IHL & NCD October 6, 2015 FLIGHT TRAINING...

October 6, 2015

♦

NAVPA

40 th Annual

Conference

♦

Nashville, TN

C r e a t e d b y R o n S c o g g i n s

& K a t h e r i n e S n y d e r

J a n u a r y 2 0 1 4

L a s t R e v i s e d

S e p t e m b e r 1 4 , 2 0 1 5

IHL & NCD

FLIGHT TRAINING

WORKSHOP

Ron Scoggins Lead Education Liaison Representative

US Dept. of Veterans Affairs

VA Central Office

Southern Region

Katherine Snyder Program Consultant

Florida Dept. of Veterans’ Affairs

State Approving Agency

Flight Chair, NASAA

Flight Training and the GI Bill®

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TOPICS • Getting Started

• Contracted Vocational Flight School Approval

• Contracts/MoUs/Agreements

• Miscellaneous Policies and Requirements

• Certifying the Enrollment of VA Students in Flight Programs

• How the Various GI Bill® Programs Pay Benefits and to Whom

• Compliance Surveys

• Licensing and Certification

• Vocabulary Unique to the Professional Aviation Vocation

• Questions

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Getting Started

Determining whether specific SAA approval is required for degree programs with a component of flight/aviation : YES If a school is not considered to have “deemed approved” programs If a school with “deemed approved” programs utilizes services from a

vocational flight school, i.e., “under contract” NO If a school with “deemed approved” programs, utilizes its own flight

line, instructors, TCOs, syllabuses, Part 141 approval, etc. , however, as indicated on Slide 25, the SAA must still review each program to ensure it meets the criteria to be considered “deemed approved”

Credit hour certificate and non-degree programs of flight training may not be approved under any circumstances If the IHL is also approved as a vocational flight school, then they may

certify those students as vocational flight students subject to the rules for vocational flight schools and subject to the Chapter 33 annual cap for vocational flight schools, effective 08/01/2015: $12,048.50 (up from $11,562.86)

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Getting Started Contracted F l ight Degree Program Requirements

Requesting Approval

Utilize Appropriate SAA Application/Request for Approval Form Contact your SAA to obtain the appropriate form* to request

approval (or modification or deletion) of individual degree programs for which the school has a contract, MoU, or other agreement for use of space, equipment and/or instructors, aka degree programs “under contract .”

*Each state will have its own application/request for approval form.

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IHLs with Degree Programs “Under Contract ” If a school does not have its own flight line and offer training in-

house, the IHL must:

Make arrangements with a Part 141 pilot school to provide flight training

Ensure the flight school contractor is approved by the SAA with jurisdiction over pilot schools for veterans’ training

Submit a copy of the following to the SAA:

Contract/MoU/Agreement

Pilot school’s Air Agency Certificate

FSDO-approved TCO and Syllabus for each course offered as part of the degree

If, at any time, an IHL changes its contract from one flight provider to another, it must notify the SAA immediately so that (if all is in order) the approval of their flight degree programs may continue uninterrupted.

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IHLs with Degree Programs “Under Contract” (cont.) The IHL must inform the SAA with whom they have an

arrangement, MoU, or contract to conduct all or a portion of the flight training

SAA to ensure flight training providers are approved for veterans’ training

If IHL and flight schools under contract are not within close proximity/commuting distance of each other and within the same state, thus allowing students to physically attend in resident college classes and flight training simultaneously, additional requirements apply

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IHLs with Degree Programs “Under Contract” (cont.)

Additional requirements where the IHL and pilot school are not within commuting distance of each other and/or are in different states. The controlling CFRs are:

21.4263(g) – Providing a flight course under contract between schools or entities

21.4233(e) – Contracted courses in general

21.4266 – Approval of branch campuses

Only the college can certify the enrollment of their students to VA for pursuit of their own college credit courses

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IHLs with Degree Programs “Under Contract” (cont.)

Additional requirements where the IHL and pilot school are not within commuting distance of each other and/or are in different states (cont.)

A college approved for online training may certify online courses from their main campus for online courses regardless as to where the student is located

In resident training may only be certified to VA by the campus where the in resident training is physically being pursued

If branch campus approval is required by the SAA, it must have:

Administrative capability (including all records required of a branch)

A certifying official

Meet any other requirements specified by the SAA with jurisdiction over that site

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Air Agency Certificate Issued by the Flight Standards District Office (FSDO)

Includes a Letter of Authorization

Is valid for two (2) years

Specifies all the courses that the school is authorized to offer under FAR Part 141

Only courses listed on the Air Agency Certificate and Letter of Authorization may be considered for approval

If a Pilot School wishes to obtain approval of a course not currently listed on these documents, they must first obtain approval from their FSDO and obtain a new or revised Air Agency Certificate and Letter of Authorization

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Training Course Outline (TCO) Each training course for which approval is requested must contain:

A description of each room used for ground training, including the room's size and the maximum number of students that may be trained in the room at one time, unless the course is provided via an internet-based training medium;

A description of each type of audiovisual aid, projector, tape recorder, mockup, chart, aircraft component, and other special training aids used for ground training;

A description of each flight simulator or flight training device used for training;

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TCO (cont.) A listing of the airports at which training flights originate and a

description of the facilities, including pilot briefing areas that are available for use by the school's students and personnel at each of those airports;

A description of the type of aircraft including any special equipment used for each phase of training;

The minimum qualifications and ratings for each instructor assigned to ground or flight training; and

A Training Course Syllabus

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TCO (cont.) The SCO needs to have this information because it directly impacts

flight costs and provides information needed in order to better monitor compliance with the contract

Although the SCO may not be directly involved in monitoring and enforcing the terms of the contract, the SCO must know the people who have that responsibility and establish a good working relationship with them to ensure enough information is made available to the SCO to allow that person to make timely and accurate reports to VA on flight students.

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Syllabus There is one (1) syllabus approved for each Part 141 course

approved by the FSDO

It is approved with and accompanies the TCO or is part of the TCO

It is a lesson-by-lesson outline of how the course is to be pursued

The Ground School section specifies, lesson-by-lesson, the knowledge to be learned and how long (in hours) each lesson should take

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Syllabus (cont.) Ground School is not to be confused with preflight briefings and

post-flight critiques (pre/post) which are always associated with actual flight lessons

Pre/post is rarely ever enumerated in Part 141 syllabuses and for minimum hours is usually listed “as needed.”

