veterans benefits administration march 26, 2015 specific topics of the post-9/11 gi bill ® - ihl

VETERANS BENEFITS ADMINISTRATION March 26, 2015

Specific Topics of the Post-9/11 GI Bill® - IHL

VETERANS BENEFITS ADMINISTRATION

Agenda

• Terminology• IHL Defined• Facility Code Review• Approval Notification• Deemed Approved• Entitlement• Begin Dates• Tuition Assistance (TA)• Graduation and Reporting Issues• Yellow Ribbon• Chapter 33 Payments

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Terminology

• Institution of Higher Learning (IHL)• Long Term Solution (LTS)• Monthly Housing Allowance (MHA)• Post 9/11 GI Bill© (Chapter 33, CH33)• Transfer of Entitlement (ToE)• Tuition Assistance (TA)• Yellow Ribbon (YR)

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IHL

§21.9505 DefinitionsInstitution of higher learning (IHL) means a college, university, or similar institution, including a technical or business school, offering postsecondary level academic instruction that leads to an associate or higher degree if the school is empowered by the appropriate State education authority under State law to grant an associate or higher degree. When there is no State law to authorize the granting of such a degree, the school may be recognized as an institution of higher learning if it is accredited for degree programs by a recognized accrediting agency. * Such term shall also include a hospital offering educational programs at the postsecondary level without regard to whether the hospital grants a postsecondary degree. Such term shall also include an educational institution that offers courses leading to a standard college degree or its equivalent, and is not located in a State but is recognized as an educational institution by the secretary of education (or comparable official) of the country or other jurisdiction in which the institution is located. (Authority: 38 U.S.C. 3034(a), 3313(b), 3323(a), 3452(f))

* A recognized accrediting agency is one of the regional, national, or specialized accrediting agencies recognized by the U.S. Department of Education and/or the state education authority

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Are You An IHL?

• VA can use a facility code to determine if the school is an IHL

• The first two digits of the facility code describe the type of facility

• Do you know your facility code?

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What Do The First Two Digits Represent?

First digit of facility code:1 = Public tax supported facility2 = Private for-profit facility3 = Private not-for-profit facility

Second digit of the facility code:1 = Highest level programs offered are baccalaureate or graduate degrees2 = Accredited hospital (primarily for medical residency or clinical programs)3 = Teachers college (rarely used)4 = Highest level programs offered are associate’s degrees5 = NCD and all other schools including high schools, technical non-degree schools, etc. (some older such facilities may still have a second digit of 8 which is no longer assigned) 9 = Assigned for VR&E only for evaluation services0 = Job training establishments (JTE), i.e., apprenticeship or other on-the-job training

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Approval Notification – Effective October 1, 2013

• School Officials notified of policy changes for Non-College Degree (NCD) Programs in Accredited Public, and Private Non-Profit Institutions of Higher Learning (IHL)

• Public Law 111-377, Section 203 (Prior to 10/1/2013):

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Approval Notification

• Public Law 111-377, Section 203 (Effective 10/1/2013):

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Is Your School Deemed Approved?

First digit of facility code:1 = Public tax supported facility2 = Private for-profit facility3 = Private not-for-profit facility

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Which Schools Are Deemed Approved?

24099911

31099911

15099911

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Which Schools Are Deemed Approved?

24099911 – Not Deemed Approved(For-profit IHL)

31099911 – Deemed Approved

15099911 – Not Deemed Approved(NCD Facility)

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CH33 Entitlement - Veteran or Servicemember

• Generally a veteran or servicemember will begin with 36 months of fulltime chapter 33 benefits

• A veteran or servicemember may have less than 36 months of entitlement available if he/she used another education benefit previously or transferred entitlement to a dependent

• Benefits are paid through the end of a term when entitlement exhausts and where the veteran or servicemember has not reached the 48 month limit or her/his delimiting date

• Payments may be prorated when entitlement exhausts

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CH33 Entitlement – Dependent (TOE)

• Dependents receiving entitlement transferred can receive up to 36 months from a single sponsor and may receive more from multiple sources

• Benefits transferred count as used entitlement only on the transferor (e.g., the person giving the benefit)

• Payments to dependents are prorated when entitlement exhausts (e.g., we do not extend to the end of a term)

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When do benefits begin?

