**CONTENTS**

**CHAPTER 6. PROGRAMS OF EDUCATION**

PARAGRAPH PAGE

6.01 General 6-1

6.02 Program of Education Defined 6-1

6.03 Selection of a Program of Education 6-\[2\]

6.04 \[Objectives\] Defined 6-\[3\]

6.05 Review of Course Approval Data 6-\[6\]

6.06 Special Courses Which May Be Included in Programs 6-7

6.07 Course Not Approved 6-\[8\]

**CHAPTER 6. PROGRAMS OF EDUCATION**

**6.01 GENERAL**

**a. \[General.** Each claimant applying for one of the benefits
described in this manual (except for section 901 of Public Law 96‑342
and TAT (Tuition Assistance Top‑Up)) must select an approved program of
education.\]

**b. \[Principle.** With the exception of TAT courses, a basic principle
is that a claimant must be enrolled in a program of education [at all
times]{.underline} in order to receive VA education benefits.

*EXCEPTION: The chapter 30 program referred to as TAT does not require
the claimant to be in a program of education. See RPO Letter 22‑01‑05,
Tuition Assistance Top-Up, dated March 2, 2001 for instructions. These
instructions will be added to part V in future changes.*

*NOTE: See chapter 11 for the unique rules which apply to the section
901 benefit.*

**c. References**

\(1\) Chapter 7 describes restrictions that apply to various programs.

\(2\) Part IV, chapter 4, describes the rules that govern changes of
program.\]

**6.02 PROGRAM OF EDUCATION DEFINED**

There are separate definitions of \"program of education\" in the CFR
for each major benefit. \[For chapter 30, see 38 CFR 21.7020(b)(23). For
chapter 32, see 38 CFR 21.5021(q). For chapter 35, see 38 CFR
21.3021(h). For chapter 1606, see 38 CFR 21.7520(b)(17).\] The following
is a composite definition. A program of education:

a\. Is a combination of subjects or unit courses pursued at an
educational institution. The combination generally is accepted as
necessary to meet the requirements for a predetermined educational,
professional or vocational objective. Except for chapter 35, it may
consist of subjects or courses which fulfill requirements for more than
one objective, if all objectives pursued are generally recognized as
being related to a single career field.

b\. Includes an approved full-time program of apprenticeship or other
on-the-job training.

c\. Is any unit course, subject, or combination of courses or subjects
that the Administrator of the Small Business Administration requires to
obtain financial assistance under 15 U.S.C. 636. [This type of program
cannot be approved for chapter 35]{.underline}.

d\. \[Includes approved licensing or certification tests, except for
chapter 1606.

*NOTE: In some cases, both this manual and the education regulations use
"program of education" and "course" interchangeably. In other cases,
"course" refers to an individual unit course such as History 101.\]*

**6.03 SELECTION OF A PROGRAM OF EDUCATION**

**a. General.** \[A claimant\'s program must meet each of the following
conditions:

\(1\) Meet the definition of a program of education. (See par. 6.02.)
(The program that a claimant states on the application must be complete
in that it must include all training needed to reach the stated
objective. It may not include courses vaguely related to the selected
objective or courses and subjects desired for self‑improvement.)

*NOTE: VA will pay only for courses and subjects which are part of an
approved program. (See par. 6.01 for the TAT exception.)*

\(2\) Have an acceptable educational, professional, or vocational
objective. (See par. 6.04.)

\(3\) Be approved for VA training. (See par. 6.05.)

\(4\) The claimant must not be already qualified for the objective of
the program. See chapter 7 for detailed instruction on this issue.

*NOTE: See part IV, chapter 4 for change of program information.*

**b. Proper Completion of Applications.** Except for persons applying
for TAT, claimants must state on their application form their final
objective, and their proposed course of study. They should preferably
also state the school or training establishment they plan to attend.
(See ch. 3 for the list of application forms used in education benefit
programs.)

\(1\) The program outlined on the application must be complete in that
it must include all training needed to reach the stated objective. It
may not include courses vaguely related to the selected objective or
courses and subjects desired for self-improvement.

\(2\) When a program involves the attainment of more than one degree,
the program should be described on the application in terms of the
degrees awarded; e.g., B.A. (Bachelor of Arts), M.A. (Master of Arts)
and Ph.D. (Doctor of Philosophy).

\(3\) When the proposed program will be pursued sequentially at more
than one institution or establishment, the initial application need only
include the first institution or establishment. Subsequent applications
must show future training facilities.

