My Journey - Seeking Residency Approval to use GI Bill Benefits at Facilities that are NOT APPROVED

[BC_89]

***EDIT: I've updated information regarding Institution of Higher Learning (IHL) vs On-the-Job Training (OJT). Please consider residencies and fellowships as IHL when looking through this information.



As some may know, I had the privilege of using my Chapter 31 VR&E Benefits for my pharmacy education and documented my progress from 2018 to 2022 (link can be found here). Thanks to this benefit (and a change in law from Congress), my post 9/11 GI Bill benefits have not been touched with a 100% eligibility for future use.

I have received recent messages concerning the utilization of GI Bill benefits for on the job training (residency +/- fellowships) at facilities that have not officially been approved for such training. This is what this thread will be about: Seeking residency/fellowship approval to use GI Bill benefits at facilities that are not listed.



HOW DO I KNOW IF THE FACILITY QUALIFIES:

I'll first review how to find out if your training site has been approved (if you have questions concerning eligibility of qualifying to use GI Bill benefits, please visit the e-benefits portal and sign up following the prompts (You'll need your DD-214 to register). To get started, in your google search, type in WEAMS Institute Search and look at the "search filters" located at the top of the page and select Institution of Higher Learning (IHL) under the Program Type filter. At this point, you may select the Institutions name or state. I recommend choosing the state as the lettering can be case sensitive bringing up no results (See attachment below).

The following page will bring you a list of certified Institution programs located within your selected state. If it is not listed, chances are you do not have an approval to use such benefits. A second way to look is to go to GI Bill Comparison Tool and look for the program by name and location. The issue with this feature is two-fold:

1) It will list the facility (medical or academic research) and say approved but may not give details of your specific residency program.
2) It will list the facility but mention nothing about ANY certified programs.

If any of these issues arise, you should be able to write down the facility code (if the facility is listed anywhere in the database) associated with the medical center and keep it on file. You can use this facility code (if able) and bring it up to your residency program director or liaison of the facility (if there is one or not). If this doesn't work, you can always contact a GI Bill representative at (888) - 442 - 4551. However, they'll just use the WEAMS portal to tell you the exact information you would've researched...



HOW TO GET APPROVAL FOR MY RESIDENCY/FELLOWSHIP TRAINING:

After doing your due diligence, here is what you need to do. Each state has their very own VA Education Approving Agency (this is different than the general GI Bill Education contact number). I would do a google search with the name of your state followed by the phrase "State Approving Agency for Veterans Education." You may also try "State Approving Agency (SAA)" followed by your state and "Department of Veterans and Military Affairs." You'll then be directed to the site which should give you two options (follow this link to see an example):

1) State Approving Agencies phone number
2) SAA email --> Do this

Once you click on the SAA email link, it'll take you to a page wanting your information as well as a reason of your inquiry. Under inquiry, select "A veteran or eligible individual with questions about GI Bill education benefits." See attachment below:

The next page will ask for the facility as well as a brief description of what you wish to accomplish (ie, BC_89 seeking to specialize in ambulatory care residency at a 12-month training program at facility ABC (facility code # 12345). Once you submit, you're done. You have officially sent a request to receive GI Bill benefits for your chosen residency +/- fellowship program.



HOW LONG DOES IT TAKE TO GET A RESPONSE:

This is ultimately the purpose of this thread. I will keep tabs on how long each step of this process took. as of May 5th 2023, I have officially submitted my claim and facility code # to request residency training GI Bill coverage starting on July 3rd 2023 (when I start my PGY-2 program). I have already done due diligence in seeing what current liaison(s) and certifying officials exist within my facility, even though they're in charge of different departments. After 3 weeks of making phone calls, working with my HR, working with my residency program director (RPD), and every crook and corner at the medical center I'll be attending, I came up short with 16 phone numbers and emails, with no forward progression. I started this process in March, and am only now in May still trying to see what needs to be done. As you all may know, this is a lot of hurry up and wait (yes, good memories of our military former life).



WHAT ELSE DO I NEED TO BE PREPARED:

To meet approval, I would come prepared for answers based on the VA Form 22-1999 (Side A - page 3). This form contains information from the Eastern and Western Regional VA offices and what states fall into each category. More importantly, this form has outlines required for a certifying official to fill out. I will see how a certifying official will be chosen (be prepared to offer names), but also note how your IHL will be recorded on the form (things to consider is training time with start and end dates).

