Isakson and Roe, Section 1018 Requirements Effective August 1, 2021

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Greetings School Certifying Official,

Section 1018 of  Public Law 116-315Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020, adds new requirements for educational institutions participating in the educational assistance programs of the Department of Veterans Affairs (VA). These new provisions became effective June 15, 2021 and will apply to Institutions of Higher Learning and Non-College Degree institutions beginning August 1, 2021. Many of the requirements are consistent with the requirements of the Principles of Excellence, currently in Executive Order 13607; however, there are requirements in addition to those embodied in the Principles of Excellence which schools must also satisfy to maintain approval for GI Bill® participation.

What do you need to do?  

Schools must satisfy the requirements of section 1018 by August 1, 2021. If your school will not be able to satisfy the requirements of the section by that date, you must apply for a waiver by August 1, 2021. Once you have submitted a waiver request, your school will be in a “pending waiver decision” status. No adverse action under section 1018 will occur while your request for a waiver is pending a decision from VA. If your waiver request is decided favorably, it will be for a period not to exceed one year beginning on August 1, 2021. If your waiver request is decided unfavorably, it will be referred to the State Approving Agency and a caution flag will be added to the GI Bill comparison tool.

How do I request a waiver?  

You can request a waiver by submitting an email to body of the email must contain the following information:

  1. School name.
  2. Facility Code.
  3. Name of the institution’s requesting official and contact information.
  4. Name of institution’s responsible deciding official with the authority to request such a waiver on behalf of the institution and contact information.
  5. Justification for the waiver (choose one of the following):
    1. Currently unable to provide the personalized shopping sheet.
    2. Currently unable to provide availability of federal financial aid not administered by VA, offered by the institution or to alert the individual of the potential eligibility for other federal financial aid before packaging or arranging student loans or alternative financing.
    3. Other: [provide a brief description of the section and specific provisions in which the institution is unable to meet and the reason in which the institution is unable to meet the prescribed requirements] (limit your description to 250 characters or less).
  6. The specific actions the institution will take to become compliant with these requirements within this academic year (limit your description to 3000 characters).
  7. The timeframe and milestones in which the institution expects to become compliant with these requirements. The maximum allowable timeframe is one academic year (i.e., you must execute a plan to comply by August 1, 2022).

To be considered for a waiver, you must provide each of the 7 elements above.  Failure to provide any of the elements could result in your institution's waiver request being denied until you submit the missing elements.

Submitted waiver requests will receive a decision from VA within 60 to 90 days of August 1, 2021.

What is Section 1018?

Section 1018 codifies in statute the following requirements:

Section 1:

  • Schools must provide a covered individual (a student using benefits under chapter 30, 31, 32, 33, or 35 of title 38, U.S.C., or chapter 1606 of title 10, U.S.C.) with a personalized shopping sheet that contains:
    • Estimated total cost of the course that includes tuition, fees, books, supplies and any other additional costs.
    • Estimated cost of living expenses.
    • Amount of costs above that are covered by VA Education Benefits.
    • Other types of Federal financial aid, not administered by VA that is offered by the institution, that the individual may be qualified to receive.
    • Estimated amount of student loan debt the individual would have upon graduation.
    • Information regarding graduation rates.
    • Information regarding job-placement rates for graduates, if available.
    • Information regarding the acceptance of transfer credits including military credits.
    • Any additional requirements including training, experience, or examinations that are required to obtain a license, certification or approval for which the course of education prepares the individual.
    • Other information to facilitate comparison by the individual about aid packages offered by different educational institutions.
  • Personalized shopping sheets must be provided within 15 days after tuition and fees are determined for the academic year if there is a change.
  • Schools must maintain policies that:
    • Inform an enrolled covered individual of the availability of federal financial aid, not administered by VA that is offered by the institution.
    • Alert the individual of the potential eligibility for other federal financial aid before packaging or arranging student loans or alternative financing.
    • Prohibit automatic renewal of a covered individual in a course and/or programs.
    • Ensure each covered individual approves of the enrollment in a course.
    • Allow enrolled members of the Armed Forces, including reserve components and National Guard to be readmitted if such members are temporarily unavailable or must suspend enrollment by reason of serving in the Armed Forces.
    • Accommodate short absences for such services in the Armed Forces.
  • Schools must provide covered individuals the requirements for graduation and a graduation timeline.
  • Accredited educational institutions agree to obtain approval of the respective accrediting agency for each new course or program.
  • Schools must designate an employee of the educational institution to serve as a point of contact for covered individuals and family members seeking assistance with:
    • Academic Counseling.
    • Financial Counseling.
    • Disability Counseling.
    • Other information regarding completing a course of education at the education institution.

Section 2:

  • State Approving Agency will take action when the education institution does any of the following:
    • Carries out deceptive or persistent recruiting techniques including on military institutions.
    • Misrepresents payment of incentive compensation.
    • During a 1-month period makes three or more unsolicited contacts to a covered individual via phone, email and/or in person.
    • Engages in same day recruitment and registration.
    • Provides a commission, bonus, or other incentive payment based directly or indirectly on success in securing enrollments or financial aid to any persons or entities engaged in any student recruiting or admission activities, or in making decisions regarding the award of student financial assistance. (Please note: schools are already subject to this requirement under 38 U.S.C. § 3696(d)(1)).

VA announced the requirements of section 1018 in an email on April 1, 2021. The above list is a digested version of the requirements. Please refer to the exact wording of the statute (here) for the authoritative requirements.

 For more information 

We are committed to regular updates through briefings, direct mail campaigns, social media and/or training events as we move towards implementing each of these provisions. For timely updates about this new law, please visit the Isakson and Roe Veterans Health Care and Benefits Improvement Act of 2020  webpage. 

If you have any questions, please contact your State Approving Agency (SAA).   

Thank you for being a valued partner in support of the GI Bill program.  


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