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NATIONAL ASSOCIATION OF VETERANS’ PROGRAM ADMINISTRATORS

Proudly Serving Veterans Since 1975

Veterans’ Education Programs

Issues, Legislative, & Education Agenda

2024-2025

Suite 1975, 2020 Pennsylvania Avenue, NW

Washington D.C. 20006-1846

www.navpa.org

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ABOUT US

The National Association of Veterans’ Program Administrators (NAVPA) is an organization of institutions and individuals who are involved or interested in the operation of veterans’ affairs programs and/or the delivery of services to veterans as Veterans’ Education Program Administrators across the country.

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ABOUT US

NAVPA has served as the voice of advocacy for veterans in higher education since its founding in 1975. Our research, training, and policy initiatives have developed programs and support services to ensure veterans achieve their academic and professional goals.

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MEMBERSHIP

NAVPA’s membership includes over 400 Institutions of Higher Learning across the nation that represent over 530,000 student veterans.

Membership in NAVPA shall be extended in three levels of participation:

Institutional Membership
Auxiliary Membership
Associate Membership

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MEMBERSHIP

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Advocacy

NAVPA advocates on behalf of student veterans regarding the GI Bill® educational benefits.

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ISSUES & LEGISLATIVE AGENDA

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PRIORITY ISSUE #1

RENEWAL OF STALLED BILLS TO ADDRESS HARMFUL IMPACTS ON STUDENT VETERANS FROM PREVIOUS LEGISLATION

Issue: Due to P.L.117-333, Section 12, School Certifying Officials (SCOs), have additional responsibilities placed upon them with unreasonable time limitations to complete all requirements. The Department of Veterans Affairs (VA) interpretations of P.L. 116-315, Section 1019 has placed an unduly financial burden on student veterans. Whereas P.L. 117-328, Section 216 is harmful to student veterans if they are called up for military service while attending school.

Discussion: The SCO is the gate keeper of administering GI Bill® benefits for student veterans. The Post 9/11 GI Bill® is the most comprehensive, complex, and robust benefit to manage. The SCOs responsibilities have continued to evolve and expand oftentimes creating overworked employees who are leaving their positions in increasing numbers due to in large part, an increased administrative workload from the VA. In the NAVPA ELR survey conducted in December 2022, 55% of respondents reported having to submit a VA Form 22-8794 to garner access to VA Once for a new SCO.

NAVPA partnered with Purdue’s Military Family Research Institute (MFRI) in a 3-year study of 1,345 SCOs. The analyzed data was presented in 2019 and showed 60% of the respondents reported working in the Financial Aid or Registrar’s office whereas, only 7% reported they worked in a dedicated Military/Veterans Service office. The majority of SCOs surveyed have additional institutional duties and responsibilities other than administering GI Bill® benefits.

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P.L. 117-333, Veterans Auto and Education Improvement Act of 2022

The increased workload instituted by P.L. 117-333, Veterans Auto and Education Improvement Act of 2022, added a time limitation upon the SCO to prepare for either a VA Compliance Survey or a Risk Based Survey. Section 12 grants institutions less than 10 business days to prepare for a comprehensive VA Compliance Survey review.

For large accredited IHL schools with large quantities of information to organize and gather, this is not enough time for the SCO to gather and prepare documents for review while still serving their student veteran population.
For smaller schools, the SCO is wearing a variety of hats in addition to the many SCO responsibilities and struggles to provide this information accurately within the deadline.

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Recommendation: NAVPA was pleased to see the introduction of H.R. 8661, Reforming Education for Veterans Act in June 2024. This Bill addresses the unreasonable 10-day limit for schools to prepare for a VA Compliance Survey and the inequity of centralized institutions completing multiple survey reviews.

UPDATE:

H.R. 1527 Reforming Education for Veterans Act – March 2025

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Recommendation:

NAVPA is very appreciative of Section 3 in H.R. 1527, Department Of Veterans Affairs Compliance Surveys, as it shows Congress is listening to the struggles placed upon their constituents by this time limitation. NAVPA recommends adding the language of “NO LESS THAN” be adopted to the current language, recommend 15 business days, and to have VA recognize institutions as a singular school as does ED and not have duplicity.

