Slide 1 - Video - Amazon S3 · 1 NSI Slide 1 - Video Introduction Slide Notes Over the last few...

DoD MOU Compliance Tutorial

Wednesday, February 22, 2017

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Slide 1 - VideoIntroductionSlide NotesOver the last few years, DoD Voluntary Education has experienced policy changes and fiscal constraints that fundamentally altered the operating environment. This included implementing the President’s Executive Order 13607 which emphasized the importance of education in the Armed Forces by establishing guidelines, requirements, and accountability measures, or “Principles of Excellence,” for educational institutions receiving federal funding.

The DoD Voluntary Education Partnership MOU enhances the protection of Service members and their families through enforcement of requirements that provide meaningful information about the financial cost and quality of the school, prevent abusive and deceptive recruiting practices, and provide high-quality academic and student support services.

As a result of the recent changes, DoD Voluntary Education has developed an online training tool to aid institutions in understanding the compliance requirements of the Memorandum of Understanding in hopes to promote a continued ‘Culture of Compliance.’

In this training, we will cover an introduction to the background of the compliance culture and each phase of the student life cycle. The training tool will provide information and guidance on the requirements of the Principles of Excellence, and the Voluntary Education Partnership Memorandum of Understanding and how those requirements fit into the student life cycle.

Slide 2 - DoD IntroductionSlide NotesA Welcome Message from Dawn Bilodeau, Chief of DoD Voluntary Education

Voice (Dawn): Welcome to the Team! Your desire to sign a Voluntary Education Partnership Memorandum of Understanding with the Department of Defense is the first step toward entering into a committed partnership that provides opportunities for Service members and their families to realize their educational goals. With your support, DoD can deliver on our promise to Service members to avail themselves of quality educational opportunities that support them beyond their Service.

This training is designed just for you, as an educational institution considering participation in DoD Voluntary Education programs or a school wishing to renew its participation. Completing this training will help you better understand the terms of the agreement, or DoD MOU, that your school signs. This training will also help your educational institution better meet the needs of our military students and help the DoD facilitate the best educational opportunities possible for our Service members.

The training should take about 90-minutes to complete, and is full of critical details related to how together, we can build a ‘Culture of Compliance’ in support of the professional and personal development and the successful transition of Service members to the civilian workforce. We realize that the DoD MOU contains many nuanced requirements and we sincerely desire to be an aide in your



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understanding of these requirements. Therefore, you will also find discussion of key requirements that all schools must fulfill as signatories of the DoD MOU.

Please know that the entire DoD Voluntary Education team offers its warmest welcome to you, not only to this training module, but also as a current or soon-to-be participating DoD MOU partner school. Thank you for your continued support of our Service members and their pursuit of higher education.

The training module will begin momentarily.

Slide 3 - Navigation InstructionsSlide NotesFollowing is a list of features available to you to help navigate the course. This list will highlight the various page elements and their locations that you will need to be familiar with to successfully complete this tutorial.

At the end of each slide, a circular play button will appear in the lower right of your screen. You must click this button in order to move forward to the next slide.

If you are at the end of a lesson or module, this button will take you to the master navigation slide to check your progress and then continue to the next lesson.

The title of each slide is located in the top-right of the tutorial window.

The Resources link opens a PDF that lists various references made throughout this tutorial.

The Transcript link opens a PDF file of all slide notes and narration found throughout the course, excluding scenario content. Scenarios are brief knowledge checks found throughout the tutorial.

The Glossary link opens a PDF listing various keyword definitions used throughout the tutorial.

The Home icon is a link to the master navigation slide which is to be used as the primary navigation function of the course. After each lesson, you will automatically be directed back to the master navigation slide to choose the next available lesson and/or module. This master navigation slide will show your progress by highlighting each newly completed lesson and/or module.

Your current slide number is displayed in the bottom-right corner, except during scenario knowledge checks.

The play/pause button allows you to pause and continue the tutorial at any time.

The volume control icon allows you to mute the audio during the tutorial.

Closed captioning is available for all slides that have audio-based narration.

The Table of Contents icon will reveal a listing of all slides within the tutorial. This is provided to allow users the ability to reference other slides as needed during the course. Please note, that to



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receive credit for course completion, you must still navigate the course one lesson at a time, starting with Module 1, Lesson 1. Unless the master navigation slide shows a lesson as complete, the final certificate of completion cannot be obtained. This table of contents is also accessible by the double-arrow icon located in the top-left of your screen.

The exit icon will close your tutorial screen.

Slide 4 - Master NavigationSlide NotesThis Master table of contents will help you navigate the following course. You can return to this screen at any time by clicking the Home icon located at the top right of your page. Additional content will be made available as you complete key sections of the course. Please choose an item from the menu to start the tutorial.

Slide 5 - Module 1: Introduction to the Culture of ComplianceSlide Notes Welcome to the Culture of Compliance Module 1: Introduction to the Culture of Compliance.

The primary knowledge goal for this module is to “Understand the Culture of Compliance and relevant requirements.”

In this module, we will introduce the concept of compliance and provide a background of the development of compliance requirements for the DoD Voluntary Education Partnership Memorandum of Understanding. We will cover Executive Order 13607, Principles of Excellence for Educational Institutes serving Service members, Veterans, spouses and other family members, and the DoD MOU. Additionally, this module will outline the major compliance requirements relevant to the educational institution.

Slide 6 - Lesson 1: Principles of ExcellenceSlide NotesModule 1, Lesson 1: Principles of ExcellenceThe key objective of this lesson: “Using existing compliance resources and documentation, including the Principles of Excellence, identify the important foundations and elements of DoD MOU compliance.”

