Education and Training
Changes to Education Policy and Guidance
Pursuant to 38 U.S.C. § 3699D, notice of changes to policies and guidance relating to VA educational assistance programs are published for 90 days before the change is implemented.
The following changes will be eligible for implementation within the next 90 days.
Clarification Regarding “Employment”, including Self-Employment, for VET TEC 2.0 Training Programs Established under Section 212 of Public Law 118-210
Published:
April 16, 2026
Justification:
Through the establishment of an objective standard and baseline, this advisory intends to clarify “employment” and, furthermore, clarify how traditional employment, promotion in current employment, and “self-employment” may satisfy the employment-based outcomes under 38 U.S.C. § 3699C. This additional clarification is being provided based on a review of employment information received and reviewed since the initial rollout of the VET TEC pilot program in order to maximize the economic outcomes for VET TEC 2.0 participants.
Issue: On January 2, 2025, the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act, Public Law 118-210, was enacted into law. Section 212 of that legislation establishes the Department of Veterans Affairs high technology program, referred to here as VET TEC 2.0, by adding 38 U.S.C. § 3699C. This provides VA with the authority to furnish educational assistance to eligible individuals to enroll in high technology programs of education and identifies circumstances under which payments to training providers are tied to employment outcomes in a relevant field or industry.
Purpose: Through the establishment of an objective standard and baseline, this advisory intends to clarify “employment” and, furthermore, clarify how traditional employment, promotion in current employment, and “self-employment” may satisfy the employment-based outcomes under 38 U.S.C. § 3699C. This additional clarification is being provided based on a review of employment information received and reviewed since the initial rollout of the VET TEC pilot program in order to maximize the economic outcomes for VET TEC 2.0 participants.
Discussion/Answer: 38 U.S.C. § 3699C(c)(2)(C) and § 3699C(c)(6)(A)–(B) use employment-based outcomes in determining final payment to providers and provider preference. As the meaning of employment in these provisions is ambiguous, VA is exercising its interpretive authority through this advisory. Section 3699C(c)(2)(C) provides for final payment upon: (i) the successful employment of the covered individual for a period of 180 days in the field of study of the program, beginning not later than 180 days following graduation; (ii) the employment of the individual by the provider for a period of one year; or (iii) the enrollment of the individual in a program of education to continue education in such field of study. Section 3699C(c)(6)(A)–(B) addresses provider preference based on specified graduate employment outcomes and tuition reimbursement. Further, VA will evaluate whether the employment activity is in the field of study based on substance of duties or business activity, not merely the job title or business name.
In general, VA considers a person to be “employed” if that person is a person who performs services for another individual and is compensated for such services or otherwise engages in compensated self-employment in a career supported by the completed program of study. The nature of the relationship may be that of an employee/employer, contractor/client, or self-employed individual/client.
Specifically, “employment” includes:
- Establishing a new employee/employer relationship in a career supported by the completed program of study; or,
- Promotion in the Veteran’s current employee/employer relationship in a career supported by the completed program of study.
- A promotion must be both a monetary promotion as well as an actual position change based on knowledge, skills, and abilities gained through the VET TEC 2.0 training. It cannot simply be an increase in pay. For example, it cannot be an increase simply based on an annual adjustment (such as a cost-of-living adjustment or inflationary index) or length of service with the employer; or,
- Self-employment in a career supported by the completed program of study.
- Self-employment qualifies only when the business activity or services being performed are in the field supported by the completed program of study.
The goal of the VET TEC 2.0 program is to help Veterans obtain employment. To preserve the integrity and success of the program, VA is clarifying the job certification requirements surrounding what is deemed as acceptable and reasonable for the reporting of employment, including self-employment, i.e., the minimum standards for declaring a Veteran has obtained employment.
Documentation Standards
The following documentation is required for payment of employment certifications under 38 U.S.C. § 3699C(c)(2)(C), as applicable to the type of employment claimed. Documentation must be sufficient to show that the employment meets the applicable statutory pathway, be kept on file for the student, and appears on official company letterhead. VA may request additional documentation if the information provided is insufficient.