At this point, nothing more can be done except waiting. Once again, this is why I am making this thread: to see what bumps in the road I meet, to see how a certifying official is selected, and to see if I get approved or not. Most importantly, how long will this process take.

If others have experience in being the person who officially plays a part in certifying a program, or is in the process of wondering what to do, please also publish your experiences. At this point - we will see how long or short this journey goes...


May 5th 2023

Day one.

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[xffan624]

Medical residencies are not listed under OJT, but under Institute of Higher Learning as my entire institution was. I'm not sure any medical residencies are under OJT. Are pharmacy residencies listed under OJT?

 

[BC_89]

Well, you're definitely right - I received an email today stating:

"In approving educational and training institutions, there are differences between apprenticeships, on-the-job training, and medical/healthcare "residency". Please tell us more about your situation so we can better assist."

I was under the impression that if the residency or fellowship was not listed with a liaison and you need to re-direct yourself to the WEAMS portal, you would need to primarily look deeper under OJT. I'll need to input an edit in my original thread. It looks like it does have to be listed under Institute of Higher Learning and if one wants approval for any healthcare residency, it still needs to go through that channel.

I'll consider this my May 8th 2023 update with a swing-and-a-miss

 

[BC_89]

May 10th 2023:

tldr;
1) No current provisions to use GI Bill Benefit
2) Program not considered an IHL or OJT
3) Waiting to here about a "final option" within the next coming days.



I have a strong feeling this is going to be catered to any residency outside the realm of medical/dental residencies (In particular, pharmacy). I have received an update that my residency program is not considered an IHL or an OJT based on 38 CFR 21.4265 with the following summarization I received in an email (for a small background, the medical center I plan on doing my PGY-2 is indeed a VA Medical Center):

"VA hospitals are typically not Institutions of Higher Learning (IHL) alone. Healthcare-related residencies are typically through an IHL that has already been approved for practical training." In a small summation, the following is an outline of what practical training is approved as IHL or OJT:

§ 21.4265 Practical training approved as institutional training or on-job training.
(a) Medical-dental internships and residencies.
(b) Nursing courses.
(c) Medical and dental specialty courses.
(d) Medical and dental assistants courses for the Department of Veterans Affairs.
(e) Professional training courses.
(f) Other practical training courses.
(g) Nonaccredited courses.

In continuing my communication with the SSA, questions were brought up concerning any Memorandum of Understanding (MOU) I may have between my pharmacy program and the VA facility that I plan on attending. I outlined no connection or agreement between my alumni status of my pharmacy program vs my continuing residency training status at the soon-to-be facility (this includes nearby schools that have an affiliation with the PGY-2 program).

With this communication, I did outline one of the bullets under the defined CFR code(s):

(e) Professional training courses.
(1) Any non-medically related professional internship program, such as a clinical pastoral course, will be recognized as an institutional course when it is accredited as an institutional course by a nationally recognized accrediting agency,
AND
(2) The approved facility for such a course must be the institution or other facility where the training is given.

So, with a bit of a stretch, I did mention the national accrediting organization (American Society of Health-System Pharmacists; ASHP) is the accrediting agency that recognizes and gives accreditation to approved PGY pharmacy residencies throughout the country. I also provided the details of my program receiving such an accreditation within the past recent years.

In the end, the SSA did explain that another option does exist - but they'll need to get back to me with that option since they cannot find provisions in the law (or rather, insufficient provisions) that include residencies in pharmacology. Of course, explaining that I will receive a scope of practice with prescriptive authority upon sitting for a Board Certification after the residency was something else to be put in consideration.

At this point, I am awaiting further instruction and guidance.

 

[BC_89]

May 11th 2023:

Took me a couple of days to post this, but this is where I am at with the SAA - they're unlikely my pharmacy residency can be approved under 38 CFR 21.4264(e). I considered earning a teaching certificate from a nearby (well-established) pharmacy program and try to use that angle to utilize their school certifying official, but unfortunately, it is through the VA itself and not the school.

After further correspondence with the SAA's program specialist team, there is a small chance that I could consider my residency as a "non-accredited internship" under 38 CFR 21.4262 (which is the specifics under 38 CFR 21.4265(g) - Nonaccredited Courses). Should this work, I would need to designate a certifying official from my program (as I planned on doing) and have them submit the program application for approval as well as complete all of the training before being granted the certifying official title.

