Important Update: Isakson and Roe, Section 1015 Requirements Effective August 1, 2021

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Greetings School Certifying Officials,

Section 1015 of Public Law 116-315, Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020, amends sections 3672 and 3675 of title 38, United States Code, to require accredited institutions to be approved for and participate in Title IV of the Higher Education Act of 1965 (i.e., Federal Student Aid (FSA) programs) or receive a waiver of this requirement by the Secretary in order to be approved for GI Bill® benefits.

What do you need to do?

Schools must satisfy the requirements of section 1015 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 1015 will occur while your request for a waiver is pending a decision from the Department of Veterans Affairs (VA).

How do I request a waiver?

You can request a waiver by submitting an email to The waiver request package must include:

1. A cover letter on the organization's letterhead requesting approval for an Education Service Waiver under 38 U.S.C. §§ 3675(b)(4) and 3672(b)(2)(A)(i)(II). The request must include the following information:

  • Date of last application for participation in the Federal funded student financial aid through the Department of Education and the result of that application;
  • If the school has a currently pending Program Participation Agreement with the Department of Education and proper documentation of the submission (VA may verify this submission with the Department of Education); and
  • Enumerated list of the specific provisions of Title IV with which the institution is unable or has chosen not to comply. For each non-compliant provision, a reason or justification for non-compliance.

2. A copy of the denial notification (final adjudication notification),if the institution has previously been denied Title IV funding from the Department of Education.

Failure to provide any of the elements could result in your institution's waiver request being denied until you submit the missing elements.

VA will provide a decision on submitted waiver requests within 60 to 90 days of August 1, 2021.

For More Information

We are committed to providing you with 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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