**c. Selection of an Objective**

\(1\) A program of education must lead to one of three types of
objectives: educational, professional, or vocational. (See par. 6.01 for
the TAT exception.) An individual pursuing an [educational
objective]{.underline} need only list the educational objective on his
or her application. However, an individual pursuing a [professional or
vocational objective]{.underline} must list the occupation which is his
or her objective as well as the specific course or courses the
individual plans to take.

\(2\) If a person requests a program leading to a [professional or
vocational objective]{.underline} but lists an [unrelated]{.underline}
vocational or professional course on the application, \[the Education
Division\] should deny the claim.

\(3\) If a person requests a program for a [professional or vocational
objective]{.underline} in a field in which he or she is already
employed, \[the Education Division\] should consider denying the claim
on the grounds that the person is already qualified for the objective.
(See par. 7.07 regarding the \"already qualified\" principle.)

**6.04 OBJECTIVES DEFINED**

*\[NOTE: Except as noted, this paragraph contains background material
for claim examiners. These are rules that SAAs apply during the approval
process.\]*

**a. Educational Objectives** (See 38 CFR 21.4230(b).)

\(1\) [General]{.underline}. An educational objective leads to the
awarding of a diploma, degree, or certificate which reflects educational
attainment as distinguished from a certificate or a license to practice
a profession or trade. The objective will be the name of the highest
degree, diploma, or certificate included in the program, such as a GED
(General Educational Development) certificate, high school diploma,
bachelor degree, master degree, or Ph.D. degree.

\(2\) [Non-Degree Postdoctoral and Graduate Level Certificate
Programs]{.underline}. A [postdoctoral-level]{.underline} certificate
from an accredited college or university may be accepted as an
[educational]{.underline} objective. A [graduate-level]{.underline}
certificate [may]{.underline} qualify as leading to an educational
objective if the SAA establishes that all of the courses required for
completion of the certificate program are accepted by the school for
full credit toward completion of approved accredited graduate degree
programs. All of the courses need not be acceptable to any one graduate
program, but the courses must all be creditable toward approved graduate
degrees offered by the same institution. SAAs may not approve graduate
level certificate programs which fail to meet these requirements.

*NOTE: Undergraduate-level certificate programs lead to
[vocational]{.underline} objectives. See subparagraph c.*

**b. Professional Objectives.** (See 38 CFR 21.4230(c).)

\(1\) [General]{.underline}. A professional objective leads to an
occupation after an individual completes an extended academic program of
study. The program must be at the college level and be generally
accepted as necessary to satisfy the educational requirements for
licensing or certification to practice the identified profession.
Typical examples of professional objectives are lawyer, physician
(M.D.), teacher, physical therapist, medical technologist, and medical
record librarian.

\(a\) A program leading to a professional objective may include courses
also leading to an educational objective. In this situation, the student
may specify either the educational objective or the professional
objective on his or her application. Examples are B.S. (Bachelor of
Science) degree in secondary education or high school teacher, and J.D.
(Juris Doctor) degree or lawyer.

\(b\) Bar review courses may be approved as part of an overall
professional program for a lawyer if a claimant requests such a course
to reach his or her professional objective. Similarly, CPA (Certified
Public Accountant) review courses can be approved as part of an overall
professional program for a CPA.

\(c\) A combined degree program must lead to a single career field. This
field is normally professional. (See subpar. e.)

\(d\) Clinical pastoral education programs may lead to either
professional or educational objectives.

*NOTE: In the absence of an educational certificate, an approved
postdoctoral program (including a medical program not involving a
residency) offered by an accredited institution of higher learning
qualifies as a program of education leading to an occupation when it is
specifically required to practice a profession. Except in the medical
field, postdoctoral training is seldom a general requirement for
employment or for licensing to practice a profession. When it is
generally accepted as necessary to obtain employment or to practice a
profession, a postdoctoral course may be included in a program of
education for a vocational or professional objective.*

\(2\) [Internships (38 CFR 21.4265(a))]{.underline}. An internship is a
period of supervised practical training required for licensing to
practice a profession. It is distinguished from an
[experience]{.underline} requirement in which the applicant must
practice the profession for a predetermined period [before]{.underline}
receiving the license or certificate. For example, suppose a state
requires a person to be employed in an accounting office for a specified
period [after]{.underline} completing the educational requirements for a
CPA. This would be an experience requirement. Experience requirements
are not acceptable for educational assistance payments.

