Frequently Asked Questions

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Questions Asked During the May 13, 2009, NAICU Webinar on Post-9/11 GI Bill and Yellow Ribbon Program

NAICU’s May 13 Webinar on the Post-9/11 GI Bill and the Yellow Ribbon Program generated far more questions from participants than we were able to address in the brief time allotted. Here are detailed responses to most of the questions from participants during the Webinar, grouped by topic. We have edited some of the questions for brevity and clarity.

This page includes responses provided by the Department of Veterans Affairs to questions that arose during the Webinar. Quotes identified as coming from "Yellow Ribbon FAQs" are taken from the Department of Veterans Affairs PDF document, "Yellow Ribbon Program FAQs, posted on the VA Web site.

Download a pdf version of this FAQ here.

In addition, this page includes guidance issued by the Department of Education on August 13 dealing with the treatment of Federal veterans’ education benefits for purposes of the Title IV student assistance programs.  (See section on “Interaction with Other Federal and State Education Benefits.") We've posted a short video explaining how to calculate your Yellow Ribbon Program contribution.

TOPICS 

Veteran Eligibility
Tuition & Fees
The California $0 Issue
Institutional Eligibility for Yellow Ribbon Program
Institutional Match
First-Come, First-Served
Benefit Calculations
Summer Programs
VA Program Participation Agreement Elements

Agreement Item #2
Agreement Item #4
Agreement Item #6
Agreement Item #7


Program Administration
On-line Education
Dependent Benefits
Additional Sources of Information
Other VA Educational Programs
Interaction with other Federal and State Education Benefits
Outreach

Veteran Eligibility

Q: Must a veteran have had combat duty to qualify, or does any military service qualify?
A: Any military service qualifies. The law refers to active duty service, served after September 10, 2001. As long as the veteran served on active duty for the length of time specified in the law, he/she is eligible. (In the case of the Yellow Ribbon program, an individual must have served at least three years on active duty in the Armed Forces after September 10, 2001, or have served at least 30 continuous days after that date, and been released for a service-connected disability.)   

Q: Once veterans sign up will they receive a letter verifying they qualify, which they must take to the certifying official?
A: Yes. The veteran will receive an original certificate, as well as a copy for the college. The certificate will note the individual’s eligibility, date of end of eligibility, the individual’s payment tier, and his/her potential eligibility for the Yellow Ribbon program. 

Q: How quickly will students receive certification after they apply?
VA written response:  The VA cannot estimate processing times under the new benefit, as much more manual processing is involved.  The Department hopes to maintain its current processing level--which is usually less than 45 days for original applications.    However, it generally depends on the workload and whether or not the veteran applied for a certificate of eligibility before an institution’s VA Certifying Official submits an enrollment certification to VA.   If the veteran already established eligibility under the Post-9/11 GI Bill and has the Certificate of Eligibility letter, it is generally less than 30 days from the point the VA receives the enrollment certification from the institution’s Certifying Official.  Again, much will depend on the Department’s workload at the point in time when the Certifying Official submits the student’s enrollment certification.

Q: How will we know when a student is eligible for the benefits – only by the letter the student will receive?
A: "Eligible students will be notified that they are eligible on their Certificate of Eligibility (COE), which will also instruct them to bring the form to the School Certifying Official (SCO) at the school they will be attending. The SCO will certify on the 22-1999 (Enrollment Certification) that the student has been accepted to participate in the Yellow Ribbon Program." (Yellow Ribbon Program FAQ # 32, "How will students be certified for the Yellow Ribbon Program?")

Q: If the institution charges a flat rate for tuition; and fees are included (not charged separately), how can we determine the veteran’s eligibility?
VA written response:  Payment to the veteran will be calculated based on the tuition figure.  A fee calculation will not be made because the institution does not “charge” fees.   Multiply the number of credit hours taken by the student by the maximum tuition per credit hour charge shown on the VA website for the state in which the student is attending.  The result is the maximum that the VA will pay per enrollment period for that student.  If the student is charged less than the maximum, the VA pays the lesser amount.  If the veteran served less than 36 months and is qualified for less than the 100% payment tier, the VA will pay a percentage of the maximum as the basic tuition benefit.  (Related Information:   Veterans who qualify for less than the 100% payment tier do receive a basic benefit, but they are not eligible to participate in the Yellow Ribbon program.)   

Q: If a veteran applies for Post 9/11 GI Bill eligibility, does that preclude the veteran from qualifying under all other GI Bill benefit (chapter) options?  Does the veteran have to choose only one benefit program, and does that mean he/she does not have the option to select or consider any other chapter/benefit?
VA written response:  If the person is eligible for another benefit right now, he or she does not have to switch to the Post-9/11 GI Bill unless he or she wants to do so.  If the individual decides to switch to the Post-9/11 GI Bill, he or she may have to give up the current benefit in order to receive under the Post-9/11 GI Bill.  More information is on our website.  www.gibill.va.gov. 

Q: What about Vocational Rehabilitation benefits?  If tuition is already paid, do we still need to contribute?VA written response:  Veterans cannot use the vocational rehabilitation benefit and the Post-9/11 GI Bill benefit at the same time.  So, no, you would not enter into agreements for Yellow Ribbon for those veterans utilizing Vocational Rehabilitation benefits.

Tuition & Fees

Q: Do fees include room and board as well?
A: No. The Post-9/11 GI Bill provides for a separate housing allowance, which is paid directly to the eligible veteran.

Q: Is the benefit for books & supplies above and beyond the maximum benefit amount provided in the table for fees?
A: Yes. It is a separate benefit that goes directly to the eligible student.

Q: Does the table of maximum tuition & fees reflect the basic 9/11 benefit?
A: The table is used to determine the amount of an eligible veteran’s basic benefit. The basic benefit per term will be determined by multiplying the maximum tuition per credit hour for the state times the number of credit hours taken by the veteran, and then adding the fees charged to the veteran during the term (up to the maximum amount on the chart for the state.)


Q: Are the tuition rates for Yellow Ribbon based on doctoral rates for the state?
A: No. They are based on undergraduate charges.

Q: Is there a table for maximum graduate credit and fees?
A: No. The basic tuition and fee benefit is based on maximum undergraduate charges.

Q: If my institution charges a flat tuition rate of $12,000 for full-time students (12-18 credit hours) and the in-state public maximum per term is $18,000, do we receive the $12,000 tuition and fees cost from the VA, or do we have to use the per-credit-hour calculation to determine the VA benefit?
A: The basic Post-9/11 GI Bill benefit paid to an eligible veteran at your institution will be calculated by multiplying the number of credit hours the veteran is taking times the maximum credit hour charge for your state and then adding in any fees charged up to the maximum fee for your state. It doesn’t matter whether or not your institution charges a flat fee. The VA benefit calculation will be based on the number of credits the eligible veteran is taking. (Note that the maximum dollar figures on the VA’s state tables may change when the 2009-10 figures become available.)

Related information: "Please be aware that we always consider the per credit hour charge, even if the school charges a flat amount for 12-18 credits. You should always use the number of credits in which the student is actually enrolled and multiply it by the per credit maximum in-state undergraduate rate to determine the portion available by the Post-9/11 GI Bill and the unmet charges for the Yellow Ribbon Program. Use this same method regardless of the number of credit hours the student is pursuing." (Yellow Ribbon Program FAQ #33, "How will the School Certifying Official determine the schools’ contribution to enter on the 22-1999 Enrollment Certification?") (See also “Benefit Calculations.”) 


