January 10, 2022

Timothy D. Freeman, Executive Director
North Carolina State Approving Agency
Via email

Joseph L. Garcia, Executive Director
Education Service
Veterans Benefits Administration
Via email

Re: Living Arts College Closure

Dear Mr. Garcia and Mr. Freeman,

We would like to draw your attention to the sudden closure of Living Arts College based in North Carolina. Here is a link to the Living Arts College website stating that classes will not resume in January 2023 and that the school is being “forced to retire from the scene.”1 We write to ensure that Living Arts College’s student veterans are informed about all of their options and are not rushed into another low quality school.

We have previously contacted the Veterans Benefits Administration (VBA) regarding the options available to students when a school closes, including their opportunity to apply for GI Bill restoration at any time. We have understood from communications that VBA would correct the GI Bill Restoration application and remove the requirement that students must apply for  restoration by September 30, 2023. As of January 10, 2023 the application on the GI Bill Restoration webpage still incorrectly informs veterans that they must apply by September 30, 2023.2

Of more immediate concern, however, is that the GI Bill Restoration webpage misinforms student veterans that they must first transfer to another school to learn how much of the GI Bill is restored3:

If your school closed or program was disapproved after August 1, 2021, to receive restoration of entitlement for your entire program, you must first enroll at a new school or training institution and have them evaluate how much credit they will accept. Once the evaluation is complete, VA can determine how much entitlement may be restored.

As you know, on December 27, 2022, the President signed into law legislation clarifying that student veterans are not first required to enroll in another school in order to receive their certificate of eligibility for restored GI Bill benefits. Under the Veterans Eligible to Transfer School (VETS) Credit Act,4 a veteran need only state in writing that they have transferred fewer than 12 credits and acknowledge that, if they transfer 12 or more credits, they may not be deemed an individual who did not receive credits and their certification will be rescinded.

We urge you to rapidly bring VBA’s guidance into compliance with the newly enacted VETS Credit Act.

All of the above is of particular importance because Living Arts College is encouraging its Raleigh Campus students to enroll in Full Sail University, a school that is on Warning Status with its accreditor,5 the Accrediting Commission of Career Schools and Colleges (ACCSC). The Living Arts College website proclaims6:

Completing the creative arts education you started at Living Arts may now be aided as a transfer student. Full Sail University, working with Living Arts, has set up an expedited process to explore Full Sail on campus and online options. A dedicated team at Full Sail has setup a phone hotline for one-on-one assistance. You’ll want to make immediate contact for assistance. (emphasis added)

Last November we contacted VA about Full Sail,7 and it appears that following our letter the GI Bill Comparison tool entry for Full Sail University now includes the caution flag for accreditation issues, linking to the accreditor’s notice to Full Sail.8 I know you understand the importance of this information to student veterans, and we appreciate VBA’s making this change to the Comparison Tool.

Unfortunately, this important consumer information about Full Sail University does not appear on the Living Arts College website – where Living Arts is actively encouraging students to transfer to Full Sail. It also does not seem to be on the Full Sail University website,9 although ACCSC directed Full Sail to provide this information in writing to current and prospective students.10 So long as Living Arts College promotes transfer to Full Sail University, VBA and the NC SAA should require Living Arts College to notify students that Full Sail is on warning status with its accreditor, including the reasons for the warning, by posting the information on its website and by including the information in any communications to students about transferring to Full Sail University. In addition, VBA should inquire whether Full Sail is complying with ACCSC’s directive and providing written information about its warning status to all prospective students, including Living Arts College student veterans.

Thank you in advance for your attention to these matters.


Della M. Justice
Vice President for Legal Affairs

cc: House and Senate Veterans Affairs Committees
Rep. Vern Buchanan (R-FL)
Joseph Wescott and Michelle Hill, National Association of State Approving Agencies
Betsy Wickham, Florida Department of Veterans’ Affairs, State Approving Agency

1 Living Arts College webpage https://www.creative.living-arts-college.edu/ (last accessed 1/10/23)
2 Education Benefit Entitlement Restoration Request Due to School Closure or Withdrawal form, https://www.vba.va.gov/pubs/forms/VBA-22-0989-ARE.pdf available at https://www.benefits.va.gov/GIBILL/Restoration.asp (last accessed 1/10/23)
3 US Department of Veterans Affairs, Veteran Benefits Administration, Education and Training webpage, Restoration of Benefits After School Closure or if a School is Disapproved for GI Bill Benefits https://www.benefits.va.gov/GIBILL/Restoration.asp (last accessed 1/10/23)
4 Veterans Eligible to Transfer School (VETS) Credit Act, Public L. 117-297, 136 Stat.4375 (2022) https://www.congress.gov/bill/117th-congress/house-bill/6604/text
5 ACCSC, Public Notice of Warning (Full Sail University is on the list of schools “currently on warning (as of December 20, 2022)”) https://www.accsc.org/Commission-Actions/Schools-on-Warning.aspx (last accessed 1/10/23)
6 Living Arts College webpage https://www.creative.living-arts-college.edu/meeting-the-challenge (last accessed 1/10/23)
7 Veterans Education Success Letter to Florida Department of Veterans’ Affairs and the US Veterans Benefits Administration, November 21, 2022 https://vetsedsuccess.org/letter-to-va-regarding-full-sail-university/
8 Letter to Full Sail University from Michael S. McComis, Executive Director, Accrediting Commission of Career Schools and Colleges (ACCSC), March 1, 2022 https://www.accsc.org/UploadedDocuments/2022/Public-Notice/Redacted-Letters/Full-Sail-University-055214-SAL-Warning-Letter.pdf
9 Links to information about Full Sail’s accreditation and links to consumer information would appear to be
at the very bottom of the main page (https://www.fullsail.edu/) just above the copyright statement. The information appearing at these links, however, does not mention Full Sail being on warning status with ACCSC.
10 Letter to Full Sail University from ACCSC at 14.