In this lesson, we will introduce the concepts of the Principles of Excellence and explain the relationship and significance to the DoD Voluntary Education Partnership Memorandum of Understanding.



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Slide 7 - BackgroundSlide NotesWhat are the Principles of Excellence?On April 27, 2012, the White House established the Principles of Excellence to ensure our Service members, Veterans, spouses, and other family members have the information they need to make informed decisions concerning their well-earned Federal military and Veterans’ educational benefits.

Who is affected?Institutions who receive funding from the military tuition assistance program and Veteran’s education benefits programs.

How is this relevant?The Department of Defense, U.S. Department of Veterans Affairs, and the U.S. Consumer Finance Protection Bureau were directed to accomplish the following:

• Establish guidelines for educational institutions receiving Federal funding.• Require institutions to provide information, support, and protection to Federal education

beneficiaries.• Strengthen oversight, enforcement, and accountability activities within educational benefit

programs.• Expand student data collection efforts to better understand educational outcomes.• Require development of a centralized complaint system for students.

Slide 8 - Compliance with the Principles of ExcellenceSlide NotesCompliance with the Principles of ExcellenceThe Principles of Excellence outlines the following guidelines that all educational institutions must follow if they are receiving military tuition assistance or Veteran education benefit program funding:

• Clearly outline all costs and fees associated with programs and what is or is not covered by VA assistance or federal money.

• Provide a clear understanding of financial options including federal aid to Veterans.• End fraudulent and aggressive recruiting tactics.• Obtain accreditation agency approval before adding new programs.• Allow Service members to re-enter an educational program if they must leave temporarily due

to service requirements.• Ensure that the institutional refund policy is aligned with the refund of unearned student aid rules.• Provide comprehensive education plans for students using Federal Veteran’s education benefits.• Designate a point of contact for financial and academic advising.



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Slide 9 - Compliance Operating ConceptsSlide NotesCompliance Operating ConceptsThis triad outlines the DoD Voluntary Education approach to compliance within the DoD Voluntary Education Partnership Memorandum of Understanding (MOU).

The MOU is established with institutions desiring to participate in the military tuition assistance program.

That MOU is supported by interagency coordination between the DoD, the Department of Veterans Affairs, and the Department of Education (ED). As part of participation in the MOU, institutions must agree to abide by the areas outlined in the Principles of Excellence, submit to a third-party review, and respond to feedback from the Postsecondary Education Complaint System.

Additionally, in order to remain in good standing with the DoD Voluntary Education Partnership MOU, the educational institution must be accredited by a recognized accrediting agency, approved by the Department of Veterans Affairs and have obtained Title IV eligibility/participation.

Slide 10 - Principles of Excellence SignificanceSlide NotesIn order to participate in the military tuition assistance program, an institution must agree to abide by the Principles of Excellence and commit to the following:

• Provide detailed information on the total cost of the education program.• Provide educational plans.• End fraudulent and aggressive recruiting practices.• Designate a single point of contact for academic and financial advisement.• Ensure accreditation of all new programs prior to student enrollment.

Slide 11 - Lesson 2: DoD MOUSlide NotesModule 1, Lesson 2: DoD MOUThe key objective of this lesson: “When provided an overview of the background of the DoD MOU program and the Department of Defense Instruction (DoDI) 1322.25, recall the critical requirements.”

Slide 12 — Background - DoD MOUSlide NotesThe Department of Defense Instruction (DoDI) 1322.25 establishes the following in support of the Department of Defense MOU program.



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The DoD MOU and DoDI were put together to protect our DoD Service member students. In addition, this includes:

• Voluntary education policy.• States eligibility criteria for tuition assistance (TA). • A signed Memorandum of Understanding (MOU) with DoD to provide educational programs

and receive TA. • Institutionalizes within DoD the Principles of Excellence in support of Executive Order 13607

(April 27, 2012).

Slide 13 - Background - DoD MOU (Continued)Slide NotesAll educational institutions providing education programs through the DoD Tuition Assistance program:

• Will provide meaningful information to students about the financial cost and attendance at an institution so military students can make informed decisions on where to attend school.

• Will not use unfair, deceptive, and abusive recruiting practices.• Will provide academic and student support services to Service members and their families.

Slide 14 - Eligibility CriteriaSlide NotesEligibility Criteria.To participate in the DoD Memorandum of Understanding, several criteria must first be met to include:

• Accreditation by accrediting body recognized by the U.S. Department of Education (ED).• Certified to participate in Title IV.• VA approved.• Compliance with state authorization requirements.• Signed DoD Voluntary Education Partnership Memorandum of Understanding.

Slide 15 - Scenario Introductions Slide NotesAbout the scenario assessment portion of the training:All Department of Defense MOU Compliance scenario assessments throughout this training follow a similar pattern that educational institution compliance officers can use to aid in their work.

At a high level, when encountering real-life compliance issues at your institution, each Compliance Officer should evaluate possible issues using these three steps:

1. Identify potential compliance issues.2. Assess DoD MOU compliance impact.3. Resolve the issue.



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Slides 16 - 23 - Scenario 1 - Student Recruitment IncentivesSlide 24 - Lesson 3: Compliance RequirementsSlide NotesModule 1, Lesson 3: Compliance Requirements.The key objective of this lesson: “When presented with hypothetical MOU challenges, choose the proper procedures and requirements of a satisfactory response in accordance with program guidelines.”

