Centralized Certification

Report
Centralized Certification
VETERANS BENEFITS ADMINISTRATION
AVECO July 14 – 18, 2014
Overview
• Centralized Certification Procedures
• Purpose. This document provides formal instructions for
implementing Centralized Certification of enrollment
information.
• New Procedure. As permitted by 38 CFR 21.4266, educational
institutions with multiple campuses may be eligible to submit
enrollment certifications to VA from a centralized location.
Although “centralized certification” is not required, it does
provide a streamlined alternative for institutions with multiple
campuses.
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Terminology
•
Common terms associated with centralized certification are defined below.
•
Administrative capability – the ability to maintain all records and accounts that 38
CFR §21.4209 requires.
•
•
Branch campus – a location of an educational institution that:
(a) Is geographically apart from and operationally independent of the main
campus;
(b) Has its own faculty, administration, and supervisory organization; and
(c) Offers courses in education programs leading to a degree, certificate, or other
recognized educational credential.
•
•
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Terminology
•
Combined Approval – a single approval of courses offered by the main campus and
a branch/extension. “The State approving agency may combine the approval of
courses offered at the main campus only if the extension and the campus it is
dependent on are within the same state.” (38 CFR 21.4266(e))
•
Extension – a location of an educational institution that is geographically apart
from and is operationally dependent on the main campus or a branch campus of
the educational institution.
•
Main Campus (or Parent Facility) – the location where the primary teaching
facilities of an educational institution are located. If an institution only has one
teaching location, that location is its main campus (when unclear, this is the
location of the primary office of the Chief Executive Officer).
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Terminology
•
Minimum Period of Operation – the minimum amount of time that an educational
institution (or branch or extension of such educational institution) must have been
continuously operating and offering courses before a State approving agency may
approve a course(s). Branches and extensions are subject to the minimum period
of operation requirements as stated in 38 CFR 21.4251 regardless of whether the
branch or extension receives a separate or combined approval.
•
Point of contact (POC) – a designated educational institution employee at an
extension or branch campus that does not have a school certifying official on
location. The POC performs various functions similar to those of the certifying
official but does not have the capability to certify enrollments through VA-Once.
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Terminology
•
School Certifying Official (SCO or CO) – a representative of an educational
institution designated to provide VA with the reports and certifications that title
38, Code of Federal Regulations, requires.
•
State Approving Agency (SAA) of jurisdiction – the SAA for the state where the
residence course is being taught. The SAA with jurisdiction over the main campus
will not have jurisdiction over an approved branch/extension unless that
branch/extension is in the same state as the main campus.
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CENTRALIZED CERTIFICATION - SCHOOL RESPONSIBILITIES
•
An official located at the main campus must request approval of centralized
certification with the ELR of jurisdiction.
•
Once approved for centralized certification, a school certifying official must add a
POC for each approved branch or extension as a "user" in VA-Once. POCs must
have access to VA-Once in order to provide certification information to
beneficiaries and SAA and VA representatives. However, POCs should not be
approved to transmit, edit, or delete certifications in VA-Once. SCOs will also be
required to add POCs for branches/extensions that previously had their own
designated certifying officials. ELRs will revoke certifying official access for all
individuals with access at those locations upon notification of approval for
centralized certification.
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•
The SCO must request and maintain a list of all programs, or courses, approved for
VA training for each location for which he or she is responsible for certifying
enrollments. The branch/extension POC must notify the main campus each time
approval is amended, suspended, withdrawn, or reinstated at that location.
•
SCOs must certify students using the facility code of the branch where
administrative capability exists for the teaching location where the student is
attending.
•
The SCOs and POCs must make records available for compliance surveys and SAA
site visits.
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
•
A. General
What institutions can be approved for centralized certification?
•
Educational institutions that have approved branches or extensions located in
more than one state may now centralize certification of enrollments if the
institution only offers IHL or NCD training and certifies students via the VA Online
Certification of Enrollment (VA-Once) Internet application. (Note: Centralized
certification is not available for training establishments or institutions offering
correspondence courses, flight training, apprenticeship/on-the-job training,
licensing or certification tests, or national tests due to the current limitations of VAOnce.)
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
2. If an institution with campuses in more than one state agrees to participate in
centralized certification, is each campus required to sign a separate MOU for VAOnce access?
