VETERANS BENEFITS ADMINISTRATION ABCs of Certification NCD SCHOOLS October 11, 2015 Jodie Balder NC...

VETERANS BENEFITS ADMINISTRATION

ABCs of Certification NCD SCHOOLS

October 11, 2015Jodie Balder NC ELR


GENERAL INFORMATION

This presentation provides general information about certifying VA students at NCD schools.

More detailed information on many of these topics will be addressed in the new SCO training today & at the NCD School break out session on Tuesday.

This will hopefully allow us time for you to ask and get answers to your questions today.

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Pre-CertificationWhat must be obtained

• Remind the student that they have to send an application for benefits to VA

– Hard copy or electronically on the GI Bill website

• 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

– Must obtain officialofficial transcripts

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

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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 onlyonly 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 completed4


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)

notnot 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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Questions?

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Attendance & Progress PoliciesKnow them!

Know and understand your SAA approved attendance and progress

policies

Often times, it is different than the policy for your Non VA students

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STANDARDS OF PROGRESS

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Weekly Clock Hour AttendanceCheat Sheet

CERTIFICATION

• Report the student’s scheduled hours of attendance

– Ensure that you are not certifying a length, based on the scheduled clock hours per week, that exceeds the program length as approved by the SAA

– The total clock hours certified will be checked on compliance surveys

• If the student misses classes you will NOT report the change to VA BUT

• Follow your school’s published attendance & progress policies, as approved by the SAA, and listed in your approval letter

• You generally cannot extend the student's certified period to VA if the student does not finish on time

TERMINATION

•If the student is not meeting attendance and/or progress standards you will terminate the student’s certification

•You will process a Pro Rata Refund based on the students completed hours vs total required hours for the program •If the student takes a Leave of Absence you will report it to VA

– Different procedures for CH33 than non33

– An extension may be due if student does not finish in the certified period 9


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

• There must be a clear, definite point in time when:– A VA student will be placed on probation/warning (cannot be indefinitecannot be indefinite)

• Report probation/warning through RightNowWeb (RNW)RightNowWeb (RNW)

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

• Law requires VA educational benefits be terminatedterminated when student fails to make satisfactory progress

• Report termination for unsatisfactory progress through VA-ONCEVA-ONCE

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Standards of ProgressWhen & How to Terminate in VA Once

• For unsatisfactory attendance or 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 schoolCHECK 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 conductunsatisfactory attendance, progress or conduct” from the drop down menu for reason

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Attendance PolicyMonitor it!

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

•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 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 (or report an LOA if applicable) with VA within 30 days of the date on which the student stops attending a program

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Leave of Absence (LOA)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 LOAe. You cannot extend past the approved program length

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Questions?

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PRO RATA REFUND

Schools must refund T&F on a pro rata basis when VA students withdraw or do not enroll after paying for courses, in whole or part

•The pro rata refund must, at a minimum, meet the following criteria:– School catalogs must have detailed scription of the refund policy. A simple statement that

refunds are made on a pro rata basis is not sufficient. – The description must be clear enough for students to determine the amount of their refund– VA regulations allow a 10% deviation in the refund from an exact pro rata figure– VA regulations allow schools to retain up to $10.00 of any registration fee

•Schools must make refunds promptly, i.e., within 40 days

• Schools cannot not require VA students to request the refunds

• If a school’s policy is more favorable to the student the school will use their policy

• Schools may apply the pro rata refund policy to VA students only.

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How to Calculate a Pro Rata Refund

• Calculate the number of clock hours the student completed• Divide the completed clock hours by the total approved clock hours• The resulting percentage is the amount the school can keep

Ex: A program is approved for 1528 total clock hours & costs $15,000 The student completed 950 total clock hours

950/1528 = .6217 or 62% $15,000 x 62% = $9300

The school keeps $9300The school refunds $5700 to the studentAny debt with VA is the student’s responsibility

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Questions?

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NON Chapter 33 NCD Payments

• Individuals pursuing an approved program at an NCD school under any chapter other than CH33 (and CH31 Voc Rehab) are paid a monthly stipend based on their Training Time

• The student is responsible for paying all charges to the school

• VA makes no payments directly to the school

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Chapter 33 NCD PaymentsChapter 33 NCD Payments

• Individuals pursuing an approved program at an NCD school may be entitled to the following payments under CH33:

– Tuition and Fees (paid directly to the schoolschool)– Monthly Housing Allowance (paid to the studentstudent)– Chapter 30/1606 Kickers (paid to the studentstudent)– Books and Supplies Stipend (paid to the studentstudent)

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Certifying TuitionAre you reporting the correct

dollar amounts for Chapter 33?