Slide 25 - Postsecondary Education Complaint System (PECS)ECSSlide NotesWhat is the Postsecondary Education Complaint System?In January 2014, the Department of Defense (DoD) in collaboration with the Departments of Veterans Affairs (VA) and Education (ED) launched the DoD Postsecondary Education Complaint System (PECS), and is electronically capturing complaints about educational institutions. This fulfilled a key provision of the President’s Executive Order on Principles of Excellence for Educational Institutions and created consumer protection measures for beneficiaries of education benefits (which include tuition assistance).

What complaints are reported?The PECS is intended for complaints directly related to the Principles of Excellence. It is not intended for issues that are specific to Service- or program-level policy and administration (e.g., eligibility, requesting a form, or payment).

The top 5 issues received through PECS are:1. Financial issues (e.g., tuition and fees)2. Refund or collection issues3. Quality of education4. Release of transcripts, and5. Grade policy

Slide 26 - Third-Party AssessmentSlide NotesEducational institutions may be selected for Third-Party Assessment based on:

• Provider offerings (on-installation, off-installation, or Distance Learning (DL)), • Education benefits received (large provider in terms of enrollments or TA funds), or• An observed promising practice.



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Educational institutions may also be selected as a result of reports of non-compliance with the DoD Voluntary Education Partnership MOU, complaints received, or negative information received from other government agencies and regulators.

Slide 27 - Module 2: Educating Military StudentsSlide NotesWelcome to Module 2: Educating Military StudentsIn this module, we will gain awareness of the information required for prospective military students and the ongoing reporting requirements of the institution once students are enrolled. This includes Institution TA Eligibility, Prospective Students, Refunds and Reporting, and Student Outcomes.

Slide 28 - Lesson 1: Institution TA EligibilitySlide NotesModule 2, Lesson 1: Institution TA EligibilityThe key objective of this lesson: “When presented with the requirements to receive and maintain institution TA eligibility under the DoD MOU program, distinguish between acceptable and unacceptable TA applications.”

Slide 29 - Eligibility RequirementsSlide NotesIn order for an institution to participate in the DoD Voluntary Education Partnership Memorandum of Understanding (MOU), the institution must:

• Be accredited by a national or regional accrediting body recognized by the U.S. Department of Education.

• Be state-approved for the use of Veterans’ education benefits (Post-9/11 GI Bill). For assistance with VA approval, please contact the National Association of State Approving Agencies for your state.

• Be certified to participate in federal student aid programs through the ED under Title IV of the Higher Education Act of 1965. Title IV certification may be provisional so long as the educational institution maintains eligibility to participate in the Federal Direct Loan Program.

Slide 30 - State RequirementsSlide NotesIn order for an educational institution to be state eligible, that institution must:

• Comply with state authorization requirements consistent with regulations issued by ED.• Educational institutions must meet requirements of the state where services are rendered to

include all State laws as they relate to distance education.



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Slide 31 - DoD MOU Requirements for ProgramSlide NotesIn accordance with the Principles of Excellence and requirements for participation in the DoD Voluntary Education Partnership MOU, institutions must:

• Obtain the approval of the institution’s accrediting agency for new course or program offerings before enrolling students in such courses or programs, provided that such approval is appropriate under the substantive change requirements of the accrediting agency.

• Approval must be obtained before the enrollment of a Service member into the new course or program offering.

• New courses and/or programs must be approved before allowing students to enroll.• Service members must receive appropriate approval from their Service branch before enrolling

in a new course and/or program.

Slides 32 - 39 - Scenario 2 - Principles of Excellence: Administrative Information Provided to StudentsSlide 40 - Lesson 2: Prospective Students

Slide NotesModule 2, Lesson 2: Prospective StudentsThe key objective of this lesson: “When initiating contact with potential military students, identify pre-enrollment information regarding academics, finances, and student services required to be provided to military students.”

Slide 41 - Information Provided to Prospective StudentsSlide NotesFor the purposes of recruiting military students, institutions must:

• Disclose basic information about the educational institution’s programs and costs, including tuition and other charges to the Service member.

• Ensure information is made readily accessible without requiring the Service member to disclose any personal or contact information.

• Provide a website that is easy to understand and allows contact with the institution without disclosing personal contact information (e.g., online chat).



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Slide 42 - Counseling and Advisement for Prospective StudentsSlide NotesEach institution should designate a single point of contact to prospective military students to assist in obtaining access to academic and financial advisement, disability counseling and completion of studies as well as job search activities.

The following provides a list of services to be provided:• Academic:

• Academic advisement; • Academic/competency screening; and • Degree and/or program requirements

• Financial Aid: • Financial aid/student loan counseling; and • Approval of TA funding

• Student Support: • Awarding Credit; and • Transfer Credit

• Degree Plan Support• Job Search Activities

Slide 43 - Providing Financial Information to Prospective StudentsSlide NotesInstitutions are required to provide prospective military students with a personalized and standardized form prior to enrollment.

The institution should provide the following information to prospective students:• Total cost of the educational program, including tuition and fees; • Amount of cost that will be covered by Federal educational benefits;• Type and amount of financial aid they may qualify for; • Estimated student loan debt upon graduation;• Information about student outcomes; and• Other information to facilitate comparison of aid packages offered by different educational

institutions.



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Slide 44 - Providing Financial Information to Prospective Students (Continued)Slide NotesThe institution may provide the prospective student with information from the ED on Federal Student Aid referencing and/or providing information from the College Scorecard and Financial Aid Shopping Sheet.

Links to each site can be found under the resources, menu located at the top-right of this screen.

Slide 45 - 52 - Scenario 3 - Recruitment IncentivesSlide 53 - Lesson 3: Tuition Refunds and ReportingSlide NotesModule 2, Lesson 3: Tuition Refunds and ReportingThe key objective of this lesson: “When reviewing military student disenrollment data, recall the difference between student refunds and return to government of unearned funds, and calculate each.”

