COVID-19 FAQS

COVID-19: IHL SCO FAQs (includes foreign IHLs)

Q1) With the enactment of S.3503 on 3/19/2020, signed into law on 3/21/2020, can an Institution of Higher Learning (IHL) offer programs that were not previously approved by the State Approving Agency due to COVID-19?

No, only programs previously approved by the SAA will be available for IHLs to continue enrollments of GI Bill students.

Note: If the IHL institution seeks approval of any new programs, they must contact the State Approving Agency and complete application.

Q2) IHL SCO education enrollments – S.3503 Enacted: What impact does the enactment of this Senate Bill have on Institutions of Higher Learning (IHL)?

Based on recently passed legislation (Senate Bill 3503, signed into law March 21, 2020), an IHL which converts an approved residence training modality course to an online training modality for that course (distance learning), should not submit changes when the conversion is the only factor. The law only authorizes this special authority from March 1, 2020, to December 21, 2020.

Educational institutions which convert modalities as described above do not need to submit enrollment adjustments for the current term.

Only converted courses – SCOs cannot certify resident credit hours to VA for online courses when there is no approval for a resident training counterpart.

The new law applies equally to current and new students enrolled in the converted courses.

Terms Moving Forward (not already submitted to VA):

IHL educational institutions which convert modalities as described above may submit certification of resident courses converted to online modality as resident courses if the start date of the term is prior to 21 December 2020.

Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.

Must enter Standard Remark “COVID-19 Residence Courses Taken Online” located within VA-ONCE

Note: Normal reporting requirements for all other changes should be completed per SCO handbook. (change in start/end date, change in credit/clock hours, etc.)

Q3) Post 9/11 GI Bill Beneficiary – Monthly Housing Payments: What happens when a modality changes for enrollment terms due to COVID-19?

Based on the new law, Post 9/11 GI Bill students who pursue resident courses converted to an online modality solely due to COVID 19 will continue to receive the MHA rate for resident training. The law only authorizes this special authority from March 1, 2020, to December 21, 2020.

Note: Other types of changes to the student’s enrollment status may affect payments. Non COVID-19 related changes must still be reported per normal requirements.

Q4) Educational Institutions – Post 9/11 GI Bill Tuition and Fee Payments: Will there be any impact on tuition and fee payments when only the modality changes within a term due to COVID-19?

Tuition and Fees reporting requirements will not change due to COVID-19 national emergency.

Examples: SCOs should review Change in fees associated to online modality, prorated building fees, etc.



Note: Regulations apply for same cost of program for non-veteran students. (all students).

Q5) VA education students – Remedial/Deficiency class: Will VA education students be allowed to continue or start remedial/deficiency level courses at Institutions of Higher Learning (IHL) who convert to an online modality due to COVID-19?

Based on the new law, an approved educational institution which converts an approved resident Remedial/Deficiency course to an online training modality for that course (distance learning), may continue to certify these credit hours to the VA as resident credit hours during the authorized timeframe: 1 March 2020, to 21 December 2020.

Terms Moving Forward (not already submitted to VA):

SCO’s may continue to certify Remedial/Deficiency courses due to COVID-19 conversion to modality if the start date of the term is prior to 21 December 2020.

SCO must continue to use the R/D Credit hours section of VA-ONCE.

SCO must enter Standard Remark “COVID-19 Residence Courses Taken Online”.

Q6) If an educational institution creates a new vacation break, or extends such a break, which may include a change in term dates that are due to COVID-19, what steps should the SCO take?

The SCO handbook states to always include inclusive dates of official school vacation periods of 7 or more consecutive days when certifying non-standard enrollment periods for all benefits in non-standard remarks. However, do not report vacation periods on standard length terms. This remains true during this COVID-19 national emergency.

If there is a change in enrollment dates, the SCO must adjust all elements of the enrollment certification to match actual enrollment timeframe. (includes break time and end date)

Specific instructions for amendment reporting are in the SCO handbook.

Standard and Non-standard term lengths are identified in the SCO handbook.