For programs starting in the academic year beginning on August 1, 2015 VA pays T&F up to $ 21,084.89

You certify the net T&F to VA after you deduct:

–Any waiver, scholarship, aid, or assistance (other than loans and Federal funds provided under Title IV) that can only be used toward T&F

–Any Federal aid (other than Title IV FA) such as TA, MYCAA, ROTC etc

The T&F cap is subject to proration based upon benefit % level

•ENSURE YOU ARE NOT CHARGING VA STUDENTS MORE THAN NON VA STUDENTS!

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Chapter 33 NCD Payments

• The T&F payment cap is pro-rated based on the claimant’s Benefit Level (based on length of active duty) as shown below for any program starting on/after August 1, 2015:

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Tuition and Fee Payments

Benefit Level Academic Cap100% $21,084.89

90% $18,976.40

80% $16,1867.91

70% $14,759.42

60% $12,650.93

50% $10,542.45

40% $8,433.96


Certifying FeesAre you reporting the correct

dollar amounts for Chapter 33?

• For CH33 students certify only allowableallowable 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 students in that program

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VA pays directly to the studentstudent:

•A lump-sum Books & Supplies Stipend equal to $83 for each month – Prorated for partial months of attendance and Benefit % Level– Up to an annual maximum of $996 each year

•A Monthly Housing Allowance based on the zip code for the school– prorated for partial months, Rate of Pursuit and Benefit % Level

•A DoD kicker– Only payable if the student relinquished the chapter connected to the

kicker when electing CH33

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Payments



The Books and Supplies Stipend is calculated as follows:Number of Days in Enrollment ÷ 30 X $83 X Benefit Level

•Example: A claimant is enrolled in a NCD program that begins November 15, 2015 and ends November 14, 2016 (360 days as all fiscal transaction are based on 30 day months)

360 ÷ 30 X $83 X 100% = $996.00

A Books & Supplies payment in the amount of $996.00 will be sent to the claimant for the NCD program

IMPORTANT: Because B&S are paid for the ENTIRE program a change in the END DATE may generate additional debts and/or payments on the student

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Books and Supplies Payments


CH33 Monthly Housing ExampleCH33 Monthly Housing Example

100 % Eligible Student

– AUG 2015: Student will receive $405.90

(prorated to pay 8/20 to 8/30)– Sept 2015-Nov 2016: Student

will receive $1107/month– Dec 2016: Student will

receive $332.10(prorated to pay 12/1 to 12/9)

60% Eligible Student

– AUG 2015: Student will receive $243.54

(prorated to pay 8/20 to 8/30)– Sept 2015-Nov 2016: Student

will receive $664.20/month– Dec 2016: Student will

receive $199.26(prorated to pay 12/1 to 12/9)

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Student is scheduled to attend 25 clock hours/week for a Barber program that runs from 8/20/15 – 12/09/2016. The DoD rate for the school’s zip code is $1107/month.

If the Student is scheduled to attend less than full time payments will be further prorated for Rate of Pursuit


TRAINING TIME vsvs RATE OF PURSUITDetermines monthly student payment

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Training Time – NON CH33

Students monthly payment & entitlement Charge is determined by their Training Time

Rates change 10/1 each year

The only time T&F are required is:

- CH30, 35 & 1607 who are < ½ time - Ch30 & 1607 on active duty

Example: CH30 student 22 clock = FT

Full time rate is $1717Student enrolled in 11-15 clock/weekMonthly rate is $858.50

Rate of Pursuit – CH33

Students monthly housing payment & entitlement charge determined by ROP

Rates change 8/1 each year

NET T&F are always required

**Student must be training at >50% ROP to get ANY BAH**

Example: CH33 student 22 clcok = FT FT rate for zip code is $858

- Student enrolled in 15 clock $600.60/mo (70%) - Student enrolled in 11 clock NO BAH (50%)


Determining Training Time ~ Non Ch33Non Ch33

Shop Predominate (FT=22)

16-21 clock hours per week = 3/411-15 clock hours per week = 1/26-10 clock hours per week = <12 but >1/41-5 clock hours per = 1/4

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Training Time- NON CH33. The rate of a student’s training, determined by the number of credit or clock hours the student

takes.

**TT determines the monthly rate of payment and entitlement

charge

Class Predominate (FT=18)

13-17 clock hours per week = 3/49-12 clock hours per week = 1/25-8 clock hours per week = <1/2 but >1/41-4 clock hours per week = 1/4


Determining Rate of Pursuit ~ Ch33

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18 = FT 22 = FT


Questions?

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VETERANS BENEFITS ADMINISTRATION ABCs of Certification NCD SCHOOLS October 11, 2015 Jodie Balder NC...

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