**CONTENTS**

**CHAPTER 6. MONITORING SCHOOL REPORTING PROBLEMS**

**SUBCHAPTER I. IDENTIFYING SCHOOL REPORTING PROBLEMS**

PARAGRAPH PAGE

6.01 Regional Office Responsibility 6-1

6.02 Guidelines for Identifying School Reporting Problems 6-1

**SUBCHAPTER II.**

**REPORT OF EDUCATION OVERPAYMENTS BY FACILITY CODE**

6.03 General 6-2

6.04 COIN EDU 174 - PART 1 6-2

6.05 COIN EDU 174 - PART 2 6-3

6.06 Use By Education Services Unit in Field Stations 6-4

6.07 Disposition Instructions 6-4

**CHAPTER 6. MONITORING SCHOOL REPORTING PROBLEMS**

**SUBCHAPTER I.**

**IDENTIFYING SCHOOL REPORTING PROBLEMS**

**6.01 REGIONAL OFFICE RESPONSIBILITY**

All RO (regional office) and RPO (regional processing office) personnel
should be alert for school reporting problems. If valid, such problems
may provide an early indication of non-compliance with reporting
requirements and may indicate a need for a special compliance survey or
liaison visit.

**6.02 GUIDELINES FOR IDENTIFYING SCHOOL REPORTING PROBLEMS**

RO and RPO personnel who discover school reporting errors should observe
the following guidelines.

**a. Fraud.** If fraud is alleged by a third party or suspected by VA
personnel, refer all pertinent facts to Adjudication for appropriate
action under existing instructions. This applies to school fraud as well
as to payee fraud.

\(1\) If potential *school* fraud is detected in a chapter 30 case,
Adjudication at the RO with local jurisdiction over the school will
prepare the fraud determination. If applicable, the RPO will forward all
appropriate documentation to the RO of jurisdiction. If the entire
chapter 30 folder is needed, it may be *temporarily* transferred to the
RO with jurisdiction over the fraud determination.

\(2\) If potential *payee* fraud is detected in a chapter 30 case, the
RPO will have jurisdiction over the fraud determination.

**b. Serious Reporting Errors.** Serious reporting errors are those
which cause a substantial overpayment of benefits. An example would be
if the claimant reported a change in training time but the school did
not report this event at all. Regulations require that the school report
any such change within 30 days. A report which is a few days late would
not be considered a serious reporting error.

\(1\) Any instance of a serious reporting error must be reported to the
ELR (Education Liaison Representative). The ELR should make a report to
the VSO (Veterans Services Officer). In this report, the ELR will
recommend appropriate action (e.g., a liaison call or visit, or a
special compliance survey).

\(2\) If a serious reporting error is discovered at one of the four
RPOs, the ELR at the RPO should contact his or her counterpart at the RO
with jurisdiction over the school or training establishment. The local
ELR will make a report to his or her VSO as specified in subparagraph
b(1) above.

**c. Pattern of Careless Errors.** A pattern of careless errors consists
of various types of minor errors which may or may not cause
overpayments. For example, a careless error would be the failure to
report the standard class sessions for accelerated terms. In such cases,
overpayments can be avoided since Adjudication would have the
opportunity to determine the standard class sessions before making
payment.

\(1\) As with serious reporting errors, careless errors must be reported
to the appropriate ELR. After an accumulation of such reporting errors,
the ELR will make a report to the VSO. In this report, the ELR will
recommend appropriate action (e.g., a liaison call or visit, or a
special compliance survey).

\(2\) Since it may be difficult for the ELR at an RPO to isolate a
pattern of errors, the RPO should report all minor chapter 30 reporting
errors to the ELR of the appropriate RO. The local ELR will be better
able to compare chapter 30 reporting errors with similar reporting
errors in other education benefit programs and take appropriate action.

**SUBCHAPTER II.**

**REPORT OF EDUCATION OVERPAYMENTS BY FACILITY CODE**

**6.03 GENERAL**

The COIN EDU 174, Report of Education Overpayments by Facility Code,
provides information regarding overpayments at approved educational
institutions under chapters 34 and 35. The report provides overpayment
data for 6-month and 3-year periods. With the end of the chapter 34
program, Adjudication is no longer required to review the report on a
quarterly basis as previous instructions provided.

*NOTE: The report was originally designed for chapter 34 and 35, and is
currently restricted to these programs. Eventually, it may be expanded
to other education benefit systems. The report is useful only if
Adjudicators make the appropriate data entries on each termination and
reduction action. For example, Adjudicators must make the appropriate
entries in the following fields on Target: POTENTIAL SCHOOL LIABILITY
(312/412 or 406 screens); SCH LIAB (350 screen); or A/R DUE TO NO
MITIGATING CIRCUMSTANCES (501 screen). These screens are explained in
detail in part II.*

a\. COIN EDU 174 can be used as a tool to reduce further overpayments.
(See par. 6.06.) VA will *not* initiate school liability proceedings
(see ch. 7) or other adverse action (see ch. 8) solely on the basis of
this report.

b\. The report provides the following information regarding overpayments
at each facility:

\(1\) The total amount of all overpayments;

\(2\) The amount of overpayments which involve school liability; and

\(3\) The amount of overpayments which involve failure to establish
mitigating circumstances.

**6.04 COIN EDU 174 - PART 1**

Part 1 of COIN EDU 174 is issued in three copies. Two copies are for the
regional office, and one copy is for the SAA (State Approving Agency).
The copies for the regional office are intended for use by Adjudication
and VSD. This part provides summary data for each IHL (Institution of
Higher Learning) and NCD (Non-College Degree) facility under a field
station\'s jurisdiction. The last page for each station shows the
regional office and national totals. A facility will not be listed on
this report if there were no overpayments created within the last 3
years which remain uncollected. For each facility, the report provides
overpayment data under three different general headings. The three
general headings, and their subheadings, are shown below.

a\. A/Rs - Potential School Liability

\(1\) BALANCE: The *current* balance of overpayments which may involve
some potential school liability. The report shows separate balances for
overpayments created during the last 6 months and the last 3 years.