For GI Bill® approval, pilot schools may request approval of pre/post hours totaling no more than 25% of the minimum flight hours in each course. This is also true for the flight courses the IHL for which the IHL contracts with the pilot school.

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Syllabus (cont.) Each lesson specifies the knowledge to be learned, maneuvers to

accomplish, procedures to follow for each flight lesson as well as how long each lesson should take

Includes a time distribution chart that lists all lessons, how long each should take, and totals all hours – the hours listed in the syllabus are the maximum hours that may be approved for VA training

The FSDO-stamped copy must be submitted for approval for VA training

Although most syllabuses are written within the FAA minimum hours, a pilot school may write its own syllabus for hours that exceed the FAA minimum requirements. Those hours then become the hours required for all students in that course, including VA students

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Obtaining Approval – Vocational Flight School

As required by Title 38 CFR 21.4263, flight school approval criteria includes, but is not limited to:

Meeting the two-year rule

Being financially sound

Maintain all records pertaining to the training they give for at least three years following each student’s last date of training

Have and enforce reasonable standards of progress and attendance

Have the capability to identify the last date of training

Understand… It is not a given that a flight school will be approved just because it has FAA Part 141 approval

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Finding a Flight School

IHLs may check to see if a flight school is already approved for veterans training:

Go to WEAMS Public:

http://inquiry.vba.va.gov/weamspub/buildSearchInstitutionCriteria.do

Enter Program Type as “Flight” using the drop -down menu

Click on your state

Flight Schools

Seek approval through your SAA

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Cash Tickets/Student Ledgers/Invoices These are the basic documents that record all payments made for

pursuit of flight courses We require them to verify that costs certified to VA for

reimbursement are accurate

As it relates to IHLs… These documents are key to the IHL to verify the accuracy of the

amounts of which the flight school invoices the IHL and must contain the following elements: Name and identifying information of the student Exact approved name of the course being pursued Date of training Flight or ground school lesson number Duration of training in hours and tenths of hours Aircraft flown including make, model, and tail number Per hour charge Total charges Signature of instructor and student

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Flight Course Training Records The official record of each flight and ground school lesson

completed

Required by the FAA to verify that training has been given

Flight schools often use the Jeppesen supplied tri-fold (or similar) training record, electronic records such as Paperless 141, record training in the syllabus on special lesson sheets, or devise their own record

Like the FAA, we use them to verify that training and hours certified to VA have been given

As it relates to IHLs… This is likened to a college instructor’s records of students’ class

work in academic courses and is just as important to the IHL as academic records. In fact, they are the basis for the grades assigned by the IHL for each course students pursue.

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Flight Course Training Records (cont.) Must contain the following elements:

Name and identifying information of the student

Exact approved name of the course being pursued

Date of training for each lesson

Aircraft flown for that lesson to include make, model and tail number

Amount of time expended in completing that lesson

May be compared to the FSDO-approved syllabus

The elements of the lesson completed

A grade for that lesson

Once again, is equivalent to an IHL instructor’s grade book or grade records

Instructor signature and comments

Student signature

Both instructor and student signatures may be electronic

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Flight Training Devices (FTDs) Must be specifically approved for each flight course in the Part 141

FSDO-stamped TCO

Training in FTDs is considered dual flight for VA purposes

Training in FTDs may only be paid for those lessons for which the TCO allows them to be utilized and only for the number of hours the TCO allows to substitute for actual dual flight lessons

Again, the minimum hours listed in the TCO are the maximum that may be approved and which schools can certify veterans for GI Bill® training

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These are schools that own/lease their own aircraft, hire their own flight instructors and are approved by the FAA under Part 141 with their own air agency certificate, and their own TCOs and syllabuses, i.e., they are also a flight school.

If school has its own flight line and Part 141 approval, then special approval of that degree program is not required; however, the SAA must still review the program.

The AAC, TCO and Syllabus are required when you submit a catalog or addendum

This is necessary to ensure that your program meets the criteria to be “deemed approved” and to determine the hours of your program

With this information, the SAA can make the “deemed approved” determination and establish the hours in your program. Should your school decide to add hours to the approved syllabus, you need to also provide a copy of your syllabus with the additional hours.

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Getting Started IHLs wi th Thei r Own F l ight L ine

If school has its own flight line, but training is given under Part 61, then the school should provide their own syllabus that outlines the minimum hours of dual, solo, and ground school required to complete their flight courses. Such hours then become the maximum payable for VA.

In the same situation a school could have its own fixed wing flight line and contract for rotorcraft. The fixed wing can be given under Part 61, but the rotorcraft must be given under Part 141.

Most of the payment procedures on the following slides also apply to schools with their own flight line

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Getting Started IHLs wi th Thei r Own F l ight L ine

Must clearly identify the IHL offering the degrees and the flight school providing the flight training

Each course for which training is being given must be identified

Location where flight training is given

Clear identification as to method of payment for instruction given

Students pay the flight school and are considered to be flight school students – flight school certifies the enrollment of students as vocational flight students

Students pay the college, register for college flight course, are considered to be students of the college, the college pays the flight school – IHL certifies the enrollment of students as college students

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Getting Started Contracts/MoUs/Agreements

Where students pay the college and the college pays the flight school, rates of payment must be clearly delineated

Flat rate – one fee for flight training regardless of time taken or aircraft flown

If a fee is assessed for students needing additional hours of flight training beyond the minimum required, the school cannot certify that fee to VA for reimbursement

Pay by hour – college pays flight school based upon hours completed and specific aircraft flown

Flight and ground hours upon which charges to VA are based must not exceed hours approved on the FSDO-stamped syllabus for each course at the flight school

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List of limitations for training given - examples:

Least expensive aircraft must be utilized except where required by the course syllabus or the FAA

Minimum hours required in course syllabus are the maximum allowed for VA students

All training must be completed by end of term, with exceptions defined and listed

Other obligations and restrictions on the college and the flight school. Examples include, but are not limited to:

Disposition of unused funds (refunds)

Who will supervise which personnel

Who is obligated to pay personnel salaries

Where records are maintained and who maintains them

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Things to avoid on MoUs that would not be approved by an SAA:

Arrangements to sub-contract any instruction to a non-approved school

Provisions to conduct any part of the training under Part 61

Provisions to allow for additional flight hours beyond the minimum requirements of the flight school’s syllabuses

Any clauses that would allow the IHL to alter the flight school’s FSDO-approved Part 141 courses in any way