However, this is just speculation and is not a guarantee that I can even use my Chapter 33 Benefits by July 3rd 2023 (if at all). Once again, I am awaiting the decision to see if this is the end of the road, or if I can take this opportunity to the next phase.

Shall see.

 

[BC_89]

May 16th 2023:

After sending my correspondence to the SAA, I was met with an interesting email from the Federal & State Approvals Team. As a small background, the Federal & State Approvals team is the group that has the authority to approve programs offered by agencies of the federal government. Once they're contacted, the SAA is no longer involved (since the issue has now gone from local, to state, to federal).

After some information gathering to show evidence of my residency program fulfilling each objective under 38 CFR 21.4265(g) [Nonaccredited course], I received the aforementioned email asking me to have my residency program director reach out to them (va.gov account) in order to continue with the application and instruction on how to apply for OJT program approval.

Typically, this goes the other-way around, but I was further instructed that "beneficiaries cannot be involved in this process" and that further correspondence at this time will be between my coordinator and the federal team.

May 17th 2023:

I sent the necessary information to my residency program director (RPD), and was informed that she touched base with the federal team and will reach out to me (as I imagine she will) if she has additional questions. Once again, this is a hurry-up-and-wait moment. I interpret this as a possible achievement or just a formality to properly tell me "no...I don't qualify." Regardless, I do plan on putting a straight IHL provision request to our political representatives in having the inclusion of pharmacy residency up there with medical and dental programs...It seems like my current situation is simply an opportunistic loop-hole since I am pleading my benefits to be applied at a direct VA facility.

I'll see what the end result looks like -



For further guidance (more-so confusion), here is some more references on how programs are categorized and the role of certain agencies:

Education & Training Approvals for Accredited & Non-Accredited Institutions, as well as On-the-Job-Training (OJT) & Apprenticeships

The Role of State Approving Agencies in the Administration of GI Bill Benefits

 

[BC_89]

June 20th 2023:

Through a cc message correspondence with my RPD - I got approved!

For a brief background of what happens next, I am going to highlight what the final steps are in securing a new certifying official (CO). Per previous correspondence, the estimated time to get a response concerning approval for facilities (in my case, a VA Medical Center) is ~ 45 days (mine took 35 days). Here is the remaining email correspondence on the final steps (keep in mind, I had to go through the OJT route):

***I hope this is useful for users seeking site approval. I may remark on the timeline to getting my first housing allowance but I anticipate it'd be the same process timeline as when I was utilizing my VR&E benefits -

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

As part of the approval process, organizations must designate at least one Certifying Official (CO) using the attached VA Form 22-8794, “Designation of Certifying Official”. The CO is a representative of the training facility who is authorized to sign and submit documents to the Department of Veterans Affairs to certify a Veteran’s enrollment, change in status, and any other circumstances that affect the beneficiaries’ educational assistance benefits.



New COs must complete on-line training before they can be added as a CO for the facility. Attached are directions to assist with the training registration. The link to register for and complete the On-the Job/Apprenticeship training is below:



School Certifying Official (SCO) Training - Education and Training (va.gov)



New COs must submit a copy of their training certificate to the Federal Approvals staff. Please complete the attached 22-8974 and send the certifying official training certificate to [email protected].



Once you have been established as a CO, you will need to complete the enrollment and certification process in order for the trainees to receive their benefits. Below are basic certifying official responsibilities to which I have provided the link to the handbook as reference in assisting you with the responsibilities listed below: Employer’s Certification Handbook On-The-Job Training & Apprenticeship Programs (va.gov)



• Keep up to date on current VA certification rules and procedures.

• Provide general information regarding the certification process to VA trainees and ensure they submit an application to VA to use their VA education benefits (See the Assisting Employees with Their Application section).

• Maintain the trainee’s file and make those records available to VA, and any third-party vendor contracted by VA to conduct compliance surveys (See the Basic File Maintenance and Compliance Visits/Records sections).

• Evaluate and maintain a record of previous education and training of the trainees, grant appropriate credit, shorten the course/program proportionately and notify the trainee of the results of the evaluation. A copy of the trainee’s notification should be retained in the file (See the Basic File Maintenance and Compliance Visits/Prior Credit sections).

• Verify hours submitted to VA based on review of official payroll records or other official records that reflect hours worked (See the Basic File Maintenance and Compliance Visits/Wages and Training Hours Accurately Reported sections).

