field of poppy flowers

WCET would like to take this opportunity to acknowledge and show appreciation for our veterans and military affiliated families. Thank you to those who currently serve and have served in the U.S. Armed Services. WCET Frontiers would like to honor our veterans by sharing about the history of Veterans Day and also share some updates on federal policy issues for institutions to watch that affect the process and delivery of Veterans benefits.

Historical View of Veterans Day

The traditions of Veterans Day in the United States originated with Armistice Day marking the end of World War I hostilities with Germany and their allies on the 11th day of the 11th month, November 11, 1918. Events in the United States, England, and France were held for the initial observance of Armistice Day. “Armistice” is generally defined as an agreement to maintain a truce. It was hoped that World War I was “the war to end all wars.” However, after the onset of World War II, England and other Commonwealth nations adopted Remembrance Day and the United States adopted Veterans Day.

In the United States, the first celebration of Veterans Day occurred in 1947 in Birmingham, Alabama. An event was organized by a World War II veteran, Raymond Weeks. A bill was proposed in Congress in 1953, signed by President Dwight D. Eisenhower proclaiming November 11 as Veterans Day. In November 1982, Raymond Weeks was honored by President Ronald Reagan with the Presidential Citizens Medal.

Among the traditions of Veterans Day and Remembrance Day are parades, moments of silence, laying of wreaths, and wearing a remembrance poppy, often sold by Veterans groups. The tradition of the poppy comes from the red flower that grew over the graves of fallen soldiers in Belgium during World War I. A Canadian soldier, Lieutenant Colonel John McCrae, was inspired to write a poem in 1915 after presiding over the funeral of a friend and fellow soldier. The poem, “In Flanders Fields,” refers to a location called Flanders Fields which is a common English reference to battlefields in Belgium and France. The poem gained popularity after World War I in the United States, Canada, and England. The poem was even set to music by several composers including an American, John Philip Sousa. A traditional reading of “In Flanders Fields” occurs at many Veterans Day and Remembrance Day ceremonies including at assemblies and observances for school children.

Poem with poppy flowers hand drawn around words.

 In Flanders Fields
In Flanders Fields, the poppies blow
Between the crosses, row on row,
That mark our place; and in the sky
The larks, still bravely singing, fly
Scarce heard amid the guns below.

We are the dead. Short days ago
We lived, felt dawn, saw sunset glow,
Loved and were loved, and now we lie,
In Flanders fields.

Take up our quarrel with the foe:
To you from failing hands we throw
The torch; be yours to hold it high.
If ye break faith with us who die
We shall not sleep, though poppies grow
In Flanders fields.

Veterans, we are grateful for your service and sacrifice!

Federal Policy Issues to Watch Affecting the Process and Delivery of Veterans Benefits

Seeking Parity for Monthly Housing Allowance for Students Participating in Programs Fully Online

Since 2017, WCET has sought to bring attention to the need to revise federal law for the monthly housing allowance for students eligible for Veterans Benefits who participate in programs fully online. Veterans using their G.I Bill education benefits receive a Monthly Housing Allowance (MHA) for the terms that they are enrolled. Veterans who take all of their courses online receive a reduced MHA that might be as low as 50% of what they would receive if they attended any or all classes on-campus.

In December 2010, Congress passed The Post-9/11 Veterans Education Assistance Improvements Act of 2010.  The Federal law addressed MHA by allowing a new but reduced MHA for online learners. Chapter 33 of the new Post 9/11 GI Bill indicates that if a student is enrolled full-time for the full length of the semester, and at least one on campus course (any course that does not have the Online section identifier) is to receive the full monthly housing allowance. A student who is full time, but taking classes fully online, is entitled to only half the national average MHA payment.

Congress responded quickly in Spring of 2020 to address emergency legislation when students were shifted to remote education due to the pandemic. This allowed students to receive full housing benefits despite participating in courses solely through distance education. This emergency flexibility was extended in via federal legislation to continue the benefit through June 1, 2022.

Today, MHA has returned to the previous structure – which means if the student is taking courses fully online then they are only entitled to half the national average MHA payment. The GI Bill Comparison Tool guides the veteran as to how much they are eligible for their location.