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New VA Policy Advisory Requires schools to provide complete descriptions of flight lab

subjects which provide for breakdown of hours (dual, solo, ground, and pre/post) and flight fees (for dual, solo, ground, and pre/post hours)

The curriculum or syllabus conforms to the FAA Part 141 Flight Standards District Office (FSDO) approved hours for the individual pilot flight lab hours offered by the IHL

Complete description for each pilot rating (private pilot, commercial, instrument, multi-engine, certified flight instructor, certified flight instructor-instrument) for airplane/fixed wing single engine land (SEL), airplane fixed wing multi -engine land (MEL), and the same for helicopter/rotorcraft listings

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Getting Started Miscel laneous Pol ic ies and Requirements

New VA Policy Advisory (cont.) Documentation published by the IHL in the catalog (or addendum)

disclosing information in previous slide and if offered by/under contract or in-house

Contracted fixed base operator (FBO) must be an FAA Part 141 approved pilot school that has been issued an Air Agency Certificate (AAC) and is also approved by the SAA as a standalone, vocational flight school

In-house flight training must also be approved by the FAA under Part 141 or conducted under Part 61. The minimum hours approved will be the hours published in the school’s Part 141 syllabus or a specified number of hours that the school adds to that syllabus and publishes as the course requirements or, for Part 61 approval, the hours the IHL publishes as minimum requirements for completion of the course.

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Missed and Make-up Flights Where flights cannot be conducted because of inclement weather,

mechanical problems, illness, unavailability of instructors, etc., a policy for making up such missed flights, including time limits, must be delineated in the MoU, school catalog and any program material

Because of concerns regarding keeping students current in training and skills, time limits for making up missed flights cannot be as liberal as with other courses for which an incomplete grade has been issued

In no case may students fly and be certified to VA for more than the minimum hours required in the course syllabus

It should be rare that students need to make up flights after the end of the enrollment period

Frequent such occurrences would be a red flag

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Prior Training Flight schools must grant credit for all appropriate prior education

and training without regard to the wishes of the veteran, just the same as with all IHLs

The FAA 50% and 25% rules with regard to transfer of prior Part 141 training do apply for GI Bill benefits - FAR 141.77(b) Credit may be given for up to no more than 50% of the course requirements

for training received at another Part 141 certified school

Credit may be given for up to no more than 25% of the course requirements for training given under Part 61

The request for prior training, evaluation of same, and proper application to the student’s current course must be documented

All appropriate training transferred must be deducted from the student’s program with the hours of dual and solo flight, ground school shortened proportionately, and cost reduced appropriately

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Standards of Progress IHLs As stated in school catalog and approved by the SAA

Individual flight lab courses Example: Flight lab may have a minimum number of flight

instructional hours for incomplete (I) grades or nonpassing

Vocational Flight Schools Like any other school approved for GI Bill® training, flight schools

must have and enforce standards of progress

The SAAs have certain minimum standards

Other typical standards are tied to stage checks, e.g., failure to pass two stage checks will result in termination of the student’s VA education benefits)

Records must be maintained to reflect that the student was terminated and why

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Standards of Progress & Attendance For the flight courses, standards are set by the flight school and

are specific for all subjects containing elements of flight training. This includes standards of attendance/frequency of scheduling and taking flight lessons to ensure that flight skills are maintained.

A suggested standard might require students schedule flights every week and at a frequency to ensure they will complete all flights within the term. Failure to schedule any flights for two consecutive weeks will result in the student being dropped from the course as of the date of the last flight for failure to attend.

Flight school standards relate to individual lesson grades and stage checks may contain a probationary period which is generally linked to the number of poor lessons grades and/or failed check rides

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Standards of Progress & Attendance (cont.) IHL and flight school must have a system in place to notify IHL, in a

timely manner, of failure to progress satisfactorily or failure to schedule/show up for flight lessons, e.g., did not schedule flights for two weeks

Regardless of the fact that the flight school may have given late notice to the IHL of a change, the IHL is still held responsible for reporting all changes/terminations within 30 days

Hence the importance of open and continuous lines of communication between the flight school and the IHL and between appropriate elements of the IHL and the SCO

Records must be maintained to reflect that the student was terminated and why, along with the date the IHL was notified of the unsatisfactory progress by the flight school

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Refund Policies IHLs IHLs must follow their published and approved refund policies,

including any special refund policies delineated in their contract with the flight school(s).

Flight Schools For their VA students, flight school refund policies must be pro rata Not a problem for ‘pay as you go’ If student pays on account then drops, the refund must be for all

funds still on account that have not been applied to appropriate training already given prior to the drop

Records must be maintained to verify that the refund was given and for the correct amount

Should an IHL choose to have this type of pro rata refund policy, refunds such as this are easy for IHLs to administer since all flight schools are required by the FAA to maintain detailed progress and attendance records.

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Term Dates/Enrollment Periods IHLs use standard and accelerated term dates just the same as for non-

flight students

Flight courses are certified in appropriate credit hours just the same as any other non-flight students

Course Descriptions Flight courses should be described in the IHL’s catalog the same as any

other course

The course title/description should clearly indicate the flight objective (instrument rating, commercial pilot, certified flight instructor, etc .)

If all required hours of flight, ground school and pre/post are listed, they must match the FSDO-approved syllabus

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Course Sequencing School’s approved catalog must have the degree program outlined

As a best practice, the program outline should sequence course pursuit to reflect a healthy mix of flight and general education/academic courses each term

Students should not be allowed to take all flight courses up front, sometimes called front-loading

Since FAA rules require a certain sequence of flight training, i.e., from one course to another, front-loading should not normally be a problem

For instance, all students must take private pilot course first and absolutely cannot pursue any other flight courses concurrently. The credits awarded for that course are normally insufficient for award of the monthly housing allowance (MHA). Thus, Chapter 33 students must take additional academic courses in the program to receive the MHA. 40


Aircraft Utilized For VA purposes, aircraft also means FTD/simulators

Only the aircraft listed in the TCO for a course may be used for that course

The syllabus specifies when a specific type of aircraft must be used such as a complex aircraft (retractable landing gear), multi engine aircraft, etc.

Aircraft used by the flight school must be approved by the FAA in the TCO

Substitutions may be allowed, but only in very limited circumstances such as temporary unavailability of aircraft for overhauls, aircraft sold and replacement not in place yet, etc.

