**CONTENTS**

**CHAPTER 7. REPORTS AND CORRESPONDENCE**

PARAGRAPH PAGE

7.01 General 7-1

7.02 VA Form 22-1934, Compliance Survey of Schools and Establishments
Furnishing Education and Training 7-1

7.03 Narrative Report 7-1

7.04 Supporting Documentation 7-2

7.05 Correspondence to School or Training Establishment 7-3

**CHAPTER 7. REPORTS AND CORRESPONDENCE**

**7.01 GENERAL**

a\. Compliance survey reports are the basis for determining if a school
or training establishment is meeting the requirements of the law and
regulations. Therefore, all areas reviewed during the compliance survey
must be documented to the extent possible. Reports may be reviewed both
within VA and by interested Federal Government elements outside VA,
including GAO (General Accounting Office) and the Justice Department.
Under the provisions of the Freedom of Information Act, reports may also
be released to interested parties outside of the Federal Government.
However, reports will not be routinely furnished to parties outside of
the Federal Government including SAA\'s (State approving agencies) and
schools.

b\. The materials described in paragraphs 7.02 through 7.04 constitute a
compliance survey report. The compliance survey report must be assembled
in a logical and consistent manner. The recommended organization is to
assemble the materials in descending order as listed below. The ELR
(Education Liaison Representative) may modify this recommendation to
suit local circumstances. When a single school offers more than one type
of training (e.g., courses leading to a standard college degree and
non-degree courses) and has several facility codes, all types of
training will normally be surveyed at the same time, but a separate
survey report will be prepared for each facility code assigned to the
school.

**7.02 VA FORM 22-1934, COMPLIANCE SURVEY OF SCHOOLS AND ESTABLISHMENTS
FURNISHING EDUCATION AND TRAINING.**

a\. **General.** Use this form for all schools and training
establishments. Make entries in all items applicable to the type of
school or training establishment being surveyed. The purpose of the form
is to provide statistical data and a summary of the types of
discrepancies found, if any, as recorded on the compliance survey
worksheet for each case reviewed. Test versions of on-line forms may be
used where available.

b\. **Dates of Survey.** In the item \"FROM,\" enter the first date of
the site visit if no remote review was done. If a remote review was
done, whether or not a site visit was made, enter the date the review of
submitted documents began. In the item \"THROUGH,\" enter the last date
of the site visit if no remote review was done. If a remote review was
done, and no site visit was necessary, enter the date the review of
submitted documents ended. If the remote review was completed by a site
visit, enter the last date of the site visit.

c\. **Reason for Survey.** If a remote review was done, whether or not a
site visit was made, always check the box marked \"OTHER,\" and enter
\"Remote,\" [in addition to]{.underline} making any other appropriate
entries in this item.

d\. **Areas of Inquiry.** Make an entry under \"FINDINGS\" for all
numbered or lettered lines. If the line does not apply, enter \"N/A,\"
or a similar annotation. If the line applies but was not reviewed
(especially on remote reviews), enter \"Not observed,\" or a similar
annotation.

**7.03** **NARRATIVE REPORT**

a\. **General.** The narrative report is the body of compliance survey
findings. It should contain not only the facts identified during the
compliance survey, but also observations and conclusions reached by
survey specialist. Decisions, such as determinations concerning the need
for a site visit or for expansion of the survey, must be included.
Compliance survey narratives are internal VA documents, and are subject
to the provisions of both the Freedom of Information Act and the Privacy
Act. They will not be routinely provided to facility officials or other
individuals outside VA. However, brief passages of the report,
describing particular discrepancies, may be included verbatim in
correspondence to schools or SAAs. When an on-line version of VA Form
22-1934 is used, the narrative report may be produced as part of the
same document. The narrative report consists of three sections.

b\. **Section I - General.** Briefly describe the records which were
reviewed and the reason for the review. Attach appropriate documentation
to the compliance survey report if the reason is other than routine or
follow-up, e.g., memo from Adjudication, letter from beneficiary. If
remote review procedures were used for all or part of the survey,
indicate the reasons. If simultaneous surveys of more than one type of
training were conducted, indicate the facility code(s) for the other
type(s) of training. List the names and titles of officials who were
briefed before the review, whether conducted on site or not.

c\. **Section II - Discrepancies.** Clearly and fully document, with
specific information, the discrepancies found in individual cases and in
general areas of review. (See subpar. c and d below.) Use this
documentation to list and evaluate discrepancies which have been
identified during the compliance survey. For convenience, discrepancies
may be grouped either by type of discrepancy or by individual trainee.
In either case, they will be listed in line number order as they appear
on VA Form 22-1934. The following format will be used:

\(1\) **Type.** Identify the type of each discrepancy by reference to
its line number on VA Form 22-1934.

\(2\) **Facts.** Relate the findings and identify the beneficiary by
name and claim number.

\(3\) **Evaluation.** State a conclusion as to the probable cause of the
discrepancy.

\(4\) **Recommendation.** Recommend action(s) which if accomplished will
correct the discrepancy.

d\. **Section III - Summary.** Relate concisely all discussions with
facility officials, agreements reached and actions taken during the
survey, whether on site or remotely. List officials present at the exit
briefing by title. In addition, summarize any assistance provided to the
school such as discussions of laws, regulations and procedures. Include
other recommendations which were made and implemented during the survey.
If VA Form 22-1919, Conflicting Interests Certification for Proprietary
Schools Only (Chs. 32, 34, 35, and 36, Title 38, United States Code),
was completed during the survey (see par. 4.16), note that fact. Note
whether personal contacts with VA beneficiaries were made in addition to
the survey (see par. 3.02b), and summarize any significant results.
Finally, recommend that the next survey be scheduled either routinely,
or as a follow-up survey. If a follow-up survey is recommended, the
interval should also be recommended, e.g., \"within 6 months,\" \"in the
next fiscal year.\" While brevity is desirable, the summary must fully
reflect the work done during the survey and include all items noted
above.