For employment with new employer: Accepted forms of documentation may include official onboarding documentation such as Form I-9 (Employment Eligibility Verification) or a pay stub.
For employment with Training Provider: Accepted forms of documentation may include official onboarding documentation such as Form I-9 (Employment Eligibility Verification) or a pay stub.
For continued education: Accepted forms of documentation may include notice-of-registration or enrollment (documentation must display school letterhead).
For employment under 38 U.S.C. § 3699C(c)(2)(C)(i) (successful employment for 180 consecutive days in the field):
- Salary or hourly wages.
- Hours worked per week. Employment must be full-time. There is a minimum of 30 hours per week or full‑time‑equivalent income requirement for all employment claims.
- Contract Jobs. Reports of contract jobs must be sufficient to show that the work is in the field of study of the program, begins not later than 180 days following graduation, and continues for at least 180 consecutive days.
- Accepted forms of documentation may include a signed independent contractor agreement/contract and IRS Form 1099-NEC as proof of engagement or a pay stub if client used to establish self-employment, self-employment is only established after the contract has continued for a period of 180 days.
For promotion in current job:
- Documentation must show both a monetary promotion and a positional promotion.
- A promotion is not simply a job title change without an increase in salary.
- A promotion is not simply an increase in salary without a positional promotion.
- Accepted forms of documentation may include an updated employment contract, promotion letter, and/or paystubs (promotion must be both monetary and positional).
“Self-employment” criteria and verification regarding self-employment;
VA supports self-employment and other entrepreneurial endeavors as viable paths to achieving successful employment. To ensure that individuals electing to pursue employment through self-employment are adequately equipped for success, the following documentation is required for payment of employment certifications that claim any form of self-employment:
- Proof of ownership of the business. These can include a Federal Tax ID Number (EIN); Articles of Organization; Articles of Incorporation; copy of personal tax return with schedule C or equivalent; a copy of the Doing Business As (DBA) declaration; etc. It may also include a state tax ID number or state business registration information.
- Copies of any valid personal licenses or certifications required for business operations.
- Documentation sufficient to establish legitimate business activity in the field of study and continuity of that activity for the required period. Examples may include a service contract, statement of work, recurring invoices, proof of payment over period of time, client attestations, business records, or other documentation sufficient to establish the services and or products being provided as well as the start date of the business activity and its continuation for at least 180 days beginning not later than 180 days following graduation.
Effective Period: The implementation of this new policy is effective on or after July 15, 2026, and is applicable to both VET TEC 2.0 students and Training Providers, regardless of when the student began or graduated from their program. Compliance with these requirements may be reviewed by VA through provider approval criteria, contract administration, compliance reviews, surveys, or other oversight processes, as applicable.
Questions: If you have any questions, please direct them to the Education Service Policy & Regulations Team via email
Amendment of Chapter 35 definition of “educational institution” Removing High School Programs from the Statutory Scope of Benefits
Published:
April 15, 2026
Justification:
Effective August 1, 2026, Public Law 117-328, div. U, title II, § 215, enacted into law on December 29, 2022 amends the Chapter 35 definition of “educational institution” at 38 U.S.C. § 3501(a)(6) by deleting “secondary school” and replacing “secondary school level” with “postsecondary school level.” These revisions disallow students from using Chapter 35 DEA benefits for high school (also known as secondary school) benefits.
Issues: Questions have arisen concerning the impact of Public Law 117-328, enacted into law on December 29, 2022, which will narrow the scope of programs eligible for Dependents Educational Assistance (DEA or Chapter 35) beginning August 1, 2026. This advisory explains the impact of this provision and addresses related issues concerning retroactive benefit payments and programs which provide training for both high school credit and non-high school certification.
Background: Effective August 1, 2026, Public Law 117-328, div. U, title II, § 215, enacted into law on December 29, 2022 amends the Chapter 35 definition of “educational institution” at 38 U.S.C. § 3501(a)(6) by deleting “secondary school” and replacing “secondary school level” with “postsecondary school level.” These revisions disallow students from using Chapter 35 DEA benefits for high school (also known as secondary school) benefits.