In addition, NAVPA recommends adding flexibility to accommodate real world FMLA events, federal holidays, school closures and/or events, and a natural disaster stipulation.

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P.L. 116-315, Isakson and Roe Veterans Health Care and Benefits Improvement Act of 2020

The second concern stems from P.L. 116-315, Isakson and Roe Veterans Health Care and Benefits Improvement Act of 2020, Section 1019, Overpayments to eligible persons or veterans. VA continues to send overpayment letters to schools from old changes in enrollment that occurred prior to this law going into effect. Because the VA is now processing these status changes as overpayments, or if the VA has determined the student is not eligible for the amount of GI Bill® as first identified in their Certificate of Eligibility (COE), the tuition and fees have become a school debt and must be returned to the VA, leaving the student veteran with a balance they were not expecting. The VA will also send debt letters to the student veteran to recoup housing and book payments that were previously approved by the VA at no fault of the veteran. These overpayments are unexpected to the veteran and NAVPA members are reporting these are causing financial hardships.

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Recommendation: NAVPA was pleased to see Congress introduce H.R. 8627, the Student Veteran Debt Relief Act of 2024 to address this huge disservice to our veterans. Student veterans enroll in schools with the promise from the government stating they have earned GI Bill® benefits to cover the cost of their education only to have the VA come back to them later and ask for the return of monies previously approved leaving the veteran with a large debt they were not expecting.

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Student Veteran Debt Relief Act of 2024 introduced 6/27/2024 as

H. R. 8627

This Photo by Unknown Author is licensed under CC BY-SA

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P.L. 117-328 Consolidated Appropriations Act, 2023

This law does not reinstate the student veterans’ GI Bill® benefits if they are activated while in school. Mandating the institution to return all funds for services already rendered is a disservice to the institutional operations and students. Schools that serve active-duty students must have a signed Department of Defense Memorandum of Understanding (DODMOU), where schools are required to follow the DODi1322.25 directive of returning funds. Schools are required to return any unearned Federal Tuition Assistance (FTA) funds on a proportional basis through at least the 60 percent portion of the period for which the funds were provided.

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P.L. 117-328 Consolidated Appropriations Act, 2023

Mandating that students receive an “Incomplete” grade removes the academic freedom of the faculty and the servicemember as the student may decide an “Incomplete” grade is not in their best interest while they serve their country.

This Photo by Unknown Author is licensed under CC BY-SA

This Photo by Unknown Author is licensed under CC BY-SA-NC

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Recommendation: NAVPA was pleased to see the introduction of H.R.1527, Reforming Education for Veterans Act in March 2025, that would amend this law to protect students when activated for military service.

While NAVPA appreciates the language in H.R. 1527 to correct this disservice for students who are activated, we recommend a change in language to this Bill to reflect current procedures followed by the ED and the DOD for when servicemembers must withdraw or take a leave of absence to perform military duty in what is in the best academic interest of the military member.

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NAVPA Legislative Updates:

NAVPA testified before the House Subcommittee on Economic Opportunity Oversight hearing titled “Less is More: The Impact of Bureaucratic Red Tape on Veterans Education Benefits” and addressed two concerns:

The new Risk Based Survey (RBS)
The impact of increased duties placed on the School Certifying Official (SCO)

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NAVPA Legislative Updates:

NAVPA has been meeting with the HVAC and SVAC to voice concerns regarding time requirement to address the 10-day notice for Compliance Surveys.

NAVPA has addressed the lack of a database for the VA to deploy Risk Base Surveys for valid reasons.

NAVPA worked with VBA leadership in the SCO ratio

NAVPA is working with HVAC/SVAC to address 1019 issue

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NAVPA Legislative Updates:

In June 2024, NAVPA provided written testimony and testified before the House Subcommittee on Economic Opportunity Oversight hearing titled “Pending Legislation” and addressed two topics:

Student Veteran Debt Relief Act of 2024
Reforming Education for Veterans Act

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NAVPA Legislative Updates:

In October 2024, NAVPA wrote a response to the VA regarding the 85-15 change they were recommending on the Federal Registry.

