Comment from Gerald Morales on VA-2026-VACO-0001-0237

I am submitting this comment in my capacity as a School Certifying Official (SCO) overseeing VA education benefit certification at a large private research university. I support the Department’s effort to implement the outcome-verification requirements of the DOLE Act, and I offer the following observations on the proposed collection’s practical utility and burden, consistent with the four factors VA has invited comment on. First, on necessity and practical utility: outcome verification tied to final provider payment is a sound accountability mechanism, and as an SCO I understand why VA needs documented proof of employment or continued study rather than a self-report alone. However, the form’s utility depends heavily on how “acceptable documentation” is defined at the point of certification. VA’s April 2026 policy guidance on VET TEC 2.0 employment verification already distinguishes ordinary raises from qualifying promotions and addresses self-employment; it would strengthen the collection’s clarity if Form 22-10299 itself (not just separate guidance) referenced these standards directly, so SCOs are not reconciling two documents to complete one attestation. Second, on burden estimation: VA’s estimate of 5 minutes per respondent and 333 annual burden hours likely understates the actual time SCOs will spend. Completing an accurate attestation requires locating the veteran post-completion (sometimes 180–365 days after program end, after the individual has left the institution’s active systems), requesting and verifying supporting documentation such as an offer letter or pay stub, and confirming the position or coursework is genuinely “in the same field” as the completed program — a substantive judgment call, not a data-entry task. In my experience with comparable post-completion certifications, locating separated students and obtaining timely documentation is often the most time-consuming step, not form completion itself. Third, on minimizing burden: I recommend VA allow electronic submission and e-signature consistent with other VA education forms, and that VA clarify what happens procedurally if a Training Provider SCO cannot locate or obtain a response from a veteran within the certification window, since final payment is contingent on this certification. Without a defined fallback, the burden and financial risk of an unresponsive veteran falls entirely on the institution. I appreciate the opportunity to comment and VA’s continued efforts to implement the DOLE Act’s VET TEC 2.0 provisions in a workable manner for both veterans and training providers. Respectfully submitted, Gerald Morales School Certifying Official