Slide 54 - Reporting MetricsSlide NotesIn accordance with the Department of Defense Instruction 1322.25, each educational institution will provide reports via electronic delivery on all DoD TA recipients for programs and courses offered to personnel as required by the cognizant Service. This includes, but is not limited to:

• TA transactions;• Final course grades to include incompletes and withdrawals;• Degrees awarded/certificates earned;• Evaluated educational plans;• Courses offered; and• Military graduation.

Slide 55 - Reporting Metrics (Continued)Slide NotesEducational institutions who provide face-to-face courses on a DoD installation will provide a class roster to the responsible Education Advisor. The class roster will include information such as the name of the instructor, the first and last name of each student (military and non-military), the course title, the class meeting days, the start and ending time of the class, and the class location (e.g., building and room number).



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• All reporting and transmitting of this information will be done in conformity with all applicable privacy laws, including Family Educational Rights and Privacy Act (FERPA).

• Educational institutions will respond to these requests in a timely fashion, which may vary based on the specific nature and scope of the information requested.

Slide 56 - Reporting Metrics (Continued)Slide NotesThe Services may request reports from an educational institution at any time, but not later than two (2) years after termination of the MOU with such educational institution. Responses to all requests for reports will be provided within a reasonable period of time, and generally within 14 calendar days. Institutional response time will depend on the specific information sought by the Services in the report.

• All reporting and transmitting of this information will be done in conformity with all applicable privacy laws, including FERPA.

• Educational institutions are expected to respond to these requests in a timely fashion, which will vary based on the specific nature and scope of the information requested.

Slide 57 - Tuition ReportingSlide NotesEducational institutions will provide tuition charges for each degree program to the Services on an annual basis.

Any changes in the tuition charges will be provided to and explained to all the Services, as soon as possible, but not fewer than 90 days prior to implementation. In instances where the tuition decision is made outside of the 90-day requirement window the institution may:

• Request a waiver, (via the DoD MOU webpage) and provide the Services with the new tuition charges. To the extent practicable by State law or regulation, Service members already enrolled will not be impacted by changes in tuition charges.

Slide 58 - Return of Unearned TA FundsSlide NotesMOU requirement:The following MOU requirement must be applied to the Return of Unearned TA Funds:Have an institutional policy that returns any unearned TA funds on a proportional basis through at least the 60 percent portion of the period for which the funds were provided. TA funds are earned proportionally during an enrollment period, with unearned funds returned based upon when a student stops attending.

Discussion:Institutional policy: During the MOU application process, the Department requires the educational institution to describe its policy related to the return of unearned TA funds. To clarify, this policy could be different from the institution’s refund policy.



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Slide 59 - Return of Unearned TA Funds (Continued) Slide NotesReturn:For the purposes of the MOU requirement, the return of unearned TA funds is not the same as a refund. DoD requires that the educational institution describe its policy related to the return to the government of unearned TA funds, not a refund to the student.

The return of any TA program funds will be returned directly to the Military Department, not to the Service member. The requirement to return unearned TA funds applies to the TA portion only.

Any calculation performed by the institution would consider only TA program funds. For example, the Military Department paid $250.00 and the student paid $30.00 out of pocket.

In this scenario, if the student withdrew at the 60% completion point and the institution’s return of unearned TA policy calls for a 10% return of unearned TA funds at that point, the institution would return $25.00 (10 percent of $250.00) to the Military Department.

It is important to note that any refund to the student calculations would occur subsequent to calculating return to the government.

Slide 60 - Return of Unearned TA Funds (Continued) Slide NotesProportional Basis:The Department provided flexibility inherent in the use of the language “proportional” (vice pro-rated) to allow an educational institution to align its institutional refund policies with the return of unearned TA funds.

Proportionality may be addressed by providing at least three distinct points of return for calculation to determine the return of unearned TA funds.For example, the three points might be:

1) prior to class start date (100% return), 2) 60% completion point (last day to receive any return, and after which the return can be zero), and 3) some point after the start date but before the 60% completion point, with the return amount and/

or percentage established by the institution.



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Slide 61 - Return of Unearned TA Funds (Continued) Slide Notes60 Percent Portion:TA funds are approved on a course-by-course basis and each course is subject to the period for which the funds were provided, typically denoted by the start date and end date of the course.

The 60% portion reflects the point at which the educational institution considers the course to be 60% complete (i.e., day or week).

Slide 62 - Return of Unearned TA Funds (Continued) Slide NotesStop Attending:The point at which the educational institution considers the student to have dropped, withdrawn, or other similar non-attendance category.

The Department requires the return of unearned TA funds regardless of the reason for drop/withdrawal (military service-related or otherwise).

The Department encourages educational institutions to work with Service members that stop attending due to a military service obligation in identifying solutions that will not result in a student debt for the returned TA portion.

Slide 63 - Return of Unearned TA Funds (Continued) Slide NotesMOU Application:In evaluating the Educational Institution’s MOU application, DoD will calculate a hypothetical student withdrawing at various points during the course dates.

If DoD cannot calculate a hypothetical return to government amount at various points throughout the course dates (up to the 60% point of the course length), the application will be returned to the Educational Institution.

Examples:In each of the following examples it is possible for DoD to calculate the return to government of unearned funds based upon when the student stops attending. Note that preferred terminology includes “return” vice “refund.”



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Slide 64 - Return of Unearned TA Funds (Continued) Slide NotesExamples: 5-week Courses:Days 1 through 7, 100% will be returned; Day 21, 40% will be returned; and on Day 22, 0% will be returned.