Example: if your facility has a non-standard term: original break was scheduled from 16 March 2020 to 20 March 2020, but the break was extended to 27 March 2020 due to COVID-19, school is to report that the break was changed to be 16 March 2020 to 27 March 2020. Additionally, if the start or end date changes, those changes must be reported.

Note: IHL’s must make SAA aware of any changes in term dates. Current published commencement dates that fall within 7 days (week) still apply if a school makes a change.

Q7) IHL temporarily ceases operations – discontinues training of all students: If an educational institution temporarily ceases operation due to COVID-19, what steps should the school take?

If the educational institution has temporarily ceased operations for all programs and students due to COVID 19, affected students will continue to receive their MHA until the end of the term or 4 weeks (28 days) from the date that the IHL temporarily ceased operations.

When this occurs, the IHL should not submit enrollment adjustments for the current term. However, the SCO must report all affected facility codes and the date(s) of temporary cessation of operations to their Education Liaison Representative (ELR) and State Approving Agency (SAA) AS SOON AS POSSIBLE. It is important to notify the ELR and SAA as soon as practical, so the claimant’s monthly stipend is correctly adjusted.

Terms Moving Forward (not already submitted to VA):

When the IHL resumes operations, if the institution has same or new term dates all standard enrollment procedures remain in place. IHL educational institutions which convert modalities as described above may submit certification of resident courses converted to online modality as resident courses for any training occurring between March 1 and December 21, 2020.

Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.

Must enter Standard Remark “COVID-19 Residence Courses Taken Online” located within VA-ONCE

Q8) IHL discontinues training in select programs: If a school transitions from resident to online classes to continue the training of some students, but must discontinue training in select programs affecting some students, what steps should the school take?

If the educational institution remains partially open (continues to provide training to some students) but must discontinue training to students enrolled in select programs or individual classes, the school must report changes for the students whose training is stopped. Current law only provides protection for stoppage in training when the school ceases operations completely (temporary or permanent).

The SCO should review the IHL’s published attendance and “Incomplete Grade” policy as all normal VA reporting rules still apply.

The SCO must report the date that training ceased. When reporting this change using VA ONCE, the SCO should complete steps to report mitigating circumstances using “COVID 19” as the reason for the cessation of the training. If paper 1999b termination is reported, the SCO should include “COVID-19” in the remarks section.

Terms Moving Forward (not already submitted to VA):

When the IHL resumes operations, if the institution has same or new term dates all standard enrollment procedures remain in place.

IHL educational institutions which convert modalities as described above may submit certification of resident courses converted to online modality as resident courses for any training occurring between March 1 and December 21, 2020.

Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.

Must enter Standard Remark “COVID-19 Residence Courses Taken Online” located within VA-ONCE

Q9) If a student becomes ill due to COVID-19 and cannot continue training while the educational institution continues to offer course training, what steps need to take place?

The SCO should review the IHL’s published attendance and “Incomplete Grade” policy as all normal VA reporting rules still apply.

The SCO should report the withdrawal based on the attendance policy and report COVID-19 as mitigating circumstances. The student’s last day of attendance should be reported as the effective date. In these situations, the law does NOT allow VA to continue payments beyond the last day of attendance.

Q10) If a student is enrolled in a standard IHL degree program involving flight training and the school ceases the flight training due to COVID-19, what steps should the SCO take?

The SCO should review the “Incomplete” grade policy and apply that procedure if applicable. When the training can continue, the student should complete the flight training portion without any further reporting requirements to the VA when a punitive grade is assigned. Normal non-punitive grade requirements have not changed.

Note: The student should not be enrolled in the subsequent flight course until the “I” grade is completed in accordance with the school’s policy.

If the school’s “Incomplete” policy is not applicable, the SCO should report withdrawal from the flight training based on the student’s last date of attendance. The SCO should report COVID-19 as mitigating circumstances.