On September 18, 2024, the VA proposed a new regulation that states schools with an approved exemption (35% exemption) are required to provide the complete 85/15 data during regular, periodic compliance survey reviews by VA to ensure no more than 85% of students in any approved program which are students in receipt of any financial support from the educational institution or by VA under title 38, U.S.C., or under title 10, U.S.C. The rationale VA stated is that without this information, VA might pay benefits in error.

As written, this proposed rule (regulation) would impact all schools with 35% exemptions with the new regulation.

Discussion: The VA announced on January 16, 2024, that they published a Final Rule, Amendments to 85/15 Rule Calculations, Waiver Criteria, and Reports, through a Federal Register Notice. In this notice, the VA announced that they are amending the regulations by eliminating the four 85/15 rule calculation exemptions. Removing the current definitions in 38 CFR 21.4201(e)(2) of what constitutes a Supported student and by adding additional data to the 85% column will not only inflate the number of counted Supported students but will lead to erroneous calculations reported to VA as these students are considered Non-Supported by law. Institutions nationwide offer scholarships to attract academically strong students. Usually, these scholarships are offered in lieu of procuring loans for disadvantaged students. VA acknowledges that the removal of these definitions will increase the 85% column stating that schools are using these categories to “inflate their tuition and fees since there is no longer an effective counterweight.” The current law states that, “(iv) Undergraduates and non-college degree students receiving any assistance provided by an institution, if the institutional policy for determining the recipients of such aid is equal with respect to veterans and nonveterans alike.” The law requires schools to offer assistance to all students and be considered nonsupported as it is equitable and not being used to entice and enroll only veterans.

VA has consistently changed the rules of engagement for 85/15 since October 1, 2020, and has caused detrimental outcomes and confusion for schools, VA employees, and student veterans. These new VA definitions led to suspended programs nationwide with no GI Bill® students enrolled in those programs limiting the student veterans’ option of school and degree program selection. These bogus suspensions later caused these same institutions to have a Risk Based Survey (RBS) conducted at their school because of an 85/15 “violation.” NAVPA members reported that an 85/15 Rule violation was the catalyst for a RBS even though they were a 35% exempted school.

Congress passed P.L. 117-174, the Ensuring the Best Schools for Veterans Act, addressing the dysfunctional VA interpretation of a Supported student. This was a welcome relief for SCOs and student veterans, but the VA has yet to address this legislation in their rulemaking other than they will address this law more specifically in which a school is exempt from having to track 85/15 ratios.

This announcement further discusses the 35 percent exemption and recognizes P.L. 117-174 that states, “that institution is statutorily exempt from all 85/15 requirements including reporting, computing, monitoring, and complying with 85/15 ratios. Therefore, this law exempts many schools from the requirements of tracking the 85/15 ratios.” However, the VA FORM 22-10216, NOV 2021, 35% EXEMPTION REQUEST FORM 85/15 REPORTING REQUIREMENT, that schools are required to complete to obtain the exemption, states:

To request the 35% Exemption, a copy of this form and a completed VA FORM 22-10215 (STATEMENT OF ASSURANCE OF COMPLIANCE WITH 85 PERCENT ENROLLMENT RATIOS) for the corresponding term must be submitted to the Education Liaison Representative of jurisdiction via email.

Note: This exemption applies only to the submission of routine reports. Your Educational & Training Institution remains obligated to maintain compliance with the provisions of the 85/15 Rule for all programs approved to receive GI Bill® benefits and must provide 85/15 calculations for any term requested by a VA employee or State Approving Agency representative.

Also, per the VA SCO Handbook:

1. 35% Exemption. The total number of VA beneficiaries enrolled in programs approved to receive VA benefits must be less than or equal to 35% of the total student enrollment enrolled in all programs approved to receive VA benefits. An ETI with a 35% Exemption is not required to periodically report 85/15 calculations to the VA.

