UNDERSTANDING VETERAN
REQUIREMENTS
OVERVIEW
- DECIPHERING VETERAN DOCUMENTS
- NCD VETERAN ATTENDANCE
- VETERAN COMPLIANCE SURVEYS
DECIPHERING VETERAN
DOCUMENTS
- DD214s
Armed Forces Member/Veteran
• Requirement
- Serving/served on AD (including basic training) in the Army, Navy,
Air Force, Marines, or Coast Guard.
- National Guard or Reserve only considered veterans if called to
active federal duty by presidential order for a purpose other than
training.
- Any service characterization except dishonorable. Includes
fraudulent entry provided entire period of service was not voided.
- Service academy/preparatory school students for at least 1 day
are veterans if service characterization was not dishonorable.
- The possession of a DD214 does not mean the person is a veteran.
DD FORM 214
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Block 2: Department, Component and Branch
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Army/RA = Regular
Army/USAR = Reserve
Army/ARNGUS = National Guard
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Navy – USN = Regular
Navy – USNR = Reserve
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USMC – 11 = Regular
USMC – K1 = Reserve
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Air Force – REGAF = Regular
Air Force – AFRC = Reserve
Air Force – ANGUS = Air National Guard
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Homeland Security – USCG = Regular
Homeland Security – USCGR = Reserve
DD FORM 214
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Block 12.c.: Record of Service - Net Active Service This Period
- Determine length of active service for DD 214 period. Note: Guard/Reserve personnel can
have more than one DD 214.
- If the member was AD, served 1 or more days, and did not receive a dishonorable discharge
(Block 24) they are considered a veteran even if they committed a military crime or were
discharged for conduct/performance (Block 28). Fraudulent entry is acceptable permitted
their entire period of service was not voided.
Block 18: Remarks
- If the member was Guard/Reserve they must have been called to AD by presidential orders
for purposes other than training.
- If the member served for purposes other than training it will be identified stating where
they served and the dates.
- If service was anything other than dishonorable and meets the criteria list above then the
member is a veteran.
- Title 32 v. Title 10 is typically specified here.
- If the Guard/Reserve member was on active duty for training only then they are not
considered a veteran for financial aid purposes. This can be determined by looking at blocks
2, 11, 12.c, 18, 23, 24, & 28.
DD FORM 214
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Block 23: Type of Separation
- This entry depends on the Character of Service (24). If block 24 is
anything other than Honorable you will typically see “Discharge” or
“Discharged”.
- If member was Guard/Reserve and on AD for training you will see
“Release from active duty training” or “Release from IADT” or “Released
from active duty”.
- AD members will have “Released from active duty”.
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Block 24: Character of Service
- DD 214 must have a Service Characterization of anything other than
dishonorable to be considered a veteran.
Block 28: Narrative Reason for Separation
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“Completion of Required Active Service” “Fraudulent Entry” “Misconduct (Serious Offense)”
“Completion of Initial Active Duty Training”
QUESTIONS?
DECIPHERING VETERAN
DOCUMENTS
- MILITARY ORDERS
Military Orders
• Types of military orders
– TDY
– Training
– Deployment
– Memorandum
– Forms
– Title 10 vs 32
Form Breakdown
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Issuing service
- Component (e.g. Guard, Reserve, AD)
Issue date
- Depends on why orders are being submitted.
Itinerary (i.e. dates & destination)
Purpose
All services do this differently and there are different formats, depending
on type of orders, within each service.
QUESTIONS?
DECIPHERING VETERAN
DOCUMENTS
- COMMANDING OFFICER
STATEMENTS
COMMANDING OFFICER STATEMENTS
• Who has authorization to sign?
– Commanding officer
• Officer v. Enlisted v. Civilian
– By Direction (similar to proxy)
– Signing “For” Commander
• What is the document stating?
– Honorable service
– Active Duty v. Training
– Dates
– Letterhead
QUESTIONS?
NCD VETERAN
ATTENDANCE
OVERVIEW
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Clock Hour Measurement
Attendance Policy
Standards of Progress
Enrollment Periods
Prior Training
Approved Course Program Length
Certifying Tuition
Clock Hour Measurement
• One clock hour = 60 minutes of instruction
• Classroom/Theory/Lab
– Allows for 10 minutes to change classes each hour, which can be
included in the total hours of instruction (must deduct if not changing
classes)
– Also allows for 10 minutes to changes subjects even if students remain
in the same classroom (e.g., finish talking about gasoline motors and
switch to studying diesel motors)
• Shop Practice
– Allowance for 15 minute break in morning; another in the afternoon.
