VETERANS BENEFITS ADMINISTRATION Flight Training AVECO July 2015

VETERANS BENEFITS ADMINISTRATION

Flight Training

AVECO July 2015


Flight Training

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Overview• Aviation programs at Institutions of Higher Learning (IHL)

• Deemed Approved versus Non-Deemed Approved degrees

• Contracted versus “In-House” flight training

• FAA Approval (Part 141 and Part 61)

• Training Course Outline

• Certifications, billing, and documentation

• 85/15 Regulations (CFR 21.4201)


Aviation Programs at IHL’s

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• Changes effective August 1, 2011 (PL111-37)

• VA Central Office Education Service directive to conduct Compliance Surveys

at Public IHL’s with aviation programs in April and May 2015

• Flight training is not approved for non-college degree programs (certificates

and diplomas)


Deemed Approved versus Non-Deemed Approved

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“Deemed Approved”: Public and private non-profit accredited institutions

Non “Deemed Approved”: Proprietary Profit institutions

• SAA approval is required for degree programs with a component of flight/aviation:If a school does not have “deemed approved” programsIf a school with “deemed approved” programs utilizes services from a vocational flight school, i.e., “under contract”

• SAA Approval is not required: If a school with “deemed approved” programs is approved by the FAA

under Part 141 or Part 61 and utilizes its own flight line, instructors, Training Course Outline (TCO)


Contracted versus “In-House” flight training

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IHL’s with Degree Programs Under Contract

• If a school does not have its own flight line and must contract with a Part 141 flight school to provide flight training, then the flight school must be approved as a separate facility by the SAA with jurisdiction over flight schools

• Documents needed for approval: - Copy of contract- Copy of flight school’s Air Agency Certificate- Copy TCO for each course offered as part of the degree- Other documents as required by SAA

• If at any time an IHL changes its contract from one contractor to another, the IHL must notify the SAA immediately for the updated approval of its flight degree program

• Part 61 training cannot be contracted


FAA Approval

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Air Agency Certificate• Issued by the Flight Standards District Office (FSDO)• Includes a Letter of Authorization• Is valid for two (2) years• Specifies all the courses that the school is authorized to offer under FAR Part

141 (TCO)• Only courses listed on the Air Agency Certificate and Letter of Authorization

may be considered for approval• If the flight school wishes to obtain approval of a course not currently listed in

these documents, the FSDO must approve and revise the Air Agency Certificate


Training Course Outline

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Training Course Outline (TCO)

• Description of rating

• Specific aircraft and Flight Training Devices (FTDs – mockups of airplane

cockpits with varying degrees of complexity) that may be used for the course

by make and model

• Restrictions on use of FTD (limited hours and for which specific flight lessons

may be used)

• Airports that may be used in training

• Name of Chief and Assistant Chief Flight Instructor


Training Course Outline Continued

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• Each Part 141 course approved by the FSDO

• It is approved with and accompanies the TCO

• It is a lesson-by-lesson outline of how the course is to be pursued

• The Ground School section specifies, lesson-by-lesson, the knowledge to be

learned and how long (in hours) each lesson should take

• Ground School is not to be confused with preflight briefings and post-flight

critiques (pre/post) which are always associated with actual flight lessons

* Pre/post is rarely ever enumerated in Part 141 syllabi and minimum hours are

usually listed “as needed”


Certifications, billing, and documentation

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• SCO certifies course credits, tuition, and fees• IHLS can only certify tuition and fees that are charged to the student by the

institution (flight fees cannot be paid to contracted school by the students)• Flight fee limitations:

Least expensive aircraft must be utilized except where required by thecourse syllabus or the FAA

Minimum hours required in course syllabus are the maximum allowed for VA students

All training must be completed by end of term, with exceptions defined and listed (If Incompletes “I”s are assigned, school Incomplete policy must be followed)

FAA check ride costs cannot be included in the certification of fees



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Certification of aviation courses

• Enter term dates (these should be in most cases the same as for all other

students)

• Enter credit hours just the same as non-flight degree students

• Enter total charges up to TCO requirements

• Public schools enter only the in-state rate

• Private schools enter the actual total charges (there should be no state

differential)



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Documentation- what the SCO should have on file

1. Training Course Outline (TCO)• For every flight lab, are there pre-requisites?• What courses are required for the degree?

2. Valid FAA Air Agency Certificate

3. Account statement• Actual flight charges for minimum requirements (based on TCO)• Are there discounts?

4. Flight Log• Showing actual charges and flight time/instruction for each student


85/15

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• Determine if the degree program has more than one “track”

• Tracks, as referenced here, should not be confused with majors, minors, and

concentrations, although the ratio is calculated separately for those as well

• Calculate ratio separately for each “track”, major, or concentration

• VA (85%) portion of ratio includes VA students and any students receiving a grant,

waiver, discount, scholarship, etc., directly from the school and which has rules that

have the effect of excluding VA students (regardless of whether or not they are

receiving GI Bill® benefits) from receiving that school assistance

• Non-VA (15%) portion of ratio includes all other students registered for that term

• You must calculate the ratio before certifying a VA student in the program


Findings of Compliance Surveys 2015

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• Violations of 85/15

• IHL’s not calculating and tracking 85/15 by term and major/track

• Charging over TCO minimum requirements

• Lack of communication between SCO and Aviation Department or Contracted

Flight School

• No supporting documentation maintained by SCO when certifying charges

• Contracted Flight training not approved


Summary

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• SCOs should be in contact with ELR & SAA for technical assistance on

certifying flight training

• SCOs must have access to flight records

• Schools should review the communication and work flow process between

SCOs and Aviation program

• Minimum requirements must be published by schools

VETERANS BENEFITS ADMINISTRATION 15

Questions?