North Carolina State Approving Agency

1. North Carolina State Approving Agency Dr. Joseph Wescott II, Executive Director, NC SAA

2. History • FDR signs GI Bill of Rights • Congress recognizes responsibility of States to determine education of their citizens Late State Approving Agencies created; 1940’s overseen by Governor, but funded by the VA Today A cooperative and successful combined federal-state program!

3. NC SAA Staff • Joseph Wescott II, Executive Director • Program Specialists • Elizabeth Kelly • Jay Fitzgerald • Meghan-Joy Woodall • John Pritchett • Jenne Herbst, Program Assistant • Intern:

4. The Players • The “Triad” • VA • SAA • Institution/SCO • Other players • DoE • DoL • FAA • Accrediting agencies • State L&C agencies And of course--THE VA-ELIGIBLE STUDENTS Mutual trust, Mutual dependence!

5. Education Liaison Rep (ELR) State Approving Agency (SAA) Regional Processing Office (RPO) VA Central Office (VACO) VA School Certifying Official (SCO) It Takes A Team! • SAA & VA collaborate to help you • Interpret laws and regulations • Maintain integrity of programs • Train the SCOs • Encourage greater use of VA benefits • Help your school better serve veterans!

6. NC SAA Mission & Responsibility • To ensure quality instruction, appropriate administration, and fair and equitable practices for every veteran (and eligible person) who enters a NC SAA-approved educational program. • We do this by: • Validating and approving educational courses and programs to be pursued by veterans and eligible persons • Overseeing North Carolina’s educational institutions, and ensuring compliance with federal and state guidelines • Ensuring the interests and prerogatives of the State are preserved in both processes

7. NC SAA Program Specialists’ Assignments* • All: Public and Private Universities, Community Colleges • Elizabeth Kelly: On-Military-Base, Truck, Beauty, Barber • Jay Fitzgerald: Religious Exempt Institutions & Nursing • Meghan-Joy Woodall: Trade, Business, Hospitals, Massage • Joseph Wescott: Flight, High Schools, L&C, new applications * Note: Some assignment overlap occurs based on workload

8. NC SAA Our Partnership with You Approvals • Evaluate educational programs for approval • Provide written evaluations and approvals to VA and the schools Inspections and Compliance Survey Visits • Visit and inspect each new/active educational institution • Confirm compliance for approved courses and programs Technical Assistance • Respond to institutional and veteran requests for information and assistance • Provide written reports to DVA, as requested • Maintain records and files for the State of North Carolina

9. NC SAA The Approval This is THE document that actually conveys State / DVA approval for educational programs to be considered for payment under the GI Bill™. Your Approval contains… • General information about your school • Programs and hours that are approved (or EXCLUDED…) • Calendars, tuition and fees • Unique programs or policies (Remedial / Branches, others…) • Requirements specific to your institution • Note last calendar date approved

12. Remember: Every approval is different! It is specific to your school or institution, and is based upon your catalog and applicable state and federal law. You should read/review your approval annually, and comply daily. Many of your questions are answered here. Keep it handy! NC SAA The Approval, cont.

13. The Addendum… A unique NC SAA Form that contains… The General Information section from the Approval, AND A specific change to the Approval Corrects or changes some portion of an Approval Examples: Changes to the academic calendar date (after published) Change of policy in Requirements section Delete a program or change the hours approved for a program NC SAA The Approval, cont.

14. The Addendum… Addenda are mailed or emailed to you, with instructions Supersedes the original information in the Approval Print a copy of the Addendum and add it to the Approval Comply with the Addendum changes NC SAA The Approval, cont.

16. Also Note: Remedial Training • Computer based remedial content may be certified if it meets the following conditions: • It is delivered in a classroom on campus (set time and place). • Attendance is taken. • An instructor is present at all times to facilitate and answer questions. • Coursework is organized in such a fashion that students are working on the same material during the class period. • Remember: Remedial courses may not be certified if they are offered as independent study, distance learning, or hybrid course delivery.

17. Prior Credit High School Transcripts The DVA Form 22-8794 Continuing Education NC SAA Important Special Interest Items

18. Prior Credit Must be evaluated and recorded (by law…) prior to enrollment OR within 2-terms. This means you must have official transcripts of all previous training on file. Must have proof of prior credit evaluation in the student file. NC SAA Important Special Interest Items, cont.

19. Prior Credit Military Transcripts: Obtain them in accordance with your applicable school policy If your institution has signed the DoD MOU, then you must obtain military transcripts, and they must be evaluated for possible transfer credit If a student has attended degree programs through the military (e.g., Community College of the Air Force), then you must obtain official copies of those transcripts, regardless of your school policy, and evaluate for possible transfer credit NC SAA Important Special Interest Items, cont.

20. High School Transcripts: Are they required? Depends on your school and on your Approval… If HS transcripts document “part” of admission process, YES! Schools that teach degree / IHL programs generally require HS transcripts for new (freshmen) admissions Private and Proprietary schools are “generally” required to meet State standards NCD / Diploma / Certificate programs generally require “proof of high school completion” OR “ability to benefit” NC SAA Important Special Interest Items, cont.

21. NC SAA Important Special Interest Items, cont. VA Form 22-8794 “Designation of Certifying Officials” • When there are changes, submit a new form to DVA and a copy of same to NC SAA. • Be sure to include full contact information for each certifying official • Name, phone and fax number and e-mail address for each certifying official in the appropriate box. • The Approving Official must sign box 7.