•
No, the only campus required to sign a memorandum of understanding (MOU) for
VA-Once is the main campus. That campus will be responsible for ensuring that all
the requirements in the MOU are met by each of its branch locations. Points of
Contact at the branch campuses will only have access to VA-Once after the main
campus has added them as a user. Any individuals at branch/extension locations
who were previously designated as certifying officials will be removed from the
system as a certifying official by the ELR of jurisdiction upon notification of
centralized certification approval. As a result, the main campus will control who
has access to VA-Once at all locations in accordance with the VA-Once MOU.
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
If approval for a central location is withdrawn, can centralized certification be
continued?
•
No, if approval for the central location is withdrawn, the remaining locations will
need to designate a new certifying official (using VA Form 22-8794) in order to
submit enrollment certifications. However, another campus may request approval
for centralized certification by contacting the ELR of jurisdiction and submitting an
application package.
•
If the central location's approval is later reinstated, a subsequent application for
centralized certification must be submitted and approved before that institution
can resume using the centralized certification option.
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
4. Can an institution choose which branches/extensions participate in centralized
certification?
•
Yes, if an institution with several branches wants to centrally certify its
enrollments, the institution is given the flexibility of deciding which branch
locations will be included. It is not required that all school locations participate in
centralized certification.
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
5. Since institutions participating in centralized certification may have SCOs and
POCs in more than one state, who will be responsible for training those
personnel on VA-Once?
•
The ELR with jurisdiction over the campus personnel needing assistance is
responsible for providing training.
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
6. How will VA verify that the designated certifying official is submitting the
enrollment certifications?
•
Each institution using VA-Once is required to sign a memorandum of
understanding (MOU) prior to being granted access to the application. The MOU
requires that institutions take reasonable precautions to safeguard against
unauthorized access and to prevent improper disclosure of passwords. The MOU
also requires the institution to promptly notify VA if an authorized certifying
official no longer serves in that position. VA may review adherence to this policy
during school site visits and make adjustments as necessary.
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
7. How will customer inquiries be handled by POCs?
•
POCs should have view only access to VA-Once in order to provide information to
beneficiaries and SAA or VA representatives. POCs do not have the authority to
certify or amend enrollment information and must report any changes in
enrollment to a certifying official at the main campus.
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CENTRALIZED CERTIFICATION QUESTIONS AND ANSWERS
•
8. Will reporting fees be sent to approved branches/extensions or to the Main
Campus?
•
Schools are entitled to a reporting fee for each VA student enrolled during the
preceding calendar year. Currently, reporting fees are calculated based on the
number of students attending a specific facility code (as entered in the Benefits
Delivery Network). Since centralized certification procedures require SCOs to
certify students using the facility code of the branch with administrative authority
over their location, the reporting fees will be continue to be forwarded to each
branch that has active students.
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Approval Requirements/ Procedures
•
9. How and where will the records be kept for schools with centralized
certification?
•
Records will continue to be kept at each approved location in accordance with the
requirements of 38 CFR 21.4209. Records at approved branches/extensions may
be kept as originals, certified copies, or in an electronically formatted record
keeping system.
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Approval Requirements/ Procedures
•
10. Will the SAAs in each State the school has a branch location be required to
provide the certifying official at the main campus a copy of the approval for the
branch in their State?
•
No, the SAAs may provide the main campus with a copy of the approval but will
not be required to do so.
•
The main campus official should request and maintain approval information for
each approved branch/extension in accordance with the agreed upon
responsibilities of the institution (See notification and approval letters). In the
event that the main campus is unable to obtain approval information from a
branch/extension, the ELR with jurisdiction over the main campus will be
responsible for obtaining and providing the information.
(Con’t)
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Approval Requirements/ Procedures
(10. Con’t)
• If an institution is frequently unable to obtain information for one or more of it's
approved branches/extensions, the ELR may need to review centralized
certification approval for that institution to determine if approval should be
withdrawn or if a specific branch/extension should be removed from approval.
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Approval Requirements/ Procedures
11. Will the ELR in each state be required to provide the certifying official (located
at the main campus) with a copy of reports available in WEAMS?
• ELRs may, at their discretion, provide requested reports to certifying officials
•
•
12. Who is responsible for entering the "associated" branches/extensions in VAOnce?
The main campus ELR is responsible for notifying the ELRs with jurisdiction over
the branches/extensions of the approval. The ELR with jurisdiction over each
branch/extension is responsible for associating the branches/extensions in his or
her jurisdiction in VA-Once. ELRs with jurisdiction over branches/extensions
should revoke certifying official access for all individuals at those
branches/extensions. POCs at branches/extensions should only be granted "view
only" access.
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Sample Letter
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Sample Letter
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Sample Letter
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Sample Letter
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Sample VA Form 22-0831
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Approval Sample Letter
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Questions
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