A Closer Look at the Dole Act

Key Areas of the Dole Act Related to VA Education Benefits

CH33 Fry Scholarship (Sections 201 & 202)

• Temporary expansion of eligibility for the Fry Scholarship, now including children or spouses of service members who die from a service-connected disability within 120 days of discharge.
• For surviving spouses receiving Fry benefits: removal of the delimiting date and retention of benefits after remarriage.

CH33 Transfer of Entitlement Debt Liability (Section 203)

• Service members are now solely liable for VA overpayments related to any transfer of education benefits to a dependent if they fail to complete their service agreement.

Targeted Risk-Based Surveys Notice (Section 204)

• Schools will receive no more than two business days’ notice before a targeted, risk-based survey is conducted by the VA or SAA.

Approval & Participation in Title IV (Section 205)

• Schools must participate in the Title IV (Federal Financial Aid) program or obtain a VA waiver. VA must notify Congress of any waivers issued.

Oversight of Educational Institutions (Section 206)

• Schools must notify the VA or SAA within 30 days if they become subject to certain government actions. Non-compliance can lead to warnings, suspension, or revocation of school approval.
• My Thoughts: It may take a long time for notification of these types of government actions to reach the SCO(s). I would make sure that my leadership and the school’s legal team are aware of this VA compliance requirement, in hopes of ensuring you are notified immediately.

Digital Transcripts (Section 207)

• Starting August 1, 2025, schools must provide official transcripts in a digital format to eligible persons or veterans.

Rounding Out (Section 208)

• Specific to CH33 Post 9/11 GI Bill, the VA will treat the CH33 student as full-time for MHA purposes during their last semester, term, or academic period.
• My Thoughts: The legislation lacks additional details. The VA will likely need time for their official interpretation and policy adjustments. It may be that CH33 students no longer need to take additional classes to qualify for rounding out. There is no mention of non-CH33 benefit types, but the current policy extends rounding out to the other benefits, so hopefully that continues.
• Question for Readers: What has your recent experience been with rounding out students? I’m aware of issues at schools with multiple parts of term each semester and rounding out students being paid through the end of the semester. What other issues have you encountered?

Commercial Driver Programs (Section 209)

• Adjustment to the requirements of new commercial driver education programs including exemptions to the 2-year rule under certain conditions.

Electronic Notification of Certificates of Eligibility (Section 210)

• Schools should prepare for VA to provide certificates of eligibility and award letters electronically, with an opt-out option for individuals.
• My Thoughts: I hope they provide all documentation to schools electronically too! It sure would simplify reconciling Annual Reporting Fees.

Restoration of Entitlement (Section 211)

• Veterans affected by school closures or disapprovals can have their entitlement restored retroactively, covering the entire program of education if they cannot transfer at least 12 credits.

VET-TEC Program (Section 212)

• Provides a new pathway for veterans to receive education benefits for technology programs, with a tiered payment plan to schools and data collection requirements. Ends 9/30/2027.
• My Thoughts: This seems similar to the prior VET-TEC program with key milestones for payment to schools. I was hoping they had taken more of the liability off participating schools.

System to Allow EFT for Foreign Schools (Section 212)

• The VA must update its payment system to allow electronic fund transfers to foreign schools.

Changes to GI Bill Comparison Tool (Section 213, 215)

• The VA will collaborate with ED, DOT, and other agencies to enhance the tool by adding program completion data, available programs, average time for completion, employment rates, and median income of graduates.
• Schools will have up to 30 days to review and respond to feedback from students before it is published. Applicable feedback from the school will also be displayed. If schools contest the accuracy of the feedback, they can challenge its inclusion with an “official appointed by the Secretary.”
• My Thoughts: All of this should help provide students with more valuable information when selecting a school. I like the idea of better data collection in general. The feedback posted will likely be a mixed bag. Complaints are included on the current site, but the information provided about the complaint is incredibly generic, and the school’s response is not included. With this new change, the school’s input is included too, and there is an option for contesting it. Hopefully, that will be enough checks and balances to provide accountability but also truth.

The Dole Act introduces a range of updates that could significantly impact veterans and the schools serving them. From expanding eligibility for benefits to improving transparency and compliance, these changes are designed to address current gaps and challenges in the system.

What are your thoughts on these provisions? Are there any particular sections that resonate with you or raise questions? Share your insights in the comments below or start a conversation in the forums!