VASCO FAQ: The Compliance Knowledge Base

Certify enrollment after the institution's drop/add period ends and the student is attending classes. For terms, certify within 30 days of the term start date. Never certify before the term begins or if the student hasn't started attending.

Reviewed, April 2026

Late certifications can result in delayed payments to students. The VA processes certifications in the order received. If significantly late (60+ days), the student may experience substantial payment delays. Always prioritize timely certification submissions.

Reviewed, April 2026

Each institution must certify separately for their courses. The home school (where the student is degree-seeking) certifies their courses, and the host school certifies theirs. Ensure the student has a Letter of Concurrent Enrollment from the home school before certifying.

Reviewed, April 2026

No. Only courses required for the student's declared program can be certified. Elective courses must be approved by the degree plan. Courses taken "for interest" or not applying to the degree are not certifiable.

Reviewed, April 2026

Submit an amendment in Enrollment Manager immediately. The student's benefits will be adjusted or terminated based on the new enrollment status. Notify the student of the change and potential debt if they received full benefits.

Reviewed, April 2026

Common reasons: (1) Certification not yet processed by VA (takes 2-4 weeks), (2) Student didn't verify enrollment in their VA portal, (3) Direct deposit not set up, (4) Debt offset from previous overpayment, (5) SAP (Satisfactory Academic Progress) issue. Check Enrollment Manager for certification status.

Reviewed, April 2026

Students whose program is pursued entirely through distance learning receive 50% of the national average BAH rate for full-time enrollment (check the current VA rate at va.gov/education/benefit-rates, which VA updates each academic year). If the student takes at least one in-person (resident) course that counts toward the program, MHA uses the ZIP code rate for the campus where they attend. Either way, rate of pursuit must be more than 50% for any MHA (38 CFR 21.9640(b)).

Reviewed, April 2026

First payment typically arrives 4-6 weeks after certification is processed by the VA. It covers the first month of enrollment. Subsequent payments arrive around the 1st of each month during active enrollment.

Reviewed, April 2026

No. MHA is only paid during active enrollment periods. Students do not receive MHA during winter break, spring break, or summer break unless they are enrolled and certified for summer courses.

Reviewed, April 2026

Maintain: (1) Certification documentation, (2) Enrollment verifications, (3) Grade reports and transcripts, (4) Degree plan documentation, (5) Drop/withdrawal notifications, (6) SAP policy and appeals, (7) Correspondence with students and VA. Keep records for 3 years minimum.

Reviewed, April 2026

Typically every 3-5 years, but can vary. You'll receive 30 days advance notice. The survey reviews your certification practices, record-keeping, policies, and adherence to VA regulations. Prepare by organizing your records and reviewing your procedures.

Reviewed, April 2026

Common issues: (1) Late certifications, (2) Certifying courses not on degree plan, (3) Inadequate record-keeping, (4) Not reporting drops/withdrawals promptly, (5) Unclear SAP policies, (6) Lack of proper VASCO training/backup. Address these proactively.

Reviewed, April 2026

This means the student hasn't applied for VA benefits or their application isn't processed yet. Direct the student to apply at va.gov/education or call 1-888-GI-BILL-1. Once approved, they'll receive a Certificate of Eligibility (COE) with their VA file number.

Reviewed, April 2026

Check your term dates in Enrollment Manager. This error typically occurs when: (1) Dates are entered incorrectly, (2) Term end date is from a previous term, (3) Amendment has incorrect dates. Verify all dates match your academic calendar exactly.

Reviewed, April 2026

No, certifications cannot be deleted. If certified incorrectly, submit an amendment to adjust enrollment or training time to zero. For certifications not yet processed, contact the VA Regional Office to request cancellation before processing.

Reviewed, April 2026

In Enrollment Manager: (1) Find the original certification, (2) Click "Amend", (3) Update the changed information (dates, credits, training time), (4) Add a remark explaining the change, (5) Submit. Always amend immediately when changes occur.

Reviewed, April 2026

Explain: (1) They must maintain SAP to continue receiving benefits, (2) Failing courses may result in debt if they withdrew/failed after receiving payment, (3) They should contact you immediately if considering withdrawal, (4) Resources available for academic support. Review your institution's SAP policy with them.

Reviewed, April 2026

Yes, but only once per course. If a student failed or withdrew from a course, they can repeat it one time using VA benefits. After that, repeated courses are not certifiable. Some exceptions exist for courses required to be taken multiple times (e.g., Student Teaching I, II, III).

Reviewed, April 2026

Obtain the new degree plan immediately. Only certify courses required for the new major. If previously certified courses don't count toward the new degree, they may not be covered. This could create a debt situation. Counsel the student carefully.