\(a\) [Osteopathy]{.underline}. A claimant pursuing an internship in
osteopathy has a professional objective of physician (D.O.) unless he or
she specifies a specialty. For example, the specialty could be a
pathologist, surgeon, or obstetrician.

\(b\) [Other]{.underline}. The professional objective of any other
accredited internship program will be the name of the occupation for
which the internship is required.

\(3\) [Residencies (38 CFR 21.4265(a))]{.underline}. A residency is an
advanced supervised period of training required for specialized practice
in a profession.

\(a\) [Medical]{.underline}. When the residency course leads to
certification by a specialty or subspecialty board, the professional
objective is the named specialty or subspecialty for which the board has
established standards. Examples would include orthopedic surgeon,
pathologist, or specialist in physical medicine and rehabilitation.
Medical training at the postdoctoral level by an accredited IHL
(Institution of Higher Learning), such as a college or university school
of medicine, which leads to a certificate showing educational attainment
will be accepted as an [educational objective]{.underline}. This applies
even if there is no specialty board for the training. A medical
residency must be accredited either by the Accreditation Council on
Graduate Medical Education of the American Medical Association, or where
the Council has delegated this authority, by the appropriate Residency
Review Committee.

*NOTE: The American Psychoanalytic Association accredits courses
designed to train people with an M.D. degree to become psychoanalysts.
See part IX, chapter 3, for information on these courses which, to be
approved, may not include residencies.*

\(b\) [Osteopathy]{.underline}. The professional objective of a claimant
pursuing a residency course in osteopathy will be that named specialty
for which certification is given by the appropriate American Osteopathic
Association Specialty Board.

\(c\) [Optometry]{.underline}. A claimant does not have to pursue a
residency in optometry to practice the profession of optometry.
Therefore, a residency in optometry may not be approved as a regular
training program or as refresher training.

\(4\) [Medical Subspecialty]{.underline}. A medical subspecialty may be
permitted when the subspecialty is one for which there is a board, and a
certification will be issued by the board upon completion of the
subspecialty. A residency which is not accredited or does not lead to
certification by a specialty or subspecialty board may not be approved
as part of a program of education. It does not matter that the program
leads to a certificate granted by an accredited IHL.

\(5\) [Nursing Courses (38 CFR 21.4265(b))]{.underline}. A claimant may
pursue the professional objective of registered nurse or registered
professional nurse for training given by autonomous schools of nursing,
hospital schools of nursing, or schools of nursing established in other
schools or departments of colleges or universities. All other nursing
objectives such as practical nurse or licensed practical nurse are
properly classified as vocational objectives.

\(6\) [ROTC Programs]{.underline}. A student in an ROTC (Reserve Officer
Training Corps) program is commissioned as an officer only if he or she
receives a degree. Therefore, since a degree is one of the requirements
to become a commissioned officer, the objective of commissioned officer
is a professional objective. A student in an ROTC scholarship program
may show his or her objective to be commissioned officer. For ROTC
programs, the school certifies required courses for the degree
(including electives) [and]{.underline} those required for the ROTC
program.

**c. Vocational Objectives.** (See 38 CFR 21.4230(c).) A vocational
objective leads to an occupation ordinarily attained after completion of
a business, technical, trade, or other vocational school course, or an
apprenticeship or other on‑the‑job training program. \[A vocational
objective must be a recognized employment objective. It should be of the
type previously listed in the DOL (Department of Labor) Dictionary of
Occupational Titles, but currently in the DOL \"O\*NET\" database, at
the following Internet site: \"**www.doleta.gov/programs/onet**\".
Examples of vocational objectives are barber, secretary, machinist,
computer programmer, automobile mechanic, and practical nurse. With
respect to non‑degree certificate programs, an undergraduate level
certificate from an accredited college or university may be accepted as
leading to a vocational objective. See subparagraph a regarding graduate
and postdoctoral certificate programs.\]

**d. Dual Objectives.** (See 38 CFR 21.4230. Also see pt. IX, par.
3.03.) A program of education may lead to more than one educational,
professional, or vocational objective if all objectives pursued are
generally recognized as being reasonably related to a [single career
field]{.underline}. The objectives do [not]{.underline} necessarily have
to be on the same professional or technical level. [CAUTION:  The SAA
must specifically approve any program which leads to dual
objectives]{.underline}. It is not sufficient that the SAA may have
previously approved the separate courses in the student\'s program. Do
[not]{.underline} issue a Certificate of Eligibility or award benefits
until SAA approval is obtained for programs such as the following:

\(1\) Programs involving double majors.