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Aircraft Utilized (cont.) Anyone who is monitoring the student’s training flights needs to

know this to ensure that students are using the appropriate aircraft and only the aircraft actually necessary for the lesson

For example, you would want to ensure that a student is not flying an expensive multi-engine aircraft where only a single-engine aircraft is required

This is also something we will check during compliance surveys

We will review flight training records you make available from the flight school

We will compare those records to the TCO and syllabus for that course (that you again will make available to us) for the appropriateness of aircraft utilized

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Good Stewardship Flight training is inherently expensive

Congress has been focusing attention on the Post-9/11 GI Bill®, especially how much more the cost per student is than its predecessors. IHL flight training has come under close scrutiny as a particularly expensive component of that GI Bill. Congress is considering imposing a cap on contracted programs.

Schools can take measures to limit costs

Agreements with flight schools can limit the use of expensive aircraft only where absolutely required by the syllabus or FAA rules

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Getting Started Miscel laneous

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Certifying the Enrollment

of VA Students in

IHL Flight Programs

85-15% Ratio First, determine if the degree program has more than one “track”

Tracks, as referenced here, should not be confused with majors, minors, concentrations and such

Tracks are not necessarily different curriculums, but rather are different arrangements to pay for courses

Rather than pursuing their flight training at the IHL or as the IHL’s students at the IHL’s contracted flight school, do students have the option of going to a flight school on their own and paying the flight school directly, then having their credits transfer back to the IHL ? Each of these is considered to be a separate track

Is there more than one type of payment plan? If so, then each payment plan is considered to be a separate track

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Certifying the Enrollment of VA

Students in IHL Flight Programs

85-15% Ratio (cont.) Determine whether or not the program has different majors,

minors, concentrations, tracks, etc., and calculate the ratio separately for each such subdivision of the degree

Such differences are usually manifested as different courses Example: An AS, Professional Pilot degree could have Rotorcraft and

Fixed Wing concentrations/majors. The required courses are different for each such concentration/major and, thus, the ratio is calculated separately for each.

Example: A BS in Aeronautical Science may include additional options such as Rotorcraft Option, Certified Flight Instructor – Multi-Engine Option, and Airline Transport Pilot Option. The ratio must be calculated separately for each of those options.

All ratio calculations are in full-time equivalents (FTEs) Example: Two half-time students equal one FTE; two three-quarter time

students equal 1.5 FTE, etc.

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85-15% Ratio (cont.) VA/Supported (85%) portion of ratio includes VA students and any

students receiving a grant, waiver, discount, scholarship, etc., directly from the school and which has rules that have the effect of excluding VA students (regardless of whether or not they are receiving GI Bill® benefits) from receiving that school assistance, aka ‘supported’ students

Example: The contracted flight school requires all of its instructors to obtain the college degree for which they are contracted to help teach. The flight school pays those instructors to pursue the academic courses required in the degree because all of the instructors already posses the licenses and ratings required for that degree. Those students count in the 85% portion of the ratio

Non-VA/Non-supported (15%) portion of ratio includes all other students officially registered in that degree program

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85-15% Ratio (cont.) Non-VA/Non-supported (15%) portion of ratio includes all other

students officially registered in that degree program

Title 38 CFR 21.4201(e)(2) defines non-supported students as:

Students who are not veterans or reservists, and are not in receipt of institutional aid;

Students in receipt of any federal aid (other than Department of Veterans Affairs benefits);

Degree students receiving any assistance provided by an institution, if the institutional policy for determining the recipients of such aid is equal with respect to veterans and nonveterans alike.

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85-15% Ratio (cont.) Schools must calculate the ratio before certifying a VA student in the

program for the first time

If a VA student’s enrollment causes that program to be out of balance for the ratio, that student may not be certified for VA education benefits

Schools must report the ratio to the ELR within 30 days of the start of each standard term

If out of compliance for any program, school cannot enroll new students until ratio comes into compliance

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Why an 85-15% Ratio? Requiring that at least 15% of the students in a program are willing

to shell out their own hard-earned money for that program allows the free market to determine that:

The course is of sufficient quality to attract students who are spending their own money

The course is of good value and not overpriced

This helps keep prices lower, otherwise the school cannot attract sufficient non-VA/supported students to stay in balance with the ratio

The ratio was promulgated by Congress after the original World War II GI Bill® to maintain the integrity of the GI Bill. It is still valid and works well.

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Completing the Enrollment Certification (VA Form 22 -1999)

Enter the exact name of the program as found in WEAMS and your catalog

Enter term dates (these should be, in most cases, the same as for all other students)

Enter credit hours just the same as non-flight degree students

Enter total charges – flat rate

Public schools enter only the in-state rate

Private schools enter the actual total charges (there should be no state differential)

Enter actual charges – if Chapter 33 student is eligible at less than the 100% level, VA’s claims examiners will assume what you certify is the actual total in-state charges and pay the appropriate reduced rate

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Completing the Enrollment Certification (VA Form 22-1999) Enter total charges – pay as you go Public and private schools same as previous slide with respect to in-state

and out-of-state

Calculate the minimum cost that the student will incur and certify that amount up front

At end of course, calculate actual charges and submit an amended enrollment to VA In no case may additional flight or ground hours be certified for payment

beyond the hours in the FAA-approved Part 141 syllabus

Date submitted must be no later than 30 days after the first day of the term, end of drop/add, or date veteran requested the school to certify (documented), whichever is later Time limit is for certifying credit hours pursued. School may take longer to

certify tuition and fees or amended tuition and fees.

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Completing the Enrollment Certification (VA Form 22 -1999) FEES – Only required fees may be certified to VA for

reimbursement. This means that each student is required, without

exception, to pay a fee to the IHL for required equipment, etc.

Example: If a student already has the same make and model headset, the school will give the student credit for the headset and (s)he does not have to purchase it from the school. This fee may not be certified to VA.

Flight examiner fee must not be certified to VA; however, may be reimbursed under LACAS (see subsequent slides)

May not be in student’s best interest due to entitlement hit

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What to Do When a Student Drops/Withdraws from a Flight Course Always report last date of training with a 1999b

Punitive and non-punitive grade policies apply

Generally speaking, the school’s refund policy prevails

As we discussed earlier, such policies must be delineated in the MoU, school catalog, and program materials, and may actually be the refund policy of the flight school and/or be different from the IHL’s general refund policy.

