Tax Tips Logo ImageISSUE:

Section 1018 of  Public Law 116-315,  Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020, adds new requirements for educational institutions participating in the educational assistance programs of the Department of Veterans Affairs (VA). These new provisions became effective June 15, 2021 and will apply to Institutions of Higher Learning and Non-College Degree institutions beginning August 1, 2021. Many of the requirements are consistent with the requirements of the Principles of Excellence, currently in Executive Order 13607; however, there are requirements in addition to those embodied in the Principles of Excellence which schools must also satisfy to maintain approval for GI Bill® participation.

 

SITUATION:

Marathon Bible College (MBC) is a private college exempt under Internal Revenue Code section 501(c)(3) and 170(b)(1)(A)(ii).  They are required to file Form 990 annually.

The Controller at MBC has been concerned about provisions of the Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020 as MBC receives V.A. funding – but does not participate in Title IV.

“We have some questions about the Isakson Roe Veterans Benefits Act of 2020,” she said.  “Thanks for providing the model wording for the waiver request for Section 1015 of that law.  However, we have heard there is more to the law – Section 1018.  What is that all about?”

“We understand.  Ultimately, Section 1018 of the ‘Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020’ requires educational institutions participating in the educational assistance programs of the Department of Veterans Affairs (VA) to adhere to new standards.  There is an opportunity to apply for a waiver from the requirements of Section 1018, but many schools see providing a “shopping sheet” to students receiving VA funding to be an easier route than the waiver process.

“Ultimately, Section 1018, Section 1 requires schools to 1) provide those VA students with a timely provided “personalized shopping sheet” (a listing of items like estimated costs, available student aid, data on the schools performance, etc.); 2) maintain certain policies; 3) provide VA students with graduation requirements; 4) agree to accreditation requirements; and 5) appoint a point of contact for these VA students and their families.”

“Thanks,” she said. “We already have some of these elements in place.”

You can get more information on Isakson Roe Section 1018 at:

Isakson and Roe, Section 1018 Requirements Effective August 1, 2021 (govdelivery.com)

 

RULES:                                                                        .

From U.S. Department of Veterans Affairs Bulletin 07/13/2021:

What is Section 1018?

Section 1018 codifies in statute the following requirements: 

Section 1:

  • Schools must provide a covered individual (a student using benefits under chapter 30, 31, 32, 33, or 35 of title 38, U.S.C., or chapter 1606 of title 10, U.S.C.) with a personalized shopping sheet that contains:
    • Estimated total cost of the course that includes tuition, fees, books, supplies and any other additional costs.
    • Estimated cost of living expenses.
    • Amount of costs above that are covered by VA Education Benefits.
    • Other types of Federal financial aid, not administered by VA that is offered by the institution, that the individual may be qualified to receive.
    • Estimated amount of student loan debt the individual would have upon graduation.
    • Information regarding graduation rates.
    • Information regarding job-placement rates for graduates, if available.
    • Information regarding the acceptance of transfer credits including military credits.
    • Any additional requirements including training, experience, or examinations that are required to obtain a license, certification or approval for which the course of education prepares the individual.
    • Other information to facilitate comparison by the individual about aid packages offered by different educational institutions.
  • Personalized shopping sheets must be provided within 15 days after tuition and fees are determined for the academic year if there is a change.
  • Schools must maintain policies that:
    • Inform an enrolled covered individual of the availability of federal financial aid, not administered by VA that is offered by the institution.
    • Alert the individual of the potential eligibility for other federal financial aid before packaging or arranging student loans or alternative financing.
    • Prohibit automatic renewal of a covered individual in a course and/or programs.
    • Ensure each covered individual approves of the enrollment in a course.
    • Allow enrolled members of the Armed Forces, including reserve components and National Guard to be readmitted if such members are temporarily unavailable or must suspend enrollment by reason of serving in the Armed Forces.
    • Accommodate short absences for such services in the Armed Forces.
  • Schools must provide covered individuals the requirements for graduation and a graduation timeline.
  • Accredited educational institutions agree to obtain approval of the respective accrediting agency for each new course or program.
  • Schools must designate an employee of the educational institution to serve as a point of contact for covered individuals and family members seeking assistance with:
    • Academic Counseling.
    • Financial Counseling.
    • Disability Counseling.
    • Other information regarding completing a course of education at the education institution.

 

BOTTOM LINE:

  • The new rules pertaining to the “Isakson Roe Act of 2020” for schools with students who receive VA funding can be found in Section 1015 and 1018 of that law.
  • The new provisions apply to higher education institutions beginning August 1, 2021.
  • Section 1015 requires schools who receive VA funding for students to be eligible for and participate in the U.S. Department of Education’s Title IV program – unless the school applies for and receives a waiver.
  • Section 1018 requires several new items, including a “personalized shopping sheet” for VA students.

 

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