While we had hoped that Congress would take up this issue after the emergency flexibilities expired, that has not occurred. We have learned there are several barriers that must be addressed, including:

  • budget concerns,
  • quality of distance education, and,
  • determination of the appropriate address for the student for purposes of MHA calculation.

We are pleased to learn that this fall U.S. Representative Juan Ciscomani (AZ) introduced a bipartisan bill in the House: Expanded Access for Online Veteran Students Act. This bill would increase MHA for veterans taking online courses during the summer term to receive full MHA. Ciscomani Leads Bipartisan Push to Increase Benefits for Online Student Veterans. Representatives from the Student Veterans of America recently testified in support of this bill at the House Committee on Veterans Affairs. While this bill does not provide full parity for MHA regardless of the modality of instruction for all terms in an academic year, it does start the discussion and is an encouraging development.

Determining Similarities and Contrasting Requirements Between VA Regulations and New ED Regulations When Serving Students in Programs Leading to License or Certification.

The U.S. Department of Education (ED) recently released new and amended federal regulations that will be effective July 1, 2024 and that address institution responsibilities when serving students in programs leading to a license, tied to Title IV eligibility. Similarly, the U.S. Department of Veterans Affairs (VA) released new federal regulations in January 2023 that became effective just one month later in February 2023. The VA regulations address institution responsibilities when serving students in programs leading to a license but the responsibilities are tied to eligibility for Veterans Benefits.

New ED regulations require that the institution satisfy educational requirements where the institution is located and where the students enrolled by the institution in distance education or correspondence courses are located as determined at the initial time of enrollment. (34 CFR 668.14(b)(32)(ii)). Additionally, institutions must provide public and direct notifications regarding the curriculum meeting state educational requirements including where the student is located. (34 CFR 668.43(a)(5)(v) and (c)) More information on the new ED rules is available here: New Federal Regulations, Part 1: Addressing Programs Leading to a License or Certification.

Relatively new VA regulations that became effective in February 2023, require that state approving agencies (SAA) may approve a course designed to prepare an individual for licensure or certification in a state, if the course meets all instructional curriculum license or certification requirements of such state (38 CFR 21.4253(d)(9)(i)). Additionally, the VA regulations require public disclosures in a prominent manner of any conditions or additional requirements to obtain the license (38 CFR 21.4259(e)).

The VA and ED regulations appear to have the same goals of student consumer protection. However, the language used by the VA and ED is slightly different. Additionally, we are aware that the SAA has the authority to approve the programs in the state where the institution is domiciled. Therefore, we have asked questions about the VA regulations as to whether the VA regulations address institutions that serve students located in a different state than where the institution is domiciled. It would seem that for purposes of student consumer protection, there should be a process that an SAA would need to review the institution’s ability to meet all instructional curriculum requirements and provide public disclosures regarding the state where the student is located. The out-of-state student may be confused by the institutions only addressing the state where the institution is domiciled, and the public disclosures of additional conditions and requirements may not be applicable to that out-of-state student. The state in question is not clear if the student is located in a different state than the institution.

Upon release of the regulations in January 2023, the State Authorization Network (SAN) raised the question to Joeseph Garcia, Executive Director, Education Service, for the Veteran Benefits Administration, and to Dr. Joseph Wescott, National Legislative Liaison, National Association State Approving Agency (NASAA). SAN has recently sought guidance from NASAA President, Frank Myers. We understand from these communications that guidance is under consideration.

If you are tasked at your institution with managing compliance for programs leading to a license or certification, we urge you to communicate with your state’s SAA (NASAA State Contacts). You may wish to seek direction to implement the VA regulations to develop an efficient route to address both VA and ED regulations to serve students in programs leading to a license to receive Federal aid through Title IV programs and Veterans Benefits.

In Conclusion….

Again, a sincere thank you to our Veterans and their families. Additionally, please look for WCET and the State Authorization Network to continue following these issues and share information as it becomes available.

Cheryl Dowd

Senior Director, State Authorization Network & WCET Policy Innovations

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