Q11) What happens when an IHL’s resident lab portion of a course is canceled or marked as incomplete due to the emergency situation and the IHL does not allow the student to move to the next class in the degree program? (i.e. Organic Chemistry 1 lab completion needed to enroll in Org Chemistry 2 next semester) VBA Response:

VA lacks authority to handle these situations in any special way due to COVID 19. The VA has instructed schools to follow their “Incomplete” grade policy and apply that procedure, if applicable. When the school is eventually able to continue training, the student will be allowed to complete the lab portion without any further reporting requirements to the VA. However, if the discontinued class is a prerequisite to future classes, the student cannot enroll in the next sequential required class until the pre-requisite is complete.

If the IHL’s “Incomplete” policy is not applicable, the SCO should report withdrawal from the class based on student’s last date of attendance. The SCO should report COVID-19 as mitigating circumstances. But, if such a reduction changes the student’s rate of pursuit, the student’s monthly housing allowance may be affected.

Q12) Should IHL’s report enrollment changes when they temporarily change from a standard grade scale (A, B, C…) to a Pass/Fail or other grading system due to COVID-19 national emergency?

No, there is no need to report a conversion from a standard grading scale to a Pass/Fail or similar grading systems but there are other implications in doing so. Depending on the IHL’s grading policy, classes taken Pass/Fail may result in a nonpunitive grade if the student fails the class. Rules about nonpunitive grades have not changed.

Although VA does not typically make payments for classes resulting in nonpunitive grades, if COVID 19 is reported as mitigating circumstances for the student’s receipt of a nonpunitive grade (i.e., Fail in a Pass/Fail class) VA will pay for the class.

Refer to the SCO handbook for more information about reporting nonpunitive grades and mitigating circumstances.

Note: The IHL must make SAA aware of change in grading system.

Q13) Our school is once again offering on-site classes and/or hybrid training in addition to continuing to offer the “converted” online program due to the ongoing COVID-19 pandemic. If students choose to pursue the program via the “converted” online modality because of the pandemic, how do we certify? Will the students receive the higher or lower Monthly Housing Allowance (MHA) for attendance through distance learning?

Students enrolled in the converted courses should continue to be certified in accordance with the procedures previously issued for Public law 116-128. Those students will continue to receive the higher MHA rate associated with training in-residence.

Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.

Must enter Standard Remark “COVID-19 Residence Courses Taken Online” located within VA-ONCE

Note: PL 116-128 only authorizes this special authority from March 1, 2020, to December 21, 2020.





Q14) Reporting enrollment changes timely: Will there be acceptable circumstances due to COVID-19 that a IHL school certifying official may not meet the thirty day requirement to report an enrollment change?





Late reporting (30 days from reporting event) is always a concern of the VA. During this COVID-19 period the VA understands that institutions face additional challenges with timely enrollment amendment or adjustment certifications. The VA asks that the institution make every attempt to complete the changes within a reasonable amount of time. VA will consider your mitigating circumstances for the aforementioned when completing a compliance survey.





COVID-19: NCD SCO FAQs

Q1) With the enactment of S.3503 on March 19, 2020, signed into law on March 21, 2020, can a Non-College Degree (NCD) education or training institute offer programs that were not previously approved by the State Approving Agency (SAA)?

No, only programs previously approved by the SAA will be available for NCD institutions to continue enrollments of GI Bill students.

Note: If the NCD institution seeks approval of any new programs, they must contact the State Approving Agency and complete application.

Q2) NCD – S.3503 Enacted: What impact does the enactment of this Senate Bill have on Non-College Degree (NCD) schools?

Based on recently passed legislation (Senate Bill 3503, signed into law March 21, 2020), benefits may continue to be paid for a NCD which converts an approved residence training modality course to an online training modality for that course (distance learning) due to COVID-19, when the conversion is the only change. The law only authorizes this special authority from March 1, 2020, to December 21, 2020.

Educational institutions which convert modalities as described above do not need to submit enrollment adjustments for any terms certified as resident training.

Only converted courses – SCOs cannot certify resident credit hours to VA for online courses when there is no approval for a resident training counterpart.

The new law applies equally to current and new students enrolled in the converted courses.