22. Important Special Interest Items, cont. Continuing Education Courses • Generally these courses are not approved. • All courses must lead to a vocational objective, i.e. a job. • Few exceptions: state licensed, state mandates, etc. • Contract courses: • Both the contractor and host institution must be approved. • Questions of academic quality control, awarding of credit, certification and records management.

23. NC SAA Compliance Surveys • NC SAA assists DVA with this responsibility • Former “Supervisory Visits” were more focused on SCO training and process improvement • Compliance Survey primarily an audit of federal entitlement program; focus shifted from academic programs to more emphasis on finances

24. NC SAA Compliance Survey Process • NC SAA schedulesvisits with the institution • NC SAA Program Specialist conducts on-site visit reviewing: • Process Management (prior credit evaluation, timeliness/accuracy of certifications, attendance, etc.) • Records Management (required documentation is present) • Visit reportsmaintained at NC SAA with copy sent to DVA • Inspection discrepancies(if any) require resolution with documentation of corrective action to NC SAA (approval issues) or referral to DVA (payment issues). • Expanded audits: • ≥ 30% Financial discrepancies • ≥ 50% Discrepancies of any type

25. Record Keeping Requirements

26. NC SAA Changing Laws, Changing Roles • The Post 9/11 GI Bill • Public Law 111-377 • Public Law 112-249 • Principles of Excellence (Executive Order 13607) • Public Law 113-146

27. Post 9/11 GI Bill • Became effective on August 1, 2009 • A complex program! • Many levels of eligibility • Confusing concurrent eligibility • New benefits similar to original WW II GI Bill • Difficult to understand and administer • SAAs took on new “consultant/trainer” role

28. Public Law 111-377 • Became effective October 1, 2011 • Many positives • More programs now covered by Post 9/11 GI Bill • More potential beneficiaries • A “Game-Changer” for SAAs • Changed State/Federal approval authorities • SAAs acquired new role of assisting VA with Compliance Surveys

29. Public Law 111-377, cont. • Changed States’ authority to approve programs • Accredited, public & non-profit degree programs “deemed” approved without continuing State review • States no longer process approvals for public and non-profit private institutions • Approval AND disapproval authority given to U.S. Secretary of Veterans Affairs • Schools with deemed approved programs provided approval/change notifications to ELR with courtesy copy of catalog/forms to NC SAA • SAAs retained jurisdiction over for-profit schools, and Non-College Degree (NCD) programs at all schools

30. BUT… Big Change Last Year • Effective October 1, 2013, VA no longer accepts modification form--all requirements for approval go to NC SAA. • All NC institutions must submit an approval package to the NC SAA. • All approval related concerns and questions must come to the NC SAA.

31. Public Law 112-249 Improving Transparency of Education Opportunities for Veterans Public Law 112-249, signed on January 10, 2013, mandates, among other things... • A centralized mechanism for tracking/publishing feedback from students and SAA regarding quality of instruction, recruiting practices, and post-graduation employment placement of institutions of higher education. • SAA’s will share with accrediting agencies or associations information regarding the SAA’s evaluation of an IHL.

32. New This Year VA & NASAA Initiatives • National VA Online Feedback (Complaint) System • A centralized online reporting system; launched in Jan 2014 • Report violations of the Principles of Excellence (E.O. 13607) • Report negative experiences with educational institutions • Identify and address unfair, deceptive, misleading practices • Ensure high quality academic and student support services • VA Online Comparison Tool • Launched in February 2014 • Easier to calculate Post-9/11 GI Bill benefits and learn more about VA’s approved colleges, universities and other education and training programs across the country.

33. Also This Year… H.R. 3230 – Veterans Access, Choice, & Accountability Act of 2014 • Signed into law August 8, 2014, as Public Law 113-146 • Primarily addresses veterans’ health matters • Expands Fry Scholarship eligibility to spouses • Effective January 1, 2015 • Entitlement expires 15 years after service member’s death or the date the spouse remarries, whichever is earlier • If also eligible for Chapter 35 (DEA), must make irrevocable election of one chapter

34. P.L. 113-146, cont. Veterans Access, Choice, & Accountability Act of 2014 • Public IHLs and In-State Tuition • Beginning July 1, 2015: Cannot approve programs for which “covered” students, regardless of residency, are charged T&F that are higher than the in-state rate • “Covered individuals” are • Ch 30 and Ch 33 vets discharged or released from active duty (≥ 90 days) less than 3 years before enrollment in the program, and • Ch 33 Fry Scholarship beneficiaries and TOE recipients • But: IHL may require covered individual to demonstrate intent to become resident • Can require any type of proof of intent except “physical presence” STAY TUNED FOR GUIDANCE FROM VA AND STATE OF NORTH CAROLINA

35. NC SAA Responsibilities include: • 303 separate institutions of learning, plus47 branch locations Our Service to You: • Conducted 76 Compliance Survey visits • Processed requests for new approval, resulting in 41 new institutions • Reviewed and completed 175 applications for program re-approval (new catalogs) • Evaluated and approved over 1,000 individual programs Hundreds of technical assistance phone calls and e-mails  *As of September 1, 2014

36. Pending Legislation HR 456 – Reducing Barriers for Veterans Education Act of 2015 • Allows CH33 to be used for application fees at IHLs HR 475 – GI Bill Processing Improvement Act of 2015 • Potential extension of deadline for implementing Section 702 HR 476 – The GI Bill Education Quality Enhancement Act of 2015 • Clarification and codification of approval authority • Capping tuition and fees for flight programs • Changing requirements for Compliance Surveys

37. Thank you! Any (more) questions?