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Session 38. Student Eligibility, SAP, and R2T4. Carla Johnson and Andy Hagedorn| Nov-Dec. 2016 U.S. Department of Education 2016 FSA Training Conference for Financial Aid Professionals. AGENDA. Student Eligibility Requirements Satisfactory Academic Progress (SAP)
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Session 38 Student Eligibility, SAP, and R2T4 Carla Johnson and Andy Hagedorn| Nov-Dec. 2016 U.S. Department of Education 2016 FSA Training Conference for Financial Aid Professionals
AGENDA • Student Eligibility Requirements • Satisfactory Academic Progress (SAP) • Qualitative and Quantitative Requirements • Financial Aid Warning, Probation • Appeals • Return of Title IV Funds (R2T4) • Sample R2T4 Calculation
STUDENT ELIGIBILITY Eligibility Requirements For Federal Student Aid: • Be a Citizen or Eligible Non-Citizen of the United States • Have a Valid Social Security Number • Have a High School Diploma or a General Education Development (GED) Certificate • Be Enrolled at Least Half-Time in an Eligible Program as a Regular Student Seeking a Degree or Certificate • No Drug Convictions
STUDENT ELIGIBILITY Eligibility Requirements For Federal Student Aid: • Maintain Satisfactory Academic Progress (SAP) • Not Owe a Refund on a Federal Student Grant or be in Default on a Federal Student Loan • Have a Valid ISIR/SAR on File With Your Institution • Verification Not Required—However, Conflicting Information on ISIR/SAR Must be Resolved Before Paying Aid • Selective Service (Males Only)
SATISFACTORY ACADEMIC PROGRESS • Satisfactory Academic Progress (SAP) is a Student Eligibility Requirement • Institution Must Have a Reasonable SAP Policy • In Addition to Institutional Policy • Qualitative and Quantitative Components • Must be Monitored Annually or at the End of Every Payment Period • Students Must be Notified of SAP Evaluation That Adversely Impacts Aid Eligibility
SAP COMPONENTS • Qualitative Component of SAP: • Usually the Cumulative Grade Point Average (GPA) • Other Comparable Measure Against a Norm • SAP Policy Must State the Minimum Qualitative Benchmark • Quantitative Component of SAP: • Defines Maximum Timeframe for Program Completion • For Undergraduate and Graduate Medical Programs – 150% of Published Length of Program • For Graduate Programs – Defined by Institution and Based on Length of Program • Subsidized Usage Limit Applies (SULA)
SAP COMPONENTS • Quantitative Component Continued: • Describes Pace Students Must Progress Through Program • Calculated by Dividing Cumulative Hours Attempted by Cumulative Hours Completed, Excluding Remedial Courses • Policy Must State How Qualitative and Quantitative Impacted by: • Incompletes, Withdrawals, Repetitions, Transfer Credits • Credits Accepted from Another Institution Towards Students Program Must Count as Attempted and Completed Hours
SAP PROCESS Student Grades Drop Below Minimum Financial Aid “Warning” for 1 Term Financial Aid “Probation” 1 Term or Academic Plan Appeal
SAP WARNING Financial Aid Warning: • Optional • Must Describe This Status in Your Policy • Must Use Term “Financial Aid Warning” • Warning Allowed Only if SAP Measured Each Payment Period • Aid Can be Disbursed for One Payment Period • Student Does Not Need to Appeal
SAP PROBATION Financial Aid Probation: • Optional • Policy Must State Conditions Under Which a Student May Appeal • Student’s Appeal Must State: • Why He/She Failed to Make SAP • What Has Changed to Allow Student to Meet SAP in the Future • Institution Must Determine if Student Will be Able to Make SAP by End of Next Payment Period or; • Will be Placed on Academic Plan That Ensures Student Meets SAP at Certain Point in Time
SAP APPEALS • Academic Plan May Be Simple or Detailed • Student Must Successfully Appeal • First Term Under Plan is Considered Probation • Plan May be for Multiple Terms • If No Appeal Process, Policy Must State How Student May Re-Establish Title IV Eligibility • Cannot Have Two Consecutive Terms of Warning or Probation
IMPLEMENTATION QUESTIONS • Will You Have Fixed or Graduated Standards? • Will You Have Different Standards for Different Categories of Students? • How Will You Treat Course Incompletes, Withdrawals, and Repetitions? • How Will You Treat Transfer Credits?
IMPLEMENTATION QUESTIONS • How Will You Treat Remedial Courses? • Will Your Policy Permit Appeals, and if so, How Many? • Who Will Review Appeals? • If You Have Academic Plans, Who Will Develop, Approve, and Monitor Compliance With Academic Plans?