\(2\) Combination programs where instruction in several different
schools of a university is combined.

\(3\) Programs involving a major field and a minor field where the
student is required to extend the length of his or her program beyond
what is normally required for graduation.

\(4\) Programs leading to two degrees as described in subparagraph e
below.

**e. Interdisciplinary Education.** SAAs may approve courses leading to
two degrees granted simultaneously. This is not the \"normal
progression\" of degrees which is usually encountered. The goal of two
degrees under these circumstances is \"one objective\" within the
meaning of the law.

\(1\) Some schools have interdisciplinary programs resulting in the
granting of two degrees at the conclusion of a combined program. An
example would be a program combining both a bachelor of arts degree and
a Juris doctor degree. Acceptance of this type of program should not be
limited, however, to programs resulting in graduate level degrees. While
most such programs lead to professional level objectives, programs
combined to result in two degrees, both at a level below the graduate
level, may be accepted. The two degrees may be at the same or at a
different professional or technical level (for example, bachelor of
business administration and bachelor of science in engineering, or B.A.
and J.D. degrees).

\(2\) If the claimant pursues the interdisciplinary program concurrently
at two schools, each school will certify enrollments and report changes
for their respective programs.

**6.05 REVIEW OF COURSE APPROVAL DATA**

**a. General.** \[The Education Division should verify course approval
from OLAF (On‑line Approval File). See TG (Training Guide) 22-99-1, OLAF
(On-Line Approval File) for Windows to learn what data is in OLAF and
how to do searches. [Approval data does not need to be reviewed in all
IHL cases.]{.underline} [See subparagraph f.]{.underline} If you request
a print, OLAF prints approval data on VA Form 22-1998 (OLAF Report).\].

*\[NOTE: Course approval is not an issue for TAT courses. (See par. 6.01
for TAT exception.)\]*

\[**b. Approval Not in OLAF.** If the OLAF record does not provide the
information necessary to process an application, contact the ELR
(Education Liaison Representative) for the additional information.\]

**c. \[Reserved for Future Use\]**

**d. \[Reserved for Future Use\]**

**e. \[Reserved for Future Use\]**

**f. IHLs Exempt From Approval Review.** An \[EO (Education Officer)\]
may identify IHLs that do not require review of approval information
before processing applications. When the EO identifies such schools, he
or she should notify the CELO (Chief Education Liaison Officer) to have
the appropriate ELR update the OLAF "IHL Exempt" field on the
Issues/Remarks screen. However, this discretion must be specifically
authorized in writing by the EO\] and must be limited to programs from
large or well‑known IHLs that have not had a history of approval or
certification problems. The ELR will recommend institutions that meet
these requirements. Institutions meeting these requirements will appear
on the OLAF IHLs Exempt from Review listing which is produced from OLAF.

\(1\) \[See part IX, paragraph 8.06a(6) for information on the IHL
Exempt field.\]

*NOTE: If an application or accompanying enrollment certification raises
issues involving branches or additional facilities, cooperative
training, independent study, practical training, remedial courses,
deficiency courses, or refresher courses, \[review the OLAF record. When
necessary, consult the CELO on this issue. The CELO should contact the
appropriate ELR to resolve that issue.\]*

\(2\) \[The Education Division should check the listing on the first
workday of each month. If the listing has been updated, print and
distribute it as necessary. If the listing has not been updated, contact
the CELO and request him or her to have the appropriate ELR(s) update
the listing.\] The listing is only valid for 30 days from the date
printed on it. Dispose of old listings in accordance with RCS VB-1, part
1, item number 13-005.000.

\(3\) If the \[EO receives an approval problem from the ELR or
determines that an exempt IHL has a problem from an adjudication
standpoint, he or she will issue a written memorandum explaining this to
the Education Section and the CELO. Adjudicators will have to begin
reviewing OLAF approval data on all applications for programs of
education at that school. The CELO should have the appropriate ELR
immediately update the OLAF record.\]

\(4\) If the problem is resolved, the \[EO will issue another written
memorandum explaining this to the Education Division and the CELO.
Adjudicators will no longer have to review OLAF approval data on all
applications for programs of education at that school. The CELO will
have the ELR immediately update the OLAF record.\]

**6.06 SPECIAL COURSES WHICH MAY BE INCLUDED IN PROGRAMS**

In the instances listed in this paragraph, \[the Education Division\]
may approve the addition of certain courses as part of the claimant\'s
program. In each case, the claimant\'s school must certify that such
courses are required.