Can be included in total hours of instruction. Shorter breaks allowed
for part-time enrollment
Clock Hour Measurement
• All clock hours reported to VA must exclude any lunch or meal
breaks
– The morning and afternoon breaks may not be combined
for a half hour lunch
Clock Hour Measurement
• Certify the actual number of clock hours per week the student
is scheduled to attend, not the minimum it takes to be fulltime
– Certified hours will be compared with those listed on the enrollment
agreement and schedules
– No averaging unless it does not change training time or rate of pursuit
to less than full time or less than 100%
Clock Hour Measurement
• How the Difference Affects Payment of Benefits
– Training Time (Chapters 30, 35, 1606 and 1607)
Clock Hour Measurement
• How the Difference Affects Payment of Benefits
– Sample Calculations for Rate of Pursuit (Chapter 33)
Attendance Policy
• Know and understand your SAA approved attendance policy
– Often times, it is different than the policy for your other
students
• Policy for VA students may be a percentage of course hours or
total number of absences
Attendance Policy
• Ensure you are monitoring VA students’ attendance
– Maintain detail in file
• We must see a record of every day the student was scheduled; the
number of hours per day the student was scheduled; and how
many hours the student actually attended
• Excused absences must be documented
• Attendance records must be a daily record of the student’s actual
attendance and must be “positive” rather than “negative” records
Attendance Policy
• All NCD programs measured on a clock hour basis must maintain
attendance records for each class
• A student’s schedule is not an attendance record and not sufficient for this
purpose
• All instructor-led classes must have a roll book or other record maintained
by the instructor to verify each student’s attendance
– Often, a physical sign-in sheet is used for this purpose and is sufficient
as long as the class instructor maintains constant control over it so
that s/he actually observes the student signing in
Attendance Policy
• Enforce the policy if a student fails to meet attendance standards
– Student’s benefits must be terminated is s/he violates attendance
standards
• Ensure you submit within 30 days of the student’s last day of attendance
prior to violating the attendance policy
Attendance Policy
• Example:
– Attendance is verified on a monthly bases by the SCO. Students who,
for any reason, miss more than 15% of the total scheduled course
hours in a calendar month are considered to be in violation of the
attendance policy and their VA education benefits will be terminated
for unsatisfactory attendance.
• Example:
– A VA student’s enrollment will be terminated if s/he has more than
three (3) absences in any calendar month.
• One size does not fit all – Check with your State Approving Agency
if you have questions regarding your approved attendance policy
Attendance Policy
• Example:
– In order to show that the cause of unsatisfactory attendance has been
removed, students must show good attendance (as defined) for one
calendar month after being terminated for unsatisfactory attendance.
After such time, the student may be recertified for VA education
benefits.
• One size does not fit all – Check with your State Approving Agency
if you have questions regarding your approved attendance policy
Standards of Progress
• Know and understand your SAA approved Standards of Progress policy for
VA students
– Must relate to graduation requirements
• Ensure you are monitoring VA students’ progress
• There must be a clear, definite point in time when a:
– VA student will be placed on probation (cannot be indefinite)
• Report probation through RightNowWeb
– VA student’s enrollment will be terminated for not achieving
satisfactory progress
• Law requires VA educational benefits be discontinued when
student fails to make satisfactory progress toward completion of
training objective (Title 38, USC, Section 3675(b)(1))
• Report termination for unsatisfactory progress through VA-ONCE
Enrollment Periods
• Schools not operating on a term basis
– Typically, this category includes many public NCD schools and private
cosmetology, massage therapy, barbering, etc., schools which operate
their courses on the principle of competency-based instruction, open
entry/open exit (each student learns the course material at his/her
own pace and receives a certificate of completion when all
competencies have been learned). Students just starting the course
and others ready to complete the same course will be in the same
classroom/shop at the same time with the same instructor. For such
courses, a SOP may require specific grades/scores at the end of each
grading period with probationary periods of one or two grading
periods.
Enrollment Periods
• Schools not operating on a term basis (cont.)
