The National Association of State Approving Agencies for

The National Association of State Approving Agencies for Veterans Education and Training October 2018 National Training Institute: Approvals An overview of the State Approving Agency Approval Process for IHLs and NCDs

The National Association of State Approving Agencies for Veterans Education and Training What will be covered in this presentation (Session 1) • Public laws and Regulations – Our Purpose • References • NASAA Documents and Resources • IHL/NCD Approval Criteria • Definitions • Accreditation • Period of Operation • IHLs with Deemed Approved Programs • Other Accredited Programs • Nonaccredited Programs

The National Association of State Approving Agencies for Veterans Education and Training Public Laws and Regulations – Our Purpose • Protect the Quality & Integrity of the GI Bill programs and in turn protect Veterans, military members, and family members by: • Ensuring that approved programs meet the requirements of Public laws. • Advocate for changes form the basis from which the US Code (USC) and the Code of Federal Regulations (CFR) are written • https: //www. gpo. gov/fdsys/ • http: //thomas. loc. gov

The National Association of State Approving Agencies for Veterans Education and Training References Public Laws • Public laws form the basis from which the US Code (USC) and the Code of Federal Regulations (CFR) are written • https: //www. gpo. gov/fdsys/ • http: //thomas. loc. gov

The National Association of State Approving Agencies for Veterans Education and Training References – U. S. Code • A compilation and codification of the general and permanent federal laws of the United States • Title 38: Veterans Benefits • Chapter 36: Administration of Educational Benefits http: //www. gpo. gov/fdsys/browse/collection. UScode. action? collec tion. Code=USCODE https: //www. law. cornell. edu/

The National Association of State Approving Agencies for Veterans Education and Training References – Code of Federal Regulations • The codification of the general and permanent rules and regulations (sometimes called administrative law) published in the Federal Register by the executive departments and agencies of the Federal Government of the United States • Spell out in further detail how the executive branch will interpret the law

The National Association of State Approving Agencies for Veterans Education and Training References – Code of Federal Regulations • Title 38: Pensions, Bonuses, and Veterans’ Relief • Part 21: Vocation Rehabilitation and Education • Subpart D: Administration of Educational Assistance Programs • http: //www. gpo. gov/fdsys/browse/collection. Cfr. action? collectio n. Code=CFR • http: //ecfr. gpoaccess. gov • http: //www. law. cornell. edu/cfr/text

The National Association of State Approving Agencies for Veterans Education and Training References – M 22 -4 • Internal procedure manual published by the VBA to provide guidance for all education procedures, including: • procedures for processing claims that are used by staff at the RPOs, • procedures for how ELRs and compliance specialists work with SAAs to accomplish and record the approval of education and training facilities • procedures for completing compliance requirements with the schools • VA is in the process of updating the M 22 http: //www. benefits. va. gov/WARMS/Site_Map. asp

The National Association of State Approving Agencies for Veterans Education and Training References - VA Circulars and Policy Advisories • USDVA issues VA Circulars and Policy Advisories • Provide direction and guidance for RPO, ELR and SAA staff on new laws before they are published as part of the regulations. • Create an efile to store Circulars and Policy Advisories as they are received by your SAA • Policy Advisories and Circulars are sometime rescinded and/or may be amended

The National Association of State Approving Agencies for Veterans Education and Training NASAA Documents and Resources • NASAA Web Site http: //www. nasaa-vetseducation. com/ • NASAA National Training Curriculum http: //www. nasaa-vetseducation. com/default. aspx (requires User Login and Password) • NASAA Committee pages on NASAA Website http: //www. nasaa-vetseducation. com/default. aspx (requires User Login and Password)

The National Association of State Approving Agencies for Veterans Education and Training NASAA Documents and Resources NASAA Regional Vice Presidents Email and Phone numbers available on NASAA website Other experienced NASAA members NASAA committee Chairs VA website: http: //www. benefits. va. gov/gibill/ SCO Handbook: http: //www. benefits. va. gov/GIBILL/docs/job_aids/SCO_Handbook. pdf • Your ELR • • •