Note: The educational institution’s week of instruction is counted as 7 days.

Slide 65 - Return of Unearned TA Funds (Continued) Slide Notes8-Week Course Withdraw Submitted:Before or during week 1, there will be a 100% return; during week 2, there will be a 75% return; during weeks 3 and 4, there will be a 50% return; during week 5, there will be a 40% return; and during weeks 6 through 8, there will be no return.

16-Week Course Withdraw Submitted:Before or during weeks 1 and 2, there will be a 100% return; during weeks 3 through 4, there will be a 75% return; during weeks 5 through 8, there will be a 50% return; during weeks 9 through 10, there will be a 40% return; and during weeks 11 through 16, there will be no return.

Slide 66 - Return of Unearned TA Funds (Continued) Slide NotesExample 3 - Eight Week Online Classes.

• 100-percent of Tuition Assistance received will be returned if the student withdraws within the first week of class, but before submission of the first assignment. The student’s request will be processed as a drop for the purpose of returning TA funds only, not for Financial Aid attendance or recalculating of aid.

• 75-percent of Tuition Assistance received will be returned if the student withdraws after submitting the first assignment and through the end of the second week of classes.

• 50-percent of Tuition Assistance received will be returned if the student withdraws after the second week of classes, but before the end of the fourth week of classes.

• 25-percent of Tuition Assistance received will be returned if the student withdraws after the fourth week of classes, but before the end of the sixth week of classes.

• No Tuition Assistance received will be returned if the student withdraws after the sixth week of classes.



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Slides 67 - 74 - Scenario 4 - Tuition Refunds

Slide 75 - Reporting Degree Plan ChangesSlide NotesAs part of the participation requirements for the DoD Voluntary Education Partnership MOU, an institution is required to report all degree plan changes.

When a Service member changes his or her educational goal or major at the attending school and the Service’s Education Advisor approves the change, then the educational institution will provide a new evaluated educational plan to the Service member and the Service within 60 days.

Only courses listed in the Service member’s evaluated educational plan will be approved for TA.

Slide 76 - Lesson 4: Student OutcomesSlide NotesModule 2, Lesson 4: Student OutcomesThe key objective of this lesson: “When reviewing military student outcomes from identified data sources, identify those outcomes that are required to be reported.”

Slide 77 - Student Outcomes ReportedSlide NotesAs part of the implementation of the Principles of Excellence, the U.S. Department of Education through the Integrated Postsecondary Education Data System (IPEDS) works with other agencies to report student outcomes through the different phases of the student life cycle.

During school, IPEDS tracks the following outcome measures:Retention Rates, Persistence Rates, Course Completion Rates, and Transfer-Out Rates

Upon graduation, the Department of Education considers:Graduation and completion rates, Number of degrees or certificate completions, and Median federal student loan borrowing

After graduation, the Department of Education uses a variety of sources to track outcome measures related to student debt and employment:Loan default/repayment rates, Average time to complete a degree or certificate, Average number of institutions attended, Employment/unemployment rates, and Average salary



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Slide 78 - Module 3: Enrolling Military StudentsSlide NotesWelcome to the Culture of Compliance Module 3: Enrolling Military Students.In this module, we will gain an understanding of several key issues when working with military students such as Financial Issues, Student Loans, Awarding Credit, and Readmission.

Slide 79 - Lesson 1: Financial IssuesSlide NotesModule 3, Lesson 1: Financial IssuesThe key objective of this lesson: “When interacting with military students on financial matters, recognize the rules for charging military students and requirements to make student advisement available to minimize financial issues for the student and the government.”

Slide 80 - Assigning a Designated Point of Contact (POC)Slide NotesEach institution must designate a point of contact for academic and financial advising (including access to disability counseling) to assist Service members and Veteran students and their families with the successful completion of their studies and with their job searches.

The designated person or office will serve as a point of contact for Service members: • Seeking information about available, appropriate academic counseling;• Financial aid counseling; and• Student support services at the educational institution.

Slides 81 - 86 - Provide Information on Decision-Making ToolsSlide NotesBefore enrolling a Service member, provide each prospective military student with specific information to locate, explain, and properly use the following Department of Defense and Consumer Finance Protection Bureau tools:

• College Scorecard• College Navigator• Financial Aid Shopping Sheet• “Paying for College” Webpage, and• Tuition Assistance (TA) DECIDE



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Slide 87 - Automatic Program RenewalsSlide NotesBefore the start date of a class, an institution must obtain approval from both the student and his or her military service in the form of a funding authorization, in order for an institution to receive TA program funds for the Service member’s enrollment in the class.

Institutions must refrain from automatic renewals and bundling courses or enrollments.

Slides 88 - 95 Scenario 5 - Program RenewalsSlide 96 - Providing a Single Tuition Rate Slide NotesInstitutions participating in the Department of Defense Voluntary Education Partnership MOU must ensure that all Service members attending the same educational institution, at the same location, enrolled in the same course, will be charged the same tuition rate without regard to their Service component.

Tuition rates may vary by:• Mode of delivery (traditional or online), • Differing degree levels and programs, • Residency designations (in-state or out-of-state),• Full-time or part-time status,• Daytime vs. evening classes, or• Matriculation date

Slide 97 - Providing a Single Tuition Rate (Continued)Slide NotesTuition charged to a Service member will in no case exceed the rate charged to non-military students, unless agreed upon in writing by both the educational institution and the Service.

Slides 98 - 105 Scenario 6 - Providing Financial Information to Students



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Slide 106 - Lesson 2: Student LoansSlide NotesModule 3, Lesson 2: Student LoansThe key objective of this lesson: “When interacting with military students on payment and student loans, implement procedures to provide the required information and educational counseling to minimize the potential for financial issues with military students.”