The contract/MoU/agreement with the flight school must specify the financial arrangements for handling funds when students drop/withdraw

The contract/MoU/agreement should always include a policy that provides payment only for flight training actually given

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What to Do When a Student Drops/Withdraws from a Flight Course (cont.) Flat rate – because flight training is very costly, a non-refundable

flight fee is not a best practice and is not recommended

Best practice for refund – calculate cost of training given through date of drop/withdrawal

Deduct cost of training given and refund the remainder of the unearned fees (pro rata)

Pay as you go – generally, a refund of fees is not a factor since payment is only made for actual training given

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Cancelled or Postponed Flight Training In rare instances, students may not be able to complete all flight

training/lessons within the term due to inclement weather, mechanical problems, scheduling problems, etc .

The school must have a policy in place for these types of situations Schools may utilize their standard incomplete grade policy; however, for

the sake of helping the student to maintain flight proficiency, it is a best practice to require less time to make up missed flights than is allowed for other incomplete grades

Example: The student is allowed up to 30 days after the end of the term to complete the flight training or be assigned a failing grade

If flight fees are ‘pay as you go’, the flight charges may then be submitted to VA for reimbursement as an amended certification In no case may flight hours beyond the minimum approved be charged to

VA In no case may a penalty fee be charged to VA

For example: A college charges students an additional flight fee of $500 if they required training beyond the hours in he approved syllabus. This fee may not be charged to reimbursed by VA.

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How the Various GI Bill®

Programs Pay Benefits and to

Whom

All payments are made based upon the enrollment certifications submitted by the school (VA Form 22 -1999) and, in some cases, based upon monthly verifications of pursuit by the student

Chapters 30 & 1607 Benefits payments are paid to the student based on length of

credible service For less than the full service required students are eligible at a

percentage of the full-time rate Chapter 30 – Current rate on 09/14/2015, full-time monthly

payment for three (3) years of credible active duty is $1,717.00 Chapter 1607 – Current rate on 09/14/2015, full-time monthly

payment for two (2) plus years of credible active duty is $1,373.60 Payment for training to the school is between the student and the

school Entitlement is charged at the rate of one (1) month for each full -

time month paid Students must verify enrollment each month to receive benefits

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How the Various GI Bill® Programs

Pay Benefits and to Whom

Chapter 1606 Monthly payments to the student

There is no level of benefit payment for chapter 1606 – all payments are at the 100% eligibility level – current on 09/14/2015, full-time monthly benefit is $367.00

Payment for training to the school is between the student and the school

Entitlement is charged at the rate of one (1) month for each full-time month paid

Students must verify enrollment each month to receive benefits

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Chapter 35 Monthly payments to the student

There is no level of benefit payment for chapter 35 – all payments are at the 100% eligibility level – current, on 09/14/2015, full-time monthly benefit is $1,018.00

Payment for training to the school is between the student and the school

Entitlement is charged at the rate of one (1) month for each full-time month paid

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Chapter 33 Benefits payments are paid based on length of credible service

For less than the full service required, students are eligible at a percentage of the full-time rate

Payments are separate for:

Housing allowance

Books and supplies

Tuition and fees

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Chapter 33 (cont.) Reimburse each school for up to 100% of all approved charges

All payments subject to the student’s level of eligibility

For public IHLs, payment is for all allowed costs of in -state tuition and fees with no yearly limit

For private IHLs, payment is for all allowed costs of tuition and fees up to an academic year cap

Academic year is August 1 through July 31

Yearly cap (2015-2016) is $21,084.89

Cap for previous academic year was $20,235.02

Both the monthly amount paid and yearly cap are subject to the student’s level of eligibility (e.g., student eligible at the 80% level will have payments made to the school at the rate of 80% of the actual charges certified and the yearly cap is $16,867.91 (80% of yearly cap))

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If They Have a Choice, Which GI Bill Should They Use ? If they are eligible for more than one GI Bill and/or have an

opportunity to change from one to another, veterans should go to the website below and use the Comparison Tool/Payment Rates to determine which GI Bill would most advantageous for her/his situation. Alternately, veterans may call the nationwide toll free education number also listed below:

http://www.benefits.va.gov/gibill/comparison_tool.asp

VA Toll Free Number: 1-888-442-4551

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Compliance Surveys

Review of 85-15% ratio Based upon the total enrollment for the term as opposed to training

for the prior 30 days as with flight schools

Remember… the ratio must be calculated separately for each track, major, minor, concentration, option, etc.

We will check a random sampling of non-VA files to ensure those students are paying for their program out of their own funds

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Compliance Surveys

Records must be available at time of visit Review pre-survey checklist provided to you by the SAA or VA

Ensure all items are addressed

Hard copy or electronic records

Ask questions before visit if unsure

IHL Documents Registration documents - application, enrollment agreement

Class schedules

Transcripts

Drop slips; withdrawal documentation

Tuition payment ledgers; detailed record of tuition and fees

Yellow ribbon documentation

Reporting fee fund documentation 66

Compliance Surveys

Records specific to flight

For schools that contract their flight training or have their own flight line, offer training under Part 141, and charge pay as you go:

Copy of contract/MoU/agreement with the flight school (N/A for schools that have their own flight line)

Each current course TCO and FSDO-stamped syllabus

Flight school progress records

Signed by instructor and student

Flight school student cash tickets/ledgers/invoices

Current AAC (we will also review for revocation before the survey at the FAA Website)

67

Compliance Surveys

Records Specific to Flight (cont.)

For schools that contract their flight training or have their own flight line, offer training under Part 141 and charge a flat rate:

Copy of the contract/MOU/agreement with the flight school (N/A for schools with their own flight line)

Flight school’s/IHL’s Part 141 air agency certificate

TCO and syllabus for each flight course

Ground school and flight records detailing the flight/ground training given with total hours given for each type of flight (dual/solo) as well as ground school

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Compliance Surveys

Records Specific to Flight (cont.) For schools that have their own flight line and offer flight

training under Part 61 Ledger/cash tickets/invoices detailing the flight training given –

must include: Dates and duration of flights

License/rating requirement covered including a grade/evaluation of that flight

Hourly charge for that flight

Total charge for that flight

Aircraft utilized by make, model, horsepower, and tail/ID number

Ground school records showing hourly charges and what particular portion of the written exam was covered

School syllabus for each course that details what is to occur during each lesson and how long each lesson should take. Should include a time distribution chart that shows total flight hours in each program

69

Compliance Surveys

Records must be available at time of visit (cont.) FAA website link:

Pilot Schools - http://av-info.faa.gov/PilotSchool.asp

Pilot School will show up if AAC is stil l valid

70

Compliance Surveys

http://av-info.faa.gov/PilotSchool.asp





Commencement of courses First day of classes for the semester, quarter, or part of term

Program certified Must be same as what VA beneficiary is enrolled in and pursuing

Review transcripts, registrar records, application, etc.