A 35% Exemption does not mean the school does not have to comply with the 85/15 Ratio Requirement. An ETI with a 35% Exemption must still:

Report to the ELR of jurisdiction when the overall population of VA beneficiaries exceeds 35% of the total enrollment.

Monitor each approved program for compliance with the 85% Ratio Requirement.

Provide 85/15 calculations at the request of a VA official or an SAA official.

VA is not following P.L. 117-174 and NAVPA is concerned the VA will once again create barriers for student veterans to use their GI Bill® under this new final rule announcement. NAVPA is concerned the VA is using language to “amend” and modify current legislation.

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Recommendation:

Historically, VA has created nationwide turmoil with the many 85/15 modifications with little to no understanding on the operations of colleges, universities, and the effect on student veterans.

There has been and still is much confusion among the SCOs and internal VA decisionmakers regarding 85/15 with the numerous definition changes and the 35% national reset that occurred October 1, 2020, and again in 2021. NAVPA proposes a pause on any new changes to 85/15 until the VA can fully interpret, understand, and administer Public Law 117-174, the Ensuring the Best Schools for Veterans Act to address the chaos that has been created by rapid change and lack of communication from the VA.

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NAVPA Legislative Updates:

In December 2024, NAVPA testified before the House Subcommittee on Economic Opportunity Oversight hearing titled “Examining the Effectiveness of the Veterans Readiness and Employment (VR&E) Program” and addressed:

• Staffing and Management

• Effectiveness and Outcomes

• Needs

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NAVPA Legislative Updates:

In March 2025, NAVPA provided Statement for the Record for the House Subcommittee on Economic Opportunity Oversight hearing titled “Legislative Hearing” and addressed three topics:

H.R. 1527 Reforming Education for Veterans Act
Veterans Readiness and Employment Transparency Act of 2025
H.R. 1423 GI Bill® Parity Act

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PRIORITY ISSUE #2

STUDENT CALL CENTER

Issue: NAVPA members are reporting incorrect information being communicated from the VA Education Call Center (ECC) to student veterans.

The ECC customer service has deteriorated to the extent that incorrect information is consistently given to students by the Customer Service Representatives (CSR) and has affected the institution-student relationship.

Discussion: The VA announced on January 16, 2024, that they published a Final Rule, Amendments to 85/15 Rule Calculations, Waiver Criteria, and Reports, through a Federal Register Notice. In this notice, the VA announced that they are amending the regulations by eliminating the four 85/15 rule calculation exemptions. Removing the current definitions in 38 CFR 21.4201(e)(2) of what constitutes a Supported student and by adding additional data to the 85% column will not only inflate the number of counted Supported students but will lead to erroneous calculations reported to VA as these students are considered Non-Supported by law. Institutions nationwide offer scholarships to attract academically strong students. Usually, these scholarships are offered in lieu of procuring loans for disadvantaged students. VA acknowledges that the removal of these definitions will increase the 85% column stating that schools are using these categories to “inflate their tuition and fees since there is no longer an effective counterweight.” The current law states that, “(iv) Undergraduates and non-college degree students receiving any assistance provided by an institution, if the institutional policy for determining the recipients of such aid is equal with respect to veterans and nonveterans alike.” The law requires schools to offer assistance to all students and be considered nonsupported as it is equitable and not being used to entice and enroll only veterans.

VA has consistently changed the rules of engagement for 85/15 since October 1, 2020, and has caused detrimental outcomes and confusion for schools, VA employees, and student veterans. These new VA definitions led to suspended programs nationwide with no GI Bill® students enrolled in those programs limiting the student veterans’ option of school and degree program selection. These bogus suspensions later caused these same institutions to have a Risk Based Survey (RBS) conducted at their school because of an 85/15 “violation.” NAVPA members reported that an 85/15 Rule violation was the catalyst for a RBS even though they were a 35% exempted school.