Discussion: For periods of education training beginning on or after August 1, 2026, DEA may no longer pay for general K–12 instruction—including high school coursework, GED level training, tutoring, or academic remediation. This policy reflects the plain language meaning of the law.
Retroactive Approvals and Payments
A State Approving Agency (SAA) should not accept or grant approvals for high school programs starting on or after August 1, 2026. However, Chapter 35 benefit payments are allowed past August 1, 2026, for approved high school programs whose terms began before August 1, 2026. In other words, VA is permitted to pay for a term extending past August 1, 2026, if the student’s term began prior to that date. After August 1, 2026, VA cannot pay benefits for high school programs through the high school program’s graduation date, or any subsequent terms, even if required for graduation.
Additionally, because Chapter 35 benefit payments are allowed past August 1, 2026, for approved high school programs whose terms began before August 1, 2026, VA will accept retroactive certification of enrollments submitted to VA on or after August 1, 2026, for training that occurred prior to August 1, 2026.
Mixed Use or “In Conjunction With” Training
VA recognizes that the completion of certain training programs taught in high school may provide credentials or certifications in skilled trades such as welding, HVAC, carpentry, etc. However, even if a high school offers a regional vocational education certificate separate from or in conjunction with a high school diploma, the “educational institution” is a “secondary school” which will no longer be a legally recognized and acceptable “educational institution” for the purposes of Chapter 35 benefits on or after August 1, 2026; therefore, the program will not be approved for usage of Chapter 35 benefits after August 1, 2026, pursuant to the policy above. When VA is unable to pay for training at a secondary school, similarly, VA will be prohibited from paying for training for “in conjunction” with programs in high school educational institutions.
Effective Date: August 1, 2026
Questions: If you have any questions, please direct them to the Education Service Policy & Regulations Team via email
Approval Criteria for Licensure or Certification Preparatory Courses
Published:
March 27, 2026
Justification:
Section 3315B of Title 38, United States Code authorizes VA to pay Chapter 33 and Chapter 35 educational assistance for courses whose purpose is to prepare an individual to take a licensure or certification test. Since enactment of this authority and issuance of VA’s March 10, 2021, policy advisory, VA and SAAs have identified issues resulting in inconsistent approval practices and uncertainty among approving officials and training providers. These issues included differing interpretations of the permissible scope of preparatory course content, confusion regarding the distinction between preparatory courses and programs of education approved under Chapter 36 including non-college degree (NCD) programs, ambiguity arising from overlapping terminology, and questions regarding provider eligibility standards.
Purpose: This policy advisory rescinds and supersedes the Policy Advisory dated March 10, 2021. This advisory provides revised and clarifying guidance to State Approving Agencies (SAAs) regarding the approval of preparatory courses for licensure or certification tests under 38 U.S.C. § 3315B. Specifically, this guidance addresses issues identified through implementation of prior advisories and establishes updated approval criteria, classification principles, and terminology to promote the consistent administration of approvals by State Approving Agencies (SAAs).
Background: Section 3315B of Title 38, United States Code, authorizes VA to pay Chapter 33 and Chapter 35 educational assistance for courses whose purpose is to prepare an individual to take a licensure or certification test. Since enactment of this authority and issuance of VA’s March 10, 2021, policy advisory, VA and SAAs have identified issues resulting in inconsistent approval practices and uncertainty among approving officials and training providers. These issues included differing interpretations of the permissible scope of preparatory course content, confusion regarding the distinction between preparatory courses and programs of education approved under Chapter 36 including non-college degree (NCD) programs, ambiguity arising from overlapping terminology, and questions regarding provider eligibility standards.