Q: How can we find out if our state maximum is expected to change significantly? We can’t realistically budget these awards until we know for sure what the amount will be, but the contract is due prior to the release of those amounts.
A: "All Yellow Ribbon Program agreement forms must be received by June 15, 2009, in order to establish a school’s participation in the program for academic year 2009-2010. Agreements will not be accepted after this date. Additionally, agreements cannot be amended once signed and approved by VA. Some schools may have prior knowledge of anticipated state tuition increases. If not, please choose the flat amount that best fits your choice for contribution considering the 2008-2009 highest maximum tuition and fees as well as your school’s planned budget." (Yellow Ribbon FAQ #2, "How can I determine the flat amount when I do not know how much 09-10 tuition and fees will be? Can I amend my agreement when the 09-10 rates come out?")

The California $0 Issue

The questions below are two of many we received about the California tuition-and-fee situation. Briefly, the state tuition tables published by the VA show that the maximum tuition per credit hour for California is $0. This means that an eligible veteran attending a private college in California will receive a basic Post-9/11 GI Bill benefit equal only to the amount of the fees charged by the institution. Fees charged by California private colleges are substantially lower than the fees charged by public colleges in the state, because the private colleges include most of their charges in tuition. California public colleges, on the other hand, charge "fees" in lieu of tuition.

Q: We really need more clarification about California. We're a tuition-based college that charge fees no greater than $200. Our students wouldn't receive any substantial amount of assistance. Is there something we may do to verify that we are a California tuition-based, approved school in order to change the credit amount?

Q: Is there any discussion regarding the "tuition" component in California? As it stands now, private institutions are essentially being cut out of the GI Bill portion because of the fee versus tuition language.
A: "The law requires that we go by the maximum in-state tuition and fees. California’s maximum in-state tuition is $0. So, we can only use what they tell us is their maximum in-state tuition. We can’t change that one, and they have been strongly approaching us about the fact that it is $0. There is no tuition for undergraduates in-state in California." (Response from VA official participating in the Webinar.)

Related Information: Representatives Howard "Buck" McKeon (R-Calif.) and Mike Thompson (D-Calif.) have introduced legislation (H.R. 2474) that would provide the VA with unambiguous authority to recognize that fees in California are equivalent to tuition. As of June 14, 44 members of the California congressional delegation had signed on as cosponsors; however, it was not approved prior to the deadline for submission of Yellow Ribbon program agreements. Additional information about this legislation may be found on Representative McKeon's website.


Q: The State of Texas is listed to pay $1,333 in tuition per credit hour, which I believe to be incorrect. However, we are asked to complete the Yellow Ribbon application by June 15, and are not allowed to change our application. When will the tuition-per-credit-hour figures be updated?
A: August 1.

Institutional Eligibility for Yellow Ribbon Program

Q: How do we fill out the agreement form since our tuition and fees are lower than the in-state public costs?A: Unless you offer any program (e.g, graduate school) that charges more than the credit-hour maximum in your state, all eligible veterans will have all their costs at your institution paid for under the basic Post- 9/11 GI Bill benefit. In that case, your institution cannot participate in the Yellow Ribbon program—because there is no extra charge for you to match.

Related information: "My school’s tuition and fees are lower than the posted in-state undergraduate maximum tuition and fees. Should I place $0 in block 7 of the Agreement? Are we not eligible for the Yellow Ribbon Program? You should not place $0 in block 7 of the Yellow Ribbon Program; this is an indication that you are not willing to contribute any funds toward a student’s unmet charges. You are eligible to be a Yellow Ribbon Program participating school if you agree to contribute funds toward a student’s unmet charges, and list them in block 7 of the agreement.


"You should be sure that no student’s tuition or fees would be higher than the maximum public in-state undergraduate tuition and fees. Carefully consider graduate students and/or out-of-state students that may have tuition or fees that exceed the posted in-state undergraduate maximum tuition and fees. If you are certain you do not have students who could have tuition or fees that exceed the posted in-state undergraduate maximum tuition and fees, you do not have to participate in the program and you do not have to send in an agreement." (Yellow Ribbon Program FAQ #6.)


Information on calculating unmet tuition and fee charges:

Related Information: "Why is there a flat amount instead of a percentage in block 7 of the Yellow Ribbon Agreement? My school wants to contribute 50% for Yellow Ribbon Program. How do I determine how much to place in block 7 of the agreement? The final regulations were written taking into account comments from numerous schools that requested to be able to choose a flat dollar amount for budgeting purposes. To determine how much to place in block 7, compare your school’s tuition with the maximum in-state undergraduate public tuition. Then compare your school’s fees with the maximum in-state undergraduate fees. Go to: www.gibill.va.gov/GI_Bill_Info/CH33/Tuition_and_fees.htm to determine what your state’s maximum tuition and fees are. These are 2008-2009 maximum tuition and fee rates.


"To make the comparison, multiply the number of credits a student would take in a term at your school by the per credit amount from the Web site and compare that amount to what your actual tuition would be for the same number of credits. You could use a typical student, a student with a maximum course load, or any other criteria you choose in making the estimate. Then perform the same calculations for fees. Look at what your fees per term are for a student. You could use a typical student, or a student in the most expensive program, or any other criteria you choose to get the figure you will use for your estimate for fees. Compare the estimate against the maximum fees that can be paid for a term. If the highest maximum tuition is lower than your school’s, then the difference would be considered unmet tuition charges. If the highest maximum fees per term are lower than your school’s fees, the difference would be considered unmet fee charges. If there are unmet charges for either tuition or fees in a term, those unmet charges are taken into consideration for the Yellow Ribbon Program. From the estimated unmet charges per term, you would estimate the annual unmet charges by multiplying the unmet charges times the number of terms. Choose the maximum annual amount that you would want to contribute per student toward the unmet charges for the entire academic year (August 1st to July 31st) and report it in block 7." (Yellow Ribbon Program FAQ #1.)


Q: Currently we are not eligible for the Yellow Ribbon Program because of our low tuition and fees. However, in the future an adjustment could be made to the maximum state tuition and fees which significantly reduces the amount to be paid through the Post 9/11 GI Bill. How can we apply if that happens?
A: You will have an opportunity annually to sign up for the Yellow Ribbon program. In the future, agreements must be submitted by February 15.

Institutional Match

Q: If the institution contributes 30% of the gap and the VA matches this 30%, would the student be responsible for the remaining 40%?
A: Yes. Please note, though, that contributions will be made in dollar amounts, not percentages.

Q: What do you mean "we've moved away from the percentage"?
A: In the proposed regulations, Yellow Ribbon Program contributions were to be designated in the form of percentages. The final regulations changed to dollar amounts. "The final regulations were written taking into account comments from numerous schools that requested to be able to choose a flat dollar amount for budgeting purposes." (Yellow Ribbon Program FAQ #1, "Why is there a flat amount instead of a percentage in block 7 of the Yellow Ribbon Agreement? My school wants to contribute 50% for Yellow Ribbon Program. How do I determine how much to place in block 7 of the agreement?")

Q: What is the intended difference between direct grant or scholarship on the application (Question 5)?
A: "The law requires you to tell us how you will provide the contribution. VA does not have specific interpretations or definitions of these terms. However, Yellow Ribbon Program contributions cannot be loans, Federal aid funds, or funds received by a third party that are not under the unrestricted control of the IHL [institution of higher learning]. The term "unrestricted funds" refers to funding that is available to the IHL without any conditions on its use (i.e., designated for use by a specific individual or a specific group of individuals). However, funds received from a third party that are restricted for use in the Yellow Ribbon Program may be counted towards the IHL's contributions to a Yellow Ribbon Participant." (Yellow Ribbon Program FAQ #18, "How does VA interpret the terms "Direct Grant" and "Scholarship" in Question 5 of the Agreement? )

Q.  Could you provide some examples of what would be considered “restricted funds”?
VA written response:  (From VA “overall response”):  Restricted funds:  Consider that to mean Title IV aid money and any money that is restricted just to one group of people.  We may need to clarify that after we work through this first year.  What we were trying to say, for example, is that if a donor gave you $1 million for women students, you couldn’t use that $1 million to pay both male and female veterans. 

