Flight Training
VETERANS BENEFITS ADMINISTRATION
AVECO July 2015
Flight Training
Overview
• Aviation programs at Institutions of Higher Learning (IHL)
• Deemed Approved versus Non-Deemed Approved degrees
• Contracted versus “In-House” flight training
• FAA Approval (Part 141 and Part 61)
• Training Course Outline
• Certifications, billing, and documentation
• 85/15 Regulations (CFR 21.4201)
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Aviation Programs at IHL’s
• Changes effective August 1, 2011 (PL111-37)
• VA Central Office Education Service directive to conduct Compliance Surveys
at Public IHL’s with aviation programs in April and May 2015
• Flight training is not approved for non-college degree programs (certificates
and diplomas)
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Deemed Approved versus Non-Deemed Approved
“Deemed Approved”: Public and private non-profit accredited institutions
Non “Deemed Approved”: Proprietary Profit institutions
• SAA approval is required for degree programs with a component of
flight/aviation:
If a school does not have “deemed approved” programs
If a school with “deemed approved” programs utilizes services from a
vocational flight school, i.e., “under contract”
• SAA Approval is not required:
If a school with “deemed approved” programs is approved by the FAA under
Part 141 or Part 61 and utilizes its own flight line, instructors, Training
Course Outline (TCO)
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Contracted versus “In-House” flight training
IHL’s with Degree Programs Under Contract
•
If a school does not have its own flight line and must contract with a Part 141 flight
school to provide flight training, then the flight school must be approved as a
separate facility by the SAA with jurisdiction over flight schools
• Documents needed for approval:
- Copy of contract
- Copy of flight school’s Air Agency Certificate
- Copy TCO for each course offered as part of the degree
- Other documents as required by SAA
• If at any time an IHL changes its contract from one contractor to another, the IHL must
notify the SAA immediately for the updated approval of its flight degree program
• Part 61 training cannot be contracted
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FAA Approval
Air Agency Certificate
• Issued by the Flight Standards District Office (FSDO)
• Includes a Letter of Authorization
• Is valid for two (2) years
• Specifies all the courses that the school is authorized to offer under FAR Part
141 (TCO)
• Only courses listed on the Air Agency Certificate and Letter of Authorization
may be considered for approval
• If the flight school wishes to obtain approval of a course not currently listed in
these documents, the FSDO must approve and revise the Air Agency
Certificate
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Training Course Outline
Training Course Outline (TCO)
• Description of rating
• Specific aircraft and Flight Training Devices (FTDs – mockups of airplane
cockpits with varying degrees of complexity) that may be used for the course
by make and model
• Restrictions on use of FTD (limited hours and for which specific flight lessons
may be used)
• Airports that may be used in training
• Name of Chief and Assistant Chief Flight Instructor
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Training Course Outline Continued
• Each Part 141 course approved by the FSDO
• It is approved with and accompanies the TCO
• It is a lesson-by-lesson outline of how the course is to be pursued
• The Ground School section specifies, lesson-by-lesson, the knowledge to be
learned and how long (in hours) each lesson should take
• Ground School is not to be confused with preflight briefings and post-flight
critiques (pre/post) which are always associated with actual flight lessons
* Pre/post is rarely ever enumerated in Part 141 syllabi and minimum hours are
usually listed “as needed”
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Certifications, billing, and documentation
• SCO certifies course credits, tuition, and fees
• IHLS can only certify tuition and fees that are charged to the student by the
institution (flight fees cannot be paid to contracted school by the students)
• Flight fee limitations:
 Least expensive aircraft must be utilized except where required by the
course syllabus or the FAA
 Minimum hours required in course syllabus are the maximum allowed
for VA students
 All training must be completed by end of term, with exceptions defined
and listed (If Incompletes “I”s are assigned, school Incomplete policy
must be followed)
 FAA check ride costs cannot be included in the certification of fees
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Certifications, billing, and documentation
Certification of aviation courses
• Enter term dates (these should be in most cases the same as for all other
students)
• Enter credit hours just the same as non-flight degree students
• Enter total charges up to TCO requirements
• Public schools enter only the in-state rate
• Private schools enter the actual total charges (there should be no state
differential)
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Certifications, billing, and documentation
Documentation- what the SCO should have on file
1. Training Course Outline (TCO)
• For every flight lab, are there pre-requisites?
• What courses are required for the degree?
2. Valid FAA Air Agency Certificate
3. Account statement
• Actual flight charges for minimum requirements (based on TCO)
• Are there discounts?
4. Flight Log
• Showing actual charges and flight time/instruction for each student
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85/15
•
Determine if the degree program has more than one “track”
•
Tracks, as referenced here, should not be confused with majors, minors, and
concentrations, although the ratio is calculated separately for those as well
•
Calculate ratio separately for each “track”, major, or concentration
•
VA (85%) portion of ratio includes VA students and any students receiving a grant,
waiver, discount, scholarship, etc., directly from the school and which has rules that
have the effect of excluding VA students (regardless of whether or not they are
receiving GI Bill® benefits) from receiving that school assistance
•
Non-VA (15%) portion of ratio includes all other students registered for that term
•
You must calculate the ratio before certifying a VA student in the program
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Findings of Compliance Surveys 2015
• Violations of 85/15
• IHL’s not calculating and tracking 85/15 by term and major/track
• Charging over TCO minimum requirements
• Lack of communication between SCO and Aviation Department or Contracted
Flight School
• No supporting documentation maintained by SCO when certifying charges
• Contracted Flight training not approved
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Summary
• SCOs should be in contact with ELR & SAA for technical assistance on
certifying flight training
• SCOs must have access to flight records
• Schools should review the communication and work flow process between
SCOs and Aviation program
• Minimum requirements must be published by schools
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Questions?
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