Congress passed P.L. 117-174, the Ensuring the Best Schools for Veterans Act, addressing the dysfunctional VA interpretation of a Supported student. This was a welcome relief for SCOs and student veterans, but the VA has yet to address this legislation in their rulemaking other than they will address this law more specifically in which a school is exempt from having to track 85/15 ratios.

This announcement further discusses the 35 percent exemption and recognizes P.L. 117-174 that states, “that institution is statutorily exempt from all 85/15 requirements including reporting, computing, monitoring, and complying with 85/15 ratios. Therefore, this law exempts many schools from the requirements of tracking the 85/15 ratios.” However, the VA FORM 22-10216, NOV 2021, 35% EXEMPTION REQUEST FORM 85/15 REPORTING REQUIREMENT, that schools are required to complete to obtain the exemption, states:

To request the 35% Exemption, a copy of this form and a completed VA FORM 22-10215 (STATEMENT OF ASSURANCE OF COMPLIANCE WITH 85 PERCENT ENROLLMENT RATIOS) for the corresponding term must be submitted to the Education Liaison Representative of jurisdiction via email.

Note: This exemption applies only to the submission of routine reports. Your Educational & Training Institution remains obligated to maintain compliance with the provisions of the 85/15 Rule for all programs approved to receive GI Bill® benefits and must provide 85/15 calculations for any term requested by a VA employee or State Approving Agency representative.

Also, per the VA SCO Handbook:

1. 35% Exemption. The total number of VA beneficiaries enrolled in programs approved to receive VA benefits must be less than or equal to 35% of the total student enrollment enrolled in all programs approved to receive VA benefits. An ETI with a 35% Exemption is not required to periodically report 85/15 calculations to the VA.

A 35% Exemption does not mean the school does not have to comply with the 85/15 Ratio Requirement. An ETI with a 35% Exemption must still:

Report to the ELR of jurisdiction when the overall population of VA beneficiaries exceeds 35% of the total enrollment.

Monitor each approved program for compliance with the 85% Ratio Requirement.

Provide 85/15 calculations at the request of a VA official or an SAA official.

VA is not following P.L. 117-174 and NAVPA is concerned the VA will once again create barriers for student veterans to use their GI Bill® under this new final rule announcement. NAVPA is concerned the VA is using language to “amend” and modify current legislation.

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Recommendation: NAVPA recognizes the CSRs answer hundreds of questions daily from veterans and their families that may not be related to education benefits, and we appreciate their assistance. Due to the increased volume of calls to the ECC, we recommend VA creates a dedicated Student Call Center within the VBA where CSRs training can focus solely on education benefits and receive guidance and training from the National Training Team (NTT).

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PRIORITY ISSUE #3

VA INTERPRETATION OF LEGISLATION THAT INCLUDES A 30-DAY TIME-PERIOD

Issue: Current VA interpretation of 38CFR, 21.4203(d)(3) and P.L. 116-315, Section 1010, does not exclude weekends and federal holidays during the reporting period.

Discussion: P.L. 117-328, Section 216 states:

SEC. 216. ESTABLISHMENT OF PROTECTIONS FOR A MEMBER OF THE ARMED FORCES WHO LEAVES A COURSE OF EDUCATION, PAID FOR WITH CERTAIN EDUCATIONAL ASSISTANCE, TO PERFORM CERTAIN SERVICE.

(a) ESTABLISHMENT.—Chapter 36 of title 38, United States Code, amended by inserting after section 3691 the following new section: ‘‘§ 3691A. Withdrawal or leave of absence from certain education ‘‘(a) IN GENERAL.—

(1) A covered member may, after receiving orders to enter a period of covered service, withdraw or take a leave of absence from covered education.

‘‘(b) WITHDRAWAL.—If a covered member withdraws from covered education under subsection (a), the institution concerned shall refund all tuition and fees (including payments for housing) for the academic term from which the covered member withdraws.

‘‘(c) LEAVE OF ABSENCE.—If a covered member takes a leave of absence from covered education under subsection (a), the institution concerned shall— ‘‘(1) assign a grade of ‘incomplete’ (or equivalent) to the covered member for covered education for the academic term from which the covered member takes such leave of absence; and ‘‘

(2) to the extent practicable, permit the covered member, upon completion of the period covered service, to complete such academic term.

