# 2020-042 Pay and Benefits, Education Reimbursement Policies

Case summary

F&R Date: 2021-03-25

The grievor had an Individual Learning Program (ILP) approved to complete a second Master's degree. In 2019, due to funding limitations, CANFORGEN 046/19 announced a lifetime cap of $38,000 for individual learning. The grievor had already reached that amount, and therefore, his funding was ceased with two courses remaining in his program. He requested reimbursement of those courses, contending that he should have been grandfathered when the new policy came into effect. There was no Initial Authority (IA) decision as the IA did not render a decision within the prescribed time limit.

The Committee noted that an ILP is simply an education plan put forward by a member. It is not a contract, nor does it guarantee funding over multiple years it may take to complete an education program. The Committee concluded that the Canadian Armed Forces has the discretion to determine and authorize, in each fiscal year, whether funding is available for a member's particular courses taken within that fiscal year. The Committee found that the grievor was treated fairly, and in accordance with relevant policy.

FA decision summary

The Director Canadian Forces Grievance Authority, as Final Authority (FA), agreed with the Committee's recommendation to deny the grievance. The FA noted that the Canadian Armed Forces has discretion as to whether funding is available for members' courses during any given fiscal year. She added that an ILP is only a plan offered by the member; not a guaranteed education program. The FA noted that the grievor's education expenses were well over the $38,000 career-cap imposed through CANFORGEN 046/19 and found that the denial of his funding requests was justified.