Terms Moving Forward:

NCD educational institutions which convert modalities as described above may submit certification of resident courses converted to online modality as resident courses if the start date of the term is prior to December 21, 2020.

Use the Resident Credit Hour or Clock Hour portion of the VA-ONCE enrollment certification.

Must enter Standard Remark “COVID-19 Residence Courses Taken Online” located within VA-ONCE

Note 1: If a NCD resumes normal operation of a resident course prior to December 21, 2020, the school must resume certification of the actual training modality (i.e., resident training or distance education), and may only continue to certify online classes if distance education has been approved by the State Approving Agency. The NCD should also cease utilization of the "COVID-19 Residence Courses Taken Online" remark.

Note 2: Normal reporting requirements for all other changes should be completed per SCO handbook. (change in start/end date, change in credit/clock hours, etc.)

Q3) Post 9/11 GI Bill Beneficiary – Monthly Housing Payments: What happens when a modality changes for enrollment terms due to COVID-19?

Based on the new law, Post 9/11 GI Bill students who pursue resident courses converted to an online modality solely due to COVID 19 will continue to receive the MHA rate for resident training. The law only authorizes this special authority from March 1, 2020, to December 21, 2020.

Q4) What happens when an approved program at an NCD education or training institution temporarily ceases resident training and has the capability to convert training to an online modality during the COVID-19 national emergency?

An NCD with a current SAA approved program may continue to train and report enrollments to the VA. Those students who pursue courses converted to an on-line modality solely due to COVID 19 will continue to receive the MHA rate for resident training. The law only authorizes this special authority from March 1, 2020, to December 21, 2020.

SCOs should not report modality changes due to COVID-19 for any current enrollments submitted to VA.

Note: Other types of changes to the student’s enrollment status may affect payments. Non COVID-19 related changes must still be reported per normal requirements.

Terms Moving Forward (not already submitted to VA):

Educational institutions which convert modalities as described above can submit certification of resident courses converted to online modality as resident courses. Use the Resident Credit Hour or Clock Hour portion of the VA ONCE enrollment certification. If any adjustments were made to the start or end date, these adjustments need to be reported to the VA so accurate payments can be completed. Enter Standard Remark “COVID-19 Residence Courses Taken Online”



Note:

The effective dates of the new law covering March 1, 2020 to December 21, 2020 allow NCD schools to continue training for converted programs/classes/courses due solely to COVID-19. When an NCD goes back to normal operations for resident courses, the school will continue to submit enrollment certifications to the VA without the requirement of the additional “COVID-19 Residence Courses Taken Online” remark.



NCD schools not currently approved to offer online courses, will not be allowed to continue to offer online modality after 21 December 2020.

Q5) What happens when an NCD training institution temporarily ceases operations due to COVID-19 and cannot offer a program via online modality?

When this occurs, the NCD should not submit enrollment adjustments for the current term. However, the SCO must report the temporary school closure to the Education Liaison Representative (ELR) and State Approving Agency (SAA) AS SOON AS POSSIBLE. It is important to notify the ELR and SAA as soon as practical, so the claimant’s monthly stipend is correctly adjusted.

If the educational institution has temporarily ceased operations to all students due to COVID 19, affected students will continue to receive their MHA until the sooner of the end of the term or 4 weeks (28 days) from the date that the NCD temporarily ceased operations.

Current law only provides protection for stoppage in training when the school ceases operations completely (temporary or permanent).

Q6) An NCD institution discontinues training in select programs: If an NCD school transitions from resident to online classes to continue the training of some programs, but must discontinue training in select programs affecting some students, what steps should the school take?

The NCD SCO should review their institution’s attendance, leave of absence, and “Incomplete Grade” policy and apply as appropriate.

If the school’s policy dictates that an Incomplete Grade or Leave of Absence is not an option, the SCO must:

Report the withdrawal based on the attendance policy and report COVID-19 as mitigating circumstances.

The program’s last session day should be reported as the effective date.

In these situations, the law does NOT allow VA to continue payments beyond the last day of the program session.