Several participants in the webinar requested further clarification of the use of merit scholarships as the Yellow Ribbon match.  The VA addressed this issue in an “overall response,” which is included in its entirety under the “Interaction with Other Federal and State Educational Programs” section.  Sample questions --  

Q: If you agree to give every veteran $10,000, can we give those that are eligible for our scholarships, their appropriate institutional scholarship and those not eligible for our merit scholarships an institutional grant for $10,000 to keep the agreement? 

Q:  If we used our existing institutional academic scholarship program and institutional grant money to provide the match such that Vets eligible for our scholarships would receive the scholarships and those not eligible for our academic scholarships would receive institutional grant money as match, would that be acceptable? 

VA written response:  (From VA “overall response”):  Merit scholarships and other scholarships as funding sources for school’s contribution for Yellow Ribbon program.   

    • Most importantly, Title IV funds, loans, work-study, or Pell grant cannot be used for school’s Yellow Ribbon contribution. 
    • If a veteran otherwise qualifies for your merit programs, that money can be used as your contribution. 
    • Example:  “If we used our existing institutional academic scholarship program and institutional grant money to provide the match such that Vets eligible for our scholarships would receive the scholarships and those not eligible for our academic scholarships would receive institutional grant money as match, would that be acceptable?”  Yes, this is acceptable.  As long as the veterans covered in the Yellow Ribbon Program are each eligible for a maximum of $ X (you set this amount).  If one maximum comes from an academic scholarship and one comes from an institutional grant, that is fine--as long the veterans are treated equally.  You will also need to specify on the agreement whether you are using a grant, scholarship, or combination and list them.




 

Q: The participation amount is just the maximum we would pay for an individual student. We may end up paying less if a student doesn't take maximum credits. Is that correct?
A: Yes. Neither the payment by the institution nor by the VA may exceed 50% of "gap" between the basic tuition and fee benefit and the tuition and fees charged to the student.


Q: Regarding the Yellow Ribbon IHL matching funds, are they limited for use for tuition and fees only? The reason I ask is we charge different tuition/fees. Would some veterans with a lower fee, receive a "refund" for the difference between their Yellow Ribbon benefits, Post-9/11 GI benefits, and the cost of tuition and fees?
A: Yes, Yellow Ribbon matching funds are limited to tuition and fees. The basic Post-9/11 GI Bill benefit paid to a veteran will be based on the amounts actually charged to the veteran—so a veteran with a lower fee would receive a lower basic payment. The "gap" between the basic tuition and fee benefit received by the veteran and the tuition and fees charged to that veteran is what would be covered under the Yellow Ribbon agreement.

Related information: "The School Certifying Official (SCO) will report tuition charges and fee charges separately on the enrollment form. The SCO will report the full tuition amount on the enrollment certification and will enter the full fee charges on the enrollment - the SCO will not change it to a per credit hour amount. The SCO will have to determine what the unmet charges are so that he or she will know how much the school can contribute. The SCO will enter the maximum amount the school is choosing to contribute on the enrollment form. VA will compute the unmet charges and compare to the maximum amount listed by the SCO. VA will match the amount listed up to 50% of the unmet charges.

"For example, a student is taking 6 credit hours and the total tuition charge is $4,200.00 and fees are $600.00. You determine after checking the Web site maximum tuition and fees that the maximum per credit hour for your state is $400.00 and the maximum fees are $500.00. This student is eligible for a basic tuition payment of $2400 ($400.00 maximum per credit X 6 credit hours) and fees of $500.00. This results in an unmet tuition charge of $1,800.00 ($4,200.00 minus $2,400.00) and an unmet fee charge of $100.00 ($600.00 minus $500.00). The total unmet charges applicable to the Yellow Ribbon Program are $1,900.00.

"The school has chosen a maximum annual amount per student of $3,000.00. The SCO submits an enrollment certification indicating that the student is eligible for the Yellow Ribbon Program, and enters $950 for the school’s contribution under the Yellow Ribbon Program. VA will match the $950.00. The balance available under the Yellow Ribbon Program for that student is $2,050.00 ($3,000 annual amount per student minus $950.00 contributed by the school).

"Please be aware that we always consider the per credit hour charge, even if the school charges a flat amount for 12-18 credits. You should always use the number of credits in which the student is actually enrolled and multiply it by the per credit maximum in-state undergraduate rate to determine the portion available by the Post-9/11 GI Bill and the unmet charges for the Yellow Ribbon Program. Use this same method regardless of the number of credit hours the student is pursuing." (Yellow Ribbon Program FAQ #33, "How will the School Certifying Official determine the schools' contribution to enter on the 22-1999 Enrollment Certification?)


Q: So every Yellow Ribbon scholarship must be the same amount per student regardless of other sources of funding they have?
A: Yes, although you can designate different amounts by groups of students. For example, you can set a different contribution amount for your undergraduate students than for your graduate students. Within each group of students, however, the contribution amount is the same.

Q: Our college has a flat tuition rate for students enrolled in 12 to 17 credits. There is a cost per credit that is charged to the student if they go over the cap of 17 credits. How should this be calculated into the contributions for the academic year for the Yellow Ribbon Program?
A: The calculations are the same. You determine the number of credits the student is taking during the term, and multiply that by the maximum tuition per credit hour for your state. That is the tuition benefit that will be paid to the eligible student under the basic Post-9/ll GI Bill. Subtract that number from the amount of tuition you have charged the student to determine the "gap" amount that would be covered under the Yellow Ribbon program.

First-Come, First-Served

Q: Would you please elaborate on "first-come, first-served"? Perhaps give some examples of ways in which this could be set up?
A: The VA specifically did not provide detailed guidance to colleges about the details of their "first-come, first-served" policies. The institution should set the policy, and the role of the VA will be to determine if that policy is being followed. The VA wishes to assure that institutions are able to do what works for them, in terms of their own registration, admissions, and other policies.

Q: If we have 10 students this year and they return and we have an additional 10 next year, do we need to increase our number for the new year to 20, or does it go back to first-come, first-served?
A: Yes, you need to increase your number for the new year to 20. 

Q: What about currently enrolled students? Are they first in line?
A: Current students are included in "first-come, first-served."

Benefit Calculations

Q: How do we determine the number of credit hours to use when calculating the amount the VA will contribute for tuition? Is it the amount the university has established as the minimum to qualify as a full time student?
A: No. You calculate the tuition benefit by multiplying the maximum tuition per credit hour for your state by the actual number of credit hours taken by the eligible veteran.

Q: When determining number of credits, is there a limit per term (18, for example) or per year (36, for example)?
A: No, there is no limit. Benefits will be paid based on the number of credits the eligible veteran takes.

Q: Is there a cap on the number of credits? If we complete the agreement at 12 credits per semester, and the student takes 16, does that change the gap amount paid by the school and the VA or is it based on just the normal full time credit load?
A: As noted above, there is no cap on the number of credits. If the student takes 16 credits per semester – rather than 12 as originally planned – that does change the gap amount. (See Yellow Ribbon FAQ excerpts below.)

"No, VA does not limit the number of credits reported, and tuition and fee maximum amounts are calculated on a per-credit basis. For example, if a student is enrolled for 20 credit hours at your school, you would determine the highest maximum tuition eligible for payment under the Post-9/11 GI Bill by multiplying 20 credits by the maximum per credit hour tuition charge shown on the Web site for your state." (Yellow Ribbon FAQ #8, "Does VA limit the number of credits reported, and does VA relate the highest maximum undergraduate tuition and fees to the VA standard of 12 credits for full time?")

