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Why does the State Approving Agency (SAA) approve courses for veterans' training rather than the Federal Government?

The U.S. Government under the provisions of Title 38, U.S. Code, contracts with each state government for the approval of courses for the training of veterans and eligible persons. The California Department of Veterans Affairs, California State Approving Agency (CSAAVE), is the agency designated as the State Approving Agency (SAA) to perform this contractual obligation. When requested, a CSAAVE Education Specialist will provide assistance to school administrator(s) regarding the approval of courses at their institution.

What are the approval objectives?

Approval of courses of study under the provisions of Title 38, U.S. Code, is allowed in pursuit of educational, professional, or vocational objectives. An educational objective is one that leads to the awarding of a diploma, degree, or certificate reflecting educational attainment. A professional or vocational objective is one that leads to an occupation.

What are the general requirements for approval under Title 38?

A. The two-year rule: The institution must be degree granting or nondegree granting approved or licensed in accordance with California Education Code (CEC). The two-year rule applies only to courses that do not lead to standard college degree and are offered by private (as opposed to public) institutions. Courses of this type may be approved if:

  1. 1. The educational institution has been operating for at least two years; or

  2. 2. The course is offered at a branch of the educational institution and the branch has been operating for at least two years; or

  3. 3. Following either a change in ownership or a complete move outside its original general locality, the educational institution has been in operation for at least two-years unless the institution retains substantially the same faculty, student body, and courses as before the change in ownership or the move outside the general locality.

B. Courses Contracted Out: Any course that is contracted out must be separately approved by CSAAVE and the provisions of subparagraph (A) above will apply.

C. Courses Near Military Facilities: Regardless of the provisions in subparagraphs A2 and 3 above, a course may be approved if it is offered by an educational institution under contract with the Department of Defense or the Department of Transportation and is given on or immediately adjacent to a military base, Coast Guard station, National Guard facility, or Selected Reserve facility.

D. Approval criteria for accredited courses/institutions:

  1. The educational institution keeps adequate records, as prescribed by the state approving agency, to show the progress and grades of the eligible person or veteran and to show that satisfactory standards relating to progress and conduct are enforced.

  2. The educational institution maintains a written records of the previous education and training of the eligible person or veteran that clearly indicates that appropriate credit has been given by the educational institution for previous education and training, with the training period shortened proportionately.

  3. The courses, curriculum, and instruction are consistent in quality, content, and length with similar courses in public schools and other private schools in the State, with recognized accepted standards.

  4. There is in the institution adequate space, equipment, instructional material, and instructor personnel to provide training of good quality.

  5. Educational and experience qualifications of directors, administrators, and instructors are adequate.

What courses are precluded from approval under Title 38, U. S. Code?

  1. A. Bartending, personality development or any course which is a vocational or recreational in character.

  2. B. Private pilot licensing.

  3. C. Courses given by radio.

What courses are presumed to be a vocational and require the individual veteran to establish that the courses will be of bona fide use in the pursuit of his or her present or contemplated business or occupation?

Any music course (instrument or vocal), public speaking course, dancing, and sports or athletics such as horseback riding, swimming, fishing, skiing, golf, baseball, tennis, bowling, sports officiating or other sport in athletic courses. Courses in applied music, physical education, or public speaking which are offered by institutions of higher learning for credit as an integral part of a program leading to an educational objective can be approved if the veteran or eligible person can establish that the course will be of bona fide use in the pursuit of his or her present or contemplated business or occupation.

What is the Veterans Information Bulletin (VIB)?

Schools are required to prepare and distribute to each veteran or eligible person a veterans information bulletin (VIB) upon enrollment. School catalogs may be requested in lieu of a VIB but may require modifications or addenda to meet the standards of a VIB. A sample veteran's bulletin is included with the Title 38 application.

Is the Veterans Information Bulletin (VIB) a requirement?

No. The institution may submit its catalog without a VIB Bulletin as long as the policies conform to those in the sample VIB. If the catalog policies do not conform to those in the sample VIB, the institution may prepare an addendum to the catalog to include the policies that are absent from the catalog.

Refund policy is required of all non-accredited schools. Title 38, U.S. Code requires non-accredited schools to apply minimally the following refund policy. It is the State Approving Agency's suggestion that schools state this policy verbatim in the Veterans Information Bulletin when requesting original approval under the provisions of Title 38 U.S. Code:

"This school has and maintains a policy for the refund of the unused portion of tuition, fees and other charges in the event the veteran or eligible person fails to enter the course or withdraws or is discontinued there from at any time prior to completion and provides that the amount charged to the veteran or eligible person for tuition, fees and other charges for a portion of the course does not exceed the approximate pro rata portion of the total charges for tuition, fees, and other charges that the length of the completed portion of the course should bear to its total length."

