VET TEC 2.0 pays training providers in part on whether Veterans find work in their field, so this form decides how employment gets proven. The Scaffold Initiative supports the collection and offers five practical improvements: reconcile the burden estimate with the form's own statement; confirm W-2 hires through the National Directory of New Hires, which VA is already authorized to query; complete the Privacy Act statement; add an occupation code and work location so VA can produce the salary comparison the statute requires; and ask for the least sensitive proof through a secure channel.
The Scaffold Initiative is a Wyoming-incorporated 501(c)(4) social welfare organization focused on workforce equity, the capacity of community-based organizations, and the responsible use of technology in workforce programs. We have commented on Workforce Innovation and Opportunity Act (WIOA) state plans, including those of Wyoming, Oklahoma, and Oregon, and on federal workforce data collections, including the Job Corps Placement and Assistance Record (OMB Control No. 1205-0035).
We support this collection. Section 212 of the Elizabeth Dole Act (Pub. L. 118-210), codified at 38 U.S.C. 3699C, pays a training provider the final 50 percent of tuition only after the Veteran holds a job in the program’s field of study for 180 days. It also asks VA to report each year on employment rates, time to employment, and salaries. VA Form 22-10299 is the record behind both the payment and the report. Our comments draw on the draft form itself, as posted with the Information Collection Request (ICR) package, and aim to make that record more reliable with little or no added burden.
The draft form reflects how Veterans actually go back to work. It counts salaried and hourly jobs, promotions, contract work, paid internships, paid apprenticeships, and self-employment, and it lists specific proof for each. It also tells respondents that VA “will evaluate employment activity based on duties or business activity, not merely job title or business name.” Many workforce programs still count only W-2 placements and miss Veterans who start a business. We commend VA for building those outcomes in from the start.
The notice estimates 4,000 responses at 5 minutes each, or 333 hours, “Once” a year, from “Educational Institutions.” The form’s own burden statement estimates 30 minutes per respondent per year. At 30 minutes, 4,000 responses come to 2,000 hours, six times the notice’s figure. The form also has two sides, initial employment and 180-day (or one-year) continued employment, and both the Veteran and the certifying official sign each side. Training providers must also keep supporting documents on file for three years.
We recommend that VA (a) use one per-response time estimate, (b) count each side as a separate response, (c) add Individuals to the affected public, and (d) include provider recordkeeping. The total may still be modest. An accurate figure helps OMB and helps VA design the online version around the people who actually fill it out.
Today the form rests on attestation and documents that the provider collects. The provider also receives the final payment once VA accepts the certification. A light, independent check protects good providers and the program’s credibility, and VA already has the tools:
We recommend that VA match Side 1 hires against new-hire records as a routine cross-check. Employers file new-hire reports for employees, so the attestation and documents remain the main path for contract work, self-employment, and promotions. Workforce programs already measure outcomes this way. The WIOA primary indicators count employment in the second and fourth quarters after exit, plus median earnings (20 CFR 677.155). States must measure them with quarterly wage records where those records exist, and use other evidence only where they do not (20 CFR 677.175).
This step also advances two open recommendations in GAO-23-105343 (October 2022), the Government Accountability Office (GAO) review of the original VET TEC pilot. GAO found that VA calculated employment only for participants whose final payment it had decided, did not use the job-type data it collected, and did not systematically track whether Veterans kept their jobs. GAO recommended an employment rate consistent with standard government and industry approaches, and better use of available data. Form 22-10299 and a routine new-hire match together put VA in a position to close both.
The draft form’s Privacy Act statement ends mid-sentence: “may be subject to verification through computer matching with other.” The Privacy Act asks each form to tell respondents the authority, the principal purposes, the routine uses, and the effect of not responding (5 U.S.C. 552a(e)(3)). We recommend finishing the sentence, naming the system of records (58VA21/22/28), and stating plainly that VA may confirm employment through the National Directory of New Hires.
Telling Veterans at the point of collection is the simplest form of consent. It costs one sentence, and it avoids surprise later. It also matches the certification Veterans already sign, which authorizes VA “to verify my employment if needed.”
Section 3699C(f) asks VA to report, each year, the number of graduates “employed in a position related to technology,” their average salary “in various geographic areas,” and how that salary compares with the average for all technology jobs in those areas. The form already collects salary, hours, and dates. Two short additions would let VA produce the comparison consistently:
| Add | Why |
|---|---|
| Occupation code (Standard Occupational Classification, or SOC), or a one-line description of duties that VA codes | The Bureau of Labor Statistics publishes wages by occupation and metropolitan area. The SOC code is the link to that benchmark. It also records the duties-based review that the form already promises. |
| Work location ZIP code, or “remote” | Many technology jobs are remote. An employer’s headquarters address may not reflect where the Veteran works or the local wage. |
Where a program publishes a Credential Transparency Identifier (CTID) in Credential Engine’s registry, VA could record that too. With an occupation code on the job and a program identifier on the training, VA can apply one test for “in the field of study” across all providers. We made the same recommendation for the Job Corps Placement and Assistance Record (Comment of The Scaffold Initiative, FR Doc. 2026-17834, OMB Control No. 1205-0035, submitted September 29, 2026).
The accepted documents include Form I-9 and personal tax returns with Schedule C. Both carry far more personal information than VA needs to confirm a job or a business. The form also directs providers to send the form and documents by email, and the email address is still blank. We recommend that VA:
The Appendix lists small edits that would help Veterans and certifying officials complete the form correctly the first time.
Form 22-10299 is already close to a strong outcome record. With an accurate burden estimate, a routine new-hire check, a complete privacy notice, two short fields, and a secure way to submit proof, VA will have the evidence Congress asked for and a defensible basis for every final payment. The Scaffold Initiative would be glad to help test the revised form with community partners who serve Veterans.
Respectfully submitted,
Ricky Tucker
Executive Director
The Scaffold Initiative
c/o Northwest Registered Agent LLC
30 N Gould Street, Suite N
Sheridan, WY 82801
[email protected]
| Where | Suggested edit |
|---|---|
| Page 1, “How to use this form” | Refers to both “Side B” and “Side 2.” Use “Side 2” throughout. |
| Page 1, “How to submit this form” | The email address is blank. Add the address or the upload channel. |
| Side 1 | Sections run I, II, III, V. Renumber, or add the missing Section IV. |
| Side 2, Item 4, “1 Year” option | Reads “previously certified employment on SIDE 2 with my Training Provider.” Should read “Side 1.” |
| Side 2, Part II | Items jump from 16 to 21. Renumber as 17 and 18. |
| Part II certifications | Side 1 says documents were “provided and kept on file”; Side 2 says “submitted and kept on file.” Use one phrase. |
| “Field” language | The form uses “aligns with the skills,” “a career supported by,” and “the same field of study.” The statute uses “in the field of study of the program.” Use the statute’s phrase throughout. |
| Program name | The form uses “VET TEC 2.0,” the notice and statute use “Hi-Tech VETS,” and the ICR abstract uses “Veterans Education Through High Technology Education Courses.” Use one name and note the statutory name once. |
| Typos | “VET TE 2.0,” “BE SUIRE,” “TRIANING,” “ASSSITANCE,” “EDCUATIONAL,” “EDUCATIION.” |
AI Disclosure: This comment was prepared with the assistance of Claude (Anthropic), which was used for research synthesis, drafting, and citation verification. All substantive positions, recommendations, and strategic judgments are those of The Scaffold Initiative. Facts about the collection come from the Federal Register notices (91 FR 42791 and 91 FR 60491) and the draft VA Form 22-10299 posted with ICR Reference No. 202605-2900-006 on reginfo.gov.