**CONTENTS**

**CHAPTER 8. RECORDS**

PARAGRAPH PAGE

8.01 Compliance Survey File 8-1

8.02 Retention of Compliance Survey Records 8-2

**CHAPTER 8. RECORDS**

**8.01 COMPLIANCE SURVEY FILE**

a\. At the time of each initial survey, establish a compliance survey
file for each school and training establishment. This file will consist
of a folder containing all required documents and correspondence
pertaining to the conduct of compliance surveys at the school or
training establishment. It should contain only information and material
pertaining to compliance surveys. Records must be filed in a logical and
consistent manner. The recommended organization is to arrange the
materials in chronological order, as indicated in subparagraph b. below.
However, the Education Liaison Representative may alter the arrangement
to suit local circumstances. When a single institution offers more than
one type of training and is assigned more than one facility code, a
single compliance survey file may contain records for all types of
training, but these must be clearly separated by facility code.

*Note: VA Form 22-1919, Conflicting Interest Certification for
Proprietary Schools Only, pertains to approval criteria and will no
longer be filed in the compliance survey folder. See paragraph 4.16 for
instructions on when to obtain this form. A current Form 22-1919 will be
filed in the approval folder. See part IX, paragraph 7.01b(7). It is not
necessary to transfer Forms 22-1919 currently on file from the
compliance survey folder to the approval folder. However, all newly
obtained forms should be filed in the proper folder, and ESU personnel
are encouraged to transfer forms encountered during normal operations if
workload permits.*

b\. File completed survey reports (see par. 7.01.) on the right side of
the folder, in chronological order by date of survey, with the most
recent report on top. File correspondence to the school concerning the
survey on the left side of the folder, in chronological order by date of
survey, with the most recent report on top. When a possible problem area
is noted from information on certifications, periodic certifications,
correspondence with schools and training establishments, State approving
agency supervisory visit reports, or other documents, temporarily attach
the document or a note concerning the problem area to the left side of
the appropriate compliance survey file for checking during the next
survey. Other materials, such as sample copies of forms used by the
establishment, may be also be temporarily attached on the left side to
assist in future surveys.

**8.02 RETENTION OF COMPLIANCE SURVEY RECORDS**

a\. Retain the compliance survey records for each facility as long as
any irregularities or discrepancies remain unresolved. This includes
compliance surveys which would have resulted in a determination that a
substantial pattern of overpayments exists, except that this was the
first occurrence and the school or training establishment had not been
previously notified in writing (see par. 5.02). In these cases, the
survey report and letter to the facility will be retained permanently,
unless the school\'s approval has been withdrawn. If the school\'s
approval has been withdrawn, see subparagraph b. below.

b\. Once all irregularities or discrepancies have been resolved, retain
the compliance survey records for 7 calendar years after the date of the
survey, unless the school\'s approval has been withdrawn. If the
school\'s approval has been withdrawn, survey reports may be destroyed 3
calendar years after the date of the survey. Records will be destroyed
following the above periods in accordance with RCS VB-1, Part I, Item
Number 7‑662.030. Obsolete materials should be disposed of as they are
encountered during normal operations. However, it may be necessary to
periodically purge files which have not been active for a long time.

*NOTE*: *Student transcripts and other confidential materials must be
destroyed (by shredding or burning) rather than merely discarded.*