Satisfactory Academic Progress (SAP) and Return of Title IV Funds (R2T4)

1. SessionFS6 Satisfactory Academic Progress (SAP) and Return of Title IV Funds (R2T4) Carla Johnson and Andy Hagedorn | Nov.-Dec. 2017 U.S. Department of Education 2017 FSA Training Conference for Financial Aid Professionals

2. AGENDA • Satisfactory academic progress (SAP) • Qualitative and quantitative requirements • Financial aid warning, probation • Appeals • Return of Title IV funds (R2T4) • R2T4 worksheet calculation walk-through • Case studies

3. SATISFACTORY ACADEMIC PROGRESS • Institution must publish and apply a reasonable SAP policy • In addition to institutional policy • Must be monitored annually or at the end of every payment period • Students must be notified of SAP evaluation that adversely impacts aid eligibility

4. 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 time frame for program completion • For undergraduate and graduate medical programs – 150% of published length of program in credit-hours (not years) • For graduate programs – defined by institution and based on length of program

5. 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 components are impacted by: • Incompletes, withdrawals, repetitions and transfer credits • Credits accepted from another institution towards students program must count as attempted and completed hours

6. SAP WARNING Financial aid warning: • Optional • Must describe this status in your policy • Must use term “Financial aid warning” • Warning only allowed if SAP measured each payment period • Aid can be disbursed for one payment period • Student does not need to appeal (automatic status change)

7. 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

8. 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

9. 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

10. 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 • How often will you review financial aid SAP • Will you use SAP warning/probation periods

11. 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

12. R2T4 • Return applicability: • 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 • 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

13. R2T4 • R2T4 does not apply if: • Student reduced his or her course load • Student failed to begin attendance • If student enrolled but never attended any classes: • Student did not establish eligibility for any funds • All Title IV aid disbursed must be returned

14. CONSUMER INFORMATION • School must provide to prospective and current students: • Any refund policy with which school must comply • School’s tuition refund policy • Requirements for treatment of Title IV funds after withdrawal • Procedures for official withdrawal

15. R2T4 WORKSHEET CALCULATION • Date of determination: • Official withdrawal • Unofficial withdrawal (no notification) • Payment period or period of enrollment: • Standard term-based program • Nonstandard term or Nonterm program

16. R2T4 WORKSHEET CALCULATION • Net dollar amount • Aid that could have been disbursed • To include, must meet conditions for a late disbursement

17. R2T4 WORKSHEET CALCULATION • Last day of attendance • Academic related • activities • Unscheduled break • Leave of absence • Rounding rules for percentages

18. R2T4 WORKSHEET CALCULATION • Rounding rules for dollar amounts • I = amount of Title IV aid earned by student • J = post-withdrawal amount

19. R2T4 WORKSHEET CALCULATION • Institutional charges • Initial charges • Adjusted charges • School’s responsibility

20. R2T4 WORKSHEET CALCULATION • Order of return • U.S. dollars • Time frame of return

21. R2T4 WORKSHEET CALCULATION • Unearned Title IV funds • Student’s responsibility

22. R2T4 WORKSHEET CALCULATION • Not applicable to foreign schools:

23. R2T4 WORKSHEET CALCULATION • Written notification • Confirmation from student or parent borrower

24. CASE STUDY-SAM JOHNSON School profile: •Academic yr. = 30 weeks and 24 credit-hours •Payment period = 15 weeks •Withdrawal type = Unofficial •Period start date = September 4 •Payment period end date = December 17 •WD date = 50% •Institutionally scheduled breaks = None •Date of determination = December 16 •Attendance taking = Not required •50% point = October 25 COA profile: •Tuition & fees = $7,000/semester •Room = $4,000/semester •Board = $4,000/semester •Books & supplies = $500/semester Title IV award profile: •Unsub DL = $6,760/semester (disbursed) •Grad PLUS = $7,240/semester (disbursed) Other information: •At the end of the semester, the institution discovers that Sam failed all of his courses •On December 16th after faculty are consulted the office responsible for R2T4 determined that the last time Sam was at an academically-related event was October 10th

25. CASE STUDY-CALVIN HILTON School profile: •Academic yr. = 36 weeks and 24 credit-hours•Payment period = 12 weeks •Withdrawal type = Official •Period start date = April 10 •Payment period end date = July 9 •WD notification = May 31 •Institutionally scheduled breaks = May 22-28•Attendance taking = Required COA profile: •Tuition & fees = $7,000/semester •Room = $4,000/semester •Board = $4,000/semester •Books & supplies = $500/semester Title IV award profile: •Unsub DL = $6,760/semester (disbursed) •Grad PLUS = $7,240/semester

26. 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

27. 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)

28. 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. Chicago/DenverSchool Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, WyomingDouglas Parrott, Director 312-730-1532 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 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 Steven M. Marcucio – Philadelphia 215-656-5554 Sherrie Bell– Washington, DC 202-377-3349 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director 202-377-3364 Joseph Smith − Washington, DC 202-377-4321 Mark Busskohl – Washington, DC 202-377-4572 Michelle Allred – Dallas 214-661-9466 Julie Arthur – Seattle 206-615-2232 Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South CarolinaChristopher Miller, Director 404-974-9297 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

29. QUESTIONS?