Post-9/11 GI Bill® payments may be paid the later of – August 1, 2009;– The date the individual became eligible for educational assistance

under 38 U.S.C. chapter 33 eligible (usually after 90 days of creditable service following completion of initial training);

– One year before the date the valid election request was received;– The effective date of the election as requested by the claimant,

or– The begin date of the term

NOTE: Payments may be prorated for enrollments that begin prior to the effective date to receive Post-9/11 benefits

§21.9625 Beginning dates14


Tuition Assistance (TA)

Policy Advisory – November 26, 2014•DoD announced that they will no longer authorize Tuition Assistance (TA) for classes for which a member is also receiving benefits under:

– Montgomery GI Bill® – Selected Reserve program (chapter 1606), – Reserve Educational Assistance Program (chapter 1607),– or any other GI Bill® program other than the Montgomery GI Bill©–

Active Duty (chapter 30) program, or the Post-9/11 GI Bill©

program (chapter 33)To implement this policy change, DoD required all schools participating in the TA program to sign updated memoranda of understanding

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Tuition Assistance (TA) & CH33

Scenario:VA issues a tuition payment to your school but you have not certified the student for the period being paid. How did this happen?

Most likely, the student requested chapter 33 payments directly by sending VA a TA form, which is permissible

What should you do now? Should you certify the period to VA?

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Tuition Assistance (TA) & CH33

Our goal is to avoid duplicate paymentsShould you certify the period to VA? •You are not required to certify students that do not request certification•Remarks must be used to advise VA that the student is using TA when certifying enrollments or changes•You should talk to the student and coordinate certification of future enrollments if the student has ever requested enrollments certified in the past

Note: Changes to enrollments should be reported

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Graduation and Reporting Issues

Veterans Outcome Measures Reporting•In 2015, VA will begin publishing outcome measures for chapter 33 beneficiaries using the enrollment and graduation/program completion information

•Reported by your educational institution through VA-Online Certification Enrollment (VA-ONCE).

•Outcome measures data will be published by academic year cohort (August 1st to July 31st)

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Veterans Outcome Measures Reporting•VA is requesting your institution report graduation/program/certification completion information on all Veterans, Service Members and their family members in receipt of all GI Bill® benefits.

•If your institution has elected not to report any or all instances of graduation/program/certification completion, VA will not be able to report accurate graduation/program completion rates for your institution.

•If your institution tracks similar outcome measures for a broader group of Veterans, Service Members, and their family members; VA will consider publishing your data in addition to our captured data.

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Reporting Graduation in VA-ONCE•Guidance provided on page 80 of the most recent SCO Handbook

– http://www.benefits.va.gov/GIBILL/docs/job_aids/SCO_Handbook.pdf•You should submit a Termination•Degree Program Graduate = Graduation•Non-College Degree (NCD) Graduate = End of Term or Course•The last date of the term selected will be pre-populated as the date of termination •If subsequent terms were previously certified, VA-ONCE will prompt you to terminate those enrollments, or to leave them as previously certified Note: You only report graduation if it occurs at the end of a term during which the student was receiving GI Bill® benefits

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Reporting Graduation in VA-ONCE•Report the end date of what is certified

Example: •Student certified from 3/6/15 to 5/6/15•Student doesn’t complete internship by end of term•Student completes internship 5/18/15•Graduation date reported should be the end of term date of 5/6/15

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Reporting Unsatisfactory Conduct, Progress, or Attendance in VA-ONCE

•Unsatisfactory Progress (Academic Suspension) must be reported to VA as a termination.

•Terminate the semester the student is suspended

•If suspension follows the fall semester, for example, terminate fall semester and choose “Unsatisfactory Attendance, Conduct, or Progress” as the reason

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Using Remarks in VA-ONCE•Only use remarks when absolutely necessary•Suggested use of remarks

– Communication• Changes made out of order• Clock/Credit reported together (pay most advantageous)• Out of state charges• Using TA• Using “Other” as a change reason, when you must

– Better to avoid altogether

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Award Adjustments in VA-ONCE•Withdrawals and Terminations

– Example:– Student certified for 12 credit hours, $1200 tuition/fees– Student terminates from all 12 credit hours– SCO should now terminate and certify 0 credit hours, $0.00

tuition/fees

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Certifying Modular TermsCertifying Modular Terms

Example:Example:•Should you report tuition and fees per the students’ billing cycle or can schools report tuition and fees to maximize tuition payout?