RESOURCES/REFERENCES • FSA Assessments, Student Eligibility section: • http://ifap.ed.gov/qahome/qaassessments/studentelig.html • 668.16, 668.34 (SAP) • 2016-17 FSA Handbook Vol. 1, Chapter 1 • Electronic Announcement - September 2, 2011 • Policy Q & A Webpage on program integrity regulations • http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/integrity-qa.html
R2T4 Return of Title IV Funds (R2T4/Return) • The Calculation Required When a Recipient of Title IV Aid Withdraws From an Institution During a Payment Period/Period of Enrollment in Which the Recipient Began Attendance R2T4 Does Not Apply If: • Student Reduced His or Her Course Load • Student Failed to Begin Attendance
GENERAL PRINCIPLES OF R2T4 • The Calculation Compares the Amount of Title IV Aid the Recipient Earned to the Amount Disbursed and Determines Whether Funds Must Be Returned, or the Student is Eligible for a Post-Withdrawal Disbursement • Student is Entitled to the Amount of Title IV Funds Student Earned as of His/Her Withdrawal Date
ELEMENTS OF AN R2T4 CALCULATION • Withdrawal Date • Date of Determination • Aid Disbursed • Aid That Could Have Been Disbursed • Payment Period/Period of Enrollment • Post-Withdrawal Disbursement • Unearned Aid • Institutional Charges
SAMPLE CALCULATION School Profile Higher Education University (HEU) is a Two Year, Public, Semester-Based Institution that Measures Academic Progress in Credit-Hours. • Award Year: 2 Semesters, 24 Semester Hours, 32 Weeks • Period: 16 Weeks, 110 Calendar Days • Period Start Date: February 8 • Period End Date: May 27 • Withdrawal Date: March 13 • Scheduled Break: None • Required to Take Attendance: Yes
R2T4 WORKSHEET Form 1 Form 2
R2T4 BASIC INFORMATION • Withdrawal Prior to Census Date • Retroactive Withdrawal • Student Completes More Than 60% of PP or POE • Institutional or Other Refund Policies • Determining Withdrawal Date • Consumer Disclosures
RESOURCES/REFERENCES • FSA Handbook, Vol. 5, Chapter 2 • 34 CFR 668.22 • Dear Colleague Letters - GEN-04-03; GEN-11-14; GEN-00-24; GEN-04-12; GEN-05-16 • FSA Assessments https://ifap.ed.gov/qahome/qaassessments/returntivfunds.html • R2T4 on the Web calculator Available at https://fafsa.ed.gov/privacyR2T4.htm • R2T4 Website Through FAA Access to CPS Online • 10/29/10 Federal Register – Final Regulation • IFAP – Program Integrity Q’s & A’s – Return of Title IV Funds
CONTACTS • Email: FSA.Foreign.Schools.Team@ed.gov • Phone: 202-377-3168 • Fax: 202-377-3486 • Mail: U.S. Department of Education Multi-Regional and Foreign School Participation Division Union Center Plaza, 7th Floor 830 First Street, NE Washington DC, 20202 (20002-5340 if Overnight/Courier)
SCHOOL ELIGIBILITY SERVICE GROUP (SESG)Ron Bennett - Director, School Eligibility Service Group, Washington, DC (202) 377-3181School Eligibility Service Group General Number: (202) 377-3173 or email: CaseTeams@ed.gov Or call the appropriate School Participation Division manager below for information and guidance on audit resolution, financial analysis, program reviews, school and program eligibility/recertification, and school closure information. New York/Boston School Participation Division Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, New Jersey, New York, Puerto Rico, Virgin Islands Betty Coughlin, Director (646) 428-3737 Tracy Nave – Boston (617) 289-0145Jeremy Early– Washington, DC (202) 377-3620Chris Curry – New York (646) 428-3738 Philadelphia School Participation Division District of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West Virginia Nancy Gifford, Director (215) 656-6436 John Loreng – Philadelphia (215) 656-6437 Sherrie Bell– Washington, DC (202) 377-3349 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director (202) 377-3364 Barbara Hemelt − Washington, DC (202) 377-4201 Joseph Smith − Washington, DC (202) 377-4321 Mark Busskohl – Washington, DC (202) 377-4572 Michelle Allred – Dallas (214) 661-9466 Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South CarolinaChristopher Miller, Director (404) 974-9297 David Smittick – Atlanta (404) 974-9301 Vanessa Dillard – Atlanta (404) 974-9418 Dallas School Participation Division Arkansas, Louisiana, New Mexico, Oklahoma, Texas Cynthia Thornton, Director (214) 661-9457 Jesus Moya – Dallas (214) 661-9472 Kim Peeler – Dallas (214) 661-9471 Kansas City School Participation Division Iowa, Kansas, Kentucky, Missouri, Nebraska, TennesseeRalph LoBosco, Director (816) 268-0440Dvak Corwin – Kansas City (816) 268-0420 Angela Beam – Kansas City 816) 268-0534 Jan Brandow – Kansas City (816) 268-0409 Chicago/DenverSchool Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, WyomingDouglas Parrott, Director (312) 730-1532 Earl Flurkey – Chicago (312) 730-1521 Brenda Yette – Chicago (312) 730-1522 Sarah Adams − Chicago (312) 730-1514 San Francisco/Seattle School Participation Division American Samoa, Arizona, California, Guam, Hawaii, Nevada, Palau, Marshall Islands, North Marianas, State of Micronesia, Alaska, Idaho, Oregon, WashingtonMartina Fernandez-Rosario, Director (415) 486-5605 Gayle Palumbo − San Francisco (415) 486-5614 or Seattle (206) 615-3699 Dyon Toney − Washington, DC (202) 377-3639 Erik Fosker – San Francisco (415) 486-5606