For example, some SAAs interpreted preparatory courses as being limited to review or refresher instruction, while others approved preparatory courses that included substantive or new instructional content. As the statute does not impose a refresher-only limitation, and historically recognized preparatory courses may include new material, SAAs have interpreted Title 38 sec. 3315B inconsistently, leading to different approval outcomes. VA and SAAs have also been occasionally confused about the appropriate classification of offerings that share characteristics of both preparatory courses and programs of education. In some instances, the same offering was approved simultaneously as both a preparatory course under § 3315B and a program of education under Chapter 36, resulting in administrative inconsistency and uncertainty about which payment rules and benefit limitations apply.
Additionally, VA notes that ambiguity has arisen about the term “certification,” which may refer to either a third-party licensure or certification test or to a certificate issued by a school upon completion of a program of education. This ambiguity also contributed to inconsistent classification and approval decisions.
Finally, SAAs raised concerns regarding provider eligibility standards in the existing advisory, particularly as applied to preparatory course providers that may not yet have sufficient student outcome data to meet performance-based thresholds but otherwise demonstrate operational stability and legitimacy. Based on these considerations, VA is issuing this clarification of approval standards, classification principles, and terminology, while preserving SAA discretion and minimizing disruption to education beneficiaries.
Discussion/Answer:
Scope and Content of Preparatory Courses
VA clarifies that the statutory language of 38 U.S.C. § 3315B does not limit preparatory courses to review or refresher instruction. The statute does not require that a beneficiary already possesses the knowledge tested by the licensure or certification examination prior to enrolling in a preparatory course. Accordingly, VA clarifies that a preparatory course may include substantive or new instructional content provided that the primary purpose of the course is to prepare individuals to take a specific approved licensure or certification test. SAAs should not deny approval of a preparatory course solely on the basis that the course includes new, substantive, or foundational instructional content. This clarification aligns approval practices with VA’s understanding of Congress’s intention that section 3315B apply to historically recognized preparatory courses, such as bar examination preparatory courses, which may include new, substantive, or foundation instructional content.
Distinction Between Preparatory Courses and Programs of Education
Preparatory courses approved under 38 U.S.C. § 3315B constitute a distinct approval category and are not programs of education approved under Chapter 36. Programs of education are curricula or combinations of courses pursued to attain a predetermined educational, professional, or vocational objective. Conversely, preparatory courses are limited in purpose to preparation for a specific licensure or certification test. VA also clarifies that an offering may not be approved simultaneously as both a preparatory course under § 3315B and a program of education (including an NCD program) approved under Chapter 36. If an offering presents characteristics of both a preparatory course and a program of education, the SAA must determine the most appropriate classification based on the totality of the circumstances, including the structure, purpose, and outcomes of the offering. Once classified, the offering must be approved and administered under the applicable statutory authority and may not be approved concurrently under both authorities. VA will not require SAAs to classify an offering as a program of education solely because it could meet program-of-education criteria.
Clarification of “Certification” Terminology
VA recognizes that the term “certification” is used in multiple contexts which has contributed to inconsistent classification and approval decisions. Therefore, for purposes of preparatory course approval under 38 U.S.C. § 3315B, VA clarifies the relevant "certification” for consideration should be the third-party licensure or certification test approved under 38 C.F.R. § 21.4268(b). A certificate issued by a school upon completion of a course or program of education is distinct from a licensure or certification test administered by an external authority. The issuance of a school certificate does not, by itself, determine whether an offering is a preparatory course or a program of education.
Provider Eligibility and Approval Criteria
SAAs also have raised concerns regarding the application of existing provider eligibility standards, particularly for preparatory course providers that have yet to train a sufficient number of students to meet performance-based thresholds but otherwise demonstrate legitimacy and operational stability. To address these concerns, VA has clarified approval criteria to permit preparatory course providers to qualify based on either demonstrated performance outcomes or demonstrated operational longevity. Specifically, a provider may satisfy eligibility requirements by meeting the two years of operation standard as an alternative to meeting the student-volume and pass-rate standard.