*NOTE: This figure is not an estimate of potential school liability. It
is a total of overpayments for those cases in which Adjudication
determined that the school could be potentially liable for all or some
of the overpayment.*

\(2\) NUMBER: The number of overpayments, shown separately for the last
6 months and the last 3 years, which indicate some potential school
liability.

\(3\) AVERAGE: The average overpayment, shown separately for the last 6
months and the last 3 years, computed by dividing BALANCE by NUMBER.

\(4\) % TO STUDENTS: A percentage obtained by dividing NUMBER by the
number of students who were in training at that facility during the
*last 6 months.* (This computation is done only for the last 6 months.)
The % TO STUDENTS is a measure of a school\'s reporting error rate for
chapter 35 cases. For example, if the percentage were 10 percent, it
means that VA created overpayments involving potential school liability
in a number equal to 10% of the eligible persons who trained (even one
day) at the facility within the last 6 months. *The overpayments were
not necessarily for eligible persons who trained in the last 6 months.*

b\. A/Rs CREATED DUE TO LACK OF MITIGATING CIRCUMSTANCES. This section
provides data concerning overpayments which were caused by the
claimant\'s failure to establish that withdrawal from a course or
courses was due to mitigating circumstances. The report provides a
breakdown for the last 6 months and the last 3 years. The cases
identified in this section may include some of the same cases which also
appear in the school liability section since it is possible for both
issues to be involved in the same overpayment.

\(1\) BALANCE: The current balance of overpayments, for 6 months and 3
years, which are entirely or partially due to the claimant\'s failure to
establish mitigating circumstances.

\(2\) NUMBER: The number of overpayments, for 6 months and for 3 years,
which involve failure to establish mitigating circumstances.

\(3\) AVERAGE: The average overpayment, for 6 months and for 3 years,
computed by dividing BALANCE by NUMBER.

c\. TOTAL A/Rs CREATED DURING LAST 6 MOS/3 YRS. These columns provide
summary information on all overpayments created during the last 6 months
and during the last 3 years. The figures in these columns are not the
sum of the school liability columns and the mitigating circumstances
columns since overpayments may be created for reasons which are
unrelated to school liability or mitigating circumstances.

\(1\) BALANCE: The current balance of overpayments created within the
last 6 months and the last 3 years.

\(2\) NUMBER: The number of overpayments created in the last 6 months
and the last 3 years.

\(3\) AVERAGE: The average overpayment, shown separately for the last 6
months and the last 3 years, computed by dividing BALANCE by the NUMBER
of trainees.

d\. TOTAL NUMBER STUDENTS. The number of students who were in training
*at any time* during the last 6 months. This figure is used to determine
% TO STUDENTS as described in paragraph 6.04a(4) above.

**6.05 COIN EDU 174 - PART 2**

Part 2, which is generated in microfiche format, is issued in two
copies. The ELR should forward one copy to the SAA and retain one copy.
Adjudication will have access to the copy retained by the ELR. This part
contains information on the individual overpaid accounts for each
facility for the last 3 years. The items in part II are explained as
follows.

a\. FILE NO.: Self-explanatory.

b\. PAYEE NO: Self-explanatory.

c\. STUB NAME: Self-explanatory.

d\. A/R BALANCE: The accounts receivable balance at the time the report
was generated. This figure is not necessarily the amount of the original
overpayment because some part of the original overpayment may have been
recovered.

e\. TYPE: The accounts receivable type code. This report provides data
on chapter 34 and 35 overpayments only. The accounts receivable codes
for these benefits are 41 and 44 respectively.

f\. POTENTIAL SCH LIAB: An \"\*\" will be displayed if Adjudication set
the school liability indicator when they created the overpayment.

g\. LACK OF MIT CIRC: An \"\*\" will be displayed if Adjudication set
the mitigating circumstances indicator when they created the
overpayment.

h\. A/R NEW THIS RPT: An \"\*\" will be displayed if the overpayment was
created within the last 6 months. This will permit ready identification
of the recently created A/Rs.

i\. DISCOVERY DATE: The discovery date of the accounts receivable. This
is the month and year (MMYY) that the overpayment was entered on Target.

j\. CHAPTER: This will be chapter 35. The other VA education programs do
not appear on COIN EDU 174 at this time.

**6.06 USE BY EDUCATION SERVICES UNIT IN FIELD STATIONS**

a\. ELR\'s should use COIN EDU 174 to help identify potential school
reporting problems so that appropriate action can be taken to prevent
further avoidable overpayments. Appropriate actions might include:

\(1\) Advising a school that it has an unusually high rate of late
reporting of enrollment changes or other errors that have caused
overpayments;

\(2\) Encouraging schools to make telephonic or electronic reports of
enrollment changes; or

\(3\) Devising ways (such as seminars, etc.) to emphasize to schools and
beneficiaries the consequences of failing to complete courses without
acceptable mitigating circumstances.

b\. The compliance survey activity should use COIN EDU 174 to supplement
routine audits. Appropriate use of the report might include reviewing
the records of a sampling of overpaid cases in addition to the randomly
selected cases.

**6.07 DISPOSITION INSTRUCTIONS**

Both formats of the COIN 174 Report will be destroyed when 6 years and 3
months old. Records Control Schedule VB-l, part I, item number
07-690.040 is assigned to this report and for any future revisions to
the schedule.