This law does not reinstate the student veterans’ GI Bill® benefits if they are activated while in school. Mandating the institution to return all funds for services already rendered is a disservice to the institutional operations and students. Schools that serve active duty students must have a signed Department of Defense Memorandum of Understanding (DODMOU) where schools are required to follow the DODi1322.25 directive of returning funds. Schools are required to return any unearned Federal Tuition Assistance (FTA) funds on a proportional basis through at least the 60 percent portion of the period for which the funds were provided.

Currently, schools are mandated to follow guidance from the Department of Education (ED) and the Department of Defense (DOD) in how to administer to students when or if they are activated while attending the institution.

Mandating that students receive an “Incomplete” grade removes the academic freedom of the faculty and the servicemember as the student may decide an “Incomplete” grade is not in their best interest while they serve their country. Oftentimes, students that withdraw for military duty are focused on their mission and will retake the class upon their return to school as these deployments often can be long lasting of 6 months to one year dependent upon the mission.

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This current interpretation limits the SCO to less than 30 days to report a student’s change in status or a change in the number of hours in credit or attendance to the VA. NAVPA members have shared that this is frequently not a reasonable enough time to administer the current GI Bill® and still meet the 30-day requirement.

A period of 30 calendar days assures that at least 8 of those are non-workdays such as Saturday’s and Sunday’s.

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Recommendation:

NAVPA is asking for clarification of the laws to establish 30 valid workdays excluding federal holidays within a 40-hour work week. Per the Department of Labor, 29 CFR 778.105:

An employee's workweek is a fixed and regularly recurring period of 168 hours—seven consecutive 24-hour periods. It need not coincide with the calendar week but may begin on any day and at any hour of the day.

Many SCOs are non-exempt employees and are scheduled to work the established 40 hours under the Fair Labor Standards Act (FLSA). With the growing number of veterans returning to school and the complicated requirements placed on the SCOs with limited resources, oftentimes these same SCOs are working overtime to meet deadlines set by § 21.4203(d)(3) and the VA to stay in compliance. There needs to be some flexibility in administering the GI Bill® when reporting a change in status to create a more common-sense workweek where SCOs can assist and serve their student veterans while still meeting the intent of the law.

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PRIORITY ISSUE #4

GI BILL® COMPARISON TOOL COMPLAINT SYSTEM

Issue: Institutions of higher learning receive unvetted/unwarranted complaints against them as part of the Department of Veterans Affairs (VA) GI Bill® feedback system, which is then posted on the public GI Bill® Comparison Tool. The recent passing of the Elizabeth Dole Act increases the length of published feedback from 2 years to not less than 6 years.

Discussion: Schools have no recourse to remove or refute the complaints from their public-facing profile regardless of the validity of the complaint. This results in higher education institutions erroneously having a “black mark” on their public record that directly impacts a veteran or other VA education beneficiary’s choice in selecting a reputable school and program of study

The VA GI Bill® feedback system, allows recipients of VA educational benefits to submit complaints against educational institutions they believe have failed to follow the Principles of Excellence (POE) established under Executive Order, 13607, signed April 27, 2012, and codified in statue under P.L.116-315, Isakson and Roe Veterans Health Care and Benefits Improvement Act of 2020. While complaints are supposed to be reviewed by the VA and addressed by the institution, not all complaints filed have been true violations of POE and yet are still posted on the institutions profile for public viewing with no option of removal or disclaimer by the institution. SCOs struggle to find a point of contact to have disparities corrected on the GI Bill® Comparison Tool.

VA announced in 2020 that complaints older than 2-years would be removed. However, it appears that the GI Bill® Comparison Tool does not receive updates in a timely manner. Complaints posted on the public site are not vetted by the VA, have issues with a delimitating date, and are posted after student issues/concerns have been resolved.

The institutions are required to provide a response to the complainant and to VA as soon as possible, but no later than 30 days from the date that the complaint is sent to the school.