The National Association of State Approving Agencies for Veterans Education and Training IHL/NCD Approval Criteria • United States Code (USC) • 38 USC 3672 (Accredited Degree Programs at Public and Not-for. Profit Proprietary Educational Institutions) • 38 USC 3675 (All Other Accredited Programs) • 38 USC 3676 (Nonaccredited Programs) • Code of Federal Regulations (CFR) • 38 CFR 21. 4253 (Accredited Programs) • 38 CFR 21. 4254 (Nonaccredited Programs)

The National Association of State Approving Agencies for Veterans Education and Training Definitions 38 CFR 21. 4200 (a)School, educational institution, institution. The terms school, educational institution and institution mean: (1) A vocational school or business school; (2) A junior college, teachers' college, normal school, professional school, university, or scientific or technical institution; (3) A public or private elementary school or secondary school; (4) A training establishment as defined in paragraph (c) of this section;

The National Association of State Approving Agencies for Veterans Education and Training Definitions 38 CFR 21. 4200 (a)School, educational institution, institution. The terms school, educational institution and institution mean (continued): (5) Any entity other than an institution of higher learning, that provides training for completion of a State-approved alternative teacher certification program; or (6) Any private entity that offers, either directly or indirectly under an agreement with another entity, a course or courses to fulfill requirements for the attainment of a license or certificate generally recognized as necessary to obtain, maintain, or advance in employment in a profession or vocation in a high technology occupation. (Authority: 38 U. S. C. 3452, 3501(a)(6), 3689(d))

The National Association of State Approving Agencies for Veterans Education and Training Definitions 38 CFR 21. 4200 (e)Standard college degree. The term means an associate or higher degree awarded by: (1) An institution of higher learning that is accredited as a collegiate institution by a recognized regional or national accrediting agency; or (2) An institution of higher learning that is a candidate for accreditation, as that term is used by the regional or the national accrediting agencies; or (3) An institution of higher learning upon completion of a course which is accredited by an agency recognized to accredit specialized degree-level programs. (Authority: 38 U. S. C. 3452)

The National Association of State Approving Agencies for Veterans Education and Training Definitions 38 CFR 21. 4200 (h)Institution of higher learning. This term means: (1) A college, university, or similar institution, including a technical or business school, offering postsecondary level academic instruction that leads to an associate or higher degree if the school is empowered by the appropriate State education authority under State law to grant an associate or higher degree. (2) When there is no State law to authorize the granting of a degree, a school which: (i) Is accredited for degree programs by a recognized accrediting agency, or (ii) Is a recognized candidate for accreditation as a degree-granting school by one of the national or regional accrediting associations and has been licensed or chartered by the appropriate State authority as a degree-granting institution.

The National Association of State Approving Agencies for Veterans Education and Training Definitions 38 CFR 21. 4200 (h)Institution of higher learning (continued) (3) A hospital offering medical-dental internships or residencies approved in accordance with § 21. 4265(a) without regard to whether the hospital grants a post-secondary degree. (4) An educational institution which: (i) Is not located in a State, (ii) Offers a course leading to a standard college degree or the equivalent, and (iii) Is recognized as an institution of higher learning by the secretary of education (or comparable official) of the country in which the educational institution is located.

The National Association of State Approving Agencies for Veterans Education and Training Definitions 38 CFR 21. 4200 (z)Proprietary educational institution. The term proprietary educational institution (including a proprietary profit or proprietary nonprofit educational institution) means an educational institution that: (1) Is not a public educational institution; (2) Is in a State; and (3) Is legally authorized to offer a program of education in the State where the educational institution is physically located. (Authority: 38 U. S. C. 3680 A(e))

The National Association of State Approving Agencies for Veterans Education and Training Accreditation 38 USC 3675(a)(2)(A) [Accreditation] (A) For the purposes of this chapter, the Secretary of Education shall publish a list of nationally recognized accrediting agencies and associations which that Secretary determines to be reliable authority as to the quality of training offered by an educational institution. Note: The school needs to provide proof of accreditation by a recognized accrediting agency. For purposes of SAA approval, a recognized accrediting agency is one that appears on the list published by the U. S. Secretary of Education at https: //ope. ed. gov/accreditation/ Or one the accrediting agencies listed on following slide.