Q7) When an NCD training institution (which had temporarily ceased all operations) resumes operations, what steps should the SCO take to ensure returning VA students receive proper payments?

SCO would use the initial enrollment certification affected by COVID-19 to amend new end date which would cover the hours required to complete the NCD program.

SCO should also amend tuition and fees when:



An increase or decrease is identified for specific fees associated with the continuation of training (admin fee, consumable products, etc.)





If a refund was provided to the student, the school will need to collect refund back from the student.



SCO must report in non-standard remarks the time period due to COVID-19 temporary cease of operations. (last day of training and the first day of resuming training)

Q8) When an NCD training institution (which had temporarily ceased all operations) resumes operations, what steps should the SCO take for VA students who do not return for training?

SCO would use the initial enrollment certification affected by COVID-19 to terminate the student enrollment.

Per normal reporting requirements, the SCO would report last day of attendance as the effective date of termination



SCO should use the standard remark for Mitigating Circumstances “COVID-19”

The school must complete refund to student if applicable.

Q9) For an NCD training institution that has an approved program which includes classroom and practical training, and the institution can convert the classroom training but is unable to convert the practical training, what steps should the SCO follow to submit VA enrollments?

SCO would submit standard enrollment certification.

When the converted online portion is complete, and the NCD institution is still unable to provide resident practical training, the SCO must:

Submit an amended enrollment certification changing the end date of the enrollment to the last day of converted online training.



Submit Standard Remark “NCD LOA COVID-19”

Resuming Operations:

SCO would use the amended enrollment certification (which includes accurate Tuition and Fees) affected by COVID-19 to amend new end date which would cover the hours required to complete the NCD program.

SCO must report in non-standard remarks the time period due to COVID-19 temporary cease of operations. (last day of converted online training and the first day of resuming practical training)

Notes:

The effective dates of the new law covering March 1, 2020 to December 21, 2020 allow NCD schools to continue training for converted programs/classes/courses due solely to COVID-19.

NCD schools not currently approved to offer online courses, will not be allowed to continue to offer online modality after 21 December 2020.

Q10) What happens when an NCD vocational flight training institution temporarily ceases operations due to COVID-19?

When this occurs, the NCD vocational flight institution should submit current flight hours per standard reporting requirements based on the last day of training (time to report will be extended). VA will process and pay benefits for qualifying tuition and fee costs to the NCD flight institution.

Resumes Operations:

When an NCD vocational flight institution resumes operations for flight training:

Normal resumption of monthly flight training reported to the VA using VA-ONCE.



Note: Flight medical certification must still be current.

Q11) If a student becomes ill due to COVID-19 and they cannot continue training while the NCD institution continues to offer course training, what steps need to take place?

The SCO should review their institution’s attendance, leave of absence, and “Incomplete Grade” policy and apply as appropriate.

If the school’s policy dictates that an Incomplete Grade or Leave of Absence is not an option, the SCO must:

Report the withdrawal based on the attendance policy and report COVID-19 as mitigating circumstances.

The student’s last day of attendance should be reported as the effective date.

The NCD institution’s refund policy should be applied as soon as possible.

In these situations, the law does NOT allow VA to continue payments beyond the last day of attendance.

If the school’s policy allows Incomplete Grade or Leave of Absence as an option, the SCO must follow normal established procedures.

Student Resumes Attendance:

An NCD educational institution will complete standard enrollment practices associated with any prior withdrawal by a student.

Note: If the student returns during the 1 March 2020 to 21 December 2020 timeframe, the school may continue to report converted courses to the VA in accordance with established guidance provided in the FAQs.

Q12) Reporting enrollment changes timely: Will there be acceptable circumstances due to COVID-19 that a NCD school certifying official may not meet the thirty day requirement to report an enrollment change?





Late reporting (30 days from reporting event) is always a concern of the VA. During this COVID-19 period the VA understands that institutions face additional challenges with timely enrollment amendment or adjustment certifications. The VA asks that the institution make every attempt to complete the changes within a reasonable amount of time. VA will consider your mitigating circumstances for the aforementioned when completing a compliance survey.