• Submit enrollment and training information to VA for each VA trainee (See more information in the Enrollment Manager (EM) and Certification of Training sections):

• Provide additional documentation to the State & Federal Approvals Team, as appropriate, including:

o Changes in Certifying Officials or their contact information

o Changes in requirements for approved training programs

o Changes in the length of approved training programs

o Name and/or address changes for the employer or sponsor

 

[BC_89]

September 19th 2023:

I finally got approved to utilize Post 9/11 Benefits (poetically, right after 9/11).

I should be expecting my first deposit by the beginning of October, with retroactive payments going back to July. Part of my huge delay process had to do with "someone in the VA system" having my Chapter 31 VR&E Benefits showing ACTIVE on my certifying officials (residency program directors) submission form. Absolutely no one for the past 3 months new who to talk with, but finally someone did something and like that - my facility went from not being approved back in March, to now officially being able to take on any and all new pharmacy residents.

I feel those going into residency after medical / dental school have a nice pathway and ability to activate a site that is not approved following the above steps. Anyway, it was interesting to give this a shot and see the fruits of my labor displayed officially on the WEAMS Institute portal online, with my current site having "1" current applicant using the benefits.

Hope this helps with those interested in how the process works (and how it doesn't work in some instances).

 

[workingfarmer]

Why would you use GI BILL for reosidemcies unless its simply to get BAH? Am I missing something here?

 

[MusicDOc124]

Why would you use GI BILL for reosidemcies unless its simply to get BAH? Am I missing something here?

Yep, BAH.

 

[workingfarmer]

Yep, BAH.

Nah man, I'd rather use my entitlements to get the FUll benefits of tuition paid etc if 1-1.5K a month is deciding my residency there's no point. Many reasons why medical residents join the national guard during residencies to supplement the low income and if rated for VA that's also

Residencies are essentially jobs but yes could be considered paid OJTs. but that BAH factor will burn through the entitlements

If it's only for BAH I encourage OP to save the entitlements because if you have at least 1 day left on GI Bill they will reimburse you your Test scores in including Board Certs, NAPLEX USMLE etc and also Vet Tech eligibility to go into the highly demanding tech field in addition to potentially getting your desired degree paid for AFTER you get a job if your institution does not fund that MBA/MHA that you need to move in the workplace etc esp in the VA they dont pay for higher education for employees like tuition assistance in active duty or other fortune 500 companies etc

not to mention if you have gotten out after Jan 2013 it's considered forever gil bill so no requirement to use it right away also if not it's at least 15 years post discharge

 

[MusicDOc124]

Nah man, I'd rather use my entitlements to get the FUll benefits of tuition paid etc if 1-1.5K a month is deciding my residency there's no point. Many reasons why medical residents join the national guard during residencies to supplement the low income and if rated for VA that's also

Residencies are essentially jobs but yes could be considered paid OJTs. but that BAH factor will burn through the entitlements

If it's only for BAH I encourage OP to save the entitlements because if you have at least 1 day left on GI Bill they will reimburse you your Test scores in including Board Certs, NAPLEX USMLE etc and also Vet Tech eligibility to go into the highly demanding tech field in addition to potentially getting your desired degree paid for AFTER you get a job if your institution does not fund that MBA/MHA that you need to move in the workplace etc esp in the VA they dont pay for higher education for employees like tuition assistance in active duty or other fortune 500 companies etc

A few things to note:
- OP already used VRE as numerous of us have for med school, pharmacy, dental, etc, and not everyone may want to pursue another degree
- Benefits expire if you got out before 2013. I think most who are at this stage currently/recently fall into the category of having a delimiting date
- Reimbursement for an exam takes away 1 whole month entitlement, and most exams cost less than 1 month of BAH
- The money being received now can aid with living better and saving/investing sooner and have a greater return rather than waiting to get the benefit in some cases; meaning the amount you receive extra in residency may be as high as a 30% bump. Waiting to receive it in some fashion as an attending would be like about a 3-8% bump. This makes a huge difference for a resident and minimal for an attending, pharmacist, dentist, etc by comparison

Basically, if someone wants another degree and works somewhere it wont be paid for as you point out, it could benefit if the tuition is high and/or it's in person at greater than half time (esp. if in-person). Otherwise there are times when receiving the BAH in training is a much better deal even when no tuition needs to be paid.

Just a few things to keep in mind.

