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Veterans Affairs - Frequently Asked Questions

Are State Approving Agencies (SAAs) now the point of contact for all new and modified programs and policies at institutions and facilities that have deemed approved programs; accredited standard college degree programs at public and not-for-profit IHLs, diploma programs at High Schools, Registered Apprenticeships and FAA Flight schools?


  • Yes. SAAs are now the point of contact for all such programs. This includes address changes, etc.


Should SAAs or Education Liason Representatives (ELRs) begin notifying the appropriate institutions of this change?

  • Yes. SAAs should notify the appropriate institutions of this change. Many institutions were not sending program information to SAAs or ELRs. Therefore, all impacted institutions should be informed by SAAs to submit program information to SAAs. SAAs should develop a streamlined application that specifically addresses the limited criteria such programs must meet. Institutions should be advised to no longer use the VA modification form, which is now rescinded. SAAs may wish to modify this form to their preference.

    ELRs should work closely with SAAs to provide updated contact information for registered apprenticeships and FAA flight schools to ensure that these schools and institutions are appropriately notified.


Are programs that are of the type described in 38 USC 3672(b)(2)(A)(i)­
(iv) automatically "approved" or does the SAA have to first review the program to ensure that the program satisfies all of the criteria listed in 38 USC 3672(b)(2)(A) before the program is considered "deemed approved"?

  • Programs are not considered deemed approved until the SAA has reviewed the program to ensure that the requirements of 38 USC 3672, as well as other statutory criteria, are met. The statutory requirements that must be met to meet deemed approved criteria include the following:

    38 USC 3675 (b)(1) and (2)
    38 USC 3680A
    38 USC 3684
    38 USC 3696


Are contracted courses that make up part of an accredited standard college degree program at a public or not-for-profit Institute of Higher Learning (IHL) automatically deemed approved?

  • No. Such courses that are provided by a separate institution do not get to "borrow" the deemed approved status afforded to applicable programs at the degree­ granting institution. The contracted courses must be separately approved in their own right by using the applicable approval criteria.

    For example, University A is an institutionally accredited public IHL and offers an accredited Bachelor's Degree in International Studies. University A has contracted with University Z for Z to provide 12 required hours of courses in the Degree program.
    However, University Z's program that contains the contracted courses has not been approved by a State Approving Agency or the VA's Foreign ELR (if applicable).
    Therefore, the degree program at University A shall be disapproved until either Z receives approval, A provides those courses itself, or A contracts for their provision from a different institution where the courses are part of an approved program.

    It is important to note that SAAs do not approve partial programs.


Is there a specific form/application for institutions to use when requesting approval of new programs or changes to existing programs that are considered deemed approved?

  • SAAs will determine what form will be used, although VA recommends a standardized form that asks questions solely related to deemed approved criteria with an emphasis on whether or not policies have changed and if the program is contracted.


Does this change the SAAs current workload?

  • VA is requesting SAAs ensure that statutory criteria for deemed approved programs are met.

    Generally, public IHLs with approved programs are meeting the requirements of 3675 (b) (1) and b (2) and 3684 and 3696 as you have determined the programs continue to meet these requirements when re-approving programs and catalogs.

    The deemed approved clarification guidance was issued in part, due to the fact that numerous contracted courses were not being reviewed and approved. Because 3680A
    (f) requires a contracted program to have a formal approval, a standard college degree program may not be considered deemed approved unless the contracted program is approved.


What should SAAs send their schools and ELRs, and what records must be maintained?

  • As discussed and agreed upon by VA and the NASAA IHL/NCD committee, SAAs should notify their institutions to provide all necessary materials needed to determine if programs meet deemed approved criteria and should then notify ELRs that the review of deemed approved programs or modifications was completed.


Will VA be updating the WEAMS inventory of programs to reflect the names of all programs that SAAs confirm meet deemed approved criteria?

  • Yes, ELRs have already begun to enter information regarding these programs into WEAMS in preparation for the new approval system. SAAs should send ELRs all related approval information (including the approved program listing) following their review of these programs. SAAs should review all of their accredited public and not-for­ profit IHL programs before the end of FY17. SAAs should send a report to the ELR by September 30, 2017, to outline the public and not-for-profit IHLs that have been reviewed and verify that the programs meet the statutory criteria.


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