•Schools should report tuition and fees based on the submission of each term or modular program

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Example:Example:•A student is pursuing a certificate program which cost $20,000 and the program is broken into 5-week terms•The school is actually billing the student $20,000 on the first term.

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 (or whatever formula they use)?

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Answer:Answer:•The school should not report $20,000 on just the first term for the entire program

•The school should break-up the tuition and fees and apply them to each modular term

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Yellow Ribbon

Public Schools vs Private Schools

•Public Schools (effective 8/1/2011)– Chapter 33 pays the actual net cost for in-state tuition and

fees (after the application of any waiver, scholarship, aid, or assistance) directly to the institution

– Yellow Ribbon Program payments can cover the un-met charges (i.e. graduate or out of state charges)

– Annotate the out of state charges in the Remarks– No annual cap

Note: See presentation on Section 702 for impact on these provisions28


Yellow Ribbon

Public Schools vs Private Schools

•Private Schools (effective 8/1/2011)– Chapter 33 pays the lesser of the actual net cost for tuition

and fees (after the application of any waiver, scholarship, aid, or assistance) or the $20,235.02 cap-rate for the academic year

– Academic Year (August 1, 2014 through July 31, 2015)– Yellow Ribbon Program payments can cover the un-met

charges (i.e. private school, graduate, or out-of-state charges).

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Yellow Ribbon Example (Private School)

Example of payments after August 1, 2011:

A student, 100% benefit level, is attending a private school for 12 credit hours (Full Time) for the Spring 2015 term. The institution charged the student $30,000 for tuition and $2,000 for fees. This is the claimant’s first enrollment period at the institution for this academic year.

The institution certifies on the VA Form 22-1999: $32,000 for Tuition and Fees

VA PaymentsCertified for Tuition and Fees from School $32,000.00Less payment for Tuition and Fees from the VA $20,235.02Remaining in un-met charges $11,764.98

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Yellow Ribbon Example (Private School) Continued


VA Payments $32,000.00 Certified for Tuition and Fees from School -$20,235.02 payment for Tuition and Fees from the VA $11,764.98 remains in unmet charges

Can the student receive Yellow Ribbon and how much?

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Yellow Ribbon Example (Private School) Continued


$11,764.98 (un-met charges) divided by 2 (VA and School) = $5,882.49

Answer: Yes, VA will pay up to $5,882.49 (matching the amount certified by the school, up to half of the

remaining un-met charges)

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Yellow Ribbon Example (Public School)


A student, 100% benefit level, is attending a public school for 18 hours (Full Time) for the Spring 2015 term.

The institution certifies on the VA Form 22-1999: $4,025.78 for Tuition and Fees$4,500.00 Out of State Charges listed in Remarks$8,525.78 certified for total cost of term

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Yellow Ribbon Example (Public School) Continued


$8,525.78 (total cost of term for in-state + out-of-state charges) - $4,025.78 Paid by VA towards Tuition and Fees $4,500.00 remaining in un-met charges

If the school approved and certified $2,500.00 in Yellow Ribbon contributions, can VA match that amount?

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Yellow Ribbon Example (Public School) Continued


$4,500.00 remaining in un-met charges

If the school approved and certified $2,500.00 in Yellow Ribbon contributions, can VA match that amount?

Answer: No, VA cannot match $2,500.00.

Reason: Half of the Un-met charges =$4,500 divided by 2 = $2,250.00Thus, the VA can pay UP TO $2,250.00

In this case: the VA will pay $2,250.00 for the Yellow Ribbon payment(The institution should only pay $2,250.00 for Yellow Ribbon as well)

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Payments Under Chapter 33

Currently there are no “Advance Payments” under Ch33However,• Books and Supplies• Tuition and Fees• Yellow Ribbon

…when certification information is received and processed before the term begins, these payments may be released up to 2 weeks in advance of the beginning of the term

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Questions

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veterans benefits administration march 26, 2015 specific topics of the post-9/11 gi bill ® - ihl

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