Slide 107 - Providing Financial Aid AdvisementSlide NotesBefore “offering, recommending, arranging, signing-up, dispersing, or enrolling Service members for private student loans,” the institution must provide access to an institutional financial aid advisor.

The advisor will provide the following: • Clear and complete explanations of available financial aid, including Title IV Program aid; • Describe the differences between private and federal student loans (including terms, conditions,

repayment, and forgiveness options); • Disclose the institution’s cohort default rate;• Disclose the percentage of students who borrow in order to attend the institution;• Disclose how the institution’s cohort default rate compares to the national average and, if the

institution’s cohort default rate is higher than the national average, disclose such information as well as loan repayment data; and

• Explain that students may refuse all student loans or borrow less than the maximum student loan amount offered.

Slide 108 - Educating Military Students on Tuition Assistance Top-upSlide NotesIn accordance with the DoD Instruction 1322.25, “Top-up” eligible active duty DoD personnel may use the Montgomery or Post-9/11 G.I. Bill benefit in conjunction with TA funds from their Service to cover those course costs to the Service member that exceed the amount of TA paid by his or her Service.

The combination of VA education benefits and TA will not exceed 100 percent of the actual costs of tuition.

What is Tuition Assistance Top-up?Tuition Assistance Top-up is an amendment to the GI Bill signed in October 2000. It permits the Department of Veterans Affairs (VA) to pay a benefit equal to the difference between the total cost of a college course and the amount of TA that is paid by the military for the course.



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How does Top-up affect service member benefits?According to the Department of Veterans Affairs Top-up Fact Sheet, the amount of the benefit is limited to the amount that the person would receive for the same course if regular GI Bill benefits were being paid. In no case, can the amount paid by the military combined with the amount paid by VA be more than the total cost of the course. The Top-up program is only available for recipients of the Montgomery GI Bill - Active Duty or Post-9/11 GI Bill programs.

What is the institution’s responsibility regarding Tuition Assistance Top-up?1. The institution is responsible for educating the Service member on the use of Top-up benefits

in conjunction with TA. Top-up may be helpful to a Service member who is using TA and only taking a few courses while on active duty. The Service member can then save most of their GI Bill benefits to use at later time to complete an education program.

2. The institution should educate Service members on the required reimbursement timeframe to receive payment while participating in the Top-up program.

3. The Service member should be referred back to the education counselor or the VA website for additional information and to apply to the Top-up program.

Slide 109 - Other Financial Aid OpportunitiesSlide NotesDoD personnel are entitled to consideration for all forms of financial aid that educational institutions make available to students at their home campus.

Educational institution financial aid officers will provide information and application processes for the following:

• Title IV student aid programs;• Scholarships• Fellowships• Grants; and• Private loans;

Service members identified as eligible TA recipients who qualify for Pell Grants through ED’s student aid program, will have their TA benefits applied to their educational institution’s account prior to the application of their Pell Grant funds to their account. Unlike TA funds, which are tuition-restricted, Pell Grant funds are not tuition-restricted and may be applied to other allowable charges on the account.

Slides 110 - 117 Scenario 7 - Private Student Loans



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Slide 118 - Lesson 3: Awarding CreditSlide NotesModule 3, Lesson 3: Awarding Credit.The key objective of this lesson: “Given an admissions process scenario, identify best practices for reviewing degree requirements, screening for academic readiness, awarding and transferring credit in accordance with American Council on Education (ACE) and Servicemembers Opportunity Colleges (SOC) guidelines.”

When first enrolling a student in course, recall the process for creating educational plans and communicating those plans to the Service and the military student.

Slide 119 - Outlining Degree RequirementsSlide NotesWhat is provided to the student?A planning document provided by the educational institution that outlines general required courses to complete an educational program. The planning document presents the general education and major-related course requirements, degree competencies (e.g., foreign language and computer literacy), and elective course options that students may choose for specified program of study.

What is the institution’s responsibility in providing degree requirements?Educational institutions will disclose general degree requirements for the Service member’s educational program (evaluated educational plan) before the enrollment of the Service member at the educational institution.

These requirements, typically articulated in the educational institution’s course catalog, should: • Include the total number of credits needed for graduation. • Divide the coursework students must complete in accordance with institutional academic

policies into general education, required, and elective courses. • Articulate any additional departmental or graduate academic requirements, such as satisfying

institutional and major field grade point average requirements, a passing grade in any comprehensive exams, or completion of a thesis or dissertation.

Slides 120 - 127 - Scenario 8 - Change in Degree Plans



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Slide 128 - Providing Evaluated Educational PlansSlide NotesWhat should educational plans include?

1. Degree requirements required for degree completion or in the case of a non-degree program, all educational requirements for completion of the program;

2. Courses required for graduation in the individual’s intended academic discipline and level of postsecondary study; and

3. Evaluation of all successfully completed prior coursework, and evaluated credit for military training and experience, and other credit sources applied to the institutional degree requirements.

What is required by DoD for an educational plan? 1. Provide an evaluated educational plan within 60 days after admission to the institution. 2. If changes are made, generate a new evaluated educational plan within 60 days after the relevant

military Service’s education advisor approves such change. 3. Meet educational requirements for credentialing in stated career fields and graduates of a

program must be eligible for relevant professional licensure or certification. 4. Disclose any conditions, such as state limitations, or additional requirements, such as training,

experience, or exams, that are required to obtain relevant credentials.