"Please be aware that we always consider the per credit hour charge, even if the school charges a flat amount for 12-18 credits. You should always use the number of credits in which the student is actually enrolled and multiply it by the per credit maximum in-state undergraduate rate to determine the portion available by the Post-9/11 GI Bill and the unmet charges for the Yellow Ribbon Program. Use this same method regardless of the number of credit hours the student is pursuing." (Yellow Ribbon FAQ #33, "How will the School Certifying Official determine the schools’ contribution to enter on the 22-1999 Enrollment Certification?)"We define full-time as 12-18 credit credits hours and have the same flat rate tuition for all. If a student reduces from 15 to 12 credits and there is no change to the tuition charge, will I have to report the change on a VA form 22-1999b? Yes, the basic tuition payment and the Yellow Ribbon Program contribution amounts will change, as they are based on a tuition charge per credit hour." (Yellow Ribbon FAQ #48)

Q.  If the cost of fees are included in the cost of tuition, will we be able to take the maximum in-state amount for fees anyway?

VA written response:  No.  If you do not charge “fees,” the VA will not pay additional money for fees.   

Q: If fees are included in the tuition cost, how will the institution calculate the VA match?  
VA written response:  Figure the maximum tuition payment by multiplying the number of credit hours by the maximum credit hour charge for tuition shown on the VA website for the state in which the veteran is attending school.  Subtract that amount from the total charged by your institution.  The difference is what VA and the institution can match under Yellow Ribbon.       

Example.  You charge $12,000 for fall term.  The maximum on the VA chart for your state is $200 per credit hour and $3,000 for fees.  The student is enrolled in 15 credits at your school in the fall.  VA will pay $3,000 (15 x $200), if the student is entitled to the 100% payment tier.  The remaining $9,000 is not covered, but the school can pay part of that $9,000 and VA will match what the school contributes.  So, if you pay $4,500, the VA will pay $4,500 on top of the $3,000 basic benefit. 

Q: We have three quarters instead of two semesters – Will we be able to take the maximum in-state tuition rate ($203) for Georgia x 45 quarter hours for the year (15 credit hours/quarter) or are we limited to the maximum total fees per term amount of $15,401 x 2? 

VA written response:  The benefit calculation would be based on 15 credit hours per quarter for each quarter the student is enrolled in your school.  The VA would pay 15 x $203 for each quarter (assuming the credit hour charges of your school equal or exceed $203).    We would also add to that any fees charged each term, up to a total of $15,401 for fees.  The tuition and fees calculations are made separately.

Follow-up Question:  How was the $15,401 figure calculated?   
VA written response:  The Georgia State approving agency reported this information to the VA. They identified the maximum fees a student enrolled in an undergraduate program at a public institution in Georgia would pay for his or her program in any one quarter, or semester, or term.  Some states have some pretty high fees because they have flight programs, or nursing programs, or other programs with high fees.   

Q: I read that we should be liberal in estimating our total benefits available because it is intended to be a maximum.  If we estimate higher, are we obligated to fulfill those higher numbers?  Estimation is particularly difficult when we don't know what the fall rates will be yet. 
VA written response:  You will not be held to the higher numbers this agreement period.  This is the first year.  However, if you show you will cover 10,000 students at $10,000 each and you only cover five students, the VA will discuss that with you for next year and have you enter into a more reasonable agreement.   

Q: We have certificate program with credits and non-credits.  Will these students be eligible for Yellow Ribbon, and how will calculate the total tuition and fees?

VA written response:  If the student receives CEUs instead of credits, the VA does not pay benefits. 

Summer Programs

Q: Are Yellow Ribbon Benefits available in the summer?
A: Yes, if the school still has Yellow Ribbon Program funds available for the per student maximum contribution for summer term. "For example: A school is willing to contribute $1000.00 per student annually. For fall term, the school contributed $250.00, and for spring term, the school contributed $500.00. There is a balance of $250.00 available for summer term. The Yellow Ribbon Program Agreement is for a full academic year, which VA defines as August 1st to July 31st." (Yellow Ribbon FAQ #9, "Will the student receive Yellow Ribbon Program funds for summer also?")

Related Information: "Can we determine how much of our maximum annual amount (from line 7) we want to contribute for each term? Yes, the VA School Certifying Official will enter the amount the school wants to contribute for the specific term, quarter or semester on VA form 22-1999 (enrollment certification). You must make a contribution for each quarter, term or semester in which a student is enrolled, provided you have not exceeded the maximum annual contribution per student." (Yellow Ribbon Program FAQ #34.)


VA Program Participation Agreement Elements

Q: If a Yellow Ribbon participation form was completed incorrectly, will the school be notified to resubmit it?A: Yes. The VA will notify an institution of any corrections that need to be made on their agreement form.

Q: If an error was made on the Yellow Ribbon Program application, can we resubmit?
A: Yes, provided that the corrected agreement is submitted by the June 15 deadline. When you send it in, please indicate that it is an amended version, intended to replace your original agreement.

Q: Are you saying that we need to use our next year’s tuition rates to determine the amount our university will pay as part of the Yellow Ribbon Program – there will be no opportunity to change the amount?
A: Once you have an approved Yellow Ribbon agreement, that agreement may not be amended and will be in force for the full academic year. Each institution will enter into a new agreement annually; and the terms of the agreement can be changed at that time.

Related information: All Yellow Ribbon Program agreement forms must be received by June 15, 2009 in order to establish a school’s participation in the program for academic year 2009-2010. Agreements will not be accepted after this date. Additionally, agreements cannot be amended once signed and approved by VA. Some schools may have prior knowledge of anticipated state tuition increases. If not, please choose the flat amount that best fits your choice for contribution considering the 2008-2009 highest maximum tuition and fees as well as your school’s planned budget." (Yellow Ribbon Program FAQ #2, "How can I determine the flat amount when I do not know how much 09-10 tuition and fees will be? Can I amend my agreement when the 09-10 rates come out?)


Agreement Item # 2

Q: According to the VA Web site, if an institution of higher learning agrees to participate in the Yellow Ribbon Program, we agree to provide current academic year and all subsequent academic years for a student. Is that contingent upon IHL participation each year, or the year you participate for that student?
A: IHL participation is for each year. If the institution does not participate in the Yellow Ribbon program, it does not have to make any payments on behalf of continuing students.

"Do I have to keep contributing the same amount for Yellow Ribbon Program for all subsequent years of a student’s education? No, the law indicates that if you continue to be a participating Yellow Ribbon Program School, you must allow participating students to continue receiving Yellow Ribbon Program benefits. However, you may choose to contribute a different amount when you complete your new agreement for a new academic year. If you choose not to participate in the Yellow Ribbon Program for subsequent years, you will not be responsible for Yellow Ribbon Program contributions for those students." (Yellow Ribbon FAQ #26.)

Q: Is the institution required to pay at least the same amount as the first year for continuing students, or may it adjust to new rates each year?
A: The school does not have to pay the same amounts. They may be adjusted each year.

Q: If an institution decides not to participate in the Yellow Ribbon Program after doing so in the first year or subsequent years, does the student become obligated to pay full tuition and fees on their own, or transfer to another institution that is participating?
A: Every student eligible for the Post-9/11 GI Bill will receive a basic tuition and fee benefit of up to the maximum public undergraduate payment in a state – whether he/she attends a public or a private institution – as long as that institution offers a program approved by the Department of Veterans Affairs. A student attending an institution that initially participates in the Yellow Ribbon program would not continue receiving the extra Yellow Ribbon matching funds if that institution discontinued its participation in the program. If the student continued at that institution, he/she would have to pay the tuition and fee charges that exceed the basic benefit payment.

Q: Does the reference to satisfactory progress in #2 of the agreement refer to the college's GPA standards for enrollment OR the Federal SAP relies which require a pass rate threshold also?
VA written response:  It refers to whatever your college’s satisfactory progress standards are.  The ones you publish.

Agreement Item #4 

Q: I am confused by Item 4 on the Program Agreement.  Can you give an example to clarify what this language means?

VA written response:  If you offer a maximum of $10,000 per student per year, and the student has $2,000 that is not covered by the basic benefit for the fall term, we expect that you would pay $1,000 and we would pay $1,000, so that all of the veteran’s fall term tuition and fees was covered.