The National Association of State Approving Agencies for Veterans Education and Training Accreditation § 21. 4265 Practical training approved as institutional training or on-job training. (a)Medical-dental internships and residencies. (1) Medical residencies (other than residencies in podiatric medicine), dental residencies, and osteopathic internships and residencies may be approved and recognized as institutional courses only when an appropriate accrediting agency accredits and approves them as leading to certification for a recognized professional objective.

The National Association of State Approving Agencies for Veterans Education and Training Accreditation § 21. 4265 Practical training approved as institutional training or on-job training. (a)Medical-dental internships and residencies (continued). (2) The appropriate accrediting agencies are: (i) The Accreditation Council for Graduate Medical Education, or where the Accreditation Council for Graduate Medical Education has delegated accrediting authority, the appropriate Residency Review Committee, (ii) The American Osteopathic Association, and (iii) The Commission on Dental Accreditation of the American Dental Association.

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (b)Some educational institutions must be in operation for 2 years. Except as provided in paragraph (c) of this section, when a proprietary educational institution offers a course not leading to a standard college degree, VA may not approve an enrollment in that course if the proprietary educational institution (1) Has been operating for less than 2 years; (2) Offers the course at a branch or extension and the branch or extension has been operating for less than 2 years; or (3) Offers the course following either a change in ownership or a complete move outside its original general locality, and the educational institution does not retain substantially the same faculty, student body, and courses as before the change in ownership or the move outside the general locality unless the educational institution, after such change or move, has been in operation for at least 2 years. Authority: 38 U. S. C. 3680 A(e) and (g))

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (c)Exception to the 2 -year operation requirement. Notwithstanding the provisions of paragraph (b) of this section, VA may approve the enrollment of a veteran, servicemember, reservist, or eligible person in a course not leading to a standard college degree approved under this subpart if it is offered by a proprietary educational institution that (1) Offers the course under a contract with the Department of Defense or the Department of Transportation; and (2) Gives the course on or immediately adjacent to a military base, Coast Guard station, National Guard facility, or facility of the Selected Reserve. (Authority: 38 U. S. C. 3680 A(e) and (g))

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (d) Operation for 2 years. VA will consider, for the purposes of paragraph (b) of this section, that a proprietary educational institution (or a branch or extension of such an educational institution) will be deemed to have been operating for 2 years when the educational institution (or a branch or extension of such an educational institution) (1) Has been operating as an educational institution for 24 continuous months pursuant to the laws of the State(s) in which it is approved to operate and in which it is offering the training; and (2) Has offered courses continuously for at least 24 months inclusive of normal vacation or holiday periods, or periods when the institution is closed temporarily due to a natural disaster that directly affected the institution or the

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (e) Move outside the same general locality. A proprietary educational institution (or a branch or extension thereof) will be deemed to have moved to a location outside the same general locality of the original location when the new location is beyond normal commuting distance of the original location, i. e. , 55 miles or more from the original location.

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (f)Change of ownership. (1) A change of ownership of a proprietary educational institution occurs when (i) A person acquires operational management and/or control of the proprietary educational institution and its educational activities; or (ii) A person ceases to have operational management and/or control of the proprietary educational institution and its educational activities. (2) Transactions that may cause a change of ownership include, but are not limited to the following: (i) The sale of the educational institution;

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (f)Change of ownership (continued) (ii) The transfer of the controlling interest of stock of the educational institution or its parent corporation; (iii) The merger of 2 or more educational institutions; and (iv) The division of one educational institution into 2 or more educational institutions. (3) VA considers that a change in ownership of an educational institution does not include a transfer of ownership or control of the institution, upon the retirement or death of the owner, to: (i) The owner's parent, sibling, spouse, child, spouse's parent or sibling, or sibling's or child's spouse; or (ii) An individual with an ownership interest in the institution who has been involved in management of the institution for at least 2 years preceding the transfer.