Slide 129 - Disclosing Transfer Credit InformationSlide NotesServicemembers Opportunity Colleges (SOC) Principles and Criteria 2015-2017:

• Transfer policy for Servicemembers should minimize the loss of credit and avoid duplication of coursework

• A SOC institution should follow the general principles of good practice outlined in the Joint Statement on the Transfer and Award of Credit.

Non-SOC Institutions:• Disclose transfer credit policies and articulated credit transfer agreements before enrollment. • Explain the acceptance of credits in transfer is determined by the educational institution to

which the student wishes to transfer and refrain from making unsubstantiated representations to students about acceptance of credits in transfer by another institution.

• If accepting transfer credit from other accredited educational institution, then the institution agrees to evaluate these credits in conformity with the principles set forth in the Joint Statement on the Transfer and Award of Credit established by the American Association of Collegiate Registrars and Admissions Officers.

• The educational institution will then award appropriate credit, to the extent practicable within the framework of its institutional mission and academic policies.

• Decisions about the amount of transfer credit accepted, and how it will be applied to the student’s program, will be left to the educational institution.



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Slides 130 - 137 - Scenario 9 - Transfer Credit Policies

Slide 138 - Providing Credit for Work ExperienceSlide NotesServicemembers Opportunity Colleges (SOC) Principles and Criteria 2015-2017:Military occupational experience represents a legitimate area of learning outside the formal classrooms of specialized military training courses. A SOC institution should recognize the value of such experience and award appropriate credit for Military Occupational Specialties (MOS) and Navy and Coast Guard Rates and Ratings as recommended by the ACE Guide to the Evaluation of Educational Experiences in the Armed Services.

Non-SOC Institutions: Decisions about the amount of experiential learning credit awarded, and how it will be applied to the student’s program, will be left to the educational institution.

Once an educational institution has evaluated a particular military training or experiential learning opportunity for a given program, the educational institution may rely on its prior evaluation to make future decisions about awarding credit to Service members with the same military training and experience documentation, provided that the course content has not changed.

Slide 139 - Conducting Academic ScreeningSlide NotesMOU RequirementConduct academic screening and competency testing; make course placement based on student readiness.

Military Student Bill of RightsRequires appropriate academic screening and course placement based on student readiness.

Standards of Good for Practice Servicemembers Opportunity CollegesAdmissions policies and practices ensure appropriate academic screening and proper placement in courses and programs.

Slide 140 - Lesson 4: Readmission Slide NotesModule 3, Lesson 4: ReadmissionThe key objective of this lesson: “Remember that when dealing with military students who must leave as a result of military duties, you must understand the processes for readmitting and communicating with the student and the Service.”



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Slide 141 - Readmission PoliciesSlide NotesBefore enrollment, provide Service members with information on institutional “drop/add,” withdrawal, and readmission policies and procedures.

Provide information on the potential impact of military duties (such as unanticipated deployments or mobilization, activation, and temporary duty assignments) on the student’s academic standing and financial responsibilities.

For example, a Service member’s military duties may require relocation to an area where he or she is unable to maintain consistent computer connectivity with the educational institution, which could have implications for the Service member’s enrollment status. This information will also include an explanation of the educational institution’s grievance policy and process.

Slide 142 - Readmission for Temporary DutySlide NotesInstitutions must allow Service members and Reservists to be readmitted to a program if they are temporarily unable to attend class or have to suspend their studies due to service requirements.

Institutions must take additional steps to accommodate short absences due to service obligations, provided that satisfactory academic progress is being made by the Service members and Reservists prior to suspending their studies.

Slide 143 - Readmission for Program InterruptionSlide NotesIf a Service member cannot attend class due to his or her military duties, the institution must readmit the Service member with the same academic status as when the Service member last attended the school. The Service member must notify the school of the military service obligation and of the intent to return to school.

The same process applies to Service members that are temporarily unable to attend classes for less than 30 days within a semester or similar enrollment period due to his or her military service duties when such absence results in a withdrawal under institution policies.

A description of the provisions for U.S. Armed Forces members and their families is provided in Chapter 3, Volume 2 of the Federal Student Aid Handbook. A link is provided in the Resources link at the top of your screen.



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Slide 144 - Module 4: Recruiting and Marketing to Military StudentsSlide NotesWelcome to the Culture of Compliance Module 4: Recruiting and Marketing to Military Students.In this module, we will explain several key issues when recruiting and marketing to military students. Topics will include an overview of marketing information, best practices for recruiting, and general awareness of what is required for installation access.

Slide 145 - Lesson 1: Marketing InformationSlide NotesModule 4, Lesson 1: Marketing InformationThe key objective of this lesson: “Given examples of marketing for military students, identify those distinguishing characteristics of misrepresentation, false information, or copyright infringements that would result in DoD MOU non-compliance.”

Slide 146 - MisrepresentationSlide NotesWhat is Misrepresentation?Misrepresentation is any false, erroneous or misleading statement an eligible institution, one of its representatives, or any ineligible institution, organization, or person with whom the eligible institution has an agreement to provide educational programs, or to provide marketing, advertising, recruiting or admissions services made directly or indirectly to a student, prospective student or any member of the public, or to an accrediting agency, to a State agency, or to the Secretary. A misleading statement includes any statement that has the likelihood or tendency to deceive.

Intellectual Property UseNo institution shall falsely advertise, or otherwise represent falsely through the use of the DoD seal, or any military service mark whatsoever, that any project, service, or business in which it is engaged, or product which it manufactures, deals in, or sells, has been in any way endorsed, authorized, or approved by a military service or the DoD.

