Technical Training

Non-College Degree Programs: Special Considerations for Certification

Master the unique requirements and compliance considerations for certifying NCD programs

12 min readUpdated November 2024

Non-College Degree (NCD) programs represent a growing segment of VA-approved education, offering veterans pathways to careers in skilled trades, technical fields, and specialized industries. However, these programs come with unique certification requirements, compliance considerations, and potential pitfalls that differ significantly from traditional degree programs.

This guide provides comprehensive coverage of NCD program administration, from initial approval through ongoing compliance monitoring, helping you avoid common certification errors specific to this program type.

📚 What is an NCD Program?

Non-College Degree programs are VA-approved courses or programs below the baccalaureate level at institutions other than institutions of higher learning. This includes certificate programs, vocational training, and technical skills courses at proprietary schools and some public institutions.

Understanding NCD Programs

Common Types of NCD Programs

Vocational/Technical

  • • HVAC certification
  • • Welding programs
  • • Automotive technology
  • • Electrical apprenticeships
  • • Plumbing certification

Healthcare

  • • Medical assistant
  • • Phlebotomy technician
  • • Dental hygienist
  • • Pharmacy technician
  • • EMT/Paramedic

Technology

  • • IT certifications (CompTIA, Cisco)
  • • Cybersecurity bootcamps
  • • Network administration
  • • Software development
  • • Database management

Transportation

  • • Commercial Driver's License (CDL)
  • • Aviation maintenance
  • • Flight training
  • • Marine technology
  • • Railroad operations

Key Differences from Degree Programs

⏱️

Measurement System

Often measured in clock hours rather than credit hours, requiring different training time calculations

📊

85/15 Rule Compliance

Subject to the 85/15 rule—no more than 85% of students can be receiving VA funding

Stricter Approval Requirements

Programs require state licensing/accreditation plus VA-specific approval through State Approving Agency

📅

Attendance Tracking

Many NCD programs require detailed attendance records and must report absences promptly

Program Approval Process Navigation

Step-by-Step Approval Process

1

Verify State Licensing/Accreditation

Ensure your institution and program meet state requirements for operation. This is a prerequisite for VA approval.

Required Documentation:

  • • State licensure certificate
  • • Accreditation documentation
  • • Business license
  • • Program approval letters
2

Submit Application to State Approving Agency

Complete VA Form 22-8794 (Application for Approval) with detailed program information.

Key Application Components:

  • • Program curriculum and objectives
  • • Clock hour breakdown
  • • Tuition and fee schedule
  • • Refund policy
  • • SAP policy
  • • Facility description
3

Facility Visit and Review

SAA representative will conduct on-site visit to verify facilities, equipment, and qualifications.

Prepare for Visit:

  • • Tour facilities and equipment
  • • Meet with instructors
  • • Review student records systems
  • • Demonstrate attendance tracking
  • • Show certification processes
4

Receive Approval and Begin Enrollment

Once approved, you'll receive an approval letter with effective dates and any conditions.

Important Notes:

  • • Cannot certify students until approval received
  • • Approval typically valid for 2 years
  • • Must apply for renewal before expiration
  • • Report any program changes immediately

NCD-Specific Certification Requirements

Common Certification Errors to Avoid

❌ Error #1: Incorrect Training Time Calculations

The Problem: Using credit hour formulas for clock hour programs

The Solution: For clock hour programs, training time is based on actual hours of instruction per week. Full-time = 18+ clock hours/week, 3/4 time = 13-17 hours, 1/2 time = 6-12 hours.

Example:

Student attends 20 hours/week in cosmetology program = Full-time status

NOT: Convert to credits first—certify based on actual clock hours

❌ Error #2: Failing to Monitor 85/15 Compliance

The Problem: Not tracking the ratio of VA students to total enrollment

The Solution: Calculate monthly: (VA students ÷ Total students) × 100 must be ≤ 85%

Required Actions:

  • • Track ratio monthly for each program
  • • Pause VA enrollments if approaching 85%
  • • Document compliance in writing
  • • Report violations immediately

❌ Error #3: Inadequate Attendance Tracking

The Problem: Not maintaining detailed attendance records or reporting absences

The Solution: Daily attendance records required; report terminations within 30 days

Attendance Requirements:

  • • Daily sign-in sheets
  • • Make-up hour tracking
  • • Absence documentation
  • • Termination reporting (14+ days absent)

Ongoing Compliance Requirements

Monthly Tasks

  • Calculate 85/15 ratio for each program
  • Review attendance records
  • Process certification changes
  • Submit required reports to SAA

Annual Tasks

  • Submit renewal application (if expiring)
  • Update tuition and fee schedules
  • Review and update policies
  • Conduct self-audit of records

Success Strategies for NCD Programs

10 Best Practices for NCD VASCOs

1.Maintain separate tracking systems for clock hour vs. credit hour programs
2.Build buffer into 85/15 ratio—aim for 80% maximum to allow flexibility
3.Automate attendance tracking with digital sign-in systems where possible
4.Create program-specific certification checklists to avoid errors
5.Develop strong relationships with your SAA representative
6.Document all policy changes and submit to SAA for approval before implementing
7.Train instructors on attendance reporting requirements
8.Keep renewal applications on calendar—start 6 months before expiration
9.Maintain detailed records of all VA correspondence and approvals
10.Join professional associations for NCD program administrators

Key Takeaways

  • 1.NCD programs have unique requirements including 85/15 compliance and clock hour calculations
  • 2.Program approval requires state licensure plus SAA approval—cannot skip either step
  • 3.Daily attendance tracking and prompt termination reporting are mandatory
  • 4.Proactive compliance monitoring prevents program disapproval and protects students