UPDATE:  On March 21st, President Trump signed S.3503 into law addressing the potential reductions and disruptions to veterans benefits due to the COVID-19 pandemic.  See our update here.


As schools across the country respond to unprecedented challenges caused by COVID-19, students and veterans who rely on the Post-9/11 GI Bill’s educational assistance could see those benefits reduced or paused without legislative action.

In a recent announcement, the US Department of Veterans Affairs (the VA) outlined the impact on student benefits in three scenarios:

  • School temporarily closes: If a school temporarily closes because of an emergency, the VA will continue to pay benefits (including full housing allowances) for up to four weeks in a 12-month period.
  • School with approval for online program shifts to online courses: If a school shifts its in-person courses to online courses, student veterans will continue to receive benefits through the end of the term only if the school’s state approving agency (SAA) has given the school approval to offer such programs online. If programs remain solely online for additional terms, student veterans’ housing allowance would be reduced to 50% of the national average of the US Department of Defense’s basic allowance for housing for an E-5 with dependents, which is consistent with the amount the VA typically provides for online programs.
  • School without approval for online program shifts to online courses: If a school shifts its in-person courses to online courses, but does not have the SAA’s approval to offer such programs online, student veterans enrolled in those programs will stop receiving payments of all education benefits (including housing allowances) as soon as they begin their training online.

To protect these benefits from being reduced or paused, legislation has been introduced in both the US House and Senate that is intended to protect these benefits. Both bills would allow – but not require – the VA to continue providing the same level of benefits to students enrolled in programs shifted online due to a health emergency, whether or not the program was approved by the SAA for online delivery. We will continue to track this legislation and provide updates as warranted.

The VA is preparing additional guidance for schools that have changes in training modalities and operation status due to COVID-19, and it has requested schools temporarily refrain from making any adjustments to their enrollment certifications if training has changed due to COVID-19. In addition, the VA has invited school certifying officials and SAAs to attend a webinar on March 19 to discuss the impact of COVID-19. Further, President Trump’s recent declaration of a national emergency pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988 (the Stafford Act) could provide the VA some flexibility to address these challenges.

Still, we recommend that schools contact their SAA and VA education liaison representative for up-to-date information about how to navigate a transition to online programs for veteran students. Schools shifting to online programs should also notify student veterans of the potential impact on their benefits and consider whether there are short-term alternatives to allow students to continue their education uninterrupted. School certifying officials and school veteran advisors should be provided with clear guidance that they can utilize to address incoming questions.

Marjorie Arrington assists schools, colleges and universities with matters relating to the management and administration of federal, state and private student financial assistance programs.

Matt Johnson focuses on assisting higher education institutions and education technology companies regarding a variety of regulatory issues including state and federal privacy laws at the K-12 and postsecondary levels.

Shannon Noonan focuses on assisting postsecondary institutions, K-12 schools and the companies that collaborate with them navigate complex regulatory issues.

Caitlyn Shelby advises postsecondary institutions, K-12 schools and education companies on matters involving accreditation, state authorization and the provision of online education, and monitors legislative and regulatory developments in these areas.


Posted by Cooley