Education Service Outreach Section IHL – Flight Degrees

1. AVECO Conference 2014 Education Service Outreach Section IHL – Flight Degrees

2. Training Overview • IHL Degrees – Flight Major • Restrictions • Vocational Flight Training v/s IHL Flight Degrees • Approval Criteria – SAA • Contracted Training • IHL Program description – (Degree Program) • Tuition and fees costs (Flight Lab fees) • Academic Standards • Institutional accountability • SCO certifying enrollment • SCO monitoring enrollment changes • VA compliance survey findings

3. IHL Degrees – Flight Major • Colleges and Universities offer Associate or higher degrees majoring in Aviation, Aeronautics or Professional Pilot. • The IHL either owns their own flight training facility or contracts with a vocational flight school to provide the “hands on” flight instruction. • The hands on instruction is offered as a credit hour subject that includes a syllabus of XX hours for each pilot certification subject • The cost of the flight lab instructional hours is charged separately from normal registration fees but all must be charged by the IHL to the student • Academic standards of progress and competency based standards must be in place to monitor student progress.

4. Restrictions Restrictions for Flight Training: - Vocational Flight Training requires student to possess Private Pilot License as prerequisite - IHL degrees only as NCD vocational diplomas and certificates cannot be approved for programs of flight training pilot license ratings The Institution of Higher learning must be approved for the degree program, fully disclose program requirements and term costs, students register at the IHL each term for subjects in the program, all tuition and fees (including flight lab fees) are charged by the IHL and student pays the IHL Must meet FAA Part 141 Air Agency Certificate criteria in addition to approved Training Course Outline and Syllabus for each flight rating. Copy of contract is required when IHL contracts with other entity to provide flight training instructional hours for degree subjects.

5. Restrictions VA does impose the 85/15% enrollment ratio for both vocational flight schools and standard colleges and universities. If an IHL has a VA –Non VA ratio in a program that exceeds 85% supported by VA the institution must monitor and inform VA ELR. - Result is VA will not allow the school to certify any new VA students in the degree program until the ratio is in compliance. Example: IHL has a popular degree program in Professional Pilot and at the start of Spring semester 2014 there are a total of 90 degree seeking students registered. VA students represent 90% (81). The IHL is in violation of approval and must inform VA. The IHL cannot certify any new VA students for this degree major until the ratio is in compliance. VA ELR will officially notify the IHL of the suspension of new enrollments effective the start of the next term. The ratio must be computed for each subsequent term NOTE: VA Education Liaison Representative and or CELO will provide the IHL with instructions and guidance

6. Vocational v/s Degree • Vocational flight training is allowed on the GI Bill by an approved FAA Part 141 Flight School leading to a vocational objective (i.e. Commercial Pilot, Instructor, etc) • GI Bill recognizes a percentage reimbursement to non Chapter 33 students • Chapter 33 recognizes an annual dollar amount cap for vocational flight charges • The approval for flight ratings is approved as not to exceed XX hours of instruction per FAA approval and the TCO • Students pay the flight school for ongoing training • VA issues recurring payment to student

7. Vocational v/s Degree • Non Chapter 33 enrolled in an IHL for a flight degree are only awarded a monthly benefit rate based on the term and credits certified. • Chapter 33 students will be certified to VA for same but also will include tuition and fees • Critical area of review for SCO • VA issues T&F to IHL for amount certified • Student may withdraw during term • Student may be withdrawn by instructor • Student may not utilize all fees certified • *Vocational Flight Training is a “reimbursement” to student based on hours of flight training on a monthly basis

8. Vocational v/s Degree • IHL Degree in Flight or Aviation is offered by an IHL that contains a complete degree curriculum and leads to Associate or Bachelor degree • IHL either owns the flight training center or contracts with an entity to provide this portion of training • The degree program generally includes subjects of flight labs in Private Pilot, Commercial Pilot, Instrument Rating, etc that are assigned academic credits & provide for XX hours of airplane instruction • *IHL degree program does recognize college credits for Private Pilot flight lab subject • IHL certifies degree credits to VA for awarding tuition and fees to IHL, BAH to students, and book stipend

9. State Approving Agency Approval The State Approving Agency (SAA) is responsible for the approval of the IHL degree program: - the IHL is approved by the appropriate State agency(s) – public and private to offer the degree - FAA approval - Contracted training or owned by the IHL - Tuition and fees are charged by the IHL to the student - Student does not pay tuition and fees directly to the Flight facility - Degree program description and full disclosure of training costs are published

10. Contracted Flight Training The IHL is required to have a contract with any entity (Vocational Flight School – FAA part 141 approved) to offer the Flight Lab credit hour training - Contract must contain - owner of facility - location of flight training - aircraft description - qualifications of instructors - Training Syllabus - Approved FAA Training Course Outline