If they do not agree, update records and/or certification

Monitor WEAMS (22-1998) reports

Ensure program certified is exactly as it appears on WEAMS

71

Compliance Surveys

Previous education and training The school must maintain a written record that clearly indicates

that appropriate previous education and training has been evaluated and granted, with training time shortened and tuition reduced proportionately, and the veteran so notified

For flight courses, the FAA places certain restrictions on how much credit may be granted, even when considering training completed at another college or Part 141 flight school

Part 141 Pilot Schools may transfer credit that composes no more than

50% of the hours in the school’s syllabus for training completed under Part 141 at another certificated flight school

25% of the hours in the school’s syllabus for training completed under Part 61

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Compliance Surveys

Previous education and training (cont.) This varies from college transfer policies that generally allow credit

for all work successfully completed at certain other colleges

The pilot school will process the prior credit under Part 141 rules, but the IHL needs to be aware of these rules and ensure that the flight school follows them and grants credit as appropriate

73

Compliance Surveys

Certifications must be accurate and prompt Ensure enrollment dates are correct

Ensure tuition and fees are properly reported dependent upon whether the school charges flight pay as you go or flat rate

For pay as you go, schools may certify up front the minimum charges they know all flight students will incur then certify the actual charges (if more than the minimum charges) at the end of the term as an amended certification

Utilize degree program/audit sheets to ensure courses certified apply to program requirements not already satisfactorily completed

Review fees charged to ensure they are truly required of all students with no exceptions allowed under any circumstances

NOTE: This is why it is extremely important that the SCO have open communication with her/his own school’s finance/bursars office and registrar, and the appropriate officials at the flight school who can provide the training and billing records the SCO needs to properly certify enrollments to VA

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Compliance Surveys

Certifications must be accurate and prompt (cont.) Ensure that prior credit has been obtained, evaluated and granted

as appropriate. It would not be unusual for a student applicant to have already obtained some flight licenses and ratings for which credit must be granted toward the degree program An IHL cannot, under any circumstances, require a student to pursue a license

or rating at that IHL or contract flight school if the student already possesses that license or rating from the FAA

All certifications must be submitted within 30 days of the latter of any of the following three (3) events:

Start of term

End of drop/add

VA student’s request for certification of benefits

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Compliance Surveys

Terminated or Interrupted Training Must be promptly reported

During our visit we must be able to identify the last dates of training. Notification must be made to VA within 30 days of student’s last date of attendance

Maintain drop/withdrawal slips in file or make electronic record available

The last date of training should be easy to obtain for flight courses because flight training requires accurate records of dates of training given

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Compliance Surveys

Grades of I and F IHLs must follow their published grading policies

An I grade is issued for flight courses only if the student has not completed all the lessons because of inclement weather, mechanical problems, instructor unavailability, illness, etc., not because (s)he failed lessons.

With I grades, VA can pay the student to complete only the required hours of lesson remaining to be completed in the course.

An F grade is issued if the student did complete all the lessons, but was unsuccessful in, and did not pass, some of the lessons.

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Compliance Surveys

Incomplete Grades Ensure that the student does not re-enroll in same course unless

an unsatisfactory grade is assigned

Ensure that the time for completing the course is not exceeded

If the student did not complete all flights during the term, we can pay for the student to complete the remaining approved hours in the course, but no more

Student can take additional flight hours beyond that approved in the syllabus, but only at own expense

VA payments can only be made for costs associated with the required hours in each flight syllabus

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Compliance Surveys

Failing Grades Where a student has actually earned an F in a flight course

because that student failed some of the lessons, the student may retake that course and be certified for VA benefits for retaking that course

Because FAA rules do not require student pilots to retake lessons successfully completed, but only retake lessons that were failed, an IHL flight student is only required to take those lessons (s)he failed

In practical terms, the flight contractor or flight department must evaluate which lessons were failed and when the student registers for that flight course again, they will only require that student to repeat the failed lessons

The flight fees certified to VA should reflect only those costs associated with retaking the failed flight lessons

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Compliance Surveys

Standards of Progress Monitor unofficial transcripts

Monitor progress records from flight school

Ensure you have a good line of communication with the flight school or the element within your own school that would have access to those documents

Maintain documentation in files

Standards of Progress must be monitored and policy enforced

Promptly report probation to VA via ‘Right Now Web’ (VA’s Internet Inquiry System in the “Ask a Question” section of the benefits.va.gov/gibill website)

https://gibill.custhelp.com/app/utils/login_form/redirect/ask

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Compliance Surveys



Standards of Progress (cont.) SCOs must promptly report to VA when a student is no longer

meeting the standards of progress for your school

Terminate effective at the end of the last term during which the student is entitled to payment

In VA-ONCE, specify reason as “Unsatisfactory Attendance, Conduct or Progress”

Ensure the end date of the term is correct

LDA/Effective date defaults to end date of term

If the student is not returning, you must still terminate

If the student is academically suspended and submits documentation to appeal and the suspension status is overturned, you do not terminate the certification. Be sure to thoroughly document such appeals and positive results in the student’s file.

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Compliance Surveys

How do tuition and fees compare to other students’ charges? Tuition and fees charged to VA beneficiaries must be the same or

less than charges to other similarly circumstanced students

Some non-VA/non-supported student files are randomly selected for this purpose

Authority: Title 38 USC, Section 3690(c)

Schools found charging veterans more than similarly circumstanced non-VA/supported students are subject to having their approval immediately withdrawn

38 CFR 21.4210(d)(4)(i)

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Compliance Surveys

Findings/Common (and Not-so-Common) Errors (in no particular order) Student flying and being certified for more flight hours (and

associated charges) than the course syllabus requires

Notice of termination for unsatisfactory pursuit sent to VA more than 30 days after the last flight or ground school class

Administrative withdrawal date certified instead of last flight or ground school class

Flight course taken out of sequence as listed in the school’s catalog

Refund of fees after termination is not prorated for the flight lessons not taken (pay as you go/pay on account)

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Compliance Surveys

Findings/Common (and Not-so-Common) Errors (continued) 85-15% ratio does not include supported students in the 85%

portion of the ratio

VA students charged more than non-VA students for the same course

The IHL has not sought prior approval of its contractual arrangement and it is found that the flight school is not approved for GI Bill® training