Reviewed, April 2026

For Enrollment Manager system issues, certification questions, and system access problems, contact your Education Liaison Representative (ELR). VA lists the ELR contact for every state on its Education Liaison Representatives page: https://www.benefits.va.gov/gibill/resources/education_resources/school_certifying_officials/elr.asp.

Reviewed, April 2026

Try: (1) Clear browser cache and cookies, (2) Try a different browser (Chrome or Edge recommended), (3) Reset password through the login page, (4) Ensure your PIV card is up to date if using one. Still not working? Contact your Education Liaison Representative (ELR).

Reviewed, April 2026

Submit an access request through your institution's SAA (School Authorizing Official) or directly to your VA Regional Office. You'll need: (1) Completed background check, (2) Institution approval, (3) VASCO training certificate. Access typically granted within 2-3 weeks.

Reviewed, April 2026

The Rounding Out rule allows you to certify non-required courses for a student in their final academic term so they can reach full-time status and receive their maximum Monthly Housing Allowance (MHA). Per recent VA guidance, those non-required classes must still sit inside the approved program of education. You cannot simply certify any random elective to hit the credit threshold.

Reviewed, April 2026

The VA requires that all prior credit, both from civilian institutions and military experience (JSTs), be evaluated within a specific timeframe, typically within two semesters. You must grant applicable credit, shorten the student's program accordingly, and keep the evaluation on file for compliance audits. You cannot certify courses the student has already successfully completed elsewhere.

Reviewed, April 2026

Yes, but with strict limitations. Study-abroad courses must be required for the student's degree at your institution (the home school). In addition, the host school must either be VA-approved in its own right, or your institution must establish a formal written agreement absorbing the courses as your own. The VA will only pay up to the national maximum or your home school's tuition rate, whichever is applicable.

Reviewed, April 2026

Yellow Ribbon contributions should only be certified when a Chapter 33 student is at the 100% eligibility tier and their tuition and fees exceed the annual national maximum cap (or the public school in-state tuition rate). Ensure the amount entered does not exceed the maximum contribution listed in your institution's official Yellow Ribbon agreement with the VA.

Reviewed, April 2026

Under Section 1019 of the Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020, schools are financially responsible for tuition and fee debts resulting from enrollment reductions or terminations. The student remains individually responsible for any overpayments tied to the Monthly Housing Allowance (MHA) and the book stipend.

Reviewed, April 2026

Programs where supported students (veterans and dependents) make up less than 35% of total enrollment may apply for an exemption from full 85/15 reporting. However, you must still complete and retain the Statement of Assurance of Compliance with 85/15 Rule on file and be prepared to produce it during a compliance survey.

Reviewed, April 2026

Both deliver benefits to dependents of veterans, but they operate differently. Chapter 35 (Survivors' and Dependents' Educational Assistance) sends a monthly stipend directly to the student, who is responsible for paying tuition. The Fry Scholarship operates under the Chapter 33 (Post-9/11 GI Bill) rules: tuition and fees are paid directly to the school, and the student receives MHA and a book stipend. You cannot certify a student for both simultaneously.

Reviewed, April 2026

Submit a separate certification for each mini-mester using that mini-mester's start and end dates. Do not roll two sequential 8-week sessions into one 16-week certification. Training time is calculated per session, so a student who is full-time in Mini I and three-quarter time in Mini II will see their MHA step down between the two. Make sure the end date of the first certification does not overlap the start date of the second, or Enrollment Manager will flag an overlap error.

Reviewed, April 2026

If you have not yet certified: do not certify. Remove the student from the roster when your institution confirms non-attendance. If you already certified: submit an amendment the same day non-attendance is confirmed, setting training time to 0% and the end date to the last documented date of attendance (or the term start date if no attendance occurred). Document the non-attendance confirmation source (instructor, LMS login report, attendance roster) in your remarks.

Reviewed, April 2026

Independent Study and Directed Study courses are certifiable only when they are required for the student's declared degree program and listed on the approved degree plan. Credit hours count toward training time the same way as lecture courses. Keep a copy of the course syllabus, learning contract, and faculty supervisor assignment on file: compliance surveyors routinely ask for proof that the course was degree-applicable and academically supervised.

Reviewed, April 2026

For Chapter 33 at 100% eligibility, the VA pays tuition and fees up to the annual national maximum for private and foreign schools, or the actual in-state rate for public schools. Any remaining balance is the student's responsibility unless the institution participates in the Yellow Ribbon Program and the student qualifies for YRP. In EM, certify the full tuition and fees charged: the VA will apply the cap automatically and notify the school of the balance.

Reviewed, April 2026

The College Fund or "Kicker" is an additional incentive written into a service member's enlistment or re-enlistment contract. It is paid by the Department of Defense (not the VA) as an add-on to the regular Chapter 30 or Chapter 1606 monthly rate. Kicker amounts and durations vary by contract. Students can check Kicker eligibility in their VA.gov education portal. You do not need to certify the Kicker separately: certify the base chapter, and the VA applies the Kicker automatically.