**7.04** **SUPPORTING DOCUMENTATION**

a\. **General.** All findings, whether positive or negative, discovered
during the survey must be supported by appropriate notations on the
compliance survey worksheets or in other working papers. Included are
those findings relating to each case reviewed as well as general areas
of review, e.g., 85 percent enrollment restriction, charges for tuition
and fees. These notations are used in preparing the survey narrative
report and referrals to other station activities or the SAA for
corrective action. If an incorrect report or certification was submitted
by the school or training establishment, note the correct information as
obtained from school records. If a report was not submitted by the
school or training establishment, but school records indicate a report
should have been submitted, e.g., change in credit hours, note all
appropriate data which should have been furnished in the report. These
notes should be organized and legible so they may be used for school
liability or other actions when required.

b\. **VA Forms 22-1936, Compliance Survey Worksheet for Eligible
Students Pursuing Training Under Chapter 34 or 35; or 22-1936a,
Compliance Survey Worksheet for Students Pursuing Training Under Chapter
32, 34, or 35; or Other Worksheets.** Include an individual worksheet
for each beneficiary in the survey sample. Instructions for obtaining
these forms are in paragraph 2.04. Record all findings, including a full
description of each discrepancy, in appropriate spaces on the worksheet,
or on a blank sheet of paper and attached to the worksheet. Completion
of the checklist on the reverse of VA Forms 22-1936 and 22-1936a may be
omitted at the ELR\'s discretion. Nevertheless, review of all
appropriate items for the type of training is required (see ch. 3 and
4.) Upon completion of the survey, the worksheet shall become a part of
the survey report. Worksheets should be arranged in sequence either
alphabetically or numerically; worksheets with discrepancies requiring
referral may be filed in sequence ahead of other worksheets. Documents
such as notes and copies of transcripts (see subpar. d. below) should be
filed following the worksheet to which they relate. VA Forms 22-1936 or
other worksheets which were not used during the compliance survey and
which are not needed for expanded survey will not be retained.

c\. **Other Documentation.** Other supporting work papers and
documentation (notes of survey findings, copies of student transcripts,
etc.) will be included in the survey report. When a class check or
trainee interview is conducted, it may be documented on VA Form 119,
Report of Contact, which will then be included in the survey report (see
ch. 4). Only essential documentation should be retained. Information
duplicated in the approval file, e.g., list of approved programs,
enrollment limitation, class schedules, may be incorporated in the
survey report by reference, and the corresponding working papers
discarded. Student transcripts obtained for a remote review which are
not needed to support the finding of a discrepancy will not be retained,
except for a brief period in order to facilitate local quality reviews.
If personal contacts with VA beneficiaries were made in addition to the
survey (see par. 3.02b), they need to de documented only to the extent
the information elicited was pertinent to compliance issues.

**7.05 CORRESPONDENCE TO SCHOOL OR TRAINING ESTABLISHMENT**

a\. Correspondence to the school or training establishment is not a part
of the compliance survey report, but must be accurately based on the
report, and should be filed with it (see ch. 8).

b\. Discuss discrepancies which do not violate approval criteria and do
not require referral to the SAA with school officials during the
compliance survey and document them in the survey report. Following a
routine or expanded compliance survey, prepare a letter within 30 days
of the conclusion of the site visit (or remote review if no site visit
is necessary) for the signature of the Chief Education Liaison Officer
(or designee) to confirm the discrepancies found. If agreements for
appropriate corrective action could not be reached during the a site
visit, or if further corrective action is needed, the letter will
include a request for the facility to take appropriate corrective action
and furnish a report of the action taken to the VA within 60 days. See
paragraph 2.06 for controls on replies to survey correspondence.

*NOTE: Do not send a copy of the compliance survey report to the school
or establishment with a letter asking the officials to correct the
discrepancies contained in the report*.

c\. Refer discrepancies involving violations of the conditions or
criteria for approval to the SAA for information or for action. Inform
the school of these referrals , but do not discuss the discrepancies.

d\. If discrepancies would have resulted in a preliminary 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), the letter must
notify the school or training establishment that:

\(1\) Overpayments were found in a substantial proportion of the cases
reviewed;

\(2\) If this occurs on a future compliance survey, it may constitute a
substantial pattern of overpayments; and

\(3\) A finding of a substantial pattern of overpayments could result in
suspension or discontinuance of VA benefits to students or trainees.

e\. If no discrepancies were found, it is not necessary to prepare a
letter to the facility if the survey was completed by a site visit. A
letter to the facility is always required if the survey was completed by
remote review and a site visit was not necessary.

f\. If there are serious discrepancies, address correspondence to the
chief administrative officer of the school or training establishment.
This is usually the same person with authority to sign VA Form 22-8974,
Designation of Certifying Official(s), and VA Form 22-1919, Conflicting
Interests Certification for Proprietary Schools Only. When there are no
serious discrepancies, correspondence may, based on individual
circumstances, be addressed to another person, e.g., the certifying
official, in order to elicit an appropriate response. When a single
school offers more than one type of training, e.g., courses leading to a
standard college degree and non-degree courses, and has several facility
codes, all types of training will normally be surveyed at the same time.
Although separate reports are required for each facility code, the
survey specialist may decide to send a single letter conveying the
results of the surveys. This decision will be based on individual
circumstances, such as the fact that all correspondence will be sent to
the same school official. However, each type of training must be treated
separately within the single letter.