Agreement Item #6

Q: Is the number cumulative – e.g., 10 per year – or maximum – e.g., 10 total until one or more of those covered leaves?
A: If the question is whether the 10 students already covered need to be carried over to the next year if they remain in good academic standing, the answer is yes. If you wish to serve an additional 10 students in the next year, then you should indicate 20 on line 6. If you do not, then indicate 10.

Q: If I agree to accept 12 students, but then later determine that there's enough money to accept a 13th student, will the VA meet the match for that 13th student?
A: Yes. At least in the initial year, the VA has indicated that it will be flexible in this type of situation and will make the matching payment on behalf of the extra student.

Agreement Item #7

Q: We want to provide Yellow Ribbon benefits for our traditional undergraduate program and for our adult studies program, which are priced differently. Can these two programs be listed on the application as separate "colleges" or "professional schools"?
A: No. Programs cannot be listed separately unless they are a separate college or professional school.

"Can I choose to award Yellow Ribbon for specific degree programs? Can I choose day undergraduate program students and not evening undergraduate students? Can I choose to exclude out-of-state undergraduate students? Can I exclude part-time students? No. The subcategory must be chosen by 7b Undergraduate, Graduate or Doctoral and/or 7c by college or professional school." (Yellow Ribbon Program FAQ #20)

Q: Is the amount listed the total amount over what the VA pays, or is it the estimated amount of our 50% share?
A: It is the amount the institution will pay up to its 50% share.

"Can I choose to indicate the number of students and the dollar amount for each line on block 7 of the Agreement?

"Yes, schools have the flexibility to indicate the number of students for each line of block 7, and the flexibility to specify contributions based on student status (undergraduate, graduate, doctoral) and college or professional school.

"In line 7a, you may designate the maximum contribution amount for any eligible student.

"Line 7b allows the flexibility to specify the maximum amount for students pursuing different levels of education. For example, you may designate $250 for undergraduates, $500 for graduate students, and $0 for doctoral students. You may indicate the maximum number of students at each level to the right of each line.

"Line 7c allows the flexibility to specify the maximum amount for students pursuing training in different colleges/professional schools. For example, you may designate $1000 for students in your school of engineering, and $2000 for students in your school of nursing. You may indicate the maximum number of students at each level to the right of each line.

"You may also choose a combination of both 7b and 7c; however, if you will be specifying maximum contributions using both of these lines, please complete separate agreements for each combination. For example, if you will contribute $250 per undergraduate student in the school of engineering, and $500 for each undergraduate student in the school of business, please report these figures on separate Yellow Ribbon Program agreement forms." (Yellow Ribbon Program FAQ #19)

Program Administration

Q: Payment from the VA goes directly to the college, not the student – correct? Also, what is the timeline from when the student gets approved for the Yellow Ribbon Program when the college gets paid?
A: "Schools will receive tuition & fees and Yellow Ribbon Program payments directly from the VA on behalf of each eligible student. VA sent a letter and an attachment to degree granting institutions requesting a Tax Identification Number and bank account deposit information. Schools that return this information to VA will receive payments via Electronic Funds Transfer (EFT). Should VA not have active EFT information for a school, payments will be issued by paper check to the mailing address on file."

"VA will also mail School Certifying Officials a weekly ‘Vet Rep Listing Report' detailing VA education benefits students are receiving. Payments made directly to the schools will be listed on the report in a sub-section titled ‘Chapter 33 Tuition and Fees, and Yellow Ribbon Payments'."

"For additional payment information, click here. If you have other questions regarding payments or you wish to request a copy of the EFT attachment, submit your request to CH33schools@va.gov." (Source: Question 980 on VA FAQ site. Prepared 4/22/2009.)

Q: How will we submit information for payment for the Yellow Ribbon program?
A: VA's Office of Resource Management sent a letter to Higher Education Executives around April 24, explaining how schools will receive and identify payments from the VA, and discusses avoiding debts and refunding money. Click here to view the letter.

VA written response:  In general, your VA Certifying Official will complete an enrollment certification and show the charged tuition and fees, and the amount your institution is contributing for the student.  VA will process payment for the tuition and fees and a payment for its portion of the Yellow Ribbon benefit.  It is a student-by-student process.

Q: If a student receives Yellow Ribbon benefits and they withdraw during the term, how do we handle refunds?
A: The process of handling refunds is explained in a letter sent by the VA's Office of Resource Management sent a letter to higher education executives in late April. Among other things, this letter notes that "Should a student enroll in courses, begin attending classes and subsequently drop out, schools shall follow their own refund policy and deal directly with the student. Should the change in enrollment cause a VA debt, VA will collect from the student." Click here to view the letter.

Q: How will a school know if it has been approved for the Yellow Ribbon program?
A: The VA will return a copy of the agreement, with a cover letter acknowledging receipt and acceptance of it.

Q: Will certification be allowed through VA Once?  VA written response:  Yes.
 

Q: Where in VA-ONCE will the institutional contributions be entered by the VA certifying officer?
VA written response:  The VA will provide training for Certifying Officials when they begin utilizing changes in VA-Once.    IT enhancements are ongoing as they push toward the deadline of 8/1/09.  For more information, see:  http://www.gibill.va.gov/School_Info/once/index.htm  When you get to the link, scroll to Update Information and click on P028.


Q: Is it the certifying official who reports the amount the college pays for each student?
A: Yes.

"The School Certifying Official will report tuition charges and fee charges separately on the enrollment form. The SCO will report the full tuition amount on the enrollment certification and will enter the full fee charges on the enrollment – the SCO will not change it to a per credit hour amount. The SCO will have to determine what the unmet charges are so that he or she will know how much the school can contribute. The SCO will enter the maximum amount the school is choosing to contribute on the enrollment form. VA will compute the unmet charges and compare to the maximum amount listed by the SCO. VA will match the amount listed up to 50% of the unmet charges.

"For example, a student is taking 6 credit hours and the total tuition charge is $4,200.00 and fees are $600.00. You determine after checking the Web site maximum tuition and fees that the maximum per credit hour for your state is $400.00 and the maximum fees are $500.00. This student is eligible for a basic tuition payment of $2400 ($400.00 maximum per credit X 6 credit hours) and fees of $500.00. This results in an unmet tuition charge of $1,800.00 ($4,200.00 minus $2,400.00) and an unmet fee charge of $100.00 ($600.00 minus $500.00). The total unmet charges applicable to the Yellow Ribbon Program are $1,900.00.

"The school has chosen a maximum annual amount per student of $3,000.00. The SCO submits an enrollment certification indicating that the student is eligible for the Yellow Ribbon Program, and enters $950 for the school’s contribution under the Yellow Ribbon Program. VA will match the $950.00. The balance available under the Yellow Ribbon Program for that student is $2,050.00 ($3,000 annual amount per student minus $950.00 contributed by the school).

"Please be aware that we always consider the per credit hour charge, even if the school charges a flat amount for 12-18 credits. You should always use the number of credits in which the student is actually enrolled and multiply it by the per credit maximum in-state undergraduate rate to determine the portion available by the Post-9/11 GI Bill and the unmet charges for the Yellow Ribbon Program. Use this same method regardless of the number of credit hours the student is pursuing." (Yellow Ribbon Program FAQ #33, "How will the School Certifying Official determine the schools’ contribution to enter on the 22-1999 Enrollment Certification?" )

Q: Can we file in advance of the beginning of our semester once the student is registered for classes?
A: "VA anticipates beginning to process enrollment certifications in the beginning of July. Schools will be notified as to when VA will begin processing enrollment. More importantly, enrollment certifications for the Post-9/11 GI Bill received prior to this notification will not be recognized by VA’s system. These enrollments will need to be resubmitted once the school is notified that VA has begun to process enrollment certifications in order for students to receive benefits.

