CCA Files Comments to VA NPRM

Tammy L. Zimmer
Regulatory Analyst

August 20, 2003

Director
Office of Regulations Management (02D)
Department of Veterans Affairs
810 Vermont Avenue, NW
Room 1154
Washington, DC 20420

Dear Director:

The Career College Association (CCA), on behalf of its 1,100 members, appreciates the opportunity to comment on the proposed rule published in the June 30, 2003, Federal Register. CCA is a voluntary association of schools, institutes, colleges, and universities which cover the full gamut of postsecondary education, from short-term certificate and diploma programs, to two- and four-year associate and baccalaureate degrees, to master's and doctoral programs. Some of the occupational fields for which CCA institutions provide programs include accounting; allied medical; automotive technology; business administration; commercial art; culinary and hospitality management; information technology; mechanical engineering; and radio and television broadcasting. Many of CCA's members participate in Veterans Administration (VA) education and training programs, including the Montgomery GI Bill education benefits program.

CCA supports the VA's proposed rule to allow branch or extension campuses of an educational institution to combine certification functions at one central location. In some cases, extension centers are small facilities enrolling a limited number of students, only one or two of whom may be VA benefit students. In other circumstances, administrative functions of an institution may always be held at a central location rather than at satellite centers. In each of these scenarios, it creates an administrative and financial burden on institutions to have staff and offices solely for the purpose of certifying and maintaining the required VA records. Allowing institutions to house this function in one central location will ease this burden on institutions of all sizes while maintaining the integrity of the program. Additionally, it will make it easier for VA officials to review and audit VA benefit information for an institution as a whole by centrally locating these records and having one person (the VA certifying official) at an institution responsible for maintaining them. Finally, many institutions, especially in the for-profit sector, have campuses located in more than one state. By allowing educational institutions to combine the certification and record-keeping functions in one central location, even when branch campuses cross state lines, the VA is again taking steps to reduce the administrative burden institutions may face when participating in VA programs.

CCA also supports the proposal to allow the location with administrative capability to maintain records as originals, certified copies, or in an electronically formatted record-keeping system. More and more institutions are moving to "paperless" record systems. This allows records to be maintained in a secure yet easy-to-access format that again reduces burden on the institution and allows for quick retrieval of documents in response to VA or State requests.

We applaud the proposal to allow the administratively capable location to be a non-teaching location. In the for-profit sector of higher education, it is not unusual to have the primary administrative functions housed in an office separate from the actual teaching institution. By allowing the VA certifying official and all required records to be located in the same area as other administrative functions, even when those functions are located "off campus," institutions will be able to easily verify the required student records, students will be able to complete all administrative tasks in one central location, and the burden institutions face when required to maintain separate "VA offices" will be removed.

Finally, CCA supports the VA's proposed definitions of "main campus" and "branch campus." These definitions effectively illustrate the locations the VA is defining.

Thank you again for this opportunity to comment on this proposed rule. Please feel free to contact me if you have any questions or would like clarification on any of these points. I can be reached at 202-336-6839 or via e-mail at TammyZ@career.org.

Sincerely,


Tammy L. Zimmer
Regulatory Analyst

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