorization: This letter is issued to the school with the Air Agency Certificate. It provides a listing of the specific programs that have been authorized for the school to offer. It expires at the same time that the FAA issued Air Agency Certificate expires.

Medical Certificates: A medical certificate is issued by the FAA based upon completion of an appropriate medical examination by an FAA approved doctor. All pilots must have an appropriate medical certificate to be authorized to fly. There are three classes depending upon the extent of the physical exam:

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Definitions

Medical Certificates (cont.): First Class: The highest level of medical certificates – required for

pilots to exercise the privileges of an ATP rating. Second Class: Required for pilots who are exercising the privileges

of their commercial pilot’s license or are providing flight instruction. Third Class: The initial certificate required of pilots to exercise the

privileges of their private pilot’s license.

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Definitions

Part 60: This regulation (14 CFR, Part 60), governs initial and continuing qualification and use of aircraft flight simulation training devices that are used for meeting training, evaluation, or flight experience requirements for flight crew member certification or qualification.

Part 61: This is a section (14 CFR Part 61) of the FARs that specifies the requirements for various pilots‟ licenses and ratings. Part 61 training cannot be approved for VA benefits because it relates to one-on-one training without regard to a standard curriculum or school training. It is the flight equivalent of tutorial assistance. However, it is a useful reference and describes the requirements for obtaining the various pilots licenses.

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Definitions

Part 63: This section (14 CFR Part 63) of the FARs specifies the requirements for schools and courses to train flight engineers. Part 63 programs may be approved for enrollment of veterans and others eligible to receive VA education benefits because it requires a school curriculum and standard course outline that must be followed.

Part 141: This section (14 CFR Part 141) of the FARs specifies requirements for schools to train students for pilots‟ licenses and ratings. Training under part 141 may be approved for the enrollment of veterans and others eligible for VA education benefits because it specifically relates to school training and standard course outlines that must be followed.

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Definitions

Part 142: 14 CFR Part 142 of the FARs states the requirements to train students to fly using simulators. Simulator training devices can be used in most fight programs, However, simulator training is most often specific to large-body aircraft (Boeing 777 or 717, L1011, etc.) using large, complex simulators to acquire type-ratings. Simulator training is less costly than using/flying the actual aircraft. For example, the cost to fly a Boeing 737 is about $75-$90 per minute, that’s up to $5,400 an hour! A complex flight simulator may cost $500-$800 an hour. These costs increase at least annually.

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Definitions

Ratings: These generally refer to the type or class of aircraft a licensed pilot is authorized to fly such as. Aircraft Type Rating Category Rating Class Rating Instrument Rating

Rotary Wing or Rotorcraft: An aircraft that is propelled and lifted by the action of the wings (rotors) such as a helicopter.

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Definitions

Stage Checks: Stages are subdivisions of the flying or ground training syllabus of instruction. A stage may be subdivided into individual lessons corresponding to a flight or ground training event. Normally, a stage check is given to the student to determine mastery of the lessons comprising a particular stage. Satisfactory completion of a stage check indicates the student is ready to progress to the next stage of the syllabus.

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Definitions

Training Course Outline (TCO): 14 CFR 141.55 describes the requirements of a training course outline and syllabus. Each flight training program approved for veterans training must have an FAA approved TCO. A TCO will normally contain details of school’s facilities, aircraft inventory, instructors, procedures for operations, airspace and airfield facilities, and a training syllabus for each flight training program.

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Definitions

Training Syllabus: The syllabus is comprised of all lessons, both ground and flight training, which must be successfully completed prior to taking the FAA licensing/certification check ride for the particular program of training. Several standardized training syllabi are available, such as Jeppesen-Sanderson or Cessna Training programs; or, a flight school may have its own unique FAA approved syllabus for one or all of its respective programs. In either case, the flight and ground training time, whether approved or not by the FAA, MAY NOT exceed the FAA Part 141 minimum hourly course requirements for each individual program.

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Definitions

Visual Flight Rules: The rules that govern the procedures for conducting flight under visual conditions, and also used to indicate weather conditions that are equal to or greater than the minimum VFR requirements.

Visual Meteorological Conditions: Meteorological conditions expressed in terms of visibility, distance from clouds, and ceiling equal to or better than specified minima.

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Definitions

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Questions?

This presentation was created by Ron Scoggins (Lead Education Liaison Representative, U.S. Dept. of Veterans Affairs) and Katherine Snyder (Program Specialist, Florida State Approving Agency), in January 2014 and revised March 2015

Ron Scoggins

727.319.5969

[email protected]

Mailing Address:

US Department of Veterans AffairsVA Regional Office

ATTN: Education Outreach (272A)P.O. Box 1437

St. Petersburg, FL 33731

Katherine Snyder

941.979.2525

[email protected]

Mailing Address:

Florida Department of Veterans' AffairsState Approving Agency for Veterans'

Education and TrainingP.O. Box 31003

St. Petersburg, FL 33731

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Contact Information

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