"Please note that under the Post-9/11 GI Bill you must certify a student’s actual tuition and fees charges. As such, you should not certify students who are pre-registered if you do not have the exact charges for fees associated with their actual enrollment." (Yellow Ribbon Program FAQ #51, "When can I begin to certify students for the Post-9/11 GI Bill?)

Q: Can you define academic year? Usually it means two semesters. We run 3 full semesters each calendar year but define our academic year as two semesters. How will we be affected?
A: The VA defines an "academic year" as August 1 to July 31. The terms your institution offers during this period are those for which benefits will be paid and which you should include in your Yellow Ribbon agreement if you choose to participate in the program.

Q: I understand the housing stipend is based on the college's ZIP code. What is the formula or how is it determined?
A: "The monthly housing allowance is based on the Basic Allowance for Housing (BAH) for an E-5 with dependents at the location of the school. To determine the BAH for your school's ZIP code click here (link goes to a non-VA Web site)." (This information comes from the VA Web site at www.gibill.va.gov/GI_Bill_Info/benefits.htm#CH33.)

Q: How will a student file for the books or housing benefits? What role for the college?
VA written response:  VA will use the enrollment certification submitted by your VA Certifying Official to determine the amount of the books/supplies stipend.  It will be based on the number of credits the student enrolls in during the enrollment period.  You do not need to send in anything else.

On-line Education

Q: For students who are completing online classes, is the tuition based on the state where the institution is located, or where the learner is located?
A: The state where the institution is located.

Related information: "What if I have a student taking all online courses? What state would I use to determine his or her maximum public in-state undergraduate tuition and fees amount? What if I have a student taking both online courses and in-classroom courses? For a student pursuing all online courses, the SCO would send in the enrollment certification for the online campus. The maximum undergraduate tuition and fees will be determined based on the location of the campus where the student is enrolled. If the student were taking both on-line and classroom courses at two different facilities, the SCOs would each send enrollment certifications. VA would determine the maximum undergraduate tuition and fee rates based on the location of each school. If the schools are located in different states, the rates for each state will be used to determine the Yellow Ribbon Program payments. The Yellow Ribbon Program contributions would be computed separately based on each state's maximum public in-state undergraduate tuition and fees. The payments will be sent to the two separate schools." (Yellow Ribbon FAQ #38)


 

Dependent Benefits

Q: I have a student whose parent has 26 years of service. He informed me that he will be able to re-enlist for an additional four years. At what point will he be able to transfer his benefit to his child?
A: Approval for the transfer of benefits to a dependent will be done at re-enlistment (after at least six years of service, with a commitment to serve at least four more). If approved, the service member may transfer benefits to a dependent child if the member has already completed 10 years of service. For additional information, see the June 23, 2009, news release, "DoD Announces Transferability Options For Post 9/11 GI Bill."

Q: Can you clarify when a dependent is eligible for the benefits? Is it after the sixth year (when the serviceman agrees to serve another four or is it after the actual 10th year?)
A: It depends on the dependent. A service member who receives approval for a transfer of benefit may transfer it to a spouse after six years of service. The service member must complete 10 years of service before the benefit may be transferred to a dependent child.

Q: Can an eligible veteran transfer benefits to child who is attending graduate school?  That child is an independent on the FAFSA for financial aid purposes.

VA written response:  A dependent who is entitled to transferred benefits can use them for approved graduate training.  Dependents can use benefits for the same programs as the veteran can.  Note, however, that the policy guidelines issued by the Department of Defense on April 28, 2009, indicate that a dependent may not use the benefit after reaching age 26.  The policy guidelines may be found here.

  


Q: In the case of a dependent that is receiving Chapter 35, can the parent elect the new Chapter 33 vs. 35 for dependent benefits?  
VA written response:  Only individuals who are members of the Armed Forces on 8/1/09 (and who are permitted by the Department of Defense to do so) may transfer Chapter 33 benefits.  Parents whose children became eligible for Chapter 35 are either deceased or 100% permanent and totally disabled and thus would not be still a member of the Armed Forces on 8/1/09, so they would not be able to transfer Chapter 33 to their dependents.  You must be in the Armed Forces on or after 8/1/09.  The ability to transfer benefits is a “recruitment and retention” tool for the Department of Defense (DoD).  DoD makes the decision whether or not a member of the Armed Forces can transfer benefits. VA pays the benefits to the dependent that the member of the Armed Forces identifies.

Related Information:  The bill to finance continuing U.S. military operations in Iraq and Afghanistan includes a provision that extends the new post-9/11 GI Bill benefits to all children of members of the military who have died while on active duty since 9/11/01.  Click here for additional information.



Additional Sources of Information

Q: Are the slides from the May 13 NAICU Webinar available?
A: Yes. They are posted on the NAICU Web site.

Q: Where can our financial aid office find a guide to Yellow Ribbon benefits?
A: The VA Web site includes an "Information for Educational Professionals" pagehttp://www.gibill.va.gov/School_Info/landing_schools.htm. Several additional links are included on this page, including one to information about the Yellow Ribbon program.

The following information may also be helpful:

"My school President/finance office wants to know how payments will be made and how we can identify which student each payment is for. The letter posted at www.gibill.va.gov/School_Info/yellow_ribbon/index.htm explains payment processing for the Post-9/11 GI Bill and Yellow Ribbon Program payments. This letter was also mailed to schools on April 24, 2009." (Yellow Ribbon FAQ #49.)

"When will School Certifying Officials receive further training? SCO will receive training at School Conferences and through their Education Liaison Representatives. A PowerPoint presentation will be developed to provide training on the version of VA-ONCE [VA on-line form submittal] that includes the Post-9/11 GI Bill and Yellow Ribbon Program when available." (Yellow Ribbon FAQ #50.)

Q: Can you tell us where the benefit calculator is online?
A: The direct link is www.nacubo.org/Documents/government/GIBTFE040909_New.xls.

There also are links to it from the GI Bill item on the NACUBO site and from the "Other Sources of Information" page on the NAICU GI Bill mini-Web site.

Q: Can we get a list of those in our area of have signed up?
A: The VA has posted a list of institutions participating in the Yellow Ribbon program on its Web site. In addition, a Yellow Ribbon search filter will be available on the portion of the site that lists approved programs.

In the meantime, NAICU is maintaining an informal, unofficial listing of private, non-profit colleges that have announced their intent to participate, but are not yet listed on the VA site.  We will remove this informal list once the final VA list is available.

Other VA Educational Programs

Q: Is the Chapter 31 program still offered by VA?
A: Yes.

Q: Are we required as a participant of Yellow Ribbon to give these benefits to any student in any chapter of VA benefits such as Chapter 35 or only the new Post-9/11 VA Benefit?
A: No. Yellow Ribbon program benefits are available only under the new Post-9/11 GI Bill program.

Q: If we provide a student with a full institutional merit scholarship and then they sign up for Chapter 33, can we reduce the merit scholarship by the amount of the Veteran Benefits?  VA written response:  The answer depends on the rules for your scholarship and is not within VA’s purview to address.  You would be governed by your scholarship rules.  We will pay what the veteran is entitled to receive based on the statutory rules.

Interaction with Other Federal and State Education Benefits

Q: How do Pell awards factor into calculations?
A: "I have questions about how financial aid programs relate to the school’s Yellow Ribbon contribution amount. Regulations require that schools not use federal funds for Yellow Ribbon, and that all contributions consist of funds within the school’s control. Other questions about financial aid, Title IV funds, or any issues pertaining to whether you can decrease the amount of or withhold merit scholarships, etc. should be referred to school’s Financial Aid Office. VA benefits, including benefits under the Yellow Ribbon Program, are entitlement and are not considered need-based." (Yellow Ribbon FAQ #47.)