– With all NCD programs which do not operate on a term basis, the
school should enter the exact date on which the student first attends
and the exact date on which the student will last attend (i.e., the first
day of actual classroom attendance and the last day of actual
classroom attendance are to be reported).
Prior Training
• Schools must ask students to list all previous education and training
– To include where they attended, when they attended and in what
program(s) they were enrolled
– Do not ask the student if they want any credit transferred in –
irrelevant; mandatory and the students have no choice in the matter
• Schools must evaluate that education and training
– Must obtain official transcripts
• Regardless of whether student previously utilized VA benefits
Prior Training
• In most instances, schools must receive all transcripts:
– Within two (2) semesters or the equivalent
– Within 12 weeks if program is at least six (6) months long
– Prior to the start of the course if less than six (6) months long
• If applicable, schools must grant credit and reduce training time
proportionately
– Notify student and retain in student’s records
Prior Training
Independent Study/ Online Training-Prohibited
• Courses/programs taught in whole or in part in an independent study,
online, distance learning, hybrid or blended format are not approved at
any NCD school
–This also means that study labs where the students come in when they
want to during certain hours, cannot be approved
• All courses approved at NCD schools must strictly be offered in a
traditional classroom, laboratory or shop setting (i.e., students physically
in the same room at the same pre-scheduled time with a live instructor)
Prior Training
Approved Course/Program Length-Certification
• Must not certify more hours than the SAA has approved
–VA will only pay for student to be in the seat in the classroom for the
number of clock hours approved
• Keep track of total hours completed
Prior Training
Approved Course/Program Length-Certification
• Course/Program name certified must match what is listed in the WEAMS
report (aka VA Form 22-1998)
–Incorrect wording may impact whether payment is made
–If WEAMS is correct, then update VA-ONCE
–If WEAMS is incorrect, then submit a request to have it updated with
correct information
Certifying Tuition
Are you reporting the correct dollar amounts for Chapter 33?
• Certify the net tuition
• Certify only allowable fees
– Validity of Fees – Before a fee can be certified to VA it
must meet all of the requirements stated below:
–Be listed in the school’s approved catalog as a fee;
–Be listed on the student invoice/payment ledger as a fee;
–Be listed in the enrollment agreement/contract between the student and
school as a fee; and
–Be “mandatory” or otherwise “required” of all similarly circumstanced
students…
Certifying Tuition
Are you reporting the correct dollar amounts for Chapter 33?
• Validity of Fees (cont.)
–A school charges a fee for a kit, but allows students to purchase items in
that kit on the open market – this fee is not mandatory and cannot be
certified to VA.
–A school charges a kit fee and will not allow any student, under any
circumstances, to have fee waived if they purchase items on the open
market. School may allow credit to students who purchased the same kit
at another branch of the same school and have now transferred to a
second branch of that school.
Certifying Tuition
Pro Rata Refund Policy - Nonaccredited courses/programs
• The refund policy must be pro rata or more advantageous to VA students
than pro rata
–Must be pro rata to the very end
• Example: Student drops out after completing 75% of the course; the
school must refund 25% of the tuition to the student
• An accredited school could possibly have a non-accredited program to
which the pro rata refund rule would apply
Certifying Tuition
Chapter 33
• If a school charges all tuition up front
–Tuition certified to VA should be prorated between enrollment periods
–Proration at nonaccredited schools is interwoven with the pro rata
refund policy
–Important because of the way entitlement is charged
– If one enrollment period lists all tuition and fees for an entire program,
entitlement charged based on tuition and fees certified
– If subsequent enrollment periods are certified with $0.00 in tuition
and fees, entitlement will be charged based on the rate of pursuit
(results in VA student’s entitlement getting hit twice)
Certifying Tuition
Chapter 33
• If a school does not charge all tuition up front
–Tuition certified to VA should be submitted in the same increments as
which it is billed to the students
–Important because if the school bills in increments, certifies all charges
to VA up front, then the student drops, VA will charge the student with a
large debt for tuition and fees that have not actually yet been charged
Certifying Tuition
Entitlement
• All Stand-alone NCD Schools (not part of a college or university)
–VA charges entitlement differently than how they charge it for IHLs
– Essentially, VA charges 12 months of entitlement for each $20,235.02
paid for tuition and fees, prorated up to that yearly maximum. This
comes out to one day of entitlement charged for each $56.21 paid
($20,235.02 divided by 360 days – VA computers calculate every
month as 30 days in length).