Removal of References to National Exam Preparatory Courses
VA also acknowledges that references in prior guidance to “national exam” preparatory courses created confusion by suggesting it was associated with licensure and certification preparatory courses under 38 U.S.C. § 3315B. Admission-test preparatory courses (e.g., tests used for admission to institutions of higher learning or graduate programs) are already treated as programs of education under long-standing statutory definitions and are administered under different authorities. The reference to preparatory courses under 38 U.S.C. § 3315B conflated differing approval frameworks and contributed to inconsistent interpretation. Accordingly, references to national exam preparatory courses have been removed from this advisory. This change does not affect VA’s authority to pay for admission-test preparatory courses under other provisions of law.
Implementation and Transition
VA recognizes that clarification of approval criteria and classification principles may affect existing approvals. VA also recognizes that implementation of this guidance may result in reclassification or withdrawal of approval for certain offerings that were previously approved. Where such action is required, SAAs must take appropriate action consistent with statutory and regulatory requirements.
Actions to Withdraw Approvals:
Withdrawal of NCD (Program of Education). The SAA withdraws approval of NCD programs under Chapter 36—(not the preparatory course):
A State Approving Agency (SAA) should withdraw program approval due to this new policy, i.e. a program that is approved simultaneously as a preparatory course under § 3315B and a program of education under Chapter 36. The SAA letter to the institution offering the program must specifically note that the reason for the withdrawal is due to a change in policy implemented on (insert relevant date), and per VA’s Secretary’s authority under 38 U.S.C. 3699(d), students will be permitted to continue to receive benefits through the end of their program, if they maintain continuous enrollment. Accordingly, SAAs shall ask for a list of currently enrolled students with their anticipated graduation date or completion date and shall supply that to VA with the withdrawal letter. The SAA will also advise the school that it is barred from enrolling new students and to notify all beneficiaries about the withdrawal and advise them that they may continue to receive benefits through the end of their program if they maintain continuous enrollment.
An Educational Liaison Representative (ELR) should withdraw program approval in WEAMS by leaving the program approval intact but enter the withdrawal date in the remarks section and will track the withdrawal until the last student has finished the program. Remarks shall be very specific noting “Withdrawal due to change of policy implemented on (insert relevant date). Students that maintain continuous enrollment may receive benefits through the end of their program.
An ELR should contact the school and the local VR&E office of jurisdiction before final withdrawal action is taken in WEAMS to ensure all continuously enrolled students have completed their program. After verification, WEAMS can be modified to show the withdrawal. Finally, the ELR should contact the school or facility before final withdrawal action is taken in WEAMS to ensure all continuously enrolled students have completed their program. Withdrawal actions taken pursuant to this guidance apply prospectively and do not permit submission of new enrollments following the effective date of withdrawal.
NOTE: The ELR process will change significantly when Approval Manager is deployed and WEAMS decommissioned. New procedural guidance will be provided at that time.
Withdrawal of the preparatory course only. The SAA withdraws approval of the preparatory course under § 3315B, not the NCD program: An Educational Liaison Representative (ELR) should withdraw program approval in WEAMS using the effective date provided by the SAA.
Approval Requirements
Educational assistance may be payable for a preparatory course only if:
1. The licensure or certification test for which the course is designed is approved under 38 C.F.R. § 21.4268(b); and;
2. The preparatory course is approved by the SAA under one of the approval pathways below.
Facility-Based Approval
The facility providing the preparatory course: Is approved, or approvable, under 38 C.F.R. §§ 21.4253 or 21.4254; Has official recognition or accreditation from the relevant licensure or certification authority, if applicable; Provides verification of course name and dates upon request; and Clearly identifies tuition and mandatory fees applicable to all students.
Provider Performance- or Longevity-Based Approval The provider: Has operated for at least two years, or Has trained at least 100 students and demonstrates a 75 percent pass rate within two years of completion; Provides verification of course name and dates upon request; and clearly identifies tuition and mandatory fees applicable to all students.
Payment Limitations
Payment for preparatory courses is limited to reimbursement of tuition and mandatory fees in accordance with 38 U.S.C. § 3315B. Preparatory courses do not confer entitlement to Monthly Housing Allowance (MHA).
Questions: If you have any questions, please direct them to the Education Service Policy & Regulations Team via email
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