Question:  What is the impact, if any, to GI Bill recipients when their schools are either closed or has directed their students to take classes online as a result of precautions taken due to COVID-19?

BLUF:  Benefit payments may continue at the same rate for some period of time; however, as time progresses, the amounts payable for monthly benefits will decrease or end, even if students are still taking classes.

Answer:  The answer will depend on the type of action taken by the school, the timing of the action, and the current program approval.

• If a school temporarily closes due to an established policy based on an Executive order of the President or due to an emergency situation, VA may continue benefit payments (including the Monthly Housing Allowance under the Post-9/11 GI Bill) for up to 4 weeks during an 12 month period.  This authority, and limitation, are codified in statute (38 U.S.C. § 3680(a)(2)(A).
• If the school remains open (virtually, rather than physically), and students are transitioned to pursuit solely through online classes, then benefit payments will be impacted as follows:

• If the switch from training in-residence to online classes occurs during the term, and the program has been approved by the State Approving Agency for delivery through an online modality, then benefit payments (including the Monthly Housing Allowance under the Post-9/11 GI Bill) will remain unchanged for the remainder of that term.
• However, for any subsequent terms pursued solely online, the Monthly Housing Allowance (MHA) under the Post-9/11 GI Bill will be reduced to one-half of the national average of DoD’s Basic Allowance for Housing rates for an E-5 with dependents.  The limitations on MHA rates are codified in statute (38 U.S.C. § 3313(c)(1)(B)(iii).
• Lastly, if the program has not been approved by the State Approving Agency for delivery through an online modality, benefit payments will completely stop (including the Monthly Housing Allowance under the Post-9/11 GI Bill) when students begin training online. 

Please note: There is a draft bill to address our limitations, but until that passes we are restricted to what is described above.