**a. Courses Required for Admission to the Next Level of Training.**
Courses required for admission to the next level of training may be
approved in two situations. The first is when an IHL requires a student
to pursue courses at an educational level for which he or she already
holds a diploma or degree. The second is when an IHL requires a student
to pursue courses at an educational level for which he or she appears
qualified by reason of previous training. For example, a college may
require a student with a B.A. degree to take some undergraduate subjects
for admission to a graduate degree program, or to gain teacher
certification for specific subjects. A statement from the school as to
requirements of any specific courses for the student must accompany the
claimant\'s application.

**b. Grade Point Deficiency.** When additional subjects beyond those
generally required for a degree are needed in order to overcome a grade
point deficiency for continuation in the approved program, the
additional subjects may be approved. The school must certify that:

\(1\) The student is taking the courses for the purpose of removing the
grade point deficiency;

\(2\) No course previously taken for which credit has been granted is
being repeated, unless repetition of that particular course is required
for continuation in the approved program; and

\(3\) The student\'s progress is satisfactory under the school\'s
standards.

**c. Language Courses for Graduate Students.** When an applicant
requests a language course to help pass a language examination
requirement for a graduate degree, the course may be approved as part of
the program if the graduate institution certifies that the course will
assist the applicant in passing the examination. This does not mean that
VA will grant the approval for subjects taken abroad which are not
creditable toward the degree but are merely to \"learn the language\" in
order to pass an examination in a U.S. institution.

**d. Noncredit Deficiency, Remedial, or Refresher Courses.** See chapter
7.

**e. Concurrent Enrollment.** See part IV, chapter 1.

**f. Full Credit Refresher Training.** See chapter 7.

**6.07 COURSE NOT APPROVED**

**a. General**. Courses may be not approved for a variety of reasons.
See subchapter I of chapter 7. Some courses may never be approved
because they fail to meet legal requirements. Some may be approved under
certain conditions or for certain benefit programs. Others are not
currently approved but might become approved in the future. The
adjudicator must consult with the ELR in all cases where a course is not
approved unless the \[situations or circumstances in subparagraphs c or
d below clearly apply. This initial consultation can be made using
electronic mail. The Education Division\] should ask the ELR at that RPO
who will then coordinate with the ELR having jurisdiction over the
school.

*\[NOTE: Course approval is not an issue for TAT courses. (See par. 6.01
for TAT exception.)\]*

**b. Course Not Approved by SAA or VA**

\(1\) If the ELR confirms that the course is not approved by the SAA or
VA, the adjudicator will annotate the application \"course not
approved\" in accordance with paragraph 6.05e and disallow the claim.
\[In TIMS, put appropriate information in a FLASH.\] (See fig. 9.08 for
suggested wording on the notification letter when the SAA is the
approval authority. See fig. 9.09 for suggested wording on the
notification letter when VA is the approval authority.)

\(2\) For courses that are not approved, send one copy of the
notification letter to the ELR having jurisdiction over the school. This
notification can be sent using electronic means. Send a copy of the
notification letter to the SAA having jurisdiction over the school.

\(3\) The ELR having jurisdiction over the school should retain copies
of denial letters for one year. He or she should compare them to
approvals as they are received.

\(4\) If the course is approved during the year that the copy of the
notification letter is retained, the ELR should return the copy to the
\[Education Division\] with an Optional Form 41 indicating that the
\[course is approved and the file number of the claimant who had been
denied for that course. The ELR should specify at least the date of
approval and the facility code. The ELRs at ROs and RPOs have the option
of sending this information using electronic means. The Education
Division\] should pull the claimant\'s folder and take appropriate
action on the claim.

**c. Course Not Approvable**. If the adjudicator, after reviewing
chapter 7 or consulting with the ELR, determines that the course is not
approvable, he or she should annotate the application (see
par. 6.05e(3)) with \"course not approvable\" and disallow the claim.
\[In TIMS, put appropriate information in a FLASH.\] (See figs. 9.10 and
9.11 for suggested wording on the notification letter.)

**d. Course Approved but Not Appropriate**. If a course is approved but
is clearly not permitted for a particular category of claimant, \[the
Education Division\] may deny such claims without referral to the ELR.
\[In TIMS, put appropriate information in a FLASH.\] For example, a
child under chapter 35 applies for a correspondence course. \[The
Education Division\] may deny such a claim since chapter 7 clearly
indicates that chapter 35 children may not take correspondence courses.
(See fig. 9.11 for suggested wording on the dictated notification
letter.)