NAICU Washington Update

GI Bill/Yellow Ribbon Final Regulations

April 01, 2009

On March 31, the Department of Veterans Affairs published final regulations for the post-9/11 GI Bill.  The regulations are posted on the GI Bill section of the NAICU Web site, and may also be downloaded from the on-line Federal Register.


  • Institutions will be able to develop multiple Yellow Ribbon agreements, based on type of student (i.e. undergraduate/graduate) or "subelement" of the institution ("subelement" is not defined but is intended to cover such entities as a university's College of Business). 

  • The match could be different for each separate agreement.  (Note:  The regulations also indicate that the match would have to be the same across all programs or disciplines in any particular "subelement," suggesting that an institution cannot have a separate agreement for "programs.")

  • The requirement that the Yellow Ribbon match be provided in the "form of a waiver" was replaced with language stating the match must be provided by "funds under the unrestricted control" of the institution.  (Note:  The regulations specifically state that scholarship funds send directly to an institution on behalf of an individual or specific group of students may not be used to meet the matching requirements.  Likewise, other Federal funds may not be used for the match.)  Further clarification of the "unrestricted control" language is now available on the VA Web site.  

  • An institution's Yellow Ribbon match will now be stated as a dollar figure, rather than a percentage. 

  • Institutions must provide Yellow Ribbon contributions to a participant for all academic years in which the institution participates in the program and the student maintains satisfactory progress, conduct, and attendance.

  • The requirement that Yellow Ribbon benefits be offered to veterans on a "first-come, first-served" basis is maintained.   

  • With respect to tuition and fee calculations, the final regulations maintain the methodology described on the VA Website for making separate calculations for tuition and for fees in determining the maximum benefit level. The maximum tuition and maximum fee numbers, respectively, will be the basis for determining the amounts subject to the Yellow Ribbon match.

  • The final regulations also note that the tuition and fee figures currently listed on the VA Web site are 2008-09 figures, and that they will be changed to reflect 2009-10 information.  Final figures may not be available until July.

Discussion of comments received about the Yellow Ribbon program appears on pp. 14660-1 of the Federal Register.  The Yellow Ribbon regulations appear on page 14692.


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