Reviewed, April 2026

An SAP appeal package should contain: (1) the student's written appeal stating the mitigating circumstance, (2) supporting documentation (medical records, death certificate, deployment orders, etc.), (3) the institution's SAP committee decision in writing, (4) the academic plan the student must follow to regain good standing, and (5) the date benefits were restored or denied. Retain the appeal package alongside the student's file for a minimum of 3 years after last enrollment. Do not recertify until the institution has formally restored good standing.

Reviewed, April 2026

TRRs are narrower than full compliance surveys and are triggered when the VA's risk-scoring flags anomalies in your institution's certification patterns. Common triggers include: a spike in late certifications, a high rate of amendments, unusual MHA distribution relative to peer schools, GI Bill Feedback System complaints, or a data mismatch against the State Approving Agency's program approval list. A TRR can be remote or onsite and typically focuses on a specific risk area rather than reviewing the whole program.

Reviewed, April 2026

Retain all records related to school-side tuition and fee debts under Section 1018 (bad-faith overpayments) and Section 1019 (post-2020 debt reassignment) for a minimum of 3 years after the debt is resolved or written off, per 38 CFR 21.4209. This includes the amendment that triggered the debt, the VA debt letter, any school-side invoice, and correspondence with the Debt Management Center. If litigation or audit is pending, retain until resolution plus 3 years.

Reviewed, April 2026

Pending Processing means the certification is in the VA's queue but has not been reviewed by a Regional Processing Office (RPO) examiner. Typical processing time is 2 to 4 weeks, but peaks (fall term, end-of-year) can stretch to 6+ weeks. If a certification has been pending for more than 4 weeks during a peak or 3 weeks off-peak, contact your assigned ELR with the student's VA file number and the certification submit date. Do not resubmit: duplicate submissions push the student further back in the queue.

Reviewed, April 2026

Role assignment flows through your institution's SAA (School Authorizing Official). The SAA submits a role request via the EM administrative portal or by contacting the VA Regional Office directly. Required documents: (1) a completed VA Form 22-8794 Designation of Certifying Officials, (2) evidence the new VASCO has completed required training, (3) institution letterhead confirming the appointment. Reassignments typically take 1 to 2 weeks. Until the new role is active, the outgoing VASCO remains responsible for all certifications.

Reviewed, April 2026

Certify as Chapter 33. The Fry Scholarship operates under Chapter 33 rules: tuition and fees are paid directly to the school, and the student receives MHA and a book stipend. In Enrollment Manager, select Chapter 33 as the benefit and enter the full tuition, fees, and credit hours as you would for any Chapter 33 certification. The Fry designation on the COE is informational (it identifies the eligibility basis) and does not change how you certify.

Reviewed, April 2026

No. A student can only receive benefits under one chapter at a time. However, students often have eligibility under multiple chapters (for example, a veteran with both Chapter 30 and Chapter 33, or a dependent eligible for Chapter 35 and transferred Chapter 33). They must formally elect which chapter to use via VA Form 22-1995 or 22-5490, and elections can typically only be changed once. Counsel the student carefully before they elect: Chapter 33 generally provides the largest benefit for degree programs, but non-degree or flight programs may pay more under other chapters.

Reviewed, April 2026

As of April 2026, EM officially supports the current and previous major versions of Microsoft Edge and Google Chrome on Windows 10 and Windows 11. Firefox and Safari are unsupported and routinely hit authentication errors. PIV card login requires ActivClient (government-issued workstations) or the DoD-approved smartcard reader + middleware on institutional machines. TLS 1.2 or higher must be enabled. JavaScript and third-party cookies must be allowed for va.gov subdomains. Mobile browsers are not supported for certifications.

Reviewed, April 2026

Not always. If each campus has a distinct Facility Code (separate VA approval), each needs at least one designated VASCO with EM access to that Facility Code. A single individual can hold VASCO roles across multiple Facility Codes, but each role must be individually designated on VA Form 22-8794. If multiple campuses share one Facility Code (a true multi-site single approval), one VASCO account can certify for all. Verify your institution's facility structure with your ELR if you are unsure.

Reviewed, April 2026

Step 1: The SAA submits a new VA Form 22-8794 designating the replacement VASCO and terminating the outgoing VASCO's access. Step 2: While the paperwork is processing, the outgoing VASCO completes all open amendments and in-progress certifications (or the SAA formally delegates temporary authority to another certified VASCO at the institution). Step 3: The replacement VASCO reviews the student roster, the open-amendment queue, and any pending SAP appeals before assuming full responsibility. Step 4: Update internal SOPs, VA contact lists, and the GI Bill Feedback System contact information with the new VASCO's details. Plan the transition to avoid peak certification windows whenever possible.

Reviewed, April 2026