Currently, there is no method to notify the institution when the complaint response submitted to the student is considered satisfactory and the issue closed. Nor are schools notified when complaints have been removed from the public facing GI Bill® Comparison Tool. There is no opportunity for institutions to contest a complaint. Nor are there any known delimiting dates for complaints as they are posted on the GI Bill® Comparison Tool and all complaints are reviewed during Compliance Surveys.

NAVPA is concerned that these unvetted complaints will trigger unwarranted Risk Based Surveys at institutions. Members have reported the following examples of invalid complaints:

A school received a complaint that they are not a Yellow Ribbon school when in fact they are and published as such on the GI Bill® Comparison Tool.
A school received a complaint from a non-student demanding to be certified as attending on-ground classes in an online only program. She was directed by the VA to file the complaint.

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With the new legislation passed through the enactment of the Elizabeth Dole Act- Section 215 -Improving Transparency and Accountability of Educational institutions for Purposes of Veteran Educational Assistance the VA will now allow all information on the GI Bill Comparison Tool including Feedback to be retained for a period of not less than 6 years. This goes well beyond the current VA retention policy of 2 years for feedback and 3 years for VA Document Compliance per 38CFR 21.4209.

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Members have reported the following examples of invalid complaints:

An RBS was initiated due to unsubstantiated student complaints. The complaints which were submitted to the VA were really errors on the student’s part not understanding school policies or how the GI Bill® works.
One school reported receiving complaints because of benefit processing errors by the VA, not the institution. But the VA does not have a process to count such complaints as anything other than fault by the school.

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Recommendation:

While the Elizabeth Dole Act provides some positive updates to the Feedback tool, there are still several items that need to be addressed and clarified.

NAVPA asks that:

The VA vets all complaints so as not to post unwarranted/unproven feedback which could trigger Risk Based Surveys (RBS). Stop posting unvetted and unwarranted complaints/feedback on the GI Bill® Comparison Tool.
The VA provides schools with the process to challenge student feedback before it is published.
The Elizabeth Dole Act aligns feedback retention policy so that it is consistent with 38CFR 21.4209(f) of 3 years.

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Recommendation:

If a valid complaint has been addressed and closed to everyone’s satisfaction, it should not be used as retribution against the school nor published on the Comparison Tool. VA should notify the institution that the complaint has been resolved and closed.
NAVPA recommends that VA not accept anonymous complaints. Schools can better serve their students who may not fully understand their benefit if they can identify who the students are and help them in understanding the very complicated GI Bill®. Anonymous complaints would make it impossible for the institution to address the students’ concern and make the feedback difficult.

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NATIONAL ASSOCIATION OF VETERANS’ PROGRAM ADMINISTRATORS

ON THE HILL

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Areas of Concern

LACK OF ELRS TO SUPPORT SCOS

Issue: There are not enough Education Liaison Representatives (ELRs) to support the School Certifying Officials (SCO’s) in the implementation of the many changes in recent Department Veterans Affairs (VA) policies, procedures, and legislation.

Discussion: There have been many job postings by the VA for ELRs across the nation in the past two years. It is our understanding that the VA is experiencing a major employee shortage. This has been highlighted in the SCO community from lack of communication from ELRs, missing reports, delay in catalog approvals, and lack of training.

SCOs are reporting a decline of communication from the state ELR when addressing the numerous changes that have occurred in the past three years. Oftentimes, SCOs send emails asking questions or need clarification regarding a student veteran issue, and these emails will go unanswered. The VA established ELR email boxes for schools to submit concerns or questions. However, these email boxes often are not monitored as the limited ELRs are backlogged in other responsibilities.

Per the SCO Handbook:

When to contact your ELR:

Updating Certifying Officials; VA Form 22-8794
Questions about reporting student enrollment and related changes
Access to VA-Once and related technical guidance
85/15 reporting matters
Clarification of approval issues, WEAMS 22-1998 reports

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Recommendation:

NAVPA recommends a review of the current organizational structure within the VA Education Services to ensure the ELR has administrative support to meet mission requirements. Hiring a team to input mundane data will free up the ELR to respond to the needs of SCOs in understanding specific student veteran issues and the many changes in policies and procedures.