 

[workingfarmer]

A few things to note:
- OP already used VRE as numerous of us have for med school, pharmacy, dental, etc, and not everyone may want to pursue another degree
- Benefits expire if you got out before 2013. I think most who are at this stage currently/recently fall into the category of having a delimiting date
- Reimbursement for an exam takes away 1 whole month entitlement, and most exams cost less than 1 month of BAH
- The money being received now can aid with living better and saving/investing sooner and have a greater return rather than waiting to get the benefit in some cases; meaning the amount you receive extra in residency may be as high as a 30% bump. Waiting to receive it in some fashion as an attending would be like about a 3-8% bump. This makes a huge difference for a resident and minimal for an attending, pharmacist, dentist, etc by comparison

Basically, if someone wants another degree and works somewhere it wont be paid for as you point out, it could benefit if the tuition is high and/or it's in person at greater than half time (esp. if in-person). Otherwise there are times when receiving the BAH in training is a much better deal even when no tuition needs to be paid.

Just a few things to keep in mind.

I agree if OP got out before Jan 2013 go ahead and get that BAH but if not should consider saving it; just to supplement/support your thought processes/points OP can also get the higher degree later through loans if OP never got initial loan forgiveness being if being 100% P&T which can refunded and invested strategically in our beloved stock market

I recently did use my GI bill ch.33 while working full-time but also to go to a tuition and yellow ribbon school worth over 80K cost of attendance all paid for by uncle sam but I told the VA enrollment folks to leave me 1 day of my GI Bill entitlement which I highly recommend OP to consider for those test fees and Vet Tech and you never know what other Pilot programs come out in the near future with possible same stipulations

 

[BC_89]

Nah man, I'd rather use my entitlements to get the FUll benefits of tuition paid etc if 1-1.5K a month is deciding my residency there's no point.

You're not incorrect, however I think we are on different bandwidths in terms of when/how the benefits should be used. Since I joined the service after my bachelors (100% paid), I ended up using Chapter 31 (VR&E) benefits upon my medical retirement while getting my doctor of pharmacy. Since VR&E benefits do not take away benefits from the GI Bill, I automatically have 100% of my GI Bill untouched while obtaining a bachelors + professional degree.

Residencies are essentially jobs but yes could be considered paid OJTs. but that BAH factor will burn through the entitlements

The only benefit I am eligible to receive at this point is the BAH (since I already exhausted all of my other benefits). In my case, that's a win-win.

If it's only for BAH I encourage OP to save the entitlements because if you have at least 1 day left on GI Bill they will reimburse you your Test scores in including Board Certs, NAPLEX USMLE etc and also Vet Tech eligibility to go into the highly demanding tech field in addition to potentially getting your desired degree paid for AFTER you get a job.

Again, valid points for veterans who are seeking a pivot in there career, or for those veterans embarking on their journey as being a student. In terms of paying for board certifications - in my case the cost to do so is the equivalent of one month of my current BAH ($2,000), which would not do me any good in terms of board cert coverage. Also, I am not seeking a career pivot once my second year of residency comes to an end.

not to mention if you have gotten out after Jan 2013 it's considered forever gil bill so no requirement to use it right away also if not it's at least 15 years post discharge

Correct. I also am considered a Forever GI Bill recipient.

I agree if OP got out before Jan 2013 go ahead and get that BAH but if not should consider saving it; just to supplement/support your thought processes/points OP can also get the higher degree later through loans if OP never got initial loan forgiveness being if being 100% P&T which can refunded and invested strategically in our beloved stock market.

Got out after 2013 and already used other benefits to cover school at this point. Unless congress plans on allowing me to reciprocate my benefits to my kids well after leaving the service, it is best in my interest to capitalize on the $2,000 monthly BAH for the duration of my residency. Matter of fact, when it is all said and done, I'll still have 24 months worth of benefits untouched.

To summarize, all of what @MusicDOc124 has mentioned is what is being applied to this thread (that is, a few of us members have already exhausted VR&E and other strategies to pay for schooling in the hopes to save our GI Bill for the housing allowance during residency, especially at facilities that may not be currently certified).

For all other veterans, I would agree that the common pathway would be to use GI Bill to the full extent while being a fulltime student (book stipend, tuition, BAH).

 

[esob]

As an update, I was initially denied my housing stipend during residency, but after requesting a higher-level review, the regional office reversed course and approved my residency. Shoutout to @MusicDOc124 for doing all the leg work gathering evidence that I used to bolster my appeal.