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (g)Substantially the same faculty, student body, and courses. VA will determine whether a proprietary educational institution has substantially the same faculty, student body, and courses following a change of ownership or move outside the same general locality by applying the provisions of this paragraph. (1) VA will consider that the faculty remains substantially the same in an educational institution when faculty members who teach a majority of the courses after the move or change in ownership, were so employed by the educational institution before the move or change in ownership.

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (g)Substantially the same faculty, student body, and courses (continued). (2) VA will consider that the courses remain substantially the same at an educational institution when: (i) Faculty use the same instructional methods during the term, quarter, or semester after the move or change in ownership as were used before the move or change in ownership; and (ii) The courses offered after the move or change in ownership lead to the same educational objectives as did the courses offered before the move or change in ownership.

The National Association of State Approving Agencies for Veterans Education and Training Period of Operation 38 CFR 21. 4251 Minimum period of operation requirement for educational institutions (continued) (g)Substantially the same faculty, student body, and courses (continued). (3) VA considers that the student body remains substantially the same at an educational institution when, except for those students who have graduated, all, or a majority of the students enrolled in the educational institution on the last day of classes before the move or change in ownership are also enrolled in the educational institution after the move or change in ownership. (Authority: 38 U. S. C. 3680 A(e) and (f)(1))

The National Association of State Approving Agencies for Veterans Education and Training IHLs with Deemed Approved Programs: Deemed Approved Criteria: • Subject to sections 3675(b)(1) and (b)(2), 3680 A, 3684, and 3696 of Title 38, United States Code, the following programs are deemed to be approved for purposes of this chapter: • (i)An accredited standard college degree program offered at a public or not-for-profit proprietary educational institution that is accredited by an agency or association recognized for that purpose by the Secretary of Education. • http: //www. law. cornell. edu/uscode/text/38

The National Association of State Approving Agencies for Veterans Education and Training IHLs with Deemed Approved Programs 38 USC 3675(b)(1) and (b)(2) • The educational institution keeps adequate records, as prescribed by the Secretary or the State Approving Agency, to show the progress and grades of the eligible person or veteran and to show that satisfactory standards relating to progress and conduct are enforced. • The educational institution maintains a written record of the previous education and training of the eligible person or veteran that clearly indicates that appropriate credit has been given by the educational institution for previous education and training, with the training period shortened proportionately.

The National Association of State Approving Agencies for Veterans Education and Training IHLs with Deemed Approved Programs 38 USC 3680 A SAAs will not approve certain IHL and NCD programs including: • Bartending and personality development programs • Any sales or sales management course which does not provide specialized training within a specific vocational field • Avocational and recreation programs • Photography or entertainment program (unless it is clearly vocational leading to an educational objective) • Self Improvement programs • Medical or dental internships from non-accredited schools • Independent study courses offered by a non-accredited school • Programs offered by radio

The National Association of State Approving Agencies for Veterans Education and Training IHLs with Deemed Approved Programs 38 USC 3684 • Requirements of reporting enrollment by educational institutions to the VA 38 USC 3696 • Limitation on certain advertising, sales, and enrollment practices • Erroneous, misleading and deceptive advertising, sales, and enrollment practices • Educational institutions must maintain a complete record of all advertising, sales, or enrollment materials • Prohibition against an educational institution providing any commission, bonus, or other incentive payment based directly or indirectly on success in securing enrollments

The National Association of State Approving Agencies for Veterans Education and Training Other Accredited Programs 38 CFR 21. 4253 (d)School qualification. A school desiring to enroll veterans or eligible persons in accredited courses will make application for approval of such courses to the State approving agency. The State approving agency may approve the application of the school when the school and its accredited courses are found to have met the following criteria and additional reasonable criteria established by the State approving agency: (1) The institution (other than an elementary or secondary school) has submitted to the State approving agency copies of its catalog or bulletin which are certified as true and correct in content and policy by an authorized representative, and the publication shall: (i) State with specificity the requirements of the institution with respect to graduation;