Certifying Tuition
Entitlement
• Example 1
–First student enrolled Jan 15th through May 14th for 30 clock hours per
week with a tuition charge of $3,000. Although this student is enrolled at
100% ROP for about 4 months, VA will charge the student only about 1 ½
months of entitlement. This is based upon dividing the $3,000 total
charges by the daily rate of $56.21 (as calculated above). The result of
53.37 days is roughly 1 ½ months.
Certifying Tuition
Entitlement
• Example 2
–Second student enrolled Jan 15th through May 14th for 30 clock hours
per week with a tuition charge of $20,500. Although this student is
enrolled for only 4 months at a ROP of 100%, VA will charge the student 12
months of entitlement because VA paid the maximum $20,235.02 for the
academic year.
Certifying Tuition
Entitlement
• Multiple Periods of Enrollment
–Same first student enrolled for the following periods and charges:
– Aug 15th – Dec 14th 30 clock hours $1,000 total charges
– Jan 15th – May 14th 30 clock hours $1,000 total charges
– Jun 1st – Oct 14th 30 clock hours $1,000 total charges
–Although this student has been enrolled for a total of 12 months of
enrollment at the 100% ROP, VA will charge only 1 ½ months of
entitlement based on the total charges of $1,000 each enrollment period
($1,000 divided by $56.21 = 17.79 days of entitlement each enrollment
period for a total of 53.37 days or roughly 1 ½ months)
Certifying Tuition
Entitlement
• Multiple Periods of Enrollment
–Same first student enrolled the same way; however, all tuition and fees
are charged up front for the first enrollment period. If you don’t prorate,
more entitlement is charged:
– Aug 15th – Dec 14th 30 clock hours $3,000
– Jan 15th – May 14th 30 clock hours No charges
– Jun 15th – Oct 14th 30 clock hours No charges
• –In this case, VA would charge about 1 ½ months of entitlement for the
first enrollment period based upon the total charges of $3,000. Since
there are no charges for the other two (2) enrollment periods VA then
charges entitlement as they would for the other GI Bill programs (i.e., one
(1) month for each month enrolled at 100% ROP. This means VA would
charge about four (4) months entitlement each for the last two terms for a
total of eight (8) months. Combined with the two (2) months VA charged
for the first term, that means this student would be charged a total of ten
months
Certifying Tuition
Entitlement
• Same second student enrolled for the following periods and charges:
– Aug 15th – Dec 14th 30 clock hours $6,833.33 total
– Jan 15th – May 14th 30 clock hours $6,833.33 total
– Jun 15th – Oct 14th 30 clock hours $6,833.33 total
• Based again upon a daily rate of $56.21, VA would charge about 122 days
(roughly 4.1 months) for each of the first two (2) enrollment periods, then
the remaining 3.9 months for the last enrollment period for a total of 12
months of entitlement used.
Certifying Tuition
Entitlement
• Same second student enrolled for the same periods; however, all tuition
and fees are charged up-front for the first term/period:
–Aug 15th – Dec 14th 30 clock hours $20,500 total
–Jan 15th – May 14th 30 clock hours No charges
–Jun 15th – Oct 14th 30 clock hours No charges
• As you may have surmised by now, VA would have charged 12 months of
entitlement for the first term since they would have paid a year’s worth of
total charges. Then, with no charges for the last two (2) terms, VA would
charge about four (4) months entitlement for each of those terms. That
means the student would have used up a total of about 20 months of
entitlement even though enrolled for a total of only 12 months.
QUESTIONS?