Registration fee for non-accredited schools: Non-accredited schools are limited to a non-refundable registration fee not to exceed $10.00. Any registration fee over $10.00 requires that the amount in excess of $10.00 be subject to pro ration.

Why do CSAAVE specialists visit schools approved under Title 38, U.S. Code?

Once an institution has been approved for veterans training purposes under the provisions of Title 38, U. S. Code, an education specialist from CSAAVE assigned to the area will make periodic visits as part of the contractual obligation of the CSAAVE to the Department of Veterans Affairs (DVA). Generally, the CSAAVE specialist will make an appointment with the appropriate school personnel prior to such visitation. CSAAVE has two primary responsibilities during the visitation:

  1. A. To determine whether an educational institution is qualified and equipped to offer a course of education or training pursuant to the criteria established in both state and federal laws; and

  2. B. To remove a course from approved status if it no longer meets the conditions upon which approval was granted. It is NOT the responsibility of CSAAVE to verify the propriety of DVA authorization of benefits.

What type of records must be made available for examination?

Upon request of a duly authorized representative of the SAA or the DVA, each school must make available for examination all appropriate records and accounts, including but not limited to:

  1. A. Records and accounts, which are evidence of tuition and fees, charged to and received from or on behalf of all veterans and eligible persons and from other students of similar circumstance.

  2. B. Records of previous education or training of veterans and eligible persons at the time of admission as students, and records of advance credit, if any, granted by the school at the time of admission.

  3. C. Records of the veteran's or eligible person's grades and progress.

  4. D. Records of the advertising, sales, or enrollment materials as required by CFR §21.4252(h) and Section 3496(b), Title 38, U.S. Code.

  5. E. Records and computations showing compliance with the requirements of CFR §21.4201 regarding the 85-15 percent ratio of students for each course.

  6. F. Records necessary to demonstrate compliance with the requirements of the CFR §21.4252(e) pertaining to the time necessary to complete an independent study course.

  7. G. Records necessary to demonstrate compliance with the requirements of the CFR §21.4252(g) pertaining to employment of graduates of the course.

  8. H. Records of articulation agreements in accordance with the requirements of the CFR §21.4252 pertaining to transfer to the college or university granting a baccalaureate degree.

In addition to these records, schools having veterans or eligible persons enrolled in a course or courses which do not lead to a standard college degree, must make available the records of attendance, leave, absences, class cuts, make-up work, and tardiness.

Schools having veterans or eligible persons enrolled in non-accredited courses must also make available:

  1. A. Records of interruptions for unsatisfactory conduct or attendance;

  2. B. Records of refunds of tuition, fees, and other charges made to a veteran or eligible person who fails to enter the course or withdraws or is discontinued prior to completion of the course.

What are compliance surveys?

Educational liaison specialists from the U.S. Department of Veterans Affairs will conduct visitations. Their unannounced visitations are commonly referred to as "compliance surveys." The compliance survey program has the following objectives:

  1. A. To verify and assure the propriety of payments of educational benefits to veterans and eligible individuals under the provisions of Title 38, U. S. Code.

  2. B. To assist school or training officials and eligible individuals to better understand their responsibilities and the procedural requirements of the DVA.

  3. C. To determine, on the basis of facts disclosed during visitations, whether there are deviations from the requirements of the law by eligible individuals, schools or establishments.

  4. D. To assure that proper action is taken through appropriate channels for the correction or elimination of existing discrepancies, or the discontinuance of benefits to eligible individuals in the event correction is not accomplished.

Why is there a CSAAVE follow-up to DVA compliance surveys?

The compliance survey program is not intended to duplicate the function of the CSAAVE. Alleged discrepancies in approval criteria discovered by ELS during compliance surveys are routinely referred to CSAAVE for appropriate investigation. The DVA may require CSAAVE to visit the school and report its findings relating to such "apparent discrepancies" within 30 days of receipt of the referral at the CSAAVE office.

What authorizes CSAAVE and the DVA personnel to examine school records?

The Code of Federal Regulations (CFR) Section 21.4209 states that, "Notwithstanding any other provision of law, educational institutions must make the following records and accounts available to authorized government representatives:

  1. A. Records and accounts pertaining to veterans or eligible persons who receive educational assistance under Chapter 1606 of Title 10 U.S. Code; Chapters 30, 32, 34, 35 or 36 of Title 38 U.S. Code; Title 10 U.S. Code 2136, Title 38 U.S. Code 3690c, 5701d, 7332 and 8223(b)(4).

  2. B. Other students' records necessary for the DVA to ascertain institutional compliance with the requirements of these chapters."

What are the requirements when advertising a school approved for the training of veterans and other eligible persons?