The National Association of State Approving Agencies for Veterans Education and Training Other Accredited Programs 38 CFR 21. 4253(d) (continued) (ii) Include institution policy and regulations relative to standards of progress required of the student by the institution (this policy will define the grading system of the institution, the minimum grades considered satisfactory, conditions for interruption for unsatisfactory grades or progress, a description of the probationary period, if any, allowed by the institution, conditions of reentrance for those students dismissed for unsatisfactory progress, and a statement regarding progress records kept by the institution and furnished the student); (iii) Include institution policy and regulations relating to student conduct and conditions for dismissal for unsatisfactory conduct; and (iv) Include any attendance standards of the institution if the institution has and enforces such standards.

The National Association of State Approving Agencies for Veterans Education and Training Other Accredited Programs 38 CFR 21. 4253 (2) Adequate records are kept by the school to show the progress of each veteran or eligible person. The records must be sufficient to show continued pursuit at the rate for which enrolled and the progress being made. They must include final grade in each subject for each term, quarter, or semester; record of withdrawal from any subject to include the last date of attendance for a resident course; and record of reenrollment in subjects from which there was a withdrawal; and may include such records as attendance for resident courses, periodic grades and examination results. (3) The school maintains a written record of previous education and training of the veteran or eligible person which clearly indicates that appropriate credit has been given by the school for previous education and training, with the training period shortened proportionately. The record must be cumulative in that the results of each enrollment period (term, quarter or semester) must be included so that it shows each subject undertaken and the final result, i. e. ,

The National Association of State Approving Agencies for Veterans Education and Training Other Accredited Programs 38 CFR 21. 4253 (4) The school enforces a policy relative to standards of conduct and progress required of the student. The school policy relative to standards of progress must be specific enough to determine the point in time when educational benefits should be discontinued, pursuant to 38 U. S. C. 3474 when the veteran or eligible person ceases to make satisfactory progress. The policy must include the grade or grade point average that will be maintained if the student is to graduate. For example, a 4 -year college may require a 1. 5 grade point average the first year, a 1. 75 average at mid-year the second year, and a cumulative average of 2. 0 thereafter on the basis of 4. 0 for an A. (5) If the school has a standard of attendance, it maintains records of attendance for veterans and eligible persons enrolled in resident courses which are adequate to show the student meets the school's standard of attendance.

The National Association of State Approving Agencies for Veterans Education and Training Other Accredited Programs 38 CFR 21. 4253 (6) The accredited courses, the curriculum of which they form a part, and the instruction connected with those courses are consistent in quality, content, and length with similar courses in public educational institutions and other private educational institutions in the State with recognized accepted standards. (7) There is in the educational institution offering the course adequate space, equipment, instructional material, and instructor personnel to provide training of good quality. (8) The educational and experience qualifications of directors, and administrators of the educational institution offering the courses, and instructors teaching the courses for which approval is sought, are adequate.

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (b)Application. Any school desiring to enroll veterans or eligible persons in nonaccredited courses will submit a written application to the appropriate State approving agency for approval of such courses ( 38 U. S. C. 3676(a)). Such application will be accompanied by not less than two copies of the current catalog or bulletin which is certified as true and correct in content and policy by an authorized owner or official of the school and will include the following: (1) Identifying data, such as volume number, and date of publication; (2) Names of the school and its governing body, officials, and faculty; (3) A calendar of the school showing legal holidays, beginning and ending date of each quarter, term, or semester, and other important dates;

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (4) School policy and regulations on enrollment with respect to enrollment dates and specific entrance requirements for each course; (5) School policy and regulations relative to leave, absences, class cuts, makeup work, tardiness, and interruptions for unsatisfactory attendance; (6) School policy and regulations relative to standards of progress required of the student. This policy will define the grading system of the school, the minimum grades considered satisfactory conditions for interruption for unsatisfactory grades or progress, and a description of the probationary period, if any, allowed by the school, and conditions of reentrance for those students dismissed for unsatisfactory progress. A statement will be made regarding progress records kept by the school and furnished the student;