Invalid fees charged to VA for reimbursement

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Compliance Surveys

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Licensing and Certification

(LACAS)

Following is the link that will take you to the information regarding Licensing and Certification (LACAS). It gives complete instruction on how a veteran may seek reimbursement for LACAS exams not covered under GI Bill benefits:

http://www.benefits.va.gov/gibil l/l icensing_certif ication.asp

Pamphlet: http://www.benefits.va.gov/gibil l/docs/pamphlets/lc_brochure.pdf

Individuals may also go to the following link to search for approved exams and to find the appropriate address for submission (name and address of organization issuing license is required when submitting to VA for reimbursement):

http://inquiry.vba.va.gov/weamspub/buildSearchLCCriteria.do

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Licensing and Certification LACAS

http://www.benefits.va.gov/gibill/licensing_certification.asp

http://www.benefits.va.gov/gibill/licensing_certification.asp

http://www.benefits.va.gov/gibill/docs/pamphlets/lc_brochure.pdf

http://inquiry.vba.va.gov/weamspub/buildSearchLCCriteria.do

Items eligible for reimbursement under LACAS: FAA examiner’s fee for the check ride

Entitlement Student is charged one (1) month of entitlement for every test VA

pays

May not always be in the student’s best interest

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Enter “Commercial Pilot” for example as in the following screen as well as “Both” in the LAC Category type, and do a search by country (USA), then click Submit:

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89


Once there, click on Commercial Pilot to get the next screen:

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Click on Institutional Profile and that will give the institution name and address for submission:

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92

Vocabulary

Unique to the

Professional Aviation

Vocation

Air Agency Certificate: The Air Agency Certificate is issued by the FAA to flight schools authorizing them to offer courses of instruction leading to pilot ’s licenses and ratings. Air Agency Certificates list the specific flight programs approved by the FAA for the school to which the certificate is issued. Certificate validity dates vary, but are always indicated on the certificates. A Letter of Authorization must accompany an Air Agency Certificate.

Chief Flight Instructor : The Chief Flight Instructor is the person in charge of all flight training at a flight school. Chief Flight Instructor qualifications are contained in the Federal Aviation Regulation (FAR), 14 CFR Part 141.35. The FAR requires each school to designate a Chief Flight Instructor.

93

Definitions

Federal Aviation Administration (FAA): The federal government organization primarily responsible for the advancement, safety and regulation of civil aviation. The FAA establishes regulations and policies prevailing over flight, including flight training, flight schools, and certificates issued, and it oversees the development of air traffic safety and control .

Federal Aviation Regulations (FARs): The FARs are a compilation of FAA regulations governing all aspects of flight training, air carrier operations, medical requirements for pilots, aviation safety, aircraft maintenance training, airfield and airspace operations within the US, its territories and their respective boundaries.

94

Definitions

Fixed Base Operator (FBO): A commercial business granted the right by an airport to operate on the airport and provide aeronautical services such as fueling, hangaring, tie-down and parking, aircraft rental, aircraft maintenance, flight instruction, etc. When referring to Part 141 pilot schools this term is applied to the primary location listed on the air agency certificate and satellite operations under that same air agency certificate located at other air fields

95

Definitions

Fixed Wing: An aircraft is describes as “fixed wing” when it derives the majority of its lift from a stationary or variable geometry wing, as opposed to a helicopter, which derives its lift from rotors (rotary wing). Fixed wing aircraft may be powered by engines attached or built into its fuselage or wings.

Flight Engineer Courses: The flight engineer course is a separate program with skills and requirements described in 14 CFR Part 63, Subpart B. Although the FAA has only one flight engineer certificate, it also approves courses leading to endorsements to the certificate for the aircraft on which the engineer is qualified to serve. The SAA must approve a flight engineer program offered by a school and the additional add-on training endorsements. A VA student may receive benefits for the endorsements.

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Definitions

Flight Programs: Flight training programs are formal courses leading to FAA certifications or ratings to operate aircraft. (NOTE: Pursuit of a private pilot ’s license, except as part of a degree program, is not approvable for veteran students). All flight training must be received from an authorized instructor. Commercial Pilot: The course of instruction leading to

licensing as a commercial pilot, authorized to operate aircraft for hire. This is the initial program approvable for VA training.

Instrument Rating: A course of instruction leading to certification to operate an aircraft in instrument meteorological conditions (IMC); during periods of low visibility.

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Definitions

Flight Programs (cont.):

Certified Flight Instructor (CFI): Course of instruction leading to certification as a flight instructor, authorized to conduct ground or flight training I accordance with the privileges and limitations listed on the holder’s flight instructor certificate.

Additional Flight Instructor Qualifications:

Certified Flight Instructor-Instrument (CFI-I): A course of instruction qualifying the CFI to provide ground and flight instruction in all phases of flight planning, flight, and air traffic control procedures when operating in instrument meteorological conditions.

98

Definitions


Additional Flight Instructor Qualifications (cont.):

Certified Flight Instructor Single Engine Land (CFI -ASEL – as opposed to seaplane) and Certified Flight Instructor-Multi Engine Land (CFI-AMEL): A course of instruction qualifying the CFI to provide ground and flight instruction in single -engine aircraft (ASEL) or multi-engine aircraft (AMEL), respectively.

Other: specific qualifications for unique aircraft or unique capabilities, such as aerobatic instructor qualifications are addressed in the FARs.

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Definitions


Airline Transport Pilot (ATP): A course of instruction qualifying the commercial pilot to perform duties and responsibilities as an airline pilot.

Additional Aircraft Type-Rating Certificates: Courses of instruction that qualify pilots to operate specific types, categories or classes of aircraft.

Ground School Instructor Certification: A course of instruction qualifying a person to provide instruction in the ground training aspects of flight training. Specific details are contained in 14 CFR Part 141, Appendix H.

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Definitions

Flight School (Pilot School): A school, other than an IHL, or an entity such as an aero club, located in a state, that has been issued either a pilot school certificate or a provisional pilot school certificate by the FAA which specifies each course the school is approved to offer under 14 CFR Part 141.

Flight Standards District Office (FSDO): The FSDOs are regional offices located throughout the US. FSDOs promote safe transportation by setting standards and regulations for oversight of airmen, air operators and air agencies. They approve flight and ground training curricula at flight schools under their geographic jurisdiction. FSDOs issue Air Agency Certificates. 101

Definitions

Flight Simulators: A flight simulator is a replica of a specific type, make or model of aircraft, which includes the assemblage of equipment and computer programs necessary to represent aircraft operations in ground and flight conditions. Simulators must have visual systems providing out-of-cockpit views, and have a full range of capabilities of the systems installed in the device as described in 14 CFR, Part 60.