The advertising must not be "erroneous, deceptive, or misleading by actual statement, omission, or imitation." (CFR 21.4252(h)(1) and 21.4254(c)(10).) If it is, CSAAVE cannot award approval. Rather than saying a school or program is "VA Approved," samples of correct statements are: "Approved for Veterans Benefits by the State Approving Agency," or "Approved for veterans training." Although the VA issues payments to the veteran students, it is the State Approving Agency for veterans training that approves the school to train veterans and other eligible persons.

Is the school Certifying Official required to monitor veteran-students' attendance?

The Certifying Official is required to monitor and maintain records of attendance and academic progress. If a veteran-student violates either the attendance policy or the standards of (academic) progress policy approved by CSAAVE, the Certifying Official has 30 days to take actions specified in the policy.

Do schools have to give credit for all previous education and training?

No, but schools must adhere to the following policy:

A veteran-student must report all previous education and training. Schools must evaluate and grant credit, if appropriate**, with training time and tuition reduced proportionately with the VA and veteran student notified. (Accredited schools - 38 CFR 21.4253(d)(3), Non-accredited schools. (38 CFR 21.4254(b)(12) and 38 CFR 21.4254(c)(4).)
** The school evaluates and determines what previous education and training is appropriate for credit.

A veteran attending an approved program received a denial letter stating the calendar dates were not approved. What must I do so that the veteran can receive payment?

This may have happened because the VA was not notified of a change in an approved class date at the veteran's school. Dates for all classes or programs must be submitted for approval. If approved dates are changed, the school must notify the CSAAVE of the change. This information is then forwarded to the VA.

I received a federal check from the U.S. Treasury. What is it for?

The VA pays each school an annual reporting fee based upon the number of eligible persons who were enrolled at the end of the calendar year. This fee helps offset the costs associated with certifying the enrollment of eligible students. The VA pays $7 for each student enrolled under any of the chapters noted. The VA pays an additional $4 if an advanced payment check was delivered on behalf of a student.

We recently added a new staff member who will be responsible for certifying the enrollment of veterans. How do we get the new staff member listed as a certifying official?

The VA has a Designation of Certifying Officials Form (VA Form 22-8794) that must be updated if you wish to make changes (additions or deletions) in the certifying officials listed at your institution. You may contact the CSAAVE or VA to secure a copy of the form. Complete it and return it to the VA Regional Office for processing.

I am a new certifying official. Will CSAAVE visit my school to provide assistance to me?

Contact CSAAVE to request assistance and orientation in training. Upon receiving a written request, CSAAVE will then coordinate with you to visit your school. Training is also available on-line at in the section identified as "Information for Education Professionals."

A veteran at my school is pursuing a dual degree. May this be approved?

Dual degrees must be approved by the SAA if the student will exceed the number of hours approved for a single degree. Requirements for completion of both degrees must be forwarded to the SAA.

A student at our institution has a bachelor's degree and now wants to earn a teaching certificate. May the teaching certificate be approved?

Yes, the teaching certificate may be approved as a professional objective since it requires state licensure to practice the profession.

A veteran recently told me that he did not want to transfer any credit hours from his previous college. Does the veteran have an option?

No. A veteran must provide a record of all previous training. The school must maintain a written record that demonstrates that prior credit was evaluated, appropriate credit was granted, and the training period was shortened proportionately.

I am a new certifying official at a clock-hour school. What determines if my veteran students will be paid benefits on a full-time basis?

The VA has published requirements that specify what constitutes full-time enrollment at a clock-hour school. If laboratory instruction predominates in the curriculum, the student must be in attendance at least 22 clock hours per week to receive full-time benefits. If theory predominates, a student must attend 18 clock hours per week.

Must I report any changes to my publications, programs, or policies to CSAAVE?

Yes, failure to report any changes could result in immediate suspension of enrollments and the interruption of benefits to veterans. Changes that must be reported:

  • Education programs offered and policies or regulations described in official school publications.

  • New or Discontinued programs leading to an educational or immediate vocational goal such as a degree, certificate, post-graduate residency, or non-collegiate technical or trade program.

  • Policies on attendance, academic progress, evaluation or credit for prior education and training, and student conduct.

  • Specific types of instruction such as television courses, independent study, practical training or internships, and distance learning.

  • English-as-a-Second Language or other developmental programs.

  • Programs of basic skills, remedial education, and refresher courses.

Can you recommend what are the requirements when advertising a school approved for the training of veterans and other eligible persons?

The advertising must not be "erroneous, deceptive, or misleading by actual statement, omission, or imitation" (CFR 21.4252 (h)(1) and 21.4254 (c)(10)). If it is, CSAAVE cannot award approval. Rather than saying a school or program is "VA Approved," samples of correct statements are:

"Approved for Veterans Benefits by the State Approving Agency," or
"Approved for veterans training"

Although the VA issues payments to the veteran students, it is the State Approving Agency for veterans training that approves the school to train veterans and other eligible persons.

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