Q: Can the federal Pell Grant be applied toward tuition prior to calculating a Yellow Ribbon Program contribution? If not, then won't the Pell Grant funds be duplicative of the housing allowance the student receives?  VA written response:  Our understanding is the Pell Grant is need based and is for cost of attendance not just specifically for the cost of tuition and fees. For example:  If an individual, eligible for the current Montgomery GI Bill (MGIB or ch 30) during the fall of 2009, has a cost of attendance is $7,200, of which $3,000 is for tuition, the veteran’s Pell Grant can be used for any of the expenses related to “cost of attendance”.   Thus, this veteran could receive $3,600 from VA under the MGIB and still utilize the Pell Grant toward his/her cost of education. 

As the Pell Grant is for cost of attendance and both the basic tuition and fee and Yellow Ribbon provisions of the Post-9/11 GI Bill are for tuition and fees, we should not reduce the tuition and fees by the Pell Grant nor should we reduce the charges not covered by the Post-9/11 GI Bill by the Pell Grant. 

Q.  A number of participants in the webinar raised questions regarding the relationship between the new Post-9/11 GI Bill benefit and other federal and state student assistance programs.  Rather than responding individually to each question, the VA provided the following over all response.  (This overall response also addresses several questions that were raised about the institutional match.)   

A.  VA Overall Response  Under law, VA must pay the housing allowance, tuition and fee benefit, and books and supplies benefit without consideration of Title IV aid amounts.  We can only look at the eligibility criteria for the Post-9/11 GI Bill benefit.  The Yellow Ribbon program is part of the overall Post-9/11 GI Bill benefit, so Title IV aid cannot be used to determine what we pay, to include Yellow Ribbon (and, as mentioned during the call, Title IV funds cannot be used as the Institution’s contribution.) Under statute, we must look at the “established charges” or actual charges of tuition and fees, charged the veteran for the quarter, term, or semester.  These charges must be the same as similarly circumstanced non-veterans, i.e.:  veterans cannot be charged more than non-veterans for the same program.  The best thing for everyone to remember is that VA is paying the veteran’s earned benefit to the school on the veteran’s behalf.   Qualifications for financial aid do not enter into, and cannot enter into, our decision to pay, or the amount we pay.  We most go by the amount charged for the program for the quarter, term, or semester. We understand the schools administer many aid programs, but unfortunately we cannot address how you will handle the continued entitlement to any of those programs in connection with this veteran’s benefit. We can state the following: Consider the veteran’s Post-9/11 GI Bill benefit first payer regardless of when VA funds are received.  Any payments under the Post-9/11 GI Bill are entitlement and not needs based or aid.  The Yellow Ribbon provision is part of the GI Bill, so if the school partners with us, the amount we pay is also an entitlement.  After VA payments, school’s contribution, any additional costs not covered may be covered by another aid program the veteran qualifies for.   

State Veteran Aid – 

 

  • If the veteran is not charged/billed for the portion the state is picking up, the portion the state is paying should not be included in the tuition and fee certification to VA.
    • Example:  All students pay $1000 tuition and $100 fees per semester, except veterans.  Veterans are charged $500 tuition and $100 fees.  Your certifying official should report $500 for tuition and $100 in fees.


  • If the veteran is charged $1000 tuition and $100 fees and the VA payment totally covers the $1100, any money the veteran would subsequently be entitled to from the state, should be awarded or withheld in accordance with the rules for the state program.
    • Example:  VA pays $1100.  The cost of tuition and fees is fully covered by the VA payment.  The veteran brings in papers showing he is a National Guard member and is in good standing.  The state offers $1000 for such student.  You will need to review the eligibility rules for the state program to determine if the veteran should receive the $1000 for cost of attendance or if he/she is no longer entitled because the Post-9/11 GI Bill covered the full tuition and fees.


  • Merit scholarships and other scholarships as funding sources for school’s contribution for Yellow Ribbon program. 
    • Most importantly, Title IV funds, loans, work-study, or Pell grant cannot be used for school’s Yellow Ribbon contribution.
    • If a veteran otherwise qualifies for your merit programs, that money can be used as your contribution.
    • Example:  “If we used our existing institutional academic scholarship program and institutional grant money to provide the match such that Vets eligible for our scholarships would receive the scholarships and those not eligible for our academic scholarships would receive institutional grant money as match, would that be acceptable?”  Yes, this is acceptable.  As long as the veterans covered in the Yellow Ribbon Program are each eligible for a maximum of $ X (you set this amount).  If one maximum comes from an academic scholarship and one comes from an institutional grant, that is fine--as long the veterans are treated equally.  You will also need to specify on the agreement whether you are using a grant, scholarship, or combination and list them. 


  • Restricted funds:  Consider that to mean Title IV aid money and any money that is restricted just to one group of people.  We may need to clarify that after we work through this first year.  What we were trying to say, for example, is that if a donor gave you $1 million for women students, you couldn’t use that $1 million to pay both male and female veterans. 


If you haven’t done so yet, we encourage you to meet with your school’s employee that is the “Veterans Certifying Official” for your institution.  They are knowledge about the VA certification process for submitting enrollment certifications and our programs. 

 

Q: In New York State we have a state tuition grant program. Students are charged full tuition and then the grant is credited against only tuition. Sounds like veterans in New York State will not be eligible to receive the state grant since all of the tuition will be covered by the new GI Bill due to our high per credit hour rate.  At what point in the calculation do we count our state (NYS) grant program which is only to be applied toward tuition?
VA written response:  That will be up to your school/state.  We do not have jurisdiction on this issue.  We can only state that we must pay the benefit the veteran is entitled to based on the tuition and fees you actually charge him or her. 

Q: If state tuition assistance reduces actual charges, then that is what the VA reimburses the school? 
VA written response:  VA does not reimburse schools under this program.  This is not like the vocational rehabilitation program.  VA pays the veterans benefit to the school on the veteran’s behalf.  The amount VA pays is based on the report the school sends to us and is also based on the amount that the school certifies as the charges for tuition and fees.  We then will send the veteran’s benefit to the school.  If you charge all students $10,000, but the state program says charge the veterans only $6,000 and $6,000 is what you actually charge them, we will pay based on the $6,000 amount.  But if you charge them $10,000 and later the state sends you or credits you $4,000, you report the $10,000 and we pay based on the $10,000 figure.
 

Q: The term “unrestricted funds” refers to funding that is available to the IHL without any conditions on its use (i.e, designated for use by a specific individual or a specific group of individuals).  How does this definition apply to the State Grant funds awarded to residents of the state who attend full-time? 
VA written response:  How is resident full-time student charged?  If the student is charged full tuition and fees equal to that of non-resident, then you report the full amount and VA and the school can split the remaining.  If you don’t charge the student, then you report what the student is charged.  If the Post-9/11 GI Bill does not cover the full tuition.  As far as using state resident money for Yellow Ribbon, we are waiting a response from our General Counsel’s office.

On August 13, the Department of Education issued the following guidance on the treatment of Federal veterans’ education benefits for purposes of the Title IV student assistance programs:http://ifap.ed.gov/eannouncements/081309GuidFedVeteransEdBenefits.htmlPosted Date: August 13, 2009                Author: David Bergeron, Acting Deputy Assistant Secretary for Policy, Planning, and Innovation, Office of Postsecondary Education

Subject: Guidance on Federal Veterans' Education Benefits for Purposes of the Title IV Student Assistance Programs

On July 1, 2009, President Obama signed H.R. 1777 into law as Public Law 111-39, making technical corrections to the Higher Education Act (HEA). Among other things, H.R. 1777 updated the list of programs that meet the definition of "veterans' education benefits" in section 480(c) of the HEA by including new programs and revising the statutory citations. Those programs are included in the attachment to this announcement. Note that section 480(c) includes, along with a listing of education benefit programs administered by the Department of Veterans Affairs (VA), certain ROTC programs that are administered by the Department of Defense (DOD).

