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Risk-Based Surveys &

Supervisory Visits

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Risk Based Surveys

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

  • 38 USC §3673A Risk Based Surveys
    • Defines these type of visits in statute

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    • Outlined risk factors:
      • Rapid student population increase
      • Rapid tuition and fee payment increase
      • Volume and severity of validated student complaints
      • 85/15 rule violation
      • Veteran completion rates
      • Financial stability
      • Advertising and marketing practices
      • Federal or State government actions in court

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Georgia Department

of Veterans Service

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Risk Based Surveys

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

38 USC §3673(e): SAAs will conduct surveys within 60 days after receipt of notice of government action

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Types of triggers:

    • Institution is placed on Heightened Cash Monitoring Level 2 (HCM2)

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    • Provisional certification status from Dept. of Education

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    • Notice of punitive action for misconduct or misleading marketing practices by:
      • U.S. Attorney General
      • Federal Trade Commission, or
      • Other Federal agency

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Georgia Department

of Veterans Service

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Risk Based Surveys

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

Types of triggers (cont’d):

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    • Notice of punitive action taken by a state against an ETI

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    • Notice of action taken by an accrediting agency or association due to:
      • Loss of accreditation
      • Risk of losing accreditation:
        • Probation
        • Suspension
        • Show cause related to institution’s academic policies and practices, financial stability, revocation of accreditation

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Georgia Department

of Veterans Service

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Dole Act Sec. 206

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

Oversight of Educational Institutions: Approval Requirements

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Adds an additional approval requirement that requires an educational institution to agree to notify the State Approving Agency (SAA), or VA when acting in the role of an SAA, if the institution becomes subject to a government action or event in 38 U.S.C. 3673(e)(3).

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The educational institution must notify VA or the SAA not later than 30 days after the date that the institution becomes subject to such action or event.

The SAA or VA could take action to:

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  • Submit a recommendation that VA publish a warning on the VA website about the school;

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  • Suspend the school approval by disapproving new enrollments;

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  • Or revoke the school approval by disapproving all enrollments.

Georgia Department

of Veterans Service

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What to Expect if You’re Expecting

a Risk Based Survey…

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

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  • SAA will contact school prior to visit with a Pre-Survey List of Required Items
    • Typically includes student records requests, advertising and marketing materials, financial documentation (except at a public institution), and review of student complaints.

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  • Pre-Survey time will vary based on risk level and SAA schedules.

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  • Upon receipt of documents, SAAs will review items and schedule an on-site visit.

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  • On-site visit will include interviews with school officials, tour of facility, classroom observation, and additional record review.

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  • SAA will take action in accordance with survey findings and institution will receive a final report of the survey findings.

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Georgia Department

of Veterans Service

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Supervisory Visits

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

  • Purpose of a Supervisory Visit:
    • Review approval requirements
    • Discuss differing roles and responsibilities of the SCO, SAA, and VA
    • Identity solutions to problems and provide guidance as needed
    • Provide intervention in cases of non-compliance
    • Establish and maintain professional relationships and foster ongoing, positive communication

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  • Changes in FY25:
    • Expansion to IHLs, NCD, Vocational Flight, Non-Registered Apprenticeships, and OJTs

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Georgia Department

of Veterans Service

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Supervisory Visits (cont’d)

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

  • Scheduling:
    • Generally, will not visit schools with more than 17 VA beneficiaries
    • Generally, will not schedule in back-to-back years
  • Exceptions:
    • Complete turnover of SCOs within the last 60 days
    • Facility recently became active again and approval is out of date
    • Follow up to RBS
    • Change of ownership that does not involve a change in profit status
    • **SAA has received a supervisory visit request from the ETI**

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Georgia Department

of Veterans Service

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What to Expect if You’re Expecting

a Supervisory Visit...

NATIONAL ASSOCIATION OF STATE APPROVING AGENCIES

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    • Should receive notification letter in advance detailing date/time/outline.

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    • Student Files: 3 VA beneficiaries, 1 Non-VA beneficiary

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    • On-site visit may take anywhere from one hour to one day depending on your facility’s needs (most will likely fall into a 2-3 hour time frame.)

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    • Although SAAs aim to cover a range of topics, these visits will likely be tailored to your school’s specific needs and circumstances.

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    • Follow up report sent to school after visit.

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Georgia Department

of Veterans Service

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QUESTIONS

Georgia Department

of Veterans Service