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (7) School policy and regulations relating to student conduct and conditions for dismissal for unsatisfactory conduct; (8) Detailed schedule of fees, charges for tuition, books, supplies, tools, student activities, laboratory fees, service charges, rentals, deposits, and all other charges; (9) Policy and regulations relative to the refund of the unused portion of tuition, fees, and other charges in the event the student does not enter the course, or withdraws, or is discontinued therefrom;

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (10) A description of the available space, facilities, and equipment; (11) A course outline for each course for which approval is requested, showing subjects or units in the course, type of work, or skill to be learned, and approximate time and clock hours to be spent on each subject or unit; and (12) Policy and regulations relative to granting credit for previous education and training.

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (c)Approval criteria. The appropriate State approving agency may approve the application of such school when the school and its nonaccredited courses are found upon investigation to have met the following criteria: (1) The courses, curriculum, and instruction are consistent in quality, content, and length with similar recognized accepted standards. (2) There is in the school adequate space, equipment, instructional material, and instructor personnel to provide training of good quality. (3) Educational and experience qualifications of directors, administrators, and instructors are adequate.

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (4) The school maintains a written record of the previous education and training of the veteran or eligible person and clearly indicates that appropriate credit has been given for previous education and training, with the training period shortened proportionately, and the veteran or eligible person and the Department of Veterans Affairs so notified. (5) A copy of the course outline, schedule of tuition, fees, and other charges, regulations pertaining to absences, grading policy, and rules of operation and conduct will be furnished the veteran or eligible person upon enrollment. (6) Upon completion of training, the veteran or eligible person is given a certificate by the school indicating the approved course and indicating that training was satisfactorily completed.

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (7) Adequate records as prescribed by the State approving agency are kept to show attendance and progress or grades, and satisfactory standards relating to attendance, progress, and conduct are enforced. (8) The school complies with all local, city, county, municipal, State, and Federal regulations, such as fire codes, building, and sanitation codes. The State approving agency may require such evidence of compliance as it deemed necessary. (9) The school is financially sound and capable of fulfilling its commitments for training.

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (10) The school does not utilize advertising of any type which is erroneous or misleading, either by actual statement, omission, or intimation. The school will not be deemed to have met this requirement until the State approving agency: (i) Has ascertained from the Federal Trade Commission whether the Commission has issued an order to the school to cease and desist from any act or practice, and (ii) Has, if such an order has been issued, given due weight to that fact.

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (11) The school does not exceed its enrollment limitations as established by the State approving agency. (12) The school administrators, directors, owners, and instructors are of good reputation and character. (13) The school either: (i) Has and maintains a policy for the pro rata refund of the unused portion of tuition, fees and charges if the veteran or eligible person fails to enter the course or withdraws or is discontinued from it before completion, or

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 CFR 21. 4254 (14) Such additional reasonable criteria as may be deemed necessary by the State approving agency.

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 USC 3676 (14) In the case of a course designed to prepare an individual for licensure or certification in a State, the course— (A) meets all instructional curriculum licensure or certification requirements of such State; and (B) in the case of a course designed to prepare an individual for licensure to practice law in a State, is accredited by an accrediting agency or association recognized by the Secretary of Education under subpart 2 of part H of title IV of the Higher Education Act of 1965 (20 U. S. C. 1099 b).

The National Association of State Approving Agencies for Veterans Education and Training Nonaccredited Programs 38 USC 3676 (15) In the case of a course designed to prepare an individual for employment pursuant to standards developed by a board or agency of a State in an occupation that requires approval, licensure, or certification, the course— (A) meets such standards; and (B) in the case of a course designed to prepare an individual for licensure to practice law in a State, is accredited by an accrediting agency or association recognized by the Secretary of Education under subpart 2 of part H of title IV of the Higher Education Act of 1965 (20 U. S. C. 1099 b).