Institutions should not imply an endorsement from the DoD or any particular Service branch. An appropriate statement would be:

“We have an MOU with the DoD to provide active duty Service members…”



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Slide 147 - Providing Accessible Information to Military StudentsSlide NotesFor SOC Institutions:The document Standards of Good Practice for Servicemembers Opportunity Colleges provides prospective students with a clear understanding of the total financial obligation they have undertaken by engaging in specific academic pursuits.

For Non-SOC Institutions: Disclose basic information about the educational institution’s programs and costs, including tuition and other charges to the Service member.

This information will be made readily accessible without requiring the Service member to disclose any personal or contact information.

Slides 148 - 155 - Scenario 10 - Use of Logos and InsigniaSlide 156 - Lesson 2: Recruiting PracticesSlide NotesModule 4, Lesson 2: Recruiting PracticesThe key objective of this lesson: “Know that when recruiting military students, educational institutions must understand the distinguishing characteristics of aggressive recruiting and avoid recruitment violations by implementing proper recruitment practices.”

Slide 157 - MOU Rules on InducementsSlide NotesOffering InducementsThe MOU bans inducements to any individual or entity, or its agents including third-party lead generators or marketing firms for the purpose of securing enrollments of Service members or obtaining access to TA funds, including any:

• Gratuity• Favor• Discount • Entertainment • Hospitality • Loan • Transportation, lodging, or meals, and • Other items having a monetary value of more than a de minimis amount



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Slide 158 - Providing Commissions and BonusesSlide NotesCommissions, bonuses, or other incentive payments based directly or indirectly on securing enrollments or federal financial aid (including TA funds) should not be provided to any persons or entities engaged in any student recruiting, admission activities, or making decisions regarding the award of student financial assistance.

Slide 159 - High Pressure Recruiting PracticesSlide NotesUnsolicited Contact:Institutions should not use high-pressure recruitment tactics such as making multiple unsolicited contacts in a row.

Unsolicited contact includes contacts by phone, email, or in-person.

Same-Day Recruitment:Refrain from engaging in same-day recruitment and registration for the purpose of securing Service member enrollments.

Slides 160 - 167 - Scenario 11 - Recruiting PracticesSlide 168 - Lesson 3: Installation Access AwarenessSlide NotesModule 4, Lesson 3: Installation Access AwarenessThe key objective of this lesson: “Know that when recruiting or accessing military students on military installations, the educational institution must identify the requirements and follow the procedures in place for requesting installation access.”



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Slide 169 - Requesting Installation AccessSlide NotesWhat is installation access?The Principles of Excellence (EO 13607) directed DoD to establish new uniform rules and strengthen existing procedures for access to military installations by education institutions.

DoD Instruction 1322.25, “Voluntary Education Programs,” allows educational institutions access to installations to provide programs, services, and education guidance to their students or to participate in sanctioned education fairs. It also has a new section covering access for institutions that only want to provide academic counseling or support services to their students. These institutions must have a minimum of 20 military-connected students enrolled and must adhere to certain reporting requirements following the visit.

Slides 170 - 177 - Scenario 12 - Installation AccessSlide 178 - Requesting Installation Access (Continued)Slide NotesWhat are the requirements for installation access?Educational institutions may be allowed access to installations to provide on-installation education programs, services, and education guidance to their students and/or to participate in sanctioned education fairs if they meet all of these criteria:

• Signed Voluntary Education Partnership MOU with DoD.• Compliance with state requirements and laws.• State-approved for the use of veterans’ education benefits (Post 9/11 GI Bill).• Certified to participate in federal student aid programs through the Department of Education.• Accredited by a national or regional accrediting body recognized by the Department of

Education and conduct programs that support degree programs from that institution.

What is required from the institution to request installation access?• Submit a written request to the responsible Education Advisor who will analyze the request and

make a determination on behalf of the installation Commander.• Have a signed Voluntary Education Partnership MOU with DoD. Further, a signed Voluntary

Education Partnership MOU with DoD is dependent on the educational institution being state-approved for the use of veterans’ education benefits, certified to participate in federal student aid programs through the Department of Education (ED), and accredited by a national or regional accrediting body recognized by the ED.

• Be in compliance with state requirements and laws.



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Slide 179 - Granting and Monitoring Installation Access RequestsSlide NotesAll requests for DoD installation access by an educational institution are referred to the responsible Education Advisor (government official).

The Education Advisor, on behalf of the installation Commander, is responsible for ensuring all educational institutions and its agents granted access to DoD installations to provide education, guidance, training opportunities, and participate in sanctioned education fairs to Service members adhere to referenced laws and instructions, applicable DoD installation policies and procedures.

Responsible Education Advisors will monitor educational institutions and its agents granted access to DoD installations ensuring the compliance with the provisions of DoDI 1322.25, “Voluntary Education Programs,” during the visit.

Slides 180 - 187 - Scenario 13 - Installation AccessSlide 188 - Important Elements - 8 Keys to SuccessSlide NotesThe 8 Keys to Success on campus are:

• Create a culture of trust and connectedness across the campus community to promote well-being and success for Veterans.

• Ensure consistent and sustained support from campus leadership.• Implement an early alert system to ensure all Veterans receive academic, career, and financial

advice before challenges become overwhelming.• Coordinate and centralize campus efforts for all Veterans, together with the creation of a

designated space (even if limited in size).• Collaborate with local communities and organizations, including government agencies, to align

and coordinate various services for Veterans.• Utilize a uniform set of data tools to collect and track information on Veterans, including

demographics, retention and degree completion.• Provide comprehensive professional development for faculty and staff on issues and challenges

unique to Veterans.• Develop systems that ensure sustainability of effective practices for Veterans



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Slide 189 - EndSlide NotesNone.

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