11. Degree Program • IHL program for degrees in Aviation or Pilot will have a standard degree which will include pilot Flight Labs for as an example: • Private Pilot - 2 credits (40 hours of instruction) • Commercial Pilot – 4 credits (80 hours) • Instrument – 2 credits (40 hours) • Multi-Engine – 2 credits (30 hours) • Instructor – 2 credits (30 hours) • * for either airplane or helicopter

12. Tuition & Fees – Flight Degree IHL charges standard tuition per credit hour and fees for standard college subjects. Flight Lab fees are exceedingly higher based on aircraft rental, instructor fees which are based on hourly rates varying based on type of aircraft and horsepower. Typical flight lab fees for a subject in one term may exceed $10,000 The cost is based on a syllabus for lesson plans as prescribed by the Federal Aviation Administration (FAA)

13. Tuition & Fees – Flight Degree The IHL publishes the cost of the flight degree program – and students are charged the tuition and fees when registering each term. - Business office student account ledgers must be maintained for the charges - Business office must reconcile at the end of each term of actual fees student accrued - These costs may vary since this is competency based training and aircraft hourly rates may also vary in price.

14. Institutional Academic Standards The IHL must establish a standard of progress for academic performance of Flight Labs under the IHL academic standards for: - Incomplete grades - Punitive F grades - Pursuit of hours of flight training during the term – when must student retake the flight lab - Limitation of flight lab hours to not exceed the IHL flight lab hour maximum - Communication between Flight program director, Business Office, and SCO

15. Institutional Accountability The SCO must ensure accurate enrollment information is submitted to VA for: - terms and non-standard Flight Lab terms - tuition - standard fees and published fees for Flight Lab - Monitoring and review of Flight Lab hours of training and cost of the training - Amend charges based on actual IHL fees of student Flight Lab hours of instruction - Adjust or terminate when student withdraws

16. SCO Certifications The SCO obtains the registration schedule and student account ledger to accurately certify term dates, credits, modality, and tuition and fees. Monitoring is critical to ensure students do not exceed the IHL flight hours per subject. VA does not allow the IHL to certify flight lab charges beyond the approved hours. *Excessive hours are the student responsibility

17. What the SCO Certifies on each Enrollment • The 85/15% enrollment ratio requirement has been satisfied • Student certified is not an owner or officer of the school nor is the student certified as an official authorized to sign enrollment certifications • The institution holds no power of attorney agreement authorizing the institution to negotiate VA educational assistance allowance checks • No course certified is a repetition of any course previously satisfactorily completed except as permitted by VA regulations • The course or courses certified (added: excluding DEEMED approved institution degree programs) are approved by the State Approving Agency and are generally acceptable to meet requirements for the student’s objective

18. Example Chapter 33 student certified to VA for Spring Semester 2014 in AS Professional Pilot Degree program. 15 credits = $ 1,800 Standard fees = $ 340 Flight Lab fees = $12,000 Student withdraws from the flight lab Private Pilot 2 credit subject March 10, 2014 IHL Flight instructor reports $4,500 of fees charged

19. Example A remaining balance of $7,500 in flight lab fees for the Private Pilot 2 credit subject is confirmed - In this example SCO would submit an amended certification to VA reducing total fees by $7,500 resulting in a school overpayment to VA *This amount should not be viewed as a student refund or no refund at all if over the time frame for the institutional policy to refund student. - Following the amended certification SCO would submit an adjusted certification reducing total number of credits from 15 to 13.

20. Example Basis of this action is the fact that the IHL flight lab fees for Spring term for the 2 credit subject was $12,000 based on 40 hours of instruction for the Private Pilot Flight Lab syllabus. Fact that student actually completed 15 hours resulted in balance of fees certified but not pursued.

21. Example 2 Student registers and pursues Private Pilot 2 credit subject which requires 40 hours of flight instruction. The cost is $12,000. Student level of proficiency is below standard and flight instructor will not sign off satisfactory status at the conclusion of 40 hours. Student requires additional hours. The additional hours and charges cannot be certified to VA as the maximum of 40 hours were certified and paid by VA.

22. VA Compliance Findings • Identified IHL’s certifying excessive flight lab fees beyond the maximum hours for the subject. • IHL Business Office Manager had no exchange of information from the Flight Training Director of actual charges for unit flight labs • IHL Business Office Manager could not reconcile any charges until student graduates or leaves the college which may take 6-8 semesters • Students and flight instructors not following established syllabus for instruction

23. VA Compliance Findings • The IHL • did not have a valid contract with the flight school entity providing flight instruction • did not have any standards of progress for flight degree students • retained unspent flight lab fees when students withdrew from the flight lab subject • The IHL did not charge students for flight lab fees and students paid directly to flight training location or contractor – yet IHL certified flight lab fees • No procedures for grading practices for flight labs

24. COMPLIANCE SURVEY