VETERAN
COMPLIANCE SURVEYS
Overview
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Compliance Survey Objectives
Preparation
On – Site Review
Common Findings
Post Survey
COMPLIANCE SURVEY OBJECTIVES
• Routine reviews of selected students’ records to verify that payments of
GI Bill benefits were properly made to your VA students
• Assist School Officials in better understanding their responsibilities and
the procedural requirements of VA
• Conducted in order to ensure schools and training establishments, along
with their approved courses and programs, are in compliance
– To determine, on the basis of facts disclosed from document reviews
& personal visits, whether there are deviations from the
responsibilities & requirements by eligible individuals, schools or
training establishments
• Scheduled to previously approved facilities to monitor and assure
continued acceptability of approval
– To assure that proper action is promptly taken through appropriate
channels for the correction of existing discrepancies
COMPLIANCE SURVEY - PREPARATION
• VA will establish and maintain a schedule of compliance surveys and
inform SAA of which schools it has been assigned to visit
– Schedules will be prepared before the beginning of each fiscal year
– Certain number of schools assigned to the SAA; VA retains the
balance
• Visits conducted at approved schools and facilities with veterans
enrolled during the previous federal fiscal year (October - September)
• Several schools visited per week to reduce costs
– Same geographical location
• Majority of compliance surveys we conduct involve travel meaning
a number of institutions may be scheduled for a given week
(Monday – Friday). We strive to not schedule at institution peak
workload periods however this may not occur based on travel
plans.
• May be more than one person conducting visit if at a large school
COMPLIANCE SURVEY - PREPARATION
How are student files selected?
• Randomly chosen by the SAA or VA employee who will be conducting
the visit (to identify any pattern of error)
– (no longer chosen by the school or training facility as they were with SAA supervisory
visits)
• VA reports (RCS 20-0259-60 & COIN 289); TIMS or VA-Once used to
obtain random sample
• RCS – Records Control Schedule
• COIN – Computer Output Identification Number
• The institutional records copied will be retained by VA and SAA to include
in our compliance survey records – PII data is safeguarded and necessary
as internal quality reviews by VA are conducted to ensure all aspects of
the compliance survey were accurately reviewed and completed.
COMPLIANCE SURVEY - PREPARATION
How many files must be reviewed?
• Depending upon the size of your VA student population
– Sample Size is based on total VA Student awarded enrollment total - No fewer than 10
(unless you have less than 10 current enrolled VA students) ~~~Expanded ~ If review of
the initial sample reveals overpayment errors in 30 percent or more of the cases, or
discrepancies of any type in 50 percent or more of the cases reviewed, the survey will be
expanded using a sample equal to the size of the initial sample. The survey specialist
may exercise his/her discretion to expand any survey based on professional judgment
and not to expand surveys in cases of repeated minor errors.
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VA Student Population
0 to 99
100 to 199
200 to 299
300 to 399
400 to 499
500 to 599
600 to 699
700 or more
Records to Review
10
15
20
25
30
35
40
45
COMPLIANCE SURVEY - PREPARATION
How will we notify you?
• Email, phone call or fax to inform you of our visit
– Advance notice provided
• VA and/or SAA will call the primary SCO to schedule a date(s) and
time for conducting the survey in addition to providing institution
with names of students in the sample size to be reviewed.
• A letter or email will be furnished the SCO of the student names
and the institutional records to copy for our review.
• Survey Confirmation Letter emailed or mailed
– Confirm date and time of appointment
– Provide school official with names of student files required and
items/types of records to be reviewed
– Schedule face-to-face interviews with students, if applicable
COMPLIANCE SURVEY - PREPARATION
What Records & Accounts are needed for the survey?
• Institutional Records Needed for Student Records:
– Copy of unofficial transcript
– Copy of Degree Audit Report (DAR)
– Copy of Student Account Ledger
– Copy of Student term registration schedules
• Identifying start date, end date
• Identifying modality of instruction
• Captures non-standard term dates by subjects
• Verification of prior credit evaluations
• Progress Standards (GPA)
• Obtaining LDA or last activity to confirm withdraw of subjects for
student records
COMPLIANCE SURVEY – ON-SITE REVIEW
What happens when we arrive?
• Entrance Interview
– Typically with certifying official
– Others included as school (Student Accounts, Financial
Aid, Registrar, etc.)
• as the facility, SAA, or Compliance Survey Specialist sees fit
COMPLIANCE SURVEY – ON-SITE REVIEW
Records and Accounts
• Are your records/files available?
– Records and accounts of VA beneficiaries and other students must be
provided for examination
GUIDANCE
– Review checklist provided to you by SAA or VA (whoever is
conducting the visit)
• Ensure all items are addressed
• Ask questions if unsure
– Must have records available at time of visit
COMPLIANCE SURVEY – ON-SITE REVIEW
Commencement of Courses
• Did the student begin when certified?
