White Paper for Prep Form

WHITE PAPER
Application for Reimbursement of Preparatory (Prep) Course
for Licensing or Certification Test
OMB Control Number 2900-NEW (VA Form 22-10275)
July 21, 2021
By Electronic Submission
The Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Dear OIRA Desk Officer:
Pursuant to 5 C.F.R. § 1320.13, the Department of Veterans Affairs (VA) requests
emergency approval by August 1, 2021, of the use of the Application for
Reimbursement of Preparatory (Prep) Course for Licensing or Certification Test, VA
Form 22-10275.
On August 8, 2020, Public Law 116-154, entitled the ‘‘Ryan Kules and Paul Benne
Specially Adaptive Housing Improvement Act of 2019,” was signed into law. Sec tion 5
of this law amends 38 U.S. Code § 3315 by adding section 3315B, titled “Preparatory
courses for licensure and certification tests.”
The Application for Reimbursement of Preparatory (Prep) Course for Licensing or
Certification Test is an essential instrument which the VA plans to use to collect
information from beneficiaries under the Post 9/11 GI Bill (chapter 33) and Survivors’
and Dependents’ Educational Assistance (DEA or chapter 35) seeking educational
assistance for preparatory courses for licensing and certification tests beginning on or
after August 1, 2021.
We fully understand this law passed nearly a year ago, but VA has been working on
creating this form in earnest since last year so allow adequate time to gather input
from the various stakeholders, include the 53 separate State approving agencies
ultimately responsible for adjudicating approval decisions on applications for program
approval. However, in the midst of working on this form, the Johnny Isakson and
David P.Roe, M.D. Veterans Health Care and Benefits Improvements Act (Public Law
116- 315) was signed by the President on January 5th , 2021. This legislation included
thirty-two provisions that directly impacted VA Education Benefits. Fourteen of these
provisions were effective immediately on the date of enactment. Another fifteen
provisions are effective August 1st, 2021. Accordingly, VA worked to implement those
provisions first. It was our duty to ensure those programs be in place to permit
beneficiaries to fully utilize their Post 9/11 GI Bill benefits.
Without approval of this form, eligible beneficiaries may be harmed due to the
inability to apply for reimbursement they may be rightly entitled to pursuant to 38
U.S. Code § 3315B.
VA has determined this request meets the criteria of 5 CFR 1320.13, in that the
collection of information is needed prior to the expiration of time periods established

under 5 CFR 1320. It is essential to the mission of VA to collect this information.
The use of normal clearance procedures, which will take at least 90 days, would hinder
the mission of VA by effectively making this additional funding unavailable to covered
Veterans beginning August 1, 2021. If granted, the emergency approval is only valid
for 180 days.
If you have any questions and/or confirm a publication date, please contact Rochelle
Foxworth, VA Privacy Act Officer at Rochelle.Foxworth@va.gov.

Sincerely,
THOMAS J
ALPHONSO 636328

Digitally signed by THOMAS J
ALPHONSO 636328
Date: 2021.07.30 14:27:01 -04'00'

Thomas J. Alphonso
Assistant Director,
Policy and Procedures
Education Service