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Recommendation:

NAVPA also recommends a strong mentoring and communication system be developed within the Veterans Benefits Administration (VBA) to support the necessary ELR communications and training. The lack of ELRs has been crippling in the administration of the GI Bill® to the detriment of student veterans.

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TOP FOUR PRIORITY ISSUES

Areas of Concern

SCO HANDBOOK UPDATES

Issue: The School Certifying Official (SCO) Handbook has been moved to an online format by the VA. This has created an issue in that little or no communication is sent to the field surrounding updates made to the Handbook.

Discussion:

At the beginning of June 2020 during the global pandemic, VA moved the SCO Handbook to the E-Benefits platform. There was no formal announcement to SCO’s. During this same time, the VA published their announcement of the elimination of Rounding Out in the Handbook but with no notice to schools. Unless an institution was in attendance for VA leadership updates at a conference held in February, schools were uninformed of this change.

During the recent 85/15 announcement, VA had updated the SCO Handbook to reflect the new computational requirement. However, there was never any announcement that the SCO Handbook was updated. Even after VA had rescinded the change, the SCO Handbook was not updated until December with no announcement to the field. This created much confusion for institutions especially those during a VA Compliance Survey due to internal lack of communication. The Handbook tracks revisions posted after the table of contents. Currently, the only way SCO’s can be made aware of VA changes is to review the SCO Handbook revisions and check daily.

NAVPA is concerned about the many changes occurring in the SCO Handbook with no communication and how that will affect Compliance Surveys. There are no historical Handbooks for schools or evaluators to access to review a process at that point in time.

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TOP PRIORITY ISSUES

UPDATE:

H.R. 1527 Reforming Education for Veterans Act

NAVPA supports Section 4 of H.R. 1527, Notification Of School Certifying Officials Of Handbook Updates, as SCOs need to be aware of changes implemented by the VA to stay in compliance with all federal regulations and guidance. Schools want to serve their students in the most effective way and need to have stronger communication and support from the VA.

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ISSUES & LEGISLATIVE AGENDA

TOP FOUR PRIORITY ISSUES

Areas of Concern

DELAYED STUDENT PAYMENTS

NAVPA members are reporting that their students are receiving delayed housing payments for Chapter 33 and delayed payments for Chapter 1606, Chapter 35, and Chapter 31 recipients.

As most recently, there was an update to the Enrollment Manager system in December 2024 effecting 44,500 students per the VA.

Discussion:

At the beginning of June 2020 during the global pandemic, VA moved the SCO Handbook to the E-Benefits platform. There was no formal announcement to SCO’s. During this same time, the VA published their announcement of the elimination of Rounding Out in the Handbook but with no notice to schools. Unless an institution was in attendance for VA leadership updates at a conference held in February, schools were uninformed of this change.

During the recent 85/15 announcement, VA had updated the SCO Handbook to reflect the new computational requirement. However, there was never any announcement that the SCO Handbook was updated. Even after VA had rescinded the change, the SCO Handbook was not updated until December with no announcement to the field. This created much confusion for institutions especially those during a VA Compliance Survey due to internal lack of communication. The Handbook tracks revisions posted after the table of contents. Currently, the only way SCO’s can be made aware of VA changes is to review the SCO Handbook revisions and check daily.

NAVPA is concerned about the many changes occurring in the SCO Handbook with no communication and how that will affect Compliance Surveys. There are no historical Handbooks for schools or evaluators to access to review a process at that point in time.

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ISSUES & LEGISLATIVE AGENDA

TOP PRIORITY ISSUES

Recommendation:

NAVPA asks that the VA be more receptive to SCOs when reporting technical issues and announce these issues to the SCO community and GI Bill® recipients.

It would be most helpful if these updates were scheduled at a time that would not affect as many students instead of right before the beginning or ending of a semester. December can be a busy time for SCOs as they are certifying their student veterans for the upcoming semester.