– Date certified must agree with start date
GUIDANCE
– IHL: First day of classes for the semester or quarter
– NCD: First day the student is actually physically in class
– Flight: Date of first flight or ground school lesson
– OJT/Apprenticeship:
• For OJT - first day on the job
• For registered apprenticeships - the date of indenture or the first
day on the job, whichever is later
COMPLIANCE SURVEY – ON-SITE REVIEW
Program Certified
• Is the correct program certified?
– Program certified must be the same as what the VA beneficiary is
enrolled in and pursuing
GUIDANCE
– Review transcript, registrar records, enrollment agreement
• If they do not agree, update records and/or certification
– Monitor WEAMS (22-1998) reports
– Ensure program certified is exactly as appears on WEAMS
COMPLIANCE SURVEY – ON-SITE REVIEW
Previous Education & Training
• Is There Prior Credit?
– Record and evaluation of all previous education and training must be
maintained in files
• Must review and evaluate acceptance of prior credit after no
more than two semesters (or equivalent). If additional
information is received at a later date, the evaluation can be
revised.
• The school must maintain a written record that clearly indicates
that appropriate previous education and training has been
evaluated and granted, with training time shortened and tuition
reduced proportionately, and the VA and the veteran so notified
(mandatory – not a suggestion!)
COMPLIANCE SURVEY – ON-SITE REVIEW
Previous Education & Training (cont.)
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GUIDANCE
Make available for review all transcripts from previous institutions
Review VA Forms 22-1990, 22-5490, 22-1995, 22-5495 for indication of
any previous education & training
Take note of previous institutions in VA Once
Review school application or other documentation
Record prior credit submitted and total granted
COMPLIANCE SURVEY – ON-SITE REVIEW
Records
• Are your records accurate, current and complete?
– Records of enrollment, correspondence lessons serviced, flight
training hours or OJT/APP hours must be accurate, current and
complete
GUIDANCE
– IHL: Registration documents, class schedules, transcripts, drop slips,
withdrawal documentation, tuition payment ledgers, etc.
– NCD: Attendance records, registration documents, class schedules,
transcripts, drop slips, tuition payment ledger, etc.
– Flight: Follow the Student Checklist that is supposed to be
maintained in your files
– OJT/APP: Records of hours worked and wages paid to include pay
and leave records, and records of training given
COMPLIANCE SURVEY – ON-SITE REVIEW
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Records and Accounts
Commencement of Courses
Program Certified
Previous Education & Training
Records
Accurate & Prompt Certifications
Terminated or Interrupted Training
Progress and Grades
Satisfactory Progress
Charges
Percentage of Enrollment
Timely Changes
Information furnished to students
COMPLIANCE SURVEY – ON-SITE REVIEW
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Enrollment Limitations
Refund Policy
Repeat Discrepancies
Advertising
Power of Attorney
Independent Study
Practical Training
Cooperative Courses
Tutorial Assistance
Conflicting Interests Certification
Contractual Arrangements
Advance Pay
Nonduplication of Benefits
Yellow Ribbon Program
COMPLIANCE SURVEY – COMMON FINDINGS
• Common errors involve:
– Not reporting changes or terminations
– Not reporting net charges correctly
– Not reporting unearned F grades
– Not reporting distance learning correctly
– Late reporting of enrollment changes to VA
– Failure to monitor prior credit evaluations
– Certifying credits that do not apply to program requirements
– Certifying remedial subjects when offered on line
– Incorrectly reporting LDA – last day of attendance on withdrawing
– Certifying incorrect program name or type of training
– Not reporting unsatisfactory progress or probation
– Lack of institutional records to support certifications to VA
– Certifying programs not approved by VA or SAA
COMPLIANCE SURVEY – POST SURVEY
What happens when the survey is complete?
• Before We Leave
– Exit interview conducted
• With Certifying Official and others as school or auditor sees fit
• After We Leave
– Compliance Survey site visit report
– Referrals submitted to Buffalo Regional Processing Office
• Occurs only if findings affect payment
COMPLIANCE SURVEY – POST SURVEY
What happens when the survey is complete?
• After We Leave (cont.)
– Letter to school (sent to highest administrator with copy to certifying
official)
• Identify student records reviewed
• Detail any discrepancies/findings
• Specify corrective actions (if any) required by the school or facility
• Schools and facilities are not the only ones audited…
– A random sample of compliance survey files are reviewed each
quarter for quality assurance
QUESTIONS?