COVID-19: OJT/APP SCO FAQs

Q1) What happens when an OJT or Apprenticeship establishment temporarily ceases trainee program training due to COVID-19 and the facility completely closes all operations?

When this occurs, the OJT or Apprenticeship should submit actual training hours for March (and February if not already submitted).

SCO must select “No” in the “Trainee Enrolled in and Pursuing Approved Program for Month Shown.

SCO must terminate enrollment in VA-ONCE using the Date Terminated data field. If unable to use VA ONCE, SCO must enter the date into block 4 on VA Form 22-6553d-1. The date must be the last day of training completed.

SCO must select “Other” for reason terminated and enter “FACILITY Temporarily Ceased Ops-COVID” in the Remarks text field in VA ONCE.

If using the paper form SCO should state in box 7 of the VA Form 22-6553d-1 form using a PDF attachment (VA Form 22-6553d-1 or agency letterhead) through our “Ask A Question” portal; (Note: The VA is only accepting documents via electronic means. Facsimile, mailed documents, will not be accepted for processing at this time.)

Note: Hours cannot be reported unless they are actual training hours, hours reported must be hours pursued for the approved training plan.

If the OJT or Apprenticeship facility has temporarily ceased all operations due to COVID 19, affected trainee will continue to receive their MHA until the sooner of the end of the program or 4 weeks (28 days) from the date that the facility temporarily ceased operations.

Note: The VA is only accepting documents via electronic means. Facsimile and mailed documents will not be processed during this national emergency.

Q2) What happens when an OJT or Apprenticeship establishment temporarily ceases trainee program (examples: Veteran may still be working but not training: Employer is open, lay-off or furlough of the trainee, etc.) due to COVID-19 but the facility is continuing operations?

When this occurs, the OJT or Apprenticeship should submit actual training hours for March (and February if not already submitted).

SCO must select “No” in the “Trainee Enrolled in and Pursuing Approved Program for Month Shown.

SCO must terminate enrollment in VA-ONCE using the Date Terminated data field. If unable to use VA ONCE, SCO must enter the date into block 4 on VA Form 22-6553d-1. The date must be the last day of training completed.

SCO must select “Other” for reason terminated and enter “INDIVIDUAL Temporarily Stopped Training COVID” in box 7 of the 6553d1 form or the Remarks text field in VA-ONCE.

If using the paper form SCO should state in box 7 of the VA Form 22-6553d-1 form using a PDF attachment (VA Form 22-6553d-1 or agency letterhead) through our “Ask A Question” portal (Note: The VA is only accepting documents via electronic means. Facsimile, mailed documents, will not be accepted for processing at this time.)

Note: Hours cannot be reported unless they are actual training hours, hours reported must be hours pursued for the approved training plan.

In these situations, the law does NOT allow VA to continue payments beyond the last day of training attendance.

Note: The VA is only accepting documents via electronic means. Facsimile and mailed documents will not be processed during this national emergency.

Q3) Under the new law, what happens when an OJT or Apprenticeship establishment can convert trainee programs from resident to online modality due to COVID-19?

The law allows payment for trainees that had a modality converted to online if the facility site can convert from on-site and is able to continue the trainee in their approved training program with hours counted toward journeyman status.

SCO can provide monthly training hours to the via VA-ONCE or using a PDF attachment (VA Form 22-6553d-1 or agency letterhead) through our “Ask A Question” portal.

Note: The VA is only accepting documents via electronic means. Facsimile and mailed documents will not be processed during this national emergency.





Q4) Reporting enrollment changes timely: Will there be acceptable circumstances due to COVID-19 that an OJT or Apprenticeship training establishment school certifying official may not meet the thirty day requirement to report an enrollment change?



Late reporting (30 days from reporting event) is always a concern of the VA. During this COVID-19 period the VA understands that institutions face additional challenges with timely enrollment amendment or adjustment certifications. The VA asks that the institution make every attempt to complete the changes within a reasonable amount of time. VA will consider your mitigating circumstances for the aforementioned when completing a compliance survey.