102

Definitions

Flight Training Device (FTD): An FTD is a replica of aircraft instruments, equipment, panels and controls in an open flight deck area or an enclosed aircraft cockpit replica. It includes the equipment and computer programs necessary to represent aircraft operations in ground and flight operations. An FTD need not have a motion or a visual system.

103

Definitions

Instrument Meteorological Conditions (IMC): IMC means weather conditions below the minimums defined as Visual Flight Rules. The rules cover the time and area of the sky with limited visibility when pilots must use navigational instruments to take-off, fly and land the aircraft. FAA air traffic controllers dictate all aircraft maneuvers on the ground by their radar and other flight guidance instruments.

Instrument Flight Rules (IFR): IFRs are the rules governing the procedures for conducting flight under Instrument Meteorological Conditions (IMC), and are determined by FAA air traffic controllers.

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Definitions

Letter of Authorization: This letter is issued to the school with the Air Agency Certificate. It provides a listing of the specific programs that have been authorized for the school to offer. It expires at the same time that the FAA issued Air Agency Certificate expires.

Medical Certificates: A medical certificate is issued by the FAA based upon completion of an appropriate medical examination by an FAA approved doctor. All pilots must have an appropriate medical certificate to be authorized to fly. There are three classes depending upon the extent of the physical exam (Title 14 CFR, Chapter 1, Subchapter D, Part 61.23) 105

Definitions

Medical Certificates (cont.):

First Class: The highest level of medical certificates – required for pilots to exercise the privileges of an ATP rating

Under age 40 – valid for first or second class privileges through the end of the 12th month after the date of the medical exam

Age 40 and older – valid for first class privileges through the end of the sixth month after the date of the medical exam

Second Class: Required for pilots who are exercising the privileges of their commercial pilot’s license or are providing flight instruction.

For any age, valid for second class privileges through the end of the 12th month after the date of the medical exam

Third Class: The initial certificate required of pilots to exercise the privileges of their private pilot’s license. 106

Definitions

Part 60: This regulation (14 CFR, Part 60), governs initial and continuing qualification and use of aircraft flight simulation training devices that are used for meeting training, evaluation, or flight experience requirements for flight crew member certification or qualification.

Part 61: This is a section (14 CFR Part 61) of the FARs that specifies the requirements for various pilots‟ licenses and ratings. Part 61 training cannot be approved for VA benefits because it relates to one -on-one training without regard to a standard curriculum or school training. It is the flight equivalent of tutorial assistance. However, it is a useful reference and describes the requirements for obtaining the various pilots licenses. 107

Definitions

Part 63: This section (14 CFR Part 63) of the FARs specifies the requirements for schools and courses to train flight engineers. Part 63 programs may be approved for enrollment of veterans and others eligible to receive VA education benefits because it requires a school curriculum and standard course outline that must be followed.

Part 141: This section (14 CFR Part 141) of the FARs specifies requirements for schools to train students for pilots‟ licenses and ratings. Training under part 141 may be approved for the enrollment of veterans and others eligible for VA education benefits because it specifically relates to school training and standard course outlines that must be followed.

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Definitions

Part 142: 14 CFR Part 142 of the FARs states the requirements to train students to fly using simulators. Simulator training devices can be used in most fight programs, However, simulator training is most often specific to large-body aircraft (Boeing 777 or 717, L1011, etc.) using large, complex simulators to acquire type-ratings. Simulator training is less costly than using/flying the actual aircraft. For example, the cost to fly a Boeing 737 is about $100 per minute, that ’s up to $6,000 an hour! A complex flight simulator may cost $500-$800 an hour. These costs increase at least annually.

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Definitions

Ratings: These generally refer to the type or class of aircraft a licensed pilot is authorized to fly such as.

Aircraft Type Rating

Category Rating

Class Rating

Instrument Rating

Rotary Wing or Rotorcraft: An aircraft that is propelled and lifted by the action of the wings (rotors) such as a helicopter.

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Definitions

Stage Checks: Stages are subdivisions of the flying or ground training syllabus of instruction. A stage may be subdivided into individual lessons corresponding to a flight or ground training event. Normally, a stage check is given to the student to determine mastery of the lessons comprising a particular stage. Satisfactory completion of a stage check indicates the student is ready to progress to the next stage of the syllabus.

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Definitions

Training Course Outline (TCO): 14 CFR 141.55 describes the requirements of a training course outline and syllabus. Each flight training program approved for veterans training must have an FAA approved TCO. A TCO will normally contain details of school’s facilities, approved aircraft inventory, instructors, procedures for operations, airspace and airfield facilities, and a training syllabus for each flight training program.

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Definitions

Training Syllabus: The syllabus is comprised of all lessons, both ground and flight training, which must be successfully completed prior to taking the FAA licensing/certification check ride for the particular program of training. Several standardized training syllabi are available, such as Jeppesen-Sanderson or Cessna Training programs; or, a flight school may have its own unique FAA approved syllabus for one or all of its respective programs. In either case, the flight and ground training time approved by the FAA becomes the maximum hours for which a VA student may be certified for benefits.

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Definitions

Visual Flight Rules: The rules that govern the procedures for conducting flight under visual conditions, and also used to indicate weather conditions that are equal to or greater than the minimum VFR requirements.

Visual Meteorological Conditions: Meteorological conditions expressed in terms of visibility, distance from clouds, and ceiling equal to or better than specified minima.

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Definitions

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Questions?

This presentation was created by Ron Scoggins (Lead Education Liaison Representative, U.S. Dept. of Veterans Affairs) and

Katherine Snyder (Program Consultant, Florida State Approving Agency, in January 2014 and last revised

September 14, 2015

Ron Scoggins

[email protected]

Mailing Address:

US Department of Veterans Affairs

VA Regional Office ATTN: Education Outreach (272A)

P.O. Box 1437 St. Petersburg, FL 33731

Katherine Snyder

[email protected]

Mailing Address:

Florida Department of Veterans' Affairs State Approving Agency for Veterans'

Education and Training P.O. Box 31003

St. Petersburg, FL 33731

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Contact Information

mailto:[email protected]

mailto:[email protected]

IHL & NCD October 6, 2015 FLIGHT TRAINING...

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