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Veterans Status for Student Aid Purposes
The definition of veteran for Federal student aid purposes is not
necessarily the same as the definition of veteran for VA
purposes. This can lead to potential problems, since the FAFSA
processor performs a data match with Department of Veterans Affairs
(VA) records to confirm a student's veteran status.
Section 8019 of the Higher Education Reconciliation Act of 2005
(P.L. 109-171) changed the definition of independent
student to also include members of the Armed Forces serving on active duty
for other than training purposes. HERA 2005 also defined active duty
to exclude attendance at a service school.
Independent students do not need to report their parents' financial
information on the FAFSA.
There is no minimum amount of service required, so long as it was on
active duty. A single day of service is considered sufficient, so long
as the individual was released under a condition other than dishonorable.
Active duty includes basic training. The inclusion of basic training
as active duty for independent student status is restricted to
veterans. For individuals who are currently in the military, active
duty excludes training. This is because section 480(c)(1) of the Higher
Education Act defines 'veteran' as having been "engaged in active duty
in the United States Army, Navy, Air Force, Marines or Coast Guard"
and "was released under a condition other than dishonorable", and
section 480(d)(3) defines an independent student in terms of
480(c)(1), while the Higher Education Reconciliation Act of 2005 (PL
109-171) inserted "or is currently serving on active duty in the Armed
Forces for other than training purposes". So the "training purposes"
exclusion only applies to service members who are currently in the
Armed Forces, not those who have already been discharged.
Members of the National Guard or
Reserves, however, are only considered to be veterans if they were
called up to active Federal duty by presidential order for a purpose
other than training. A member of the National Guard or Reserves who is
called up to active State duty is not considered a veteran. A key
issue is whether they were under the control of a regular component of
the US Armed Forces or remained under the control of the National
Guard or Reserves.
A member of the Reserves who was called to active duty but who was
discharged before serving on active duty (e.g., due to medical
reasons) is not considered a veteran.
If a member of the armed forces was discharged during basic training
for medical reasons, they are still considered a veteran for Federal
student aid purposes so long as they served at least one day before
being discharged.
If a member of the National Guard or Reserves was called to active
duty and released, but then remained in the National Guard or
Reserves, they are still considered a veteran. So long as they were
called to active Federal duty by presidential order for a purpose
other than training, served at least one day on active duty, and then
were released under a condition other than dishonorable, they are
considered a veteran for Federal student aid purposes.
To be considered a veteran, the student must have been released from
active duty. If
the student is still on active duty, he or she is not yet a
veteran. However, if the student will be a veteran by June 30 of the
school year, he or she is treated as a veteran for Federal student aid
purposes. In such a situation the student should supply a letter from
a commanding officer indicating that the student will be released from
active duty by June 30 and that the character of service so far has
been other than dishonorable.
Students who are currently attending a US military academy and ROTC
students are not considered veterans. However, students who attended a
US military academy or a military academy preparatory school (USMAPS
or NAPS, but not high school academies) are considered veterans, so
long as they were released under a condition other than
dishonorable. This is true even if they were discharged prior to their
being commissioned, so long as the character of discharge was other
than dishonorable. (A "dismissal" is generally considered the
equivalent of a dishonorable discharge for an enlisted member.) Such
individuals may be considered as veterans for
Federal student aid purposes but not for VA purposes, and will likely
be reported as non-veterans during the data match with the VA.
Family members who are enrolled at a US military academy are not
counted in household size or number in college because their entire
education is paid for by the US government.
Students might not show up in the VA records if they recently returned
from service, as it takes several months for the VA records to be
updated. Students might also be missing from the VA records if they
served 180 or fewer days. Serving on active duty for a single day is
sufficient for Federal student aid purposes, but not necessarily for
VA purposes.
If the data match with VA records indicates that the student is not a
veteran, but the student can present documentation indicating that
they satisfy the requirements of the Higher Education Act, the school
should perform a dependency override to treat them as an independent
student. The student should also contact a regional VA office to have
the records corrected, if necessary.
Satisfactory documentation includes a DD214 (Certificate of Release or
Discharge from Active Duty) indicating that the student served on
active study and showing a "Character of Service" as anything but
"dishonorable". The "Member 4 Copy" is particularly helpful. A DD256
(Honorable Discharge Certificate) is also
sufficient, as is a Statement of Service letter showing a "Character
of Service" other than "dishonorable". In the case of a "Statement of
Service" letter, there is no requirement that the school verify actual
discharge during the academic year, but some schools may ask for a
copy of the DD214 anyway.
If a student does not have a
copy of his or her DD214, he or she can request a copy from the
National Personnel Records Center
by submitting a
SF 180.
Veterans themselves may use vetrecs.archives.gov (online DD214 request)
to request a copy of their military records.
A member of the National Guard or Reserves who served on active duty
for purposes other than training might not have a DD214. In that case
a letter from a superior officer that documents the call-up to active
duty and which indicates that the character of service was anything
but dishonorable is sufficient. The student's "Original Orders" might
be informative, especially if it indicates a call to "involuntary
active duty". If a DD214 is available, it should indicate that the
student was called to active duty in accordance with Title 10 of the
US Code and the "Type of Separation" should indicate something other than
"active duty training".
There are only six possible entries for "Character of Service" on the DD214:
College financial aid personnel occasionally get confused when they
see a character of service of "Under Other Than Honorable
Conditions". You need to emphasize to them that this is not the same
as dishonorable, and that you are still considered a veteran for
Federal student aid purposes.
An "Entry Level Separation" will occur when the individual had fewer
than 180 days of continuous active service. The "Character of Service"
will be "Uncharacterized". Such an individual is considered a veteran
for Federal student aid purposes (i.e., an independent student) if he
or she served at least one day of active duty service.
State student aid may have more stringent requirements for the
definition of a veteran than Federal student aid. For example,
Pennsylvania state grants for veterans require the release to be under
a condition other than dishonorable, bad conduct, uncharacterized or
other than honorable. Likewise, individual VA education benefits may
have more stringent eligibility requirements, such as requiring an
honorable or general discharge.
Questions about veteran status in VA records can be directed to
1-800-827-1000. Questions about VA education benefits (i.e., GI Bill)
can be directed to 1-888-GI-BILL-1 (1-888-442-4551).
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