In an electronic announcement posted on IFAP on July 2, 2009 we informed you that H.R. 1777 changed the effective date for the exclusion of Federal veterans' education benefits, as defined in section 480(c) of the HEA, as estimated financial assistance (EFA) to July 1, 2009 (beginning with the 2009-2010 award year).

The following Questions and Answers (Q&A) provide additional information on the treatment of Federal veterans' education benefits for purposes of the Title IV student assistance programs.

Q1: Is the required institutional matching contribution under the new VA "Yellow Ribbon Program", considered Federal veterans' education benefits, and therefore excluded from EFA? Or is only the amount of the VA Federal funds provided to the student considered to be Federal veterans' education benefits and only that amount excluded from EFA?

A1: The Yellow Ribbon G.I. Education Enhancement Program (Yellow Ribbon Program) is a new program authorized by the Post-9/11 Veterans Educational Assistance Act of 2008 (Post-9/11 GI Bill), which added a new Chapter 33 to title 38 of the United States Code. Chapter 33 authorizes both a basic education benefit and the Yellow Ribbon Program. Under the Yellow Ribbon Program, an eligible institution may voluntarily enter into an agreement with the VA to jointly pay all or a part of the portion of the eligible veteran's tuition and fees that exceeds the maximum amount otherwise provided under the basic Post-9/11 GI Bill benefit program. The VA matches, on a dollar-for-dollar basis, the amount contributed by the institution under the Yellow Ribbon Program.

Because the Yellow Ribbon Program provides veterans' education benefits under chapter 33 of title 38 of the United States Code, all funds provided under this program, including funds provided by the institution as its contribution, are considered Federal veterans' education benefits under section 480(c) of the HEA, and therefore both portions are excluded from EFA. However, only the Yellow Ribbon portion of the institutional award is excluded. For example, assume an institution's tuition and fees for a veteran are $10,000 but the veteran will only be receiving $4,000 toward tuition and fees under the basic Post-9/11 GI Bill benefit program. Also assume that the VA and the institution entered into an agreement where the tuition and fee gap of $6,000 will be covered under the Yellow Ribbon Program. Thus, both the VA and the institution would each provide an additional $3,000 toward the veteran's tuition and fees. Assume that the institution was using a $5,000 institutional scholarship to meet its Yellow Ribbon contribution for this student. Under this scenario, the full amount of the basic Post-9/11 GI Bill benefit program of $4,000 and the $3,000 contribution from the VA under the Yellow Ribbon Program would be excluded from EFA, as would the required $3,000 institutional contribution from the $5,000 scholarship. The remaining $2,000 of the $5,000 institutional scholarship must be considered EFA.

Q2: Does the exclusion from EFA of Federal veterans' education benefits apply to all of the components of the assistance or to only to certain components? For example, does it apply only to amounts provided for subsistence or to only amounts provided for tuition and fees?

A2: Amended section 480(c) of the HEA includes the words ". . . benefits under the following provisions of law . . .". Therefore, the exclusion from EFA applies to all of the benefits provided under the designated program. For example, all benefits provided under the Post-9/11 GI Bill are excluded regardless of whether the assistance was for tuition and fees, books and supplies, or as a monthly housing allowance.

Q3: Does the exclusion of Federal veterans' education benefits from EFA apply where a veteran's spouse or dependent is applying for Federal student aid and the spouse or dependent is receiving Federal veterans' education benefits because of the status of the veteran?

A3: Any Federal veterans' education benefits listed in section 480(c) of the HEA that are received by an aid applicant must be excluded from EFA even if the aid applicant is receiving those benefits as a spouse or dependent of a veteran.

Q4: Are the education benefits provided under the DOD's Reserve Officers Training Corps (ROTC) considered Federal veterans' education benefits and therefore not considered EFA even though they are not administered by the VA and are not provided to veterans?

A4: As noted earlier, the amended section 480(c) of the HEA includes, in addition to education benefit programs administered by the VA, two ROTC programs that are administered by the DOD. These are the scholarship benefits provided under the Senior Reserve Officers Training Corps (ROTC) in chapter 103 of title 10 of the United States Code and the subsistence allowance benefits provided under the ROTC in chapter 3 of title 37 of the United States Code. Therefore, education benefits from these two ROTC programs must be excluded as EFA even though they are not VA programs and the recipients are not veterans.

Q5: Are "tuition assistance" programs provided by the DOD (or the individual military services) Federal veterans' education benefits and therefore not considered EFA?

A5: The only VA or DOD benefits that are to be excluded from EFA are those listed in section 480(c) of the HEA. Any benefits provided under any other program must be included as EFA in the calculation of the student's eligibility for Title IV student assistance. For example, the Tuition Assistance Program of the Army Continuing Assistance System and the Army National Guard Federal Tuition Assistance Program are not programs included in section 480(c) of the HEA. Therefore benefits received under those programs must be included as EFA.

Q6: Since the law now removes as EFA all Federal veterans' education benefits, may the institution exclude from the student's cost of attendance (COA) the amount of those benefits that cover all or a portion of a specific component of the student's COA? For example, may an institution exclude from the tuition and fees component of a student's COA the amount paid by the VA for the veteran's tuition and fees since it is not included as EFA?

A6: No. The institution may not exclude from the student's COA, either generally or under the professional judgment provisions of the HEA, the amount of Federal veterans' education benefits that cover all or a portion of a specific component of the veteran's COA. The statutory exclusion from the definition of EFA of Federal veterans' education benefits was done to remove consideration of those benefits in determining the student's financial need. If the institution also excluded from the student's COA the amount of Federal veterans' education benefits that cover all or a portion of a specific component of his or her COA, the institution would be negating the purpose of the change made in the law.

Please note that this requirement for the treatment of Federal veterans' education benefits with regard to COA is not to be confused with the recent statutory change to section 472(3)(C) of the HEA. Effective July 1, 2010, that provision requires that COA not include a housing allowance for aid applicants who live in housing located on a military base or for which a military housing allowance as provided under section 403(b) of title 37 of the United States Code - Pay and Allowances of the Uniformed Services.

Q7: Since these Federal veterans' education benefits are no longer considered EFA, may they be included as income in the calculation of a student's expected family contribution (EFC)?

A7: No. Federal veterans' education benefits, as defined in section 480(c) of the HEA, have been and continue to be excluded from the calculation of a student's EFC.

Q8: Do the words "including but not limited to" in section 480(c) of the HEA allow a school to exclude from EFA educational benefits received by a student from other programs not listed in section 480(c)?

A8: No. The statutory use of the words "including but not limited to" are intended to provide the Secretary with the flexibility needed in the event that (1) a new qualifying Federal veterans' education benefit program is created or (2) the name or statutory citation of one of the currently listed programs is changed. As stated earlier, only benefits received under one of the programs specifically listed in section 480(c) of the HEA are to be excluded from EFA.

If you have any questions regarding this topic, please contact our Research and Customer Care Center staff. Staff is available Monday through Friday between the hours of 9:00 AM and 5:00 PM (Eastern Time) at 1-800-433-7327. After hours calls will be accepted by an automated voice response system. Callers leaving their names and phone numbers will receive a return call the next business day. Alternatively, you may FAX an inquiry to the Research and Customer Care Center at (202) 275-5532, or e-mail the Care Center at fsa.customer.support@ed.gov.

 

Outreach

Q: How are you advertising this to veterans and their families? Is there any way for a college to reach out to veterans?
A: NAICU is conducting media outreach to the national, education trade, and military trade – both traditional and new media – publicizing our unofficial list of participating institutions. Colleges that plan to participate but are not listed can contact us to be added (e-mail tony@naicu.edu).

In addition, NAICU has developed a tip sheet for institutions on ways they can publicize their program to veterans. If an institution has information on its Web site about its Yellow Ribbon involvement (e